Obtaining Network Clearance
June 3, 2004
I. What is Network Clearance?
All commercials intended to air on the broadcast networks must be reviewed and approved by the networks before they can air.
The policy of the broadcast television networks is to present advertising that is truthful and tasteful, and not misleading or deceptive.
This policy is not only mandated by their obligation as broadcasters to operate in the public interest, and by state and federal laws and regulations, but as a matter of good corporate citizenship.
This function is the responsibility of the Standards and Practices Department. Each network has a standards and practices department comprised of editors who review all advertising and ensure compliance based on the network guidelines for advertising.
II. Network Guidelines
The guidelines cover a broad array of product categories and production techniques.
The guidelines tend to be substantively similar for each of the networks. However, there are often differences in style and judgment from one network to another.
The guidelines are updated regularly.
III. Network Clearance Procedure
The network clearance procedure is relatively straightforward. It consists of two parts, preliminary review and final approval.
To start the process, the advertiser or advertising agency will submit a client approved storyboard to the networks. The editors will review the creative and will provide a written status report.
This is the most important step in the clearance process for it is during the preliminary review process the networks will determine if the storyboard is approved or not.
IV. Claim Substantiation
If the storyboard is not approved, the editors will tell you why. The most common request from the editors at this stage is to provide substantiation for all claims being made in the advertising.
The type of substantiation required will depend upon the claim being made.
The network guidelines provide helpful information regarding what type of substantiation will be required. The editors are also available to provide further information as well.
V. Taste Issues
One area of great sensitivity in the network clearance arena relates to taste issues. The editors are very careful not to accept advertising which they feel will offend a large portion of their viewing audience.
What is offensive to one person, may not be offensive to another. In determining what is appropriate, the editors will take into consideration the needs of their viewing audience.
VI. Final Approval
At this point, the finished commercial will need to be submitted to the networks with a final as-produced script.
The final commercial should adhere to the originally approved storyboard as much as possible.
If either you or your client wants to make last minute changes, it is highly advised that the editors approve those changes as quickly as possible.
Once the final commercial is approved by the networks it can air.
VII. To Clear or Not to Clear? That is the Question.
The local stations are independent of the networks and will air commercials based on the needs of their individual markets.
The networks' owned and operated stations generally comply with the networks' guidelines. However, they are free to make their own decisions, independent of the networks, if they so choose.
VIII. Cable Clearance
Many of the cable networks, particularly those owned by the networks or by the same parent company as the networks, are now reviewing commercials for air.
The clearance procedure is basically the same.
The cable networks have programming that is very specific to their target market, and they determine the acceptability of commercials based on the needs of their particular target audience.
IX. Five Helpful Tips
- Start the clearance process as early as possible.
- When in doubt, call the editors.
- Submit claim substantiation and other support materials as far in advance of production as possible.
- Obtain approval on storyboards from all of the networks prior to production.
- Submit final commercials well in advance of the first airdate whenever possible.
X. What This All Means
As we all know, it takes many people working together to get a commercial from concept stage to broadcast.
The network clearance editors are an important part of that process.
The network clearance process is truly a collaborative effort. And when everyone is on the same team, we all benefit.
"Network Clearance: A Guide for Advertisers and Agencies." Marilyn Colaninno, Director of Rights and Clearances, Reed Smith LLP.