Ad Standards reflects upon recent decisions concerning outdoor women’s lingerie ads

Ad Standards has released an overview on its recent decisions regarding complaints about women’s lingerie advertisements in outdoor media, including shop fronts and shopping centre displays.

It noted that “the depiction of a person in sexy lingerie is of itself not in breach of the Code”, however the general community has “consistently been more conservative in its views around the issue of sexuality and nudity than for other sections of the Code”. The summary primarily focused on the depiction of women, since “Ad Standards does not receive a large number of complaints about advertising that features men in underwear”.

“Generally, the Australian community does not find the depiction of male chests and nipples to be strongly sexualised or inappropriate nudity,” Ad Standards noted.

A Honey Birdette poster banned by Ad Standards previously. 24 Honey Birdette decisions were referenced in the summary

More revealing images could be appropriate if they are shown in-store or online when the audience is targeted, said Ad Standards, and there are “many ways” to advertise lingerie without breaching the Code.

“It is reasonable for lingerie advertisers to depict women in the product they are selling, if the women appear confident and are not posed in a sexually provocative manner or in a manner suggestive of sexual activity,” the Community Panel determined, adding that an ad will breach the Code if it depicts the woman, rather than the lingerie, as the product.

“Advertising that suggests the woman is property or that she exists for the enjoyment of others will breach this section [2.2 – Sexual appeal must not be used in a manner that is exploitative or degrading] of the Code. This includes the depictions of unequal power such as a woman in lingerie being surrounded by fully dressed men if it does not have relevance to the product being sold.”

People can pose together in a lingerie ad, regardless of gender, so long as “it does not appear that the people are about to engage in sexual activity”, Ad Standards noted. Ads that feature straddling or embracing are likely to breach the Code.

“This includes poses such as legs spread, pushing the torso or bottom forward in a sexualised manner, or reclining with back arched and eyes closed,” Ad Standards added.

The watchdog went on to say that an ad must be appropriate for its ‘relevant audience’, but for ads in public places, it will also consider the unintended audience, which is often children. Whether children are considered an audience for the ad could depend on whether it is placed in-store versus in a store window.

Advertisers were also warned about images featuring “S&M style lingerie”.

“Featuring a collar in itself will not breach that Code, but the addition of props and overly sexual poses will make it more likely to be insensitive to the relevant audience,” the summary read.

“The use of nipple pasties can draw attention to the breast and nipples of the woman which is not appropriate for a broad audience.”

However, Ad Standards noted that images of nipples may be appropriate if they are obscured by fabric or edited out, or in ads for plastic surgery or art exhibitions, for example. Images of genitalia, full-frontal nudity, and explicit pornographic language are, however, prohibited.

“Explicit nudity includes full breasts, genitals, pubic region or full bottom, including when it is seen under sheer fabric,” it said.

“Advertising should be wary in the use of lighting or photoshop, which may bring a sexually gratuitous focus to body parts. Images that feature very high-cut or low-cut briefs or G-string should take steps to avoid bringing attention to the nudity.”

The summary also turned to the issue of body representation and positivity, referencing a practice note which states that: “Lingerie advertising must not portray unrealistic ideal body image by portraying body shapes or features that are unrealistic or unattainable through healthy practices.

“While the use of people in smaller or larger bodies is itself not necessarily problematic, advertisers must ensure that models do not adopt a pose or are not depicted in a way which produces an unrealistic sense of body image, for example through the style of the advertising, the clothing, lighting, or make-up used.”

Digitally altered images must still appear realistic or attainable through healthy practices.

In illustrating each rule as it relates to the Code, Ad Standards referenced 24 determinations made in response to complaints about lingerie retailer Honey Birdette. Of those complaints, 16 were upheld and eight dismissed.

Research Ad Standards commissioned in 2017 showed that decisions since 2007 “largely aligned with the sentiment of the wider community”, and where there was a disconnect between an Ad Standards decision and community sentiment, community opinion was almost always more conservative.

Correction 4 September 2019: An earlier version of this article suggested that Ad Standards commissioned recent research into its decisions concerning women’s lingerie ads. Ad Standards has since clarified that the summary refers to research conducted in 2017 on all Ad Standards decisions from 2007-2017.


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