From time to time I like to remind clients of specific network guidelines to keep in mind when developing advertising.  One such guideline involves sponsorship identification.

Per the network guidelines, advertising must contain proper sponsorship identification pursuant to the Communications Act and rules and policies of the Federal Communications Commission (47 C.F.R. § 73.1212).

In the case of advertising for commercial products or services, an announcement stating the sponsor’s corporate or trade name, or the name of the sponsor’s product, may be sufficient when it is clear that the mention of the name of the product constitutes sponsorship identification.  Only one such announcement need be included in the commercial.

In the case of a political advertisement, any paid advertising by a trade association or charity, or in the case of a public service announcement for which the air time is purchased, the sponsorship identification announcement must contain the term “paid for” or “sponsored by,” and must fully and fairly disclose the true identity of the person, committee, or other entity furnishing the consideration.

Sponsorship identification may be made in the audio or video of the commercial.  Any portion in the video should be clearly legible to an average viewer and remain on screen long enough to be read in full by an average viewer.

A website URL generally does not constitute adequate sponsor identification, unless it is the official name of the sponsoring entity.

The networks are careful not to accept advertising that does not contain proper sponsorship identification.  So, if you have plans to create advertising intended to air on the broadcast networks, make sure the sponsorship identification complies with the network guidelines.  And remember, when in doubt, ask questions.  The network editors are there to answer any questions you may have.

Marilyn Colaninno is Director of Rights and Clearances for Reed Smith and is responsible for clearing commercials for the firm’s many clients in the advertising industry.  If you have specific questions, please contact Marilyn directly at 212 549 0347 or at mcolaninno@reedsmith.com.