Don’t scare them off!

October 27th 2023

Halloween and Bonfire Night are nearly upon us.  While these events can provide a good marketing opportunity, advertisers must think carefully about the content of any promotions, particularly where they are likely to be seen by young children. 

Advertising is regulated in the UK by a combination of legislation and two self- regulatory codes. The UK Code of Non-broadcast Advertising and Direct & Promotional Marketing (CAP Code) and the UK Code of Broadcast Advertising (BCAP Code) are enforced by the Advertising Standards Authority (ASA).

The ASA has recently published some useful guidance on seasonal advertising, which includes examples of practices which may get advertisers into trouble.

Advertisers should not show fireworks being used in an irresponsible manner, unless the ad is intended to promote a safety message and even then, content which might cause excessive fear or distress should be avoided. Ads which show children taking part in potentially dangerous activities (for example apple bobbing) or in close proximity to dangerous objects (such as sparklers) without adult supervision could also be problematic. 

Spookiness is part and parcel of Halloween but be cautious about depicting characters such as clowns, zombies and creepy dolls which could frighten people or using excessively gory imagery. Under the BCAP Code, advertisers must be very careful about scheduling. Adverts which could distress young children should not be scheduled in or around children’s programmes or programmes likely to be seen by significant numbers of children. Similar principles apply to the targeting of online advertisements.

Sanctions for breaching the Codes include:

  • the ASA requiring the offending advert to be withdrawn or amended
  • the CAP advising its members (including the media) to withhold access to advertising space
  • referral to Trading Standards or Ofcom



Spooky is the name of the game when it comes to Halloween themed ads - especially if you’re promoting a horror film or video game. Nevertheless, care should be taken not to cause undue fear or distress to the audience and to target these types of ads appropriately.