ABSTRACT
In many countries, self-regulation is a major force in the control of advertising. Business groups, working with media associations, heavily influence advertising content in many European countries, including France and the United Kingdom. In New Zealand, ad agencies, advertisers, and media associations work together under a single self-regulatory body. These countries are culturally more homogeneous than the United States, however, and have smaller media systems serving smaller populations. (The entire population of New Zealand, for example, is less than that of many major U.S. cities.) Moreover, because the countries have no constitutional protection for free speech, their governments act more decisively against misleading advertising than does the U.S. government. And because they have no antitrust laws, their trade associations and media are able to work together to restrict many questionable practices. In the United States, on the other hand, the existence of antitrust laws, along with a fragmented and highly diverse media system, means that any effort at self-regulation involves a different set of powers and limitations.
