Production
A child in the frame changes the paperwork more than the shot. Philippine law lets children work in advertising only as an exception, with a permit from the Department of Labor and Employment before they are engaged, hour limits by age, and a short list of products they can never front. The Ad Standards Council checks for the permit at screening. Here is what the brief has to account for.
Can a child appear in a Philippine ad?
Yes, as an exception. Section 12 of the child protection law, as amended by Republic Act 9231, bars the employment of children below 15, but allows it where a child’s “participation in public entertainment or information through cinema, theater, radio, television or other forms of media is essential”. For that exception, the law sets three conditions:
→ The parents sign. The employment contract is “concluded by the child’s parents or legal guardian, with the express agreement of the child concerned, if possible, and the approval of the Department of Labor and Employment”.
→ The permit comes first. The employer “shall first secure, before engaging such child, a work permit from the Department of Labor and Employment”.
→ The employer protects the child. Health, safety, morals and normal development; no exploitation in pay or working time; and a programme for the child’s training and skills, approved by the authorities.
For these rules, “child” means anyone under 18, so a 16-year-old in a school uniform spot is covered too.
How many hours can a child work on set?
| Age | Daily limit | Weekly limit | Not allowed between |
| Below 15 | 4 hours | 20 hours | 8 p.m. and 6 a.m. |
| 15 to 17 | 8 hours | 40 hours | 10 p.m. and 6 a.m. |
These are Section 12-A’s limits. For a child below 15, a four-hour day decides the call sheet: the shots a child appears in get scheduled first, with adult-only set-ups, plates and cutaways around them.
The call-sheet rule
Write the child’s hours on the call sheet before the shot list. If the board needs more than the law allows in a day, the answer is a second shoot day, not a longer one.
Which ads can never use a child model?
Section 14 is absolute: “No child shall be employed as a model in any advertisement directly or indirectly promoting alcoholic beverages, intoxicating drinks, tobacco and its byproducts, gambling or any form of violence or pornography.”
The ASC Manual adds rules on portrayal for every category. Under its standards for the protection of children, ads “shall not present children as being in contact with, or demonstrating, a product recognized as potentially dangerous to them without adult supervision”, shall not show them alone in activities that clearly need an adult, and shall not show them in hazardous activities that disregard safety.
Who controls the child’s pay?
→ The pay belongs to the child. Section 12-B says the child’s earnings belong to the child, set aside first for support, education or skills, and that not more than 20% may go to the family’s collective needs.
→ Higher earners need a trust fund. Under Section 12-C, where a child earns at least ₱200,000 a year, the parent or guardian sets up a trust fund for at least 30% of the earnings and reports on it to DOLE twice a year.
What does ASC screening ask for?
The DOLE permit is one of the documents the ASC expects at screening. Its Manual describes an “Incomplete” decision for material whose claims are substantiated but whose required documents, “such as DOLE permit, notarized endorser’s affidavit”, have not been submitted. Those documents are due no later than 11 a.m. on the 30th calendar day, counting the date of the application. A permit that arrives late can hold up a cleared ad.
Does an AI-generated child change anything?
It removes the work permit, because no child is employed. It does not remove the rest. The ASC’s AI circular keeps in force every rule “governing the participation, representation, or portrayal of minor-aged talents in advertising”, and the Manual’s portrayal standards apply to what the ad shows, however it was made. A generated child in an alcohol ad is still a child depicted in an alcohol ad. And a generated child who looks like a real, identifiable child brings consent back in. What the ASC now requires covers the disclosure label every AI-made ad needs.
Should you cast a child or generate one?
Cast when the performance carries the spot: a reaction, a laugh, a moment between a parent and a child. Generate when the child is a background figure, the scene would push the hour limits, or the action would be unsafe to stage. PUNX runs AI video production from Makati for brands including Procter & Gamble, GCash and Sun Life, and can tell you which shots in a board need a real child, a permit and a call sheet, and which can be generated.
General information, not legal advice. Confirm DOLE’s current permit requirements and processing time before you book child talent.
FAQ
Do child actors need a work permit in the Philippines?
Yes. An employer must secure a work permit from the Department of Labor and Employment before engaging a child below 18 for public entertainment or media work, with the contract concluded by the child’s parents or legal guardian.
How many hours can a child work on a commercial shoot?
A child below 15 may work up to 4 hours a day and 20 hours a week, and not between 8 p.m. and 6 a.m. A child aged 15 to 17 may work up to 8 hours a day and 40 hours a week, and not between 10 p.m. and 6 a.m.
Can children appear in alcohol or tobacco ads in the Philippines?
No. The law prohibits employing a child as a model in any ad directly or indirectly promoting alcoholic beverages, intoxicating drinks, tobacco, gambling, violence or pornography.
Does using an AI-generated child avoid the rules?
It avoids the work permit, because no child is employed, but not the portrayal rules. The ASC’s AI circular keeps the rules on portraying minors in force, and a generated child who resembles a real child may need consent.
Related
AI video production — the service, from brief to delivery
AI disclosure in Philippine ads — what the ASC now requires
Video production brief — what to include before the shoot
Child in the board?
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