Memorandum by The Food Commission (OB
27)
The Food Commission welcomes the Select Committee's
inquiry into obesity. The Food Commission believes obesity to
be a major issue for public health policy.
1. BACKGROUND
TO THE
FOOD COMMISSION
1.1 The Food Commission is a UK-based non-governmental,
not-for-profit consumer group concerned with food supply, food
consumption, diet and health. We are independent of commercial
interests and rely for our income on general public support and
donations, and sales of our reports, books and our quarterly journal
The Food Magazine.
1.2 The Food Commission is a member of the
national umbrella body Sustain: The Alliance for Better Food and
Farming. The Food Commission is the European co-ordinator of the
International Association of Consumer Food Organizations—an
international NGO recognised by Codex and the OECD and a contributor
to the current World Health Organization's stakeholder consultation
on diet and chronic disease.
1.3 The Food Commission co-ordinates The
Parents Jury, which consists of over 1,200 parents in the UK who
participate in judging healthy and unhealthy food products and
food marketing practices aimed at children. The awards scheme
highlights issues such as poor quality foods sold for children's
lunch boxes, the use of sport personalities to promote soft drinks,
the quality of restaurant menus aimed at children, the quality
of advice given by health workers to parents, and similar themes.
1.4 The Food Commission is currently undertaking
a survey of the nature of TV advertisements broadcast to children
in the UK, analysing over 50 hours of children's programming.
We have also surveyed the types of products on supermarket shelves
which are promoted to children through their labelling, using
cartoons, competitions, toys, licensed characters, TV tie-ins,
sports promotions etc. A further Food Commission report has looked
at the use of additives in food and whether additives encourage
the consumption of foods rich in fats or sugars.
1.5 In this submission to the Select Committee
we would like to offer evidence based on our reports and our current
work showing how children are exposed to an obesity-promoting
environment through the actions of commercial food producers.
2. EVIDENCE FROM
THE FOOD
COMMISSION
2.1 Television advertising. Preliminary
results from our current study of children's TV advertising confirm
and extend the results of earlier studies (1, 2), which have shown
that the majority of advertisements shown during children's TV
are for food and soft drink products, and that the great majority
of these advertised products contain high levels of fat and/or
sugar. The definitions for "high" fat and "high"
sugar are based on criteria developed by MAFF and recently endorsed
by the Food Standards Agency (FSA) (3). Children typically watch
television for more hours per year than they spend in a school
classroom (4), and will be exposed to several hours' worth of
food product advertising every week.
The techniques used in TV advertising include
the use of popular characters derived from other TV programmes,
the use of highly promoted children's fictional characters, the
use of celebrities and other devices. Justice Bell, the High Court
judge in the "McLibel" trial, noted in the trial findings
that fast food advertising encouraged "susceptible"
children to demand certain products "by pestering their parents"
and this led to higher consumption of these products (5). The
results of the current study should be available in July 2003.
2.2 Children's food products. The
Food Commission undertook a survey of 358 foods marketed to children
(6) and found that over three-quarters (77%) contained high levels
of fat, saturated fat, sugar and/or salt, according to the MAFF/FSA
criteria. The survey examined meal-time products and explicitly
excluded snacks such as soft drinks, crisps and "treats"
such as birthday cakes.
The techniques used to promote these foods included
bright and attractive colours on the packaging, cartoon characters,
gifts and toys, the use of TV programme characters and the use
of real and fictional celebrities. Further details of this survey
can be supplied.
2.3 The use of cosmetic additives. The
Food Commission undertook a survey of foods containing additives
(7) and noted that the most common use of colouring and flavour-boosting
agents was to promote the attractiveness of foods high in fats,
sugar and/or salt. Of foods containing colourings, 87% were high
in fats, sugars or salt, as were 74% of foods containing sweeteners,
and 64% of foods containing flavour enhancers. Colourings and
flavourings were rarely used in products low in fats, sugars and
salt. The survey questioned the adequate enforcement of the food
regulations which purport to allow additives only when a need
has been established. Further details of this survey can be supplied.
2.4 Parents Jury and Food Commission
concerns. Further concerns about the inappropriate marketing
of food products to children have been expressed by the Parents
Jury and the Food Commission (8). These relate to the promotion
of food to children and other commercial promotion techniques,
and include:
— catchy jingles and frequent repetition
used in advertising to children;
— the promotion of soft drinks and
snack foods through school classroom materials;
— the use of internet "viral marketing"
methods which directly encourages children's participation in
food product promotion;
— the promotion of foods high in fat,
sugar etc as being especially suitable for packed lunches;
— encouragement to purchase and consume
fatty, sugary foods in order to obtain tokens for school equipment;
— the display at supermarket checkouts
of high fat or high sugar products targeted at children, encouraging
the pestering of parents;
— the assumption by restaurants that
children's menus should consist largely of fatty, sugary, additive-laden
foods;
— inappropriate health claims being
made for foods on the basis of particular ingredients without
regard to the remaining ingredients, including high levels of
fat, sugar etc;
— misleading product descriptions,
such as "juice drink" for products with very low fruit
content; and
— the use by soft drinks, snacks and
confectionery companies of schemes offering products such as sports
equipment in return for tokens collected from their products.
Further elaboration of these points can be supplied.
3. RECOMMENDATIONS
3.1 It is the Food Commission's observation
that the regulation of food marketing techniques, especially those
aimed at children, is not underpinned by principles of good nutrition
and clarity of information. In general, food composition, food
labelling and food marketing do little to encourage healthy choices,
and do much to undermine such choices. Indeed, it sometimes appears
that we live in an environment designed specifically to encourage
poor diets and obesity, especially among children.
3.2 The "obesogenic" environment
needs to be tackled at the highest levels. It is not adequate
to focus on the individual, especially the child, and expect them
to exercise self-control against a stream of socially-endorsed
stimuli designed to encourage the consumption of excess food calories.
3.3 Although physical activity needs to
be considered—and for children this involves school curricula,
school facilities, safe play areas, safe streets, traffic reduction
etc—reliance on increasing physical activity levels will
not solve the problem. It takes only a minute to consume a snack
bar or soft drink containing over 100 kcalories, but takes over
half and hour of running or swimming to burn those calories off
again. We are concerned that the food industry's response to the
obesity issue has been to emphasise physical activity and not
to look at their own role in encouraging over-consumption.
3.4 An integrated strategy to reduce the
prevalence of obesity involves:
— a national nutrition strategy, accepted
and understood by government departments including those departments
responsible for schools, for sports, and for retailing and marketing;
— controls on the promotion of foods
high in fats, sugars etc, including controls on TV advertising
to children. The definition of inappropriate foods can be based
on the MAFF/FSA criteria;
— a review of food regulations with
regard to the use of additives which encourage the consumption
of foods high in fats, sugars etc;
— the designation of schools as advertising-free
zones;
— the promotion of positive school
nutrition strategies as part of OFSTED's pastoral care requirements
for schools;
— improved nutritional labelling to
ensure that foods high in fats, sugars etc are easily seen as
such;
— development of counter-promotional
activities such as the promotion of healthier diets to children
through programmes such as the Food Dudes and other methods which
use the techniques of commercial advertising to promote healthier
foods;
— development of critical skills among
children so that they can evaluate the commercial techniques to
which they are subjected; and
— a range of measures which can encourage
breastfeeding of babies up to at least six months of age. We will
be happy to expand on these recommendations if the Select Committee
so requests.
REFERENCES:
1. TV Dinners: What's being served up by the
advertisers? Sustain: The alliance for better food and farming,
2001.
2. A Spoonful of Sugar, Consumers International,
1996.
3. See leaflets entitled "Salt",
"Sugars" and "Fats", Food Standards
Agency, 2002.
4. TV takes over from teacher for UK kids,
Welsh Consumer Council, 2002.
5. McDonald's vs Steel and Morris—Verdict,
Justice Bell, 19 June 1997.
6. Children's Food Examined, Food Commission,
2000.
7. Additives make our diets worse Food
Commission, 2001.
8. Food Marketing: The role of advertising
in children's health Consumer Policy Review, 2003.
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