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Food and beverage advertising and children: RAC position

About RAC

The Responsible Advertising and Children (RAC) Programme represents advertisers, agencies and the media worldwide. Its members share a common vision for the promotion of responsible marketing communications.

RAC members recognise that marketing communications need to be sensitive to children and families. Marketing communications seen by children must not mislead them or exploit their relative inexperience. Marketing communications must reflect the fact that children do not mature at the same rate and acquire consumer skills gradually. This approach is applicable to all sectors, including food and beverage advertising.

RAC members are acutely aware of the growing public health problems in the field of diet, physical activity and health, particularly the issue of childhood obesity. The global marketing communications community sees itself as part of the solution and is committed to ensuring that food and beverage marketing communications do not encourage unhealthy diets or lifestyles. Indeed, responsible marketing communications should help facilitate healthy choices.

RAC members understand the challenge and are responding directly to concerns expressed. Indeed, RAC members around the world, including in the US and Europe, are actively engaged in constructive multi-stakeholder fora in order to help make a participative and constructive contribution. 

Our commitment to high standards in advertising

National Self-Regulatory Organisations (SROs) monitor, police and enforce codes of conduct in over 100 countries worldwide. Effective self-regulation is ensured by the SRO providing a participative and robust framework in which codes can be monitored and enforced in a transparent and accountable way1.

Properly monitored and enforced, these ethical standards provide fast, free and flexible redress for consumers. These systems complement, rather than substitute, the existing regulatory framework and provide an additional layer of consumer protection. Without self-regulation, the only recourse for consumer complaints would be via the courts. 

The European Advertising Standards Alliance (EASA)2 has set out a best practice model of advertising self-regulation. Endorsed by the European Commission3, it is currently being implemented across Europe. It also provides a reference for self-regulatory systems worldwide.

RAC members comply with the international marketing communications standards set by the International Chamber of Commerce (ICC) in its Code of Marketing and Advertising Practice4, which are implemented, enforced and monitored at national level. 

Recognising the need to ensure particular care in relation to food and beverage communications, RAC members drove the adoption of the ICC Framework for Responsible Food and Beverage Marketing Communications5, which sets minimum standards for marketers operating in all markets worldwide and across all forms of marketing communications, including the internet.

Typically, national self-regulatory codes of conduct are developed in greater detail at national level to proportionately reflect national and cultural concerns and sensitivities. This is particularly true of food marketing communications since food is an area which is intrinsically shaped intrinsically by local culture and tradition. Many countries have developed detailed code provisions relating specifically to food marketing communications to children.

Yet, self-regulation goes beyond the establishment of industry-wide standards for responsible food and beverage advertising. In light of the debate about diet and health, industry has understood that the balance and nature of food advertising must align with changing societal sensitivities.

In fact, through their own strategic decisions individual companies and entire sectors are already adapting their marketing communications so as to precisely change the balance of food advertising to children6. Furthermore, they have committed to undertaking such ‘self-regulatory initiatives’ by monitoring them in transparent and participative ways in order to engender trust in their commitments.

A holistic response to a multi-factorial problem

Advertising does have an effect on food choices. Nevertheless, there is only evidence of a ‘modest direct effect’7 on children’s food preferences, consumption and behaviour. In the context of the multitude of factors that determine individual food preferences, consumption and behaviour, advertising is clearly a minor factor.8

Many studies have pinpointed the lack of physical activity as the single most important cause of obesity9. While calorie intake has fallen,10 the amount of energy people are expending has decreased sharply in recent years as lifestyles have changed11. More sedentary lifestyles derive from a host of factors: a steady migration of workers from manufacturing to services and office work, the increase in car use, the rise of the Internet and changing play patterns by the digital generation as a result of new technologies, safety fears and the reduced number of spaces available for physical exercise.

Scheduled exercise has also been dramatically reduced in schools12. Children are not only missing the energy expenditure from their vital early years but are deprived of the physical education that can teach them about the importance of lifelong physical activity. 

Research also unequivocally demonstrates the importance of socio-economic determinants, while illustrating how children’s diets and their consumption of particular product categories (such as chocolate and soft drinks) are in no way linked to their Body Mass Index.13

The importance of proportionality

‘Proportionality’ means that regulation must “achieve the stated public policy objectives without imposing unnecessary or disproportionate regulatory burdens”14. Any measures taken to address public health issues (nutrition, obesity, healthy lifestyles, etc.) must take into account the multi-factorial nature of the problem, while bearing in mind the relatively small influence of food and beverage advertising.

RAC members believe that proportionate public policy measures must include a regulatory framework that provides for fundamental rules against unfair and misleading advertising practices.15 In the field of food and beverage advertising, code provisions are being adopted and implemented to ensure that food advertisements are fast adapting to changing societal sensitivities.  By adopting specific self-regulatory code provisions at a national level, a response is ensured, which is measured against the level of political and societal concern about obesity. The incidence of obesity is not the same in all countries and is not the only eating-related disorder of concern to public health authorities.16

Advertising bans miss the mark

cademic and empirical studies17 compound the evidence that advertising bans are ineffective in combating excessive or unbalanced consumption and unhealthy

lifestyles. For example, empirical evidence shows that advertising bans do not affect obesity rates18. Furthermore, there is absolutely no correlation between food and beverage advertising spend or the number of food advertisements viewed by children and obesity rates.19

Independent data illustrate how in most mature markets the volume of food and beverage advertising and the number of ads viewed by children has been in decline or stagnation.20 Despite this obesity rates have risen inexorably in those very same markets. Often the data shows a mirror image of declining ad spend or food commercials viewed on the one hand and an increasing incidence of obesity rates on the other. (see appendices)

There is no scientific evidence to demonstrate that advertising restrictions could impact the incidence of obesity. The evidence clearly demonstrates that advertising bans cannot fulfil public health policy objectives and would therefore be, as numerous reports have concluded, both “disproportionate and ineffective21”.

Furthermore, any restrictions to advertising would have serious social, cultural and economic ramifications. In Europe, research shows that as much as 94% of revenues from children’s TV advertising are reinvested in children’s programmes22. In addition to the impact on the broadcasting industry, advertising bans would have significant negative consequences for the food industry and the economy in general.23 Reduced sales, job cuts, decreased consumer choice, stifled innovation and barriers to market entry are some of the potential repercussions of marketing restrictions.

Companies are responding

Consumers drive markets. A company will only remain profitable as long as it remains relevant to the consumer. There is an unprecedented shift underway as product portfolios of major food and drink companies are moving away from products high in fat, sugar and salt and towards products with higher micro-nutrient contents.  In addition to changes in product portfolios, companies are adapting their marketing practices and overall business strategies – from research and development and product reformulation, to marketing and community-related initiatives – to reflect consumers’ increasing health awareness.24

It is clear from the number and content of company initiatives in this field that consumer demand is having a profound impact on the supply chain, and although the process requires time, progress to date is “encouraging”25. Raising awareness of healthy diets and lifestyles and investing in consumer education will be crucial to accelerating the pace of change in both demand and supply.

Accordingly, industry understands that it has a role to play in helping to use advertising as a force for good to communicate the need for healthy lifestyles.  Already, the advertising industry has played a central role in public information campaigns around the world26 with over 20 such campaigns being launched in the EU alone.  With the EU Platform for Action on Diet, Physical Activity and Health27, the European advertising industry has further demonstrated its willingness to fund, develop and implement social marketing campaigns to promote healthy lifestyles.

Media Literacy

The World Health Organisation notes that the “acquisition of media literacy, starting in primary school, [is] important to promote healthier diets, and to counter food fads and misleading dietary advice.”

As part of the advertising industry’s response to the WHO Global Strategy, it has been investing in media education for 6 to 11 year olds and providing, free of charge, educational materials to primary schools that teach children to think critically about advertising in the context of their daily lives.  Media Smart28 has already been taught to over a million children in the UK, has been rolled out to Belgium, Germany and the Netherlands, Hungary, Finland and Sweden and will soon be in Italy and Portugal.

The Media Smart Expert Group, consisting of leading academics and educationalists in the field of media literacy, ensures the quality and independence of the programme by writing, reviewing and approving the teaching materials.  Endorsed by the Times Educational Supplement,29 the programme also enjoys the support of Rt. Hon Tessa Jowell, UK Secretary of State for Culture, Media and Sport,30 Ofcom (The UK independent broadcaster regulator),31 the UK department for Education and Skills, the Dutch Government and the European Commission.

When talking about digital media citizens of the future, Tim Suter of Ofcom, the UK independent broadcast regulator, said at to a meeting of stakeholders in January 2007:
“Media Smart so obviously, so patently gets it.  It understands that that’s the challenge of the future, it appeals to children clearly, it appeals to teachers equally clearly. It appeals to industry, people in this room are a testament to that and it appeals to policy makers, ditto.”

Conclusions 

In conclusion, RAC members:

  • Are committed to championing a responsible approach to food and beverage advertising to children.
  • Recognise the need for a strong but proportionate regulatory framework, able to meet its stated regulatory objectives without imposing disproportionate regulatory burdens.
  • Believe that this delicate balance is best achieved by maintaining a regulatory framework, such as that currently embodied in the EU Audi-visual Media Services Directive, complemented by detailed and effective self-regulatory advertising standards.
  • Are committed to full compliance with statutory regulation, but also to upholding, promoting and, where necessary, further strengthening effective advertising standards and their enforcement at national level.
  • Are open to constructive dialogue with all stakeholders to identify and address sensitivities to which codes of conduct can be adapted.
  • Are committed to a participatory and constructive approach in further developing advertising standards for food and beverage products and to accountability with regard to their implementation and enforcement.32
  • Will further employ their skills and know-how so that advertising be a force for good to promote healthy lifestyles.
  • Will continue to fund and support the development of media literacy campaigns in the EU and worldwide to better equip children with the skills needed to interact with a modern commercial world.

RAC, March 2007

APPENDICES

A)   Childhood obesity & food advertising in the UK: An inversely proportional trend
Source: Nielsen Media Research, UK Office for National Statistics, 2004


    Obesity rate/%                                                                                    ads/year

B)   No correlation between exposure to food advertising and overweight/obesity
Source: Based on IOTF obesity figures and Consumers International data on advertising

 

1. For example, advertisers in Europe have committed to monitoring the compliance of food and beverage advertisements with existing codes of conduct and making the results public in the context of the EU Platform For Action on Diet, Physical Activity and Health (http://mail.wfa.be/CodeComplianceResults2.zip)

6. For example, The US CBBB Food Advertising Pledge programme (http://www.cbbb.org/initiative/ProgramDocument.pdf) or the Contribution by UNESDA and its corporate members to the EU Platform for Action on Diet, Physical Activity and Health
 (http://www.unesda.org/linkdocs/commitments.pdf)

7. Ofcom, Childhood Obesity – Food Advertising in Context, 2004; Hastings et al, Review of research on the effects of food promotion to children, 2003.

8. Among the most important determinants of food preferences, consumption and behaviour, individual taste preferences, price and familiarity and the family food environment play the major role (See for example: Ofcom, Childhood Obesity – Food Advertising in Context, 2004; Johnson et al., 1991
; Dickinson, R., 1997
).
There is broad consensus that the causes of obesity and its related diseases are multi-factorial (including genetic predisposition, diet, sedentary lifestyles, socio-economic factors, etc). Does Children’s Screen Time Predict Requests for Advertised Products? Cross-sectional and Prospective Analyses, Lisa J. Chamberlain, MD, MPH; Yun Wang, MS; Thomas N. Robinson, MD, MPH-  April 2006 and published in the Archives of Paediatric Adolescent Medicine (From Pg 366 or 4/6): "Third graders reported an average of nearly 11 hours per week of TV watching and nearly 23 hours per week of total screen media use. They also reported requesting an average of about 2 foods or drinks every 3 weeks. An extra 1 hour per day in total weekly TV viewing at baseline was associated with an [one] average extra request for an advertised food/drink about every 6 to 13 weeks (0.08-0.15 requests per week) 7 to  20 weeks later, and an extra 1 hour per day of total screen media exposure was associated with an [one] average extra request for an advertised food/drink about every 13 to 24 weeks (0.08-0.04 requests per week) 7 to 20 months later." The number of requests for advertised products seems hardly out of the ordinary, and the incremental effect of increased media exposure is actually negligible. It seems unlikely that this level of requests could have anything but a minimal impact on an individual's diet and it even more unlikely it could impact long-term health indicators. In addition, requests do not reflect actual consumption – children, even third graders, will usually heavily rely on parental purchasing decisions.

9. WHO Technical Report 916, Diet, Nutrition and the Prevention of Chronic Diseases: "Energy expenditure through physical activity is an important part of the energy balance equation that determines body weight. A decrease in energy expenditure through decreased physical activity is likely to be one of the major factors contributing to the global epidemic of overweight and obesity (…) The amount of physical activity has been greatly reduced both at home and in school, as well as by increasing use of mechanized transport." "Lack of physical activity is already a global health hazard and is a prevalent and rapidly increasing problem in both developed and developing countries." "A sizeable proportion of deaths in overweight and obese populations are probably a result of low levels of cardio-respiratory fitness rather than obesity per se."
‘Sport Participation in the European Union', presentation by Prof. Maarten van Bottenburg to EU Platform for Action on Diet, Physical Activity and Health, July 2005: "Four out of ten Europeans are sportingly inactive and indicate that they do not do any kind of exercise or sport whatsoever during an entire year."
European Commission Green Paper on Promoting Healthy Diets and Physical Activity, December 2005: "A 2003 Eurobarometer survey [European Commission (2003), Special Eurobarometer 183-6/Wave 58.2 - European Opinion Research Group] showed that around 60% of Europeans (EU 15) had no vigorous physical activity at all in a typical week, and more than 40% did not even have moderate physical activity in a typical week. Europe-wide, only about one third of schoolchildren appear to be meeting recognised physical activity guidelines [Health Behaviour in School-Aged Children Survey, 2001/2002]."

10. UK Health Select Committee Report on Obesity: "Summing up the energy equation, the Royal College of General Practitioners suggested that food intake had fallen on average by 750 kcal per day; but activity levels by 800 kcal. Out of this small imbalance has come the wave of obesity."
Jebb, S. and Prentice, A., "Obesity in Britain: gluttony or sloth?" BMJ 1995;311: 437-439, quoted in UK Health Select Committee Report on Obesity: "The paradox of increasing obesity in the face of decreasing food intake can only be explained if levels of energy expenditure have declined faster than energy intake, thus leading to an over-consumption of energy relative to a greatly reduced requirement (…) in sharp contrast with the suggestion that a secular drift towards high fat diets has induced people to overeat, there is evidence, based on the National Food Survey's annual measures of household food consumption, that the British are becoming fatter in spite of consuming less energy than in the 1970s. Even after adjustments for meals eaten outside the home, and for consumption of alcohol, soft drinks, and confectionery, average per capita energy intake seems to have declined by 20% since 1970."

11. National Audit Office, Tackling Obesity in England, 2001: "Extra physical activity involved in daily living 50 years ago, compared with today was the equivalent to running a marathon a week."

12. UK National Office of Statistics, The Health of Children and Young People, 2004: "The proportion of school children spending less than one hour per week on physical education (PE) rose from five per cent in 1994 to 18 per cent in 1999."

13. Kiel Obesity Prevention study, 2003; Koletzko et al 2004

14. White Paper on European Governance, Report of the Working Group on Better Regulation, May 2001.

15. The EU Unfair Commercial Practices Directive forbids under misleading practice 28:“a direct exhortation to children to buy advertised products or persuade their parents or other adults to buy advertised products for them.”

16. European Parliament Resolution on ‘promoting healthy diets and physical activity’ states that the fight against obesity should be considered a political priority of the EU. But there is a danger that ‘excessive zeal’ in fighting obesity can itself lead to other dietary disorders such as anorexia and bulimia.

17. Ofcom, Childhood Obesity – Food Advertising in Context, 2004; Hastings et al, Review of research on the effects of food promotion to children, 2003. The Ofcom and Hastings reports independently reviewed a wide range of literature available in English over the past twenty years, and can be considered the most comprehensive research ever done on this subject. The Ofcom report concludes that a ban would be “both ineffective and disproportionate in its wider impact.” These findings were confirmed most recently by German research (German Ministry of Consumer Protection, Food Advertising for Children’s Products – Strategy Proposals for Preventative Consumer Protection, April 2005), which also concluded that banning advertising to children would be inappropriate.

18. Despite bans on advertising to children in Sweden, Norway and Québec, childhood obesity rates in these countries/regions are not lower than in other, similar countries/regions where such advertising restrictions exist, and continue to rise inexorably.

19. Nielsen data.

20 Nielsen, 2004. In the US, children aged 2-11 saw 34% fewer ads on TV between 1977 and 2004– meanwhile, childhood obesity has quadrupled (CDC, 2005). In the UK, the estimated number of food and restaurant commercials viewed per child aged 4-15 declined by over 50% between 1994 and 2004 – meanwhile childhood obesity increased by over 40% (UK National Office of Statistics, 2004). In Germany and Italy, the volume of food and drink advertising spend has stagnated over the past decade, (Nielsen, 2004), while childhood obesity has risen dramatically.

21. Ofcom 2004 inter alia.

22. European Group of Television Associations (egta).

23. Arnaud Langlois of JPMorgan Equity Research illustrated at the 1st Annual European Obesity Conference in Brussels on 14-15 June 2005, how a ban on advertising will result in lower sales growth and diminished brand equity. A worse case scenario could result in the creation of barriers to entry and the development of oligopolistic situations.

25. EU Health Commissioner Kyprianou, CIAA Congress, October 2006, words echoed by Deborah Platt Majoras, Chairman of the Federal Trade Commission and J. Michael McGinnis, Senior Scholar, Institute of Medicine.

26. In Australia: www.jolively.com, in Canada: www.longlivekids.ca, in NZ: www.moh.govt.nz, in the US: www.smallstep.gov, etc.

28. www.mediasmart.org.uk

29. www.tes.co.uk

30. “Media Smart acknowledges the power of advertising and attempts to empower the consumer.  And it is an example of an industry taking responsibility for its own actions.  It is enlightened self-interest.”

31. “It’s no accident that Media Smart and Ofcom are roughly the same age.  WE are joined together in this task of bringing media literacy to audiences and we hugely value and support the practical work that Media Smart is doing….Investing in media literacy is particularly important as we think about how best to support audiences in the new media age and Media Smart is blazing a trail in helping our youngest audiences to feel confident in their understanding of media.” – Tim Suter, February 2006.

 

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