Memorandum by The Food Commission (OB
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 Organisationsan
international NGO recognised by Codex and the OECD and a contributor
to the current World Health Organisation'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
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,
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 targeting at children, encouraging
the pestering of parents;
the assumption by restaurants that children's
menus should consist largely of fatty, sugary, additive-laden
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
misleading product descriptions, such
as "juice drink" for products with very low fruit content;
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 consideredand for children this involves school curricula,
school facilities, safe play areas, safe streets, traffic reduction
etcreliance on increasing physical activity levels will
not solve the problem. It takes only a minute to consume a snack
bar or a soft drink containing over 100 kcalories, but takes over
half an 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
the promotion of positive school nutrition
strategies as part of OFSTED's pastoral care requirements for
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
3. See leaflets entitled "Salt",
"Sugars" and "Fats", Food Standards Agency,
4. TV takes over from teacher for UK
kids, Welsh Consumer Council, 2002.
5. McDonald's vs Steel and MorrisVerdict,
Justice Bell, 19 June 1997.
6. Children's Food Examined, Food
7. Additives make our diets worse
Food Commission, 2001.
8. Food Marketing: The role of advertising
in children's health, Consumer Policy Review, 2003.