Imprints on campaign materials promoting a political party
Under the Political Parties, Elections and Referendums Act 2000, there are rules about putting imprints on printed election material promoting political parties or categories of candidates at certain elections.
IMPORTANT !
Reform UK policy is to include a legal imprint on everything, all campaign material, both printed and online, at all times.
The reasons for this are as follows:
i) It removes the need to work out whether or not one is legally required, based on laws and guidelines which are not always crystal clear.
ii) Election material can be produced in advance of a period where it is legally required, and “persist”, still be around, during a period where it is. For example, an post online could be made in advance of an election campaign period, but still be available to view during it, or a leaflet could be printed several weeks or months before, but still be “in circulation” when an election campaign period subsequently begins.
iii) It’s just a really good habit to acquire, it protects both you and the Party.
Election material is published material that can reasonably be regarded as intended to influence voters to vote for or against one or more political parties or a category of candidates.
Whenever this sort of material is produced, it must contain an imprint to show who is responsible for creating the material and promote transparency.
These materials include t-shirts and other items of clothing, badges and business cards. As there would be printed material on these items, an imprint is required.
For example, a party could produce a t-shirt with an image or a phrase on it saying “Vote for X Party”.
In some cases, such as a badge of business card, if it is impractical to include a full imprint on it, you should include the text of a link that leads to your full imprint.
Here is a link to a factsheet on imprints which may be helpful.
Party spending is material that promotes the party, it is not confined to material that has campaign messaging, it includes material that is aimed at enhancing the standing of the party generally.
It also includes material put out by the party that promotes its candidates, before the start of the period where the rules for candidate spending apply.
The imprint on campaign material being caused to be published by the national party, typically paid for by it, just promoting itself, can be very simple and look like this
Promoted by Reform UK, Millbank Tower, 21-24 Millbank, London SW1P 4QP
— note that there is no requirement to include the name of a person in Reform UK in the imprint,
— if you choose to include someone in the imprint, then it should be the name of the person within the organisation who caused the material to be published, ie, the person who authorised the spending involved, typically this might be the party treasurer.
Imprints on campaign materials promoting candidates
Under the Representation of the People Act 1983 and associated legislation, there are rules about putting imprints on printed election material.
Candidate election material is any material that can be reasonably regarded as intended to promote or procure the election of a candidate at an election.
Whenever printed election material is produced, it must contain certain details (referred to as an ‘imprint’) to show who is responsible for the material. This helps to ensure there is transparency about who is campaigning.
The Electoral Commission provides advice and guidance on these rules but does not enforce them.
Decisions on the investigation and prosecution of imprint offences are a matter for the police and the prosecution services, and any allegations of non-compliance should be made to the police.
Please read the following full guidance carefully:
What must you include?
On printed election material such as leaflets and posters, you must include the name and address of:
- the printer
- the promoter
- any person on behalf of whom the material is being published (and who is not the promoter)
The promoter is whoever has caused the material to be published. The printer whoever printed it.
You must use an address where you can be contacted. You can use a home address or an office or business address. You can also use a PO Box address or other mailbox service.
You may use the Reform UK’s Head Office address, for both Promoted By and Printed By, if you are both promoting yourself, printing material at your own home, and the party knows who you are, and where to forward any post to, should any be sent to you at “Reform UK, Millbank Tower, 21-24 Millbank, London SW1P 4QP“.
Examples:
i) If you are the candidate, and are your own agent, paying for your own campaign materials, then
Promoted by Pete Durnell, Reform UK, Millbank Tower, 21-24 Millbank, London SW1P 4QP – covers legal requirements
— where the person is promoting themselves, there is no need to use “on behalf of”, ie no need to state “Promoted by Pete Durnell on behalf of Pete Durnell…”
ii) If you are the candidate, and are lucky enough to have been able to appoint an election agent, Joe Bloggs, who is dealing with your expenses, paying for campaign material, and will complete and send in your candidate spending return, then you can use an imprint along these lines:
Promoted by Joe Bloggs on behalf of Pete Durnell, Reform UK, Millbank Tower, 21-24 Millbank, London SW1P 4QP
— this assumes that both Joe Bloggs and Pete Durnell can be contacted at the London address.
— if they can’t, addresses where each may be separately contacted must be specified.
iii) If you are even luckier, and the party is paying for your campaign materials, these should include an imprint similar to this:
Promoted by Reform UK, on behalf of Pete Durnell, Reform UK, Millbank Tower, 21-24 Millbank, London SW1P 4QP
(Note that a spend value for this would need to be included in the candidate’s spending return, and also be recorded as a donation, by the party, to the candidate).
Digital Imprints
Under the Elections Act 2022, the law requires imprints on some kinds of electronic material. This guidance refers to electronic material as ‘digital material’. Examples of the types of digital material that need an imprint are explained in the guidance.
IMPORTANT !!!
Remember Reform UK policy is to include a legal imprint on everything, all campaign material, both printed and online, at all times.
The digital imprint requirements do not apply to digital material published prior to the commencement of Part 6 of the Act. However if that material is republished once the Act has been commenced, the republished material will become subject to the requirements.
Details of the new requirements for digital material can be found here, along with some examples:
https://www.electoralcommission.org.uk/statutory-guidance-digital-imprints
Imprints on campaign material purchased by a local branch, promoting itself
If the promoter is not a person then it should be a body registered with the Electoral Commission, either the political party, Reform UK, or an accounting unit of it, which may be a branch in the future, however at the time of writing, the party has no accounting units registered with the Electoral Commission, so
Promoted by Reform UK, Millbank Tower, 21-24 Millbank, London SW1P 4QP
— should cover the legal requirements regarding promoter and promoted in this instance, where only one name/address is specified, it is assumed that “doing the promoting” and “being promoted” are the same.
— Reform UK is the organisation causing the material to be published, the London address is an address through which it can be contacted if there is an issue with the leaflet. Remember branches are just a part of the Party.
If you have material that you would like the Electoral Commission to review and provide an opinion on,
– contact them, and they will be very happy to look at it and advise you:
https://www.electoralcommission.org.uk/contact-us/contact-us-online
Pete Durnell 