In Search of an Egyptian Product Placement Regulation
Department of Journalism and Mass Communication, The American University in Cairo, Egypt
- *Corresponding Author:
- Tara Al-Kadi
Department of Journalism and Mass Communication
The American University in Cairo
Mass Communication, AUC Avenue
New Cairo, Cairo, Egypt
E-mail: [email protected]
Received Date: Jun 29, 2018; Accepted Date: Jul 09, 2018; Published Date: Jul 17, 2018
Citation: Al-Kadi T. In Search of an Egyptian Product Placement Regulation. Global Media Journal 2018, 16:31.
Copyright: © 2018 Al-Kadi T. This is an open-access article distributed under the terms of the Creative Commons Attribution License, which
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Global Media Journal
This article analyses product placement regulation in different countries and regions. The investigative aim is to extrapolate from other systems’ regulations useful elements, which might benefit the Egyptian broadcast ecology given the current goals and challenges it faces. The methodology is based on official document analysis in nine countries grouped into four broad categories ranging from no existing product placement policies in a country such as India to more effective well-defined laws in countries such as the United Kingdom, Korea, and Turkey. The research highlights the drawbacks and advantages of each category concluding that the fourth and final category of regulation models has the highest potential of usefulness for future policy considerations in the Egyptian context.
Egyptian broadcast; Product placements;
Spot advertising; Satellite channels
Product placement is simply defined as the subtle
presentation of a specific brand in mass media programs on
television or in films . The practice dates back to more than
a hundred years , but the concept came into the limelight in
the 1980s following Spielberg’s blockbuster film E.T., which
was released in 1982. Gupta and Gould  implied that
Hershey’s experienced a 66 per cent increase in sales of their
Reese’s candy as a result of product placement in the film.
Since then scholars started paying close attention to media
content to spot instances of product placements.
Recently, the challenges faced by marketers with regards to
spot advertising have led to growing reliance on product
placement as a more feasible alternative. Newell, Salmon, and
Chang  point out that “the business of product placement
has been an integral and active portion of mass media for
more than a century” as producers attempt to cut costs by
obtaining free props and create an additional source of
revenue in cases of paid product placements.
In Egypt, however, spot advertising is still a growing business
and while product placement use is acknowledged as a source
of revenue for filmmakers and marketers, currently there are
no broadcast policies that address or attempt to regulate this
practice on Egyptian television.
This study provides a review of current international
product placement practices by examining four different,
broad regulatory approaches and assessing the advantages
and drawbacks of each. Then a recitation of particular aspects
of existing product placement policies is done to see which
practices are well suited for Egypt.
Purpose of the Study
This study explores different broadcast systems and their
divergent regulations with regards to promotional messages.
This is to help propose a realistic, comprehensive Egyptian
product placement policy through comparing and analyzing
the strengths and weaknesses of the models in other countries.
As traditional advertising evolves and faces new limitations
across different countries, product placement becomes more
significant . The value of product placement as a source of
funding can be better appreciated when examining the
declining income yielded by spot advertisements.
When spot advertisements generate less income,
broadcasters and filmmakers have less money to fund film and
television production. They thus turn to product placement
and other innovative and non-traditional forms of marketing.
Researchers such as Balasubramanian, Gupta and Lord,
Gupta et al., Wenner, Lehu, and Williams et al. [4-9] note that
when compared to spot advertising, product placement
cannot be avoided as the brands appear as components of film
or television scenes.
However, with its advantages, many countries have decided
that regulation was pivotal for product placement or else the
practice can yield negative effects. In Egypt, though product
placement has been growing rapidly, until now there is no
valid regulation pertaining to it. The following section explores current Egyptian regulations that relate to mass media in
general and advertising in specific.
Advertising-related Regulation in
Several documents relate to Egyptian television advertising
regulation: rules for state channels, rules for satellite channels,
consumer protection laws and the newly signed Unified Media
Law. Here is a quick review to offer a proper context for this
Advertising on state channels
The Egyptian Radio and Television Union’s (ERTU’s) general
advertising policies apply to Egyptian state channels only. Here
there is an extensive list of rules governing advertisement.. By
reviewing those rules, two major themes of relevance were
found: censorship of commercials based on political, moral,
and religious content; and censorship for the protection of
There is a clear warning that advertisements are not to
contain religious, political, or immoral content. The regulations
state that advertisements for books, plays, films, or other
works of art are prohibited, if those works had not already
obtained a license from the censorship unit. Strict warnings
exist against advertisements for alcohol or those that use
violent or obscene language (“ERTU Advertising Rules”) or
challenge traditional family values (Item #16 ERTU Advertising
Rules) or “tarnish the image of Egyptians by making them
appear ignorant, rude, or vulgar” (Item #13 ERTU Advertising
The second area of policy restrictions governing state
channels clearly takes into consideration protecting consumers
from manipulation or deception by product promoters. Here,
there is a strict warning against commercials that may be
misleading. These include comparative advertisements that
belittle competitive products. Moreover, advertisements
targeting children are “to respect and protect the innocence
and well-being of younger viewers” (Item #7 ERTU Advertising
Rules). The regulations also refer to various permits issued
before particular categories of advertising are to be aired;
namely food or beverages, hospitals and medical products or
More importantly, there is a specific article, which subtly
deals with product placement. It states that the coverage of
recent films, songs, and plays is allowed, but must be limited
to once per programme with a maximum of six minutes of
coverage (Article #3 of Promotional Content in ERTU
However, this does not refer to the typical type of product
placement: when brands are embedded in a less conspicuous
manner appearing as a natural part of the scene or plot rather
than being explicitly promoted.
Advertising on private satellite channels
The satellite channels contract, signed with the Egyptian
ministry of investment, only contains two lines on the
guidelines and rules associated with advertisements. It calls for
channels to respect consumer protection laws and advertising
regulations of the countries receiving the channel signal,
including policies about advertisements for medication,
medical equipment, and holding contests (Article 12.1.D).
The contract warns that if its articles were not adhered to,
an official warning would be issued to the satellite channel to
stop airing such content. If within three days the
advertisement was not removed, then the channel may risk
suspension of transmission.
As with ERTU regulations there is no stipulation in the
private satellite contract regarding the use of product
placement or a maximum time for spot advertising within a
fixed period of broadcast time.
Consumer protection law (CPL)
The CPL was enacted by Law #67 of 2006. The purpose of
the law was to regulate consumer-trader relations, which
encompasses overseeing that advertisements are truthful and
not misleading. The Law is relevant because Article 12 informs
the public of how consumers can protect their rights in case
they face any problems when purchasing a product”
(Consumer Protection Agency: About CPA).
Article 6 of the law directly addresses advertising, stating
that every supplier and advertiser shall provide the consumer
with correct information concerning the nature and
characteristics of the product. Article 19, meanwhile, specifies
the powers of the agency stating it shall compel the violator to
adjust and remove the ad immediately or within the time limit
fixed by the Agency’s Board of Directors.
Theoretically, Articles 6 and 19 should hold advertisers
accountable when using misleading and deceptive
commercials. However, despite its promising wording, there
are some loopholes associated with the role of the Agency.
Consumer rights are generally formulated in rather general
terms in the existing Egyptian legislation, which jeopardises
effective access to justice even if the consumer is trying to
defend his/her rights” .
Unified media law
In 2014, the newly formed Egyptian parliament passed a
new media law covering the private and national media
institutions in Egypt. Among the proposed constitutional
changes was the formation of a regulatory body: the Higher
Council for Media Regulation.
Recently this Council has been charged with reforming
Egyptian television and unifying the regulations that apply to
state and private satellite channels. The Council’s duties
include overlooking advertising practices on television.
Although it does not refer to product placement specifically, it does refer to advertising related practices and the authority of
the Council concerning their regulation.
Unlike other television regulatory bodies, which were purely
of state employees, the composition of the newly formed
Council consists of a healthy mix of professionals, experts, and
relevant union members. Despite this, the new body, the
Higher Council, has been criticized for replacing the old
Egyptian ministry of information by acting as a government
arm and applying uncalled for censorship.
The above examination of advertising policies reveals that
consumer protection; along with political, cultural, and
religious sensitivities seem to be the only concerns Egyptian
policymakers have had, thus far, with advertising.
Justification for Creating an Egyptian
Product Placement Policy
There are many reasons that support the need for an
Egyptian product placement policy, as opposed to the option
of leaving this advertising practice unregulated. The
justification for regulation comes in light of issues related to
increased commercialism and materialism, subliminal
advertising effects, and the impact of promoting ethically
charged products and some media effects theories. This need
for a timely Egyptian product placement policy has proven
pivotal given the new constitutional changes that seek to
coordinate the rights of state and private channels and the
restrictions imposed on them.
What are the international regulations that could be used as
a model for an Egyptian product placement legislation?
The following is a comparison of current product placement
regulation in nine broadcast systems where the practice has
been prominent and is growing in use. The countries chosen
for closer scrutiny were Australia, Brazil, Canada, China, India,
Korea, Turkey, the United Kingdom, and the United States. The
countries were selected for various reasons. Firstly, they are
large product placement markets [2,11-15]. Secondly, they
cover a broad-geographical and cultural spectrum. Thirdly, the
countries reflect divergent product placement policies. Finally,
information on their product placement regulation was
There is no statistical data on the size of the product
placement industry in Egypt. PQ Media, which offers country
specific reports on the relevant regulatory framework and the
size of the product placement industry, does not report on
product placement in Egypt. The only available data is based
on research that compares the frequency of product
placement use in the top five Hollywood and Egyptian films
between 2010 and 2013. This report reveals that use of
product placement in top Egyptian films has doubled .
To understand product placement regulation in each nation,
policy documents and official government websites were
directly examined when written in English. This was the case
for UK and US regulation. In instances where official
documents were written in a language other than English, the
researcher accessed various websites that offered English
language translations about the country’s product placement
laws. This was the case for Turkey, Brazil, China, and Korea. In
Australia, Canada, and India, there seemed to be no specific
laws; thus, legal websites and secondary research
documentation were used to clarify the approach to product
placement in these countries.
The countries have been categorized into four regulatory
categories. Interestingly, the broadcast model did not
necessarily predict the type of product placement policy. The
first category includes countries with no product placement
regulation or restrictions: This group includes only India. The
second category encompasses countries with no specific
product placement regulation but where general advertising
laws must be respected: Australia, Brazil, and China. The third
group of countries has specific product placement laws, but
they seem fairly ineffective: Canada and the United States.
Finally, the fourth category includes countries with clear, welldefined,
and seemingly effective product placement
regulation: Turkey, the United Kingdom, and Korea.
Category 1: No product placement regulation
India is the only prominent example of country where
product placement is completely unrestricted. There are no
current particular regulations for product placement in India,
where this practice has been booming over the last 10 years
[17,18]. According to Krishnamurthy , so far there are no
plans by News Broadcasters Association of India (NBAI) to
impose any restrictions.
While the NBAI is discussing a comprehensive media code of
ethics, there is no evidence that it would contain references to
India produces the largest number of films annually when
compared to all other countries in the world . This
indicates a huge potential for product placement as a source
of revenue generation for the Indian film and broadcast
industry. This would also mean that there is room for abuse
and overuse of product placement by advertisers and
The current climate, in which there is a lack of regulation,
could result in excessive commercialization. Egypt can be
classified in this category. As in India, whilst product placement
practices are booming in Egypt, there are no specific laws to
A carefully designed product policy could allow Egypt’s
broadcast system to reap the financial benefits of this practice
without neglecting essential concerns addressed throughout
Category 2: Advertising laws define product
Australia: Regulation of product placement in Australia is
minimal. According to PQ Media, Australia is ranked fourth
globally in terms of the size of its product placement market.
Its expenditure on product placement was estimated to be
$104 million in 2010 . Existing product placement research
mainly centers on Australian audience attitudes towards the
With respect to specific Australian polices there is a selfimposed
broadcast regulation code to guide advertising
practices. This code mandates disclosure of commercial
content in non-fiction programmes, documentaries, and
current affairs programmes [24,25]. However, the disclosure is
not obligatory in other types of programming .
In a few Australian regions there are laws banning Payola,
which is a practice through which the company pays to have its
products broadcast in selected programmes. Uniform
restrictions across all Australian territories still exist, however.
For example, direct or indirect promotion of cigarettes and
tobacco is denied in any type of media. Yet there remain some
major contradictions in current policies , as long as there is
Brazil: The second country in this category is Brazil, which is
the second-largest product placement market in the world
behind the United States . Evidently the existence of
formal regulation has no direct link or apparent impact on the
overall value of the product placement market as Brazil has no
specific, detailed product placement regulation.
La Pastina  notes that product placement in telenovelas
exists as a main source of funding. Brazilian broadcasters turn
to product placement, in part, to avoid regulation, which limits
commercials to a maximum of 15 minutes each hour. In Brazil
product placement practices are influenced by three main
sources: laws created by the Brazilian advertising selfregulation
entity (CONAR), CONAR Code of Ethics (Articles 10
and 28), and the Consumer Defense Code (Article 36).
Article 36 of the Consumer Defense Code states that
promotion must be disclosed so it is immediately and clearly
recognized. Article 28 of The Code of Ethics of CONAR (the
Brazilian self-regulation body in charge of advertising and
promotion) similarly warns that an advertisement of any form
must be readily recognized. This guideline also applies to
product placement use through Article 10 .
In summary, product placement in Brazil is permissible as
long as there is some form of sponsorship identification. It
seems that economic benefits are the driving force behind
regulation in this area, with little concern about the effects of
product placement on children or the increased
commercialization of editorial content.
China: The third country in this category is China. Interest in
examining Chinese audience attitudes towards brand
placement has been evident as early as 2003. Mckechnie and
Zhou  have found that compared to other nationalities the Chinese were less accepting of product placement. In 2012,
Chinese product placement spiked to $103-million, growing
27.2 per cent compared to placement spending in 2008 .
This could be a result of the recent overall growth of China’s
television and film sectors.
Similar to Australia and Brazil, China does not have any clear
regulation on product placement. Yet, since product
placement is a form of advertisement, the existing Chinese
Advertising Law regulates it. The State Administration of Radio,
Film, and Television is the legal entity in charge of creating any
regulation in this area .
Of relevance to product placement is Article 14 of the
Advertising Law, amended in 2015, which states that an
advertisement shall be identifiable to consumers and shall not
be published in the disguised form of a news report on mass
media (Chapter 2, Article 14, Advertising Law of the People’s
Republic of China, 2015).
Here the law is too limited, only referring to removing
advertised content from news segments. This is similar to
Brazilian laws described above. A second concern is that
Article 14 suggests that product placement is not classified as
commercial content or advertising.
Clearly a main area of weakness in Chinese regulation is
associated with the application of the advertising law. For
example, Article 22 (previously Article 18 in the 1994 law)
prohibits advertisements of tobacco in newspapers, television,
radio, film, and all other media. However, as Han  notes,
product placement of tobacco is not prohibited on Chinese
Rannamets  notes that audiences in China have recently
raised complaints about product placement, which has led the
State Administration of Radio and Film to promise that it
would deliberate the matter of regulation in this area.
However, the amended advertising law of 2015 has not
reflected such pressures to directly and more specifically
address product placement or the use of props.
Category 3: Formal but ineffective product
This section is an exploration of models in which product
placement regulation is well defined yet appears to be
ineffective. Canada and the United States are examples of such
Canada: The Canadian advertising regulations stem from
four main sources: Canadian Radio, Television and
Telecommunication Commission (CRTC) regulation
implemented through the Broadcasting Act, Advertising
Standards Canada (ASC), which is advertising’s self-regulation
authority, and the Ethics Code of the Canadian Association of
The Ethics Code of the Canadian Association of Broadcasters
has created Articles 13, 14, and 15 with regards to product
placement. Of prominence is Article 14, which states that
broadcasters shall ensure that advertising material within a newscast is clearly distinguishable from the news information
adjacent to it and that there is no influence by advertisers on
the reporting of news or public affairs, which must be
accurate, balanced, and objective (Ethics Code of Canadian
Association of Broadcasters, Article 14, Clauses B and C).
Although Article 15 of the Code prohibits subliminal
advertising, the regulation in Canada, ironically, seems to be
moving away from restrictions and in favor of deregulation.
Ginosar and Levi-Faur  note that in 2006, following a
public hearing, the CRTC considered amending broadcasting
advertising by favoring decreased restrictions in response to
economic and technological changes. Of major significance for
this study, is the fact that product placement was removed
from the calculation of the maximum number of advertising
minutes which can be broadcast.
The United States: The United States is the other country in
the same category. It is the largest product placement market
in the world and “solid growth during most of the 2006-11
period fuelled a 12.8% [Compound Annual Growth Rate] CAGR
The Federal Communication Commission (FCC) regulates
product placement through the Communications Act of 1934,
Article #317 . This section, as amended, requires
broadcasters to disclose to their listeners or viewers if a matter
has been aired in exchange for money, services or other
valuable consideration (Communications Act 1934, 1934,
Payola and Sponsorship Identification).
Generally, the FCC does not prohibit product placement, but
requires disclosure. The manner of sponsorship disclosure,
however, is not specified. Thus, some sponsors may simply be
mentioned briefly in closing credits. The nature of
identification of placements has raised criticism by various
groups, including Commercial Alert, an activist group whose
mission is to protect consumers against commercial
exploitation  and The Writers’ Guild of America .
However, the conclusion was that more stringent regulation of
product placement could not be introduced because it
constituted a challenge to free speech .
A second problem with the current practice in the United
States is that unpaid placements used as props are not
regulated. Props officially offered free of charge are not
regulated and are hence unrestricted. This means, for
example, that the camera can linger on the branded product in
This ineffective policy has created a loophole, which
advertisers in the US have been taking advantage of. For
example, while, tobacco companies signed different
agreements, committing not to use paid-for brand placement
in films , Rannamets  notes that these companies
circumvent this ban by providing cigarettes to films “free of
charge.” Accordingly, the placed tobacco brands are legal and
they do not even have to be disclosed in the credits.
Given the current nature of the product placement practices
in the United States, it seems that regulatory forces are facing a dilemma, which weakens their position as effective
Category 4: Countries with effective product
The final category in this discussion consists of Turkey,
Korea, and the United Kingdom. These are examples of
countries, which have detailed, clear, and useful product
Korea: In Korea, prior to 2009, product placement was
prohibited on television and real brand names were blurred or
slightly modified. Product placement was officially legalized
through the 2009 Korean Broadcasting Act. This law was
enacted in 2010 for purposes of expanding the broadcasting
industry’s financial resources and production capacity .
The official regulatory bodies are the Korean Broadcast
Advertising Corporation (KOBACO) and the Korean
Communications Commission (KCC) .
The newly amended Korean law states that placements
must be limited to entertainment and cultural programmes. It
strictly forbids placement in children’s, current affairs, factual,
and debate programmes . In addition, broadcasters are
obliged to advise viewers about any incorporation of
placements by utilizing subtitles at the beginning of aired
The law warns that placements may not influence the
substance or composition of programmes and editorial
integrity must not be affected by it. Thus, names of placed
brands must not be (verbally) mentioned in programmes, nor
should there be advice to purchase or use those products.
Finally, the law warns that exposure to brand signs, logos, and
trademarks may not surpass five per cent of the overall
duration of the TV programme containing the placement .
The Korean system depicts a useful and practical regulatory.
Lee and King  found that Korean audiences, who were
informed about American product placement regulation, tend
to prefer the new Korean law to the American and previous
Korean product placement regulation. They find it to be
comprehensive, practical, and also socially responsible.
The United Kingdom: The second country in this category is
the United Kingdom. The UK has altered its policy towards
product placement in 2010. As result of the new policy some
estimate that the size of the UK product placement market
could grow to £120 million by the end of 2018 .
The new UK regulation implemented from February 28,
2011 came as a result of and in compliance with EU regulation
. In the United Kingdom, the Office of Communications
(OFCOM) regulates product placement under Section 9 of the
The objectives of the product placement policy as stated by
the code are to protect editorial independence, distinguish
between advertising and editorial content, protect audiences
as consumers, and ban unsuitable sponsorship .
It should be noted that placements here are distinguished
from ‘props’. Props which have not been paid for by sponsors
and props which have been paid for in an amount that costs
less than the props’ actual price are permissible because they
are not considered product placement .
In terms of reference and prominence, the UK policy warns
that a placement (paid for or unpaid) must be editorially
justified and not have any “undue prominence” or else it shall
be banned (Article 9.9, 9.10).
Regarding the types of programmes, product placement is
to be prohibited from children’s, current affairs, consumer
affairs, religious, and news programmes (Article 9.7).
The items which may not be advertised or placed on
television include weapons, escort services, tobacco; liquor;
gambling; food or beverages which are high in fat, salt, or
sugar; medication; and infant milk (Article 9.13).
A final condition set by the Code is that a product placement
logo (Figure 1) must appear for three seconds at the beginning
and end of programmes as well as at the end of each
commercial break .
Figure 1: Product Placement Logo Versions in the United Kingdom.
Clearly, the UK regulation has numerous strengths. It is a
comprehensive policy, which covers a broad range of product
placement-related issues with highly specific instructions.
Turkey: The third state in this category is Turkey. Despite
that fact that product placement use is relatively new in Turkey
, there are good laws governing the practice. The Turkish
product placement regulation reveals strong parallels to the
European Union policy and suggests that Turkey may have
adapted its legislation in line with the AVMS directive as part
of the accession talks with the European Union.
The Radio and Television Supreme Council (RTUK) is the
entity that regulates product placement in Turkey. In 2011 the
RTUK’s Law on Foundation and Broadcasting Services of Radio
and Television Institutions #6112 directly addressed product
placement in Article 13, which regulates the practice in the
Firstly, brand placement is permitted when products and
services are embedded free of charge. This is similar to the EU
regulation. Secondly, placements should not be promoted in
an exaggerated or unreasonable manner within a programme.
Thirdly, for paid placements, disclosure of sponsorship must
occur at the beginning of broadcast programmes, at the end of
each commercial break, and at the end of each programme
containing a product placement. Fourthly, any product
categories previously banned from promotion or advertising, such as tobacco and alcohol, may not be promoted through
placement. Finally, similar to EU/UK regulation, product
placement is strictly prohibited in children’s programmes as
well as news and religious programmes [43,44].
In 2014 the ‘The Second International Product Placement
Symposium in Istanbul’ promised looser regulation in this area,
alarmed by an 80 per cent decline in traditional advertisement
viewership in Turkey, for reasons, which are unclear .
In the next section, empirical findings will be drawn to group
together essential elements from the previous legislations that
may suit the Egyptian context and help in the design of an
appropriate product placement policy.
Problems with self-regulation
Industry self-regulation may seem like a useful approach for
setting basic rules for governing product placement practice.
However, it could be argued that without government
intervention, the necessary changes will never be
implemented. The government is needed to limit excessive
materialism and control the seemingly inevitable globalization
of the highly commercial models.
Transparent media laws are crucial, but they must be
strengthened by supervision and enforcement, mechanisms in
order to avoid abuse and misuse. A specialist on advertising
ethics, Alexander , rightly questioned the efficiency of
advertising self-regulatory bodies, noting that, “[t]he role of
self-regulatory bodies is rather limited in terms of achieving
major public policy goals”. More recently, Wharton  has
pointed out some serious problems related to self-regulation.
Therefore, it appears that an Egyptian government policy is
needed to guide the practice of product placement and that
self-regulation is not a practical option. The following sections
list and summarize the various aspects recommended for such
Discussions about the subject of disclosure are based on a
two-phase analysis. In the first, disclosure is determined
whether needed or not. Then, if disclosure is needed, in the
second phase the nature and form of necessary disclosure is
The need for disclosure
The existing international product placement regulation
prioritizes disclosure. This is particularly evident in current US,
Brazilian, Turkish, Korean and EU regulations. Enforcing some
form of disclosure when product placement is used is critical
from a socio-cultural perspective for ensuring that there are
no forms of subliminal or surreptitious advertising.
While the above countries agree that disclosure is
mandatory, their policies diverge on the form of disclosure required. For example, the US and Brazil do not specify the
type of disclosure. This approach is not useful, however, if the
main objective of a disclosure requirement is to alert
audiences to the commercial content. A more sound policy
therefore is that of Turkey, Korea, and the UK, where
sponsorship notifications are required to be clear and hard for
viewers to miss. Because Turkish product placement laws are
moving towards a more commercial approach that would
increase funding, the Korean and UK regulation may be more
suitable for an Egyptian policy recommendation if protection
for audiences is taken seriously.
Forms of disclosure
Both the Korean and UK systems ensure that sponsorship
identification is clear and visible. The UK requires sponsorship
identification to occur at the beginning and end of
programmes as well as after every commercial break. This is
done through a P logo, which appears on screen at the
beginning and end of a programme and at the end of
commercial breaks. In Korea, identification is only required at
the beginning of a program through subtitles.
Although the UK system applies stricter disclosure rules, the
Korean sponsorship identification, through subtitles after
opening credits, is a better option and should be emulated by
any Egyptian product placement regulation.
There are several reasons subtitles are preferred. Firstly,
subtitles allow people to read and know what specific brands
are placed. Secondly, audiences could easily miss the P logo.
Thirdly, even if people notice the P logo they might not be
aware of what it stands for.
While disclosure needs to be prominent and visible to
viewers, some forms of excessive disclosure notifications and
notifications that are embedded within programmes could
backfire. Reijmersdal, Tutaj, and Boerman  find that
audiences were irritated by excessive and repeated disclosures
of product placements within programmes. This implies the
following for an Egyptian product placement policy proposal:
While a notification signaling the use of product placement
must be strategically placed to achieve visibility, the
notifications must not be exaggerated or situated at times
when they might interrupt the viewing experience and draw
more attention to placed brands.
The most significant stipulation that should be a part of any
product placement policy is the presence of “editorial
justification” as a prerequisite. This is a strong aspect of
European Union regulation, and accordingly, incorporated by
the UK policy.
While various models reviewed call for editorial justification,
it is unclear to what extent it is actually enforced. However, in
the UK, evidence suggests that the principle of editorial
justification is firmly applied .
Editorial justification is crucial, because it helps limit
excessive international commercialism trends. This is
addressed by Rannamets  who fairly notes, “If product
placement goes as far as to invade all the possible industries,
then a minute would not go by without someone trying to sell
something”. A development like this would undermine the
important socio-democratic function of the media because
excessive placements coupled with a lack of editorial
justification would harm the trustworthiness of the media and
their editorial content. Consequently, it is strongly suggested
that editorial justification should be the basis for any proposed
product placement policy in Egypt.
Placements Offered as Props
As the review of international product placement policies
has revealed, numerous countries allow placements used as
‘props’ that are offered free of charge. But, for best results the
non-disclosure policy associated with props should only be
applied in Egyptian media if two conditions were met.
The first is that ethically charged products or brands banned
in traditional advertisements may not be used as props. If this
condition was not strictly applied, unregulated prop use would
merely become a vehicle to promote controversial products
that are restricted in other types of television promotion. The
second condition is in accordance with the current United
Kingdom policy. Any new Egyptian regulation should make
clear that in cases where props are used as placements;
editorial justification must always be present otherwise,
sponsors will abuse this rule.
Limiting Product Placement to Certain
Egypt should follow approaches seen in Turkish, Korean, and
UK television because they have a comprehensive and logical
classification that is being adequately enforced. The credibility
of factual shows might be greatly undermined if they were to
include advertising messages in the form of placements.
Viewers could rightly suspect that commercial interests were
tainting content presented as being factual and unbiased. The
UK policy’s specification that placements be banned from
religious shows seems very practical for the Egyptian context,
where religious programming is already facing credibility
challenges. Moreover, placements should not be allowed in
children’s programmes as Williams et al.  examined the
ethicality of product placement in children’s shows and has
illustrated the potential harm to younger viewers.
Ethically Charged Products
Arguments associated with the placements of ethically
charged products were examined by Balasubramanian; Basso;
Berglund and Spets; Brennan, Rosenberger, and Hementera;
Galician; Gupta, Balasubramanian, and Klassen; Kim and
McClung; Schejter; Wenner and Hackley, Tiwsakul, and Preuss
[4,6,7,13,21,49-54]. Such concerns have been reflected in the policies of the EU and other countries like Turkey, which ban
placements for certain controversial product categories such
as alcohol, tobacco, and prescription medications. A
comprehensive Egyptian product placement policy
recommendation should not overlook the issue of “ethically
charged” products. Social responsibility mandates that the
media prohibit the promotion of products that could have
Egypt may benefit from emulating the UK model in this
area. The UK regulation, in-line with the EU’s AVMS directive,
reflects a deep concern for the overall wellbeing of its citizens.
It bans typically controversial products like alcohol and
tobacco, but also goes beyond that to ban other categories like
medication, gambling, and junk food.
It is recommended that a list of culturally and religiously
controversial products be carefully compiled and thoroughly
Another reason placements of particular brand categories
should be banned is to protect children against exposure to
certain products, and their usually favourable presentation,
that may not be age appropriate. This seems particularly
important in Egypt, where there is no watershed, as there is in
the UK for example. Egyptian children generally do not have
set bedtimes, and families usually do not restrict televisionviewing
hours. Thus, in Egypt, for example, it may not be wise
to limit certain placements to late hours, assuming that
children will not be exposed to them.
Whilst regulations in other countries have some strong
points, the policies of the United Kingdom and Korea, in
particular, stand out as the most elaborative since they are
socially, culturally, and ethically, airtight and descriptive,
accommodating boundaries within its framework. A desirable
and effective comprehensive policy is not just about having
more regulations, but ‘more specific’ ones, which makes them
The Egyptian broadcast would benefit from emulating the
UK and Korean practices because they stress placement
disclosures and specify their manner, emphasise the
separation principle in certain programming, prohibit undue
prominence, attempt to limit commercialism, and ban
placements in particular brand categories.
In Egypt, the creation of a specific regulatory body which
implements such measures may not be necessary. Since a
specific advertising censorship unit already exists, this body
may become responsible for implementation of any upcoming
product placement regulation. Here again the emphasis should
not be on creating new entities, but rather making sure that
existing ones are more effective.
Given that the Egyptian constitution has recently created
the Higher Council for Audio-visual Media (Article 211), and
that this Council which has begun to play an active role in
overseeing the overall broadcast policies in a manner similar to
OFCOM. The challenge will be to avoid vagueness of roles or the creation of different bodies that have dual or redundant
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