The Broadcasting Commission of Ireland (BCI) has received only 17 submissions to its first public consultation on the development of a children's advertising code.
In this first phase of consultation, the results of which are due for release next week, it asked respondents to consider what defined "a child" in relation to advertising, and what constituted "children's advertising".
RTÉ recommended that there be three child classifications: under five years, five to 12 years and 13 to 15 years. The code should only apply to advertisements aimed at children and broadcast during programmes aimed at children. The code should not apply after 6 p.m.
TV3 defines three categories of child as those under 10, 10 to 14 year and 15 years and up, who would require "little regulation, if any". It considers children's advertising that "which is of particular interest to children and is broadcast during children's programmes".
The Independent Broadcasters of Ireland said those over 15 "do not fall within the category of child". The content of the programme around which the advert is shown and the advertiser's target audience should be used to define "children's advertising".
The submission from the Institute of Advertising Practitioners in Ireland and the Association of Advertisers in Ireland suggested a pre-school category, a primary school category and a secondary school category.
Those over 15 years fall into "the universal marketing and Irish-used research definition of an adult". However, an age definition alone was "problematic" and room should be allowed for parental guidance.
Their submission uses the same definition of children's advertising as TV3.
The National Children's Office defines a child as a person under 18 years. However, it said younger children must be governed by stricter rules. The code should include advertising which may be targeted at adults but which is viewed by or may be seen as attractive to children.
The Children's Rights Alliance defines a child as a person under 18 years and children's advertising as all advertising that children see.
The National College of Art and Design said it should be recognised that children under the age of five do not distinguish between programmes and advertising, and from five to eight years they have "no comprehension of the persuasive intentions of advertising".
The Food Safety Promotion Board said children under 12 years were particularly vulnerable to advertising, "often failing to understand the difference between the purpose of advertising and other modes of communication".
The Dental Health Foundation expressed concerns about the advertising of products to children which have a detrimental effect on their oral health and overall well-being, but did not define children's advertising
The Advertising Standards Authority said its main concern in regard to any code was that "sufficient room be left for self-regulation".