Select Committee on Health Minutes of Evidence

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.


  1.1  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.


  2.1  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.


  3.1  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.


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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