Advertising food to children
22 May 2006
It has been a long time coming but the OFCOM consultation on the advertising of food and drink products to children finally got under way towards the end of March; it finishes on 30 June. CAP and BCAP urge all those with interests in food or soft drink advertising to children to read the consultation and respond to it before the closing date.
Since the Government’s Choosing Health White Paper and Physical Activity and Food and Health Action Plans, industry has been working with the Government to contribute to the solution to the nation’s health and obesity problems. Many food and drink companies and their representatives, notably the Food and Drink Federation (FDF), have, sometimes in partnership with public bodies, have started initiatives to help influence the calorie intake or calorie expenditure of the nation. The FDF has proposed an action plan for industry to work with Government. The Obesity Bulletin, which is available from the “Obesity” section of the Department of Health’s website, www.dh.gov.uk, outlines the action, from the Government’s perspective, that is being taken to deliver the Government’s Obesity Public Service Agreement (PSA).
The Department of Health recognises that “Obesity is rising across the globe and no developed country has yet succeeded in reversing the trend. It is clear that obesity is a complex phenomenon that requires a sophisticated response combining prevention and treatment.”
Here is not the right place to go into detail about the individual projects food or drink companies have undertaken in their various new product introductions, reformulations of existing products, promotions, packaging changes, community relations initiatives and other actions. Suffice to say that much change has taken place and more is to come. It is in that context of continuing change and all the other elements of the health and obesity programme that everyone hopes will deliver the PSA objectives that the OFCOM consultation should be seen.
OFCOM has invited BCAP to propose a draft set of clauses to be inserted in the BCAP TV Code, which applies to the content of TV ads, and has included that content proposal in its consultation. The proposed restrictions apply to all food and drink products. The consultation offers three “policy options”; all three contain the BCAP content proposal. Option 1 combines it with timing restrictions on ads for specific food and drink products; option 2 combines it with timing restrictions on ads for all food and drink products and option 3 combines it with volume-based restrictions on ads for all food and drink products. Only option 1 uses the FSA’s controversial nutrient profiling method of identifying HFSS foods.
OFCOM has evaluated the likely impact of the three options; it varies both in total and by industry sector. Interested parties are invited to submit a proposal for a fourth option, which needs to: command the support of broadcasters, advertisers, retailers and manufacturers; play a part in meeting the Government’s objectives and meet OFCOM’s regulatory objectives. The clock is ticking for the delivery of a satisfactory option 4.
OFCOM recognises that, alone, the BCAP content proposal is inadequate to achieve its regulatory objectives but in concert with other restrictions should do so. And, together with all the other changes that go towards the PSA targets, it should help deliver the Government’s Health of the Nation objectives.
BCAP believes its proposal is proportionate and realistic. Together with other ad restrictions, it provides a means of changing the balance of ad content intended for pre-school and primary school children, the age ranges that are most important. Industry has already gone some way to change but still has more to do and the BCAP proposal should ensure that that will happen.
The existence of the global phenomenon referred to earlier suggests that, unless UK food ads are replicated globally, the content of ads in the UK is hardly likely to be a significant cause of obesity in British children and, indeed, all the evidence suggests that it is not. But every little helps and BCAP and industry are eager to play their part in achieving the health of the nation.
CAP has undertaken to transpose the restrictions that emerge from the OFCOM consultation to the CAP Code provided BCAP’s content proposal is not significantly altered. We should know the result of the consultation some time towards the end of the summer or early autumn.
Click here to go to the consultation document, which is on the OFCOM website. The BCAP content proposal is Annex 8, pages 178 to 183.
In brief, the proposal is that, for all food and drink products:
ads must avoid anything likely to encourage poor nutritional habits or an unhealthy lifestyle in children;
ads must neither ask children to buy or ask others to buy the products nor seem to encourage children to pester others to buy for them;
promotional offers must not be targeted at children under 10;
ads must not encourage children to eat or drink the product only to obtain a promotional offer;
celebrities or licensed characters must not be used in ads targeted directly at children under 10;
nutrition claims and health claims must not give a misleading impression of the nutritional or health benefits of the product as a whole;
no nutritional or health claim may be targeted directly at pre-school children and
ads must neither encourage nor condone excessive consumption.