The advertising at issue in CARU’s inquiry, a 30-second commercial for Subway’s Fresh Fit for Kid’s Meal, aired during children’s programming. The commercial explained that sweepstakes participants could win an Amazon Fire Kids Edition Tablet by collecting five specific Character Keepers from among the 32 Character Keepers produced as Subway premiums. CARU was concerned that the commercial contained no audio disclosures regarding the free means of entry, the likelihood of winning the Tablet or the need to be 18 years of age or older to enter the sweepstakes. After its review, CARU recommended that Subway use better disclosures, in the audio and in language understandable to kids, about these aspects of the promotion. CARU also determined that the language “Hurry in to Subway … otherwise you’ll miss out,” could create undue sales pressure and recommended that this language not be used in future advertisements.
CARU Recommends Subway Better Disclose Material Information in Advertising Sweepstakes to Children