When the Product You're Placing Is Your Own

Is cross-promotion product placement?

I ask because the Federal Communication Commission is currently mulling whether to slap tighter controls on "embedded advertising techniques," as placement is also called. This is probably a good idea: Viewers who care what marketing messages are being infiltrated into their cortices shouldn't have to watch the credits on frame-by-frame to find out.

But it does raise some interesting questions, including the one atop this post. Cross-promotion between shows has always been a feature of prime-time programming, and it seems to be enjoying a renaissance. Among the most avid practitioners (or worst abusers, depending on your point of view) is CBS's intermittently funny How I Met Your Mother, which has written scenes or even whole episodes around other CBS properties including, but not limited to, CSI, The Price Is Right, the Victoria's Secret fashion show and the Super Bowl (when it was on CBS).

Are these plugs? Definitely. Should CBS have to note, at the end of the episode or even in an on-screen crawl during the action, that, say, CSI is a CBS show? It seems a little extreme.

But say the F.C.C. decides it should. What, then, do you do with 30 Rock? Every episode is one big, self-mocking advertisement for NBC and GE. Sure, the brands it showcases -- the TriVection Oven, MILF Island -- are often made up, but it also features bona fide NBC stars and shows all the time. Do those appearances count as placement? Should every mention of GE in a script require a disclosure, even though the corporate parent is unfailingly the butt of jokes? Or would an exception be made for irony?

Which raises the biggest question of all: Does the federal government have a sense of irony?

EARLIER: The problem with product placement.

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