Advertising to children
The European arm of the World Health Organisation has just announced that marketing food to children is one of its top regulatory priorities. Here in Britain, the House of Commons Environmental Audit Committee recently recommended stricter advertising limits across all media to protect children from junk food marketing. Even the government’s public health Responsibility Deal is shortly scheduled to focus on the issue. It is increasingly recognised that both the exposure of children to junk food marketing, and the power of that marketing, need to be reduced if rising obesity levels are to be successfully tackled.
Yet go online or watch the ad breaks on TV, and it’s hard to see that recognition reflected in the behaviour of companies with sugary, chocolatey snacks to sell. The 21st Century Gingerbread House: How companies are marketing junk food to children online, is a report published jointly with the British Heart Foundation. In it we exposed how manufacturers bombard kids online to push their products. The report also highlighted the unabashed use of brand characters, animations, games, competitions, promotions, videos and social networking sites which clearly appeal to children. Under current advertising regulations, these types of online marketing tactics are deemed perfectly acceptable; even for products classified as ‘unhealthy’ by Ofcom and therefore not promoted during children’s television programmes.
Unlike the television regulations, the non-broadcast code does not distinguish between healthy and unhealthy food. Instead the Advertising Standards Authority (ASA) exists to ensure that advertising is ‘legal, decent, honest and truthful’, rather than to protect and promote health. Consequently, when it does touch on health issues, the wording of the code is vague. For example, it states that “marketing communications should not condone or encourage poor nutritional habits or an unhealthy lifestyle in children”. But what constitutes “condoning and encouraging” or “poor habits” is left open to interpretation. We have found, when submitting complaints, that the ASA’s interpretation tends to protect advertisers rather than children.
Given that a third of children are now overweight or obese by the time they finish primary school, with levels continuing to rise, one might think that both the regulator and companies might choose to take a more responsible approach to marketing directly at children or their parents. Yet our report and follow-up study reveals otherwise. A Pac-Man style game encouraging kids to ‘eat’ lots of sweets and avoid the ‘parents’ who will curtail their sweetie-munching fun belonged in the 1980s with the original arcade version, rather than on a contemporary website. The same goes for the promotion of a sugary chocolate drink as “wholesome milky goodness for kids every day” or an advert for a sugar-packed snack bar that exhorted parents to “put something good in their lunchbox today”. On these three most blatant examples at least, the ASA agreed with us; although in the latter two cases only because the wording broke the EU regulation on approved nutritional claims.
However, there are many other gaps and inconsistencies in the code which confectionery, ice cream and snack companies are very adept at exploiting, and know they are highly unlikely to be brought to book on. One of the most prevalent is offering unrestricted access on their websites to their TV adverts. This is particularly irresponsible because those adverts would not be allowed to be shown on children’s TV but the websites are targeted partly or mainly at children. It may be allowed under the letter of the current rules, but it is not within the spirit of the code.
The fact that in 4-out-of-every-5 non-broadcast cases the ASA decides not to conduct a full investigation indicates that the regulator takes a fairly laissez-faire approach. But that statistic also suggests that the public have a much greater appetite for seeing companies held to account, and for the scope of the code to be extended. The current regulatory regime has not kept pace with the explosion in internet usage by children, or the changes in how and where they view content. Neither are the Ofcom rules on advertising unhealthy food and drink to children working as well as they should be. Many of the shows most popular with children, such as X-Factor, fall into that family entertainment category that is not covered by the code. It would be both more consistent and more effective to have a 9pm watershed for such adverts.
Confectionery companies should be doing more to help parents and children make informed choices about what they purchase and consume. That includes clearer and consistent front of pack labelling, allowing them to judge how healthy or unhealthy food products are at a glance. Following recent announcements by Tesco, Morrisons, Aldi and Lidl on adopting a hybrid nutritional labelling system which includes a front of pack “traffic light” colour coding system, many manufacturers are now out-of step on this important issue. Another trick of the trade used to give a misleading impression of nutritional content, and which needs to be tackled, is unrealistic or inconsistent portion size. As our report Checkouts Checked Out found, manufacturers discouraging retailers from putting their sweets and chocolates by checkouts or queuing areas, or at child-height, and ending promotional activity at the till, would also be a popular measure.
But in the end, national and international experience shows that a legal, level playing field to regulate all non-broadcast promotion of unhealthy food is the only effective way to protect children. Without this, the efforts of parents, schools and health professionals will continue to be overwhelmed by the obesogenic food environment, of which confectionery and junk food marketing is such a powerful part.
By Malcolm Clark of Children’s Food Campaign
