Advertising aimed at children | No privilege in the meta-verse

Gap Canada announced on Friday that they are now advertising in Roblox, a popular role-playing platform for elementary school children. However The Consumer Protection Act prohibits advertising aimed at children under 13 years of age.

Posted at 06.00

Isabelle Dube

Isabelle Dube
The press

Gap Canada has proudly integrated the Friday meta-verse into the Roblox online multiplayer gaming platform. The American brand has its own virtual store where young players behind their avatar can enjoy a juice bar, try out outfits, take pictures and make fashion shows, the statement said.

The virtual store Gap Teen was also very busy Friday night during the visit of The press.


Our journalist’s avatar surrounded by other players present in the Gap Teen store on Friday

A majority of children on Roblox

Although Gap Canada announces that they want to provide “the opportunity for teens to discover the world of Gaps”, the Roblox platform attracts a majority of children under the age of 13 with its games of adopting small animals, decorating houses and roles in this modern virtual city . Roblox Corporation also stated in 2021 that 54% of its users were under 13 years of age.


The press could sign up for Roblox with 2016 as his year of birth, although the platform is reportedly designed for ages 10 and up.

Roblox is also advertised as being for ages 10 and up. However, it was possible to sign up by stating 2016 as the year of birth.

The law is clear

That The Consumer Protection Act prohibits advertising aimed at children under the age of 13, not only on television, but also on the Internet and thus in the metaverse.

“The law states that any advertising for commercial purposes directed at persons under 13 is prohibited,” said Alexandre Plourde, an attorney at Option Consommateurs. To determine if the ad is aimed at children under the age of 13, an assessment of the context is made, such as when or where it appears. »

“So an advertisement that is made on a platform where there are mainly children under 13 years, which allows young people under 13 years to register directly, the lawyer continues, one would think that it is aimed at children under 13 years. »

The law clarifies that even if an advertisement is aimed at teenagers and adults or is broadcast during a viewing period intended for this older audience, it cannot be assumed that it is not intended for children.

The law was enacted in the early 1970s and states that a child cannot distinguish between information and promotion.

Since General Mills admitted to breaking the law in 2009 with their online games inspired by Lucky Charms grain, ads disguised as games have also been investigated.

At the time, the food giant had to pay a paltry $ 2,000 in fines.

The fine was higher for Coca-Cola, in 2015, which had created a water element in the colors of the soft drink Fanta, at La Ronde. Admittedly guilty, the multinational had to pay a fine of $ 27,664 to the Quebec government.

Advertising in the form of gifts is also not tolerated. Saputo’s distribution of Igor cakes to day care centers had fined him $ 44,000. Saputo decided to plead guilty in 2009.


Young players behind their avatar can enjoy a juice bar, try out outfits, take pictures and make fashion shows in Gaps virtual store.

The law applies to any merchant doing business in Quebec, even if its head office is abroad, the Option Consumers Lawyer recalls. “To the extent that this company, Gap, conducts business in Canada, advertises for people located in Canada, promotes goods or services in Canada, it must comply with the laws in force in each of the provinces.”

If a complaint is filed with the Consumer Protection Office and it leads to an investigation, Gap could be prosecuted and fined.

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