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Q: Promotions to Children ( No Answer,   0 Comments )
Question  
Subject: Promotions to Children
Category: Arts and Entertainment
Asked by: tsan-ga
List Price: $50.00
Posted: 27 Jul 2004 17:02 PDT
Expires: 28 Jul 2004 12:55 PDT
Question ID: 379974
Question involves incentive programs for children under the age of 16.
 This is NOT a privacy act question; I'm quite familiar with COPPA. 

Here goes:

May a child (with his parent's permission) participate in an incentive
program for a for-profit commercial entity.  E.g., may a child
encourage his friends to buy a toy, and for each toy he sells, he gets
a prize (or points worth a prize)?

I already know that
a) a child may participate in an incentive program to assist a non-profit
b) a child may participate in an incentive program if all he has to do
is take surveys

Request for Question Clarification by pafalafa-ga on 27 Jul 2004 17:26 PDT
Kids work to get money all the time...selling lemonade, shovelling
snow, selling their toys on ebay.  I've never heard of any sort of
prohibition about children getting involved with income-producing
activities.

There may well be prohibitions for companies about soliciting the
involvement of children.

Is your question about the former (can kids participate) or the latter
(can companies solicit children for an incentive program)?

Oh...and please tell where you are -- state, city (or country, if
you're not in the US).

Thanks.

pafalafa-ga

Clarification of Question by tsan-ga on 27 Jul 2004 19:02 PDT
Thank you. Let me try to clarify:  

All the things that you referenced are non-commercial efforts.  That
is, selling lemonade or washing cars, etc. do not involve commercial
entities.  Moreover, things like school bake-sales and carwashes do
not rise to the level of regular employment (so no child labor laws),
nor do they involve a purely commercial third-party enterprise. 
Accordingly, I'm not interested in those things.

More specifically, I would like to know what limitations there are on
for-profit companies (like Mattel, or Schwinn) soliciting children to
"market" a new toy in exchange for a prize.  For instance, Mattel
gives child a new bike and says, "for every kid you get to buy this
bike, you get 200 points.  Save up enough points and you can get a
prize."

Hope that is more helpful.
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