15 September marks the start of the final six weeks before the new ‘unit pricing in advertising’ rules come into force. You can bet a lot of people, including ACMA, will be watching closely to see who complies and who doesn’t.
To assist, Cooper Mills has prepared this ‘Unit Pricing FAQ’.
Broadly, what are the Unit Pricing Rules about?
It’s intended to be like grocery unit pricing, where eg all the brands of cereal in their different sized packs are required to be displayed with two prices: the price of the pack and the price of the contents per 100 grams. So consumers can readily compare price and make up their minds about value.
What telco products do the rules apply to?
Only two kinds of plan are affected.
Included Value Plans
The first is post-paid mobiles that feature ‘included value’ like ‘$50 = $500’ where the $500 can be spent on calls / SMS / data. (The rules say this doesn’t apply if the use of calls, SMS and data are all unlimited under the plan, but this seems odd because if you offered a fully unlimited plan, you wouldn’t advertise it as ‘$50 = $500’.)
Post-paid Internet Plan with included data allowance
The second is an internet plan that is post-paid (ie customer can use the service in whole or part without having paid for it yet) and includes a data allowance eg a ‘1TB included’ plan.
In summary, the rules apply to:
- Post-paid mobiles with included call/SMS/data value
- Post-paid internet with included MBs
What do the rules require for these two kinds of plan?
They require that certain kinds of advertising for these two kinds of plan must include certain ‘unit pricing’ data that is calculated in a particular way and displayed in a particular way.
What kinds of ads do the rules apply to?
They apply to ‘Text Advertising’ only, and there are sub-rules that say what that is.
So what is ‘Text Advertising’?
Basically, it means written advertising that a service provider is responsible for, but excluding:
- TV ads
- non-static outdoor ads (eg on ‘video billboards’)
- website strip, banner or tile ads, or equivalent (but there are other parts of the rules that do affect these kinds of ads, so keep reading).
Get a copy of the Cooper Mills ‘Unit Pricing Compliance Guide’ for more details on ‘Text Advertising’ … what’s in and what’s out.
What’s the required ‘unit pricing’ data for mobile plans?
Cost of a 2 minute call
the cost (prior to any Discounts being applied) of making a 2 minute Standard National Mobile Call (including flagfall where applicable)
But this isn’t required if call usage on the plan is unlimited.
Cost of an SMS
the cost (prior to any Discounts being applied) of sending a Standard National Mobile SMS
But this isn’t required if SMS usage on the plan is unlimited.
Cost of a MB of data
the cost (prior to any Discounts being applied) of using one megabyte of data within Australia
But this isn’t required if data usage on the plan is unlimited.
What’s the required ‘unit pricing’ data for internet plans?
Cost of a MB of data
the cost (prior to any Discounts being applied) of using one megabyte of data within Australia
But this isn’t required if data usage on the plan is unlimited.
How does this ‘unit pricing’ data need to be displayed?
The answer is simple, and somewhat complex, at the same time!
It’s simple in the sense that the answer is ‘Prominently Displayed’.
It’s complex because ‘Prominently Displayed’ is a defined term under the Code:
Prominently Displayed means conspicuously presented in clear font and in a prominent and visible position that is appropriate for the Advertising medium in the main body of the Advertising.
We’ve made some detailed comments about that in the Cooper Mills ‘Unit Pricing Compliance Guide’. ‘Prominently Displayed’ is an important concept in the Code, and deserves special care and attention.
Some final comments
- None of the above rules apply to an ad that doesn’t include pricing or dollar value at all. So if you just advertise how great your new offer is in non-$ terms (eg ‘Fantastic Value ADSL with 2TB included’) you don’t need to state the unit cost in that ad.
- As noted above, small website ads like banners don’t count as ‘Text Advertising’ so they don’t need to include the unit pricing data. But they still have to hyperlink to a page containing it.
- There is a special rule for ‘catalogues’ of at least 8 pages. Roughly, it says you can put all the ‘unit pricing’ data in one section, even on a different page, and reference it in the offers that appear within the ‘catalogue’. (Anything under 8 pages is regarded as a ‘brochure’ that must include unit pricing data within the body of each advertised offer.)
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