Memorandum by The Food Advertising Unit
(OB 88)
INTRODUCTION
1. The Food Advertising Unit (FAU), which
represents advertisers, agencies and broadcasters, is a centre
for information, communication and research in the area of food
advertising, particularly television advertising to children.
In addition to the commission and publication of research, the
FAU holds an annual conference and is an active participant in
the debate surrounding children and the role of commercial communications.
Further details about the FAU, which is based in the offices of
the UK Advertising Association, can be found at: http://www.fau.org.uk/
2. The FAU welcomes this opportunity to
submit written evidence to the House of Commons' Select Committee
on Health, and is also keen to offer oral evidence. The FAU recognises
that obesity, particularly amongst the young, is becoming a serious
public health issue. The FAU shares the concern of the UK Government
in respect of obesity and seeks to engage and participate in a
constructive response to the problem.
3. The FAU recognises and accepts that advertisers
should and do take responsibility for the influence that marketing
may have on dietary behaviour, and that those involved in food
marketing should and do take account of the public policy environment
in respect of public health.
4. The FAU has responded to this request
by the Select Committee for evidence because the role of advertising
in society is often misinterpreted. There is considerable debate
around the notion that there is a direct causal relationship between
advertising and obesity. However, the FAU does not believe that
such a relationship exists and also notes that independent scientific
research at both national and international level has failed to
establish it.
SUMMARY
5. The prevalence of obesity is increasing
whist calorific intake has been declining. This suggests that
energy expenditure is crucial to the increase in obesity levels.
Decreased physical activity levels are a result of changes in
society, for example, longer working hours, reduced physical exercise
in schools and lack of safety in public spaces. Studies have shown
that children's exercise levels are below recommended levels and
have been declining at a faster rate than calorific intake. Furthermore,
children's eating and exercise habits generally mirror their parents'
attitudes, underlining the need for parental interaction in combating
obesity. However, schools, government, the medical community and
the advertising industry can and should all play a role in creating
effective solutions. The FAU believes that there is scope and
opportunity for the food and advertising industries to work in
partnership with the Government and other stakeholders and that
international programmes to address public health issues have
been successful where such a partnership has been fostered.
What are the trends in obesity?
6. The increase in the incidence of obesity
both in the UK and overseas is well-documented and largely uncontested.
Although the rise in obesity has gained recent attention, a long-term
overall growth in weight has been manifest over several decades.
This growth in weight has been accompanied by only modest gains
in calorie consumption, and the post-war period has witnessed
substantial growth in weight and declining intake of calories.
This suggests very strongly that occupational and physical fitness
factors explain rising levels of obesity better than food consumption
or dietary change.
What are the causes of the rise in obesity in
recent decades?
7. The FAU considers that the principal
cause of the rise in obesity in recent decades has been a substantial
decline in levels of physical activity amongst the general population.
Research published recently by Darius Lakdawalla and Tomas Philipson,
"The Growth of Obesity and Technological Change: A Theoretical
and Empirical Examination" (2003), establishes that one third
of the growth in weight over recent decades is attributable to
". . . a fall in the supply price of food, potentially through
agricultural innovation, and two-thirds of it may be due to demand
factors such as a fall in physical activity in market and home
production."
8. A combination of factors has created
the environment in which this reduction of physical activity has
occurred. These comprise occupational factors favouring more sedentary
schedules of activity, the considerable impact of technological
change at home and at work, improved regional public transport
facilities, the increased use of private cars, improvements in
medicine, enhanced leisure options and the decline of manufacturing
activity.
What has been the role of changes in diet?
9. Diets have changed substantially in recent
years. Government studies demonstrate that calorie intake amongst
children is decreasing and intake levels of fat are in line with
government recommendations.
10. The National Diet & Nutrition Survey
(NDNS) conducted in 1999, looked at the 4 to 18 year old age group,
and found that mean energy intake was significantly lower (by
around 10%) than estimated average requirements (EARs) for all
the age and sex groups studied (and slightly lower than that found
by an equivalent study in 1983). For example, 4-6 year old boys
and girls received 89% and 91% of their EAR respectively, whilst
the equivalent figure for 7-10 year olds were 91% and 92% respectively.
(The calorific intake of the population at large has been in decline
for the last 30 years.)
How much is lack of physical activity contributing
to the problem?
11. The FAU considers that the substantial
decline in levels of physical activity lies at the heart of this
debate, particularly amongst children. There is a great deal of
statistical data to demonstrate the decline in physical activity.
There are a number of factors contributing to the increased levels
of sedentary lifestyle in the UK. Longer working hours, mechanisation
of the workplace, working parents, parental concerns about the
safety of outside play, and the sale for commercial development
of playground and outside space are just some of the factors that
have contributed to this.
12. The National Transport Survey conducted
in 1999 found that the proportion of children walking to school
(which was over 85% in 1948) had fallen from 52% in 1986 to 42%
in 1999. Over the same period, the proportion of children cycling
to school had fallen from 6% to just 2%.
13. The National Survey of Young People &
Sport conducted in 2002 and commissioned by Sport England found
that ". . . there has been a consistent increase in the percentage
of young people who do not take part in sport lessons on a `regular'
basis . . . from 15% in 1994 to 17% in 1999 and 18% in 2002".
The survey also found that the proportion of young people spending
two or more hours per week on Physical Education had fallen from
46% in 1994 to just 33% by 1999.
14. The NDNS referred to in point 10 found
that around a third of 7-14 year old boys, and over half of 7-14
year old girls, failed to meet the then Health Education Authority's
(now the Health Development Agency) recommendation of one hour
of at least moderate-intensity activity per day. Meanwhile, around
10,000 sports fields have been sold off in the last twenty years
and physical education assumes only a very small percentage of
time within the curricula of schools.
15. Other research indicates this trend.
For example, Ludwig et al suggested that physical activity levels
in the UK are 50% lower than the appropriate level. This study
suggested that a lifestyle characterised by lack of physical activity
and excessive inactivity would cause obesity in children.
16. Parental levels of physical activity
play an important role in determining children's view of and engagement
in exercise. Research demonstrates that parental inactivity is
a strong determinant of child inactivity. The same research demonstrated
that childhood obesity is correlated negatively with children's
physical activity.
17. The FAU believes it necessary to distinguish
clearly between the impact on obesity of sedentary activities
such as watching TV, and the effect that TV advertisements actually
have on individual diets, which is an entirely different issue.
WHAT CAN
BE DONE
ABOUT IT?
What is the range of "levers" and drivers
(food industry, marketing, education, family life, genetics, drugs,
surgery)?
18. The FAU believes that the most important
levers in implementing solutions to combat the rising levels of
obesity are parents, schools, the medical community, government
information and the food and advertising industries. Efforts must
be made to improve parental education on nutrition, possibly using
existing health structures. Indeed, the Health Service and doctors
have an important role to play in identifying, informing and recommending
case-specific advice on avoiding and overcoming overweight and
obesity. Also, the Government should consider prioritising nutrition
and cookery lessons in school as well as promoting and creating
greater opportunities for physical and outdoor activities. Finally,
the food and advertising industries can be a tool for government
to create, strengthen and raise awareness on healthy lifestyle
programmes and messages.
Within that range, what role can the food industry,
marketing and advertising, transport, schooling play?
19. The FAU believes that food advertisers
can contribute in the following areas: support for healthy lifestyle
campaigns including emphasis on the importance of eating a balanced
diet; continuous and informed review of food advertising codes
to ensure that they take account of current consumer attitudes
as well as trends; promotion of media literacy programmes such
as Media Smart and other programmes to encourage children to engage
with the media in a positive way.
20. The food and advertising industries
are already involved in promoting healthy lifestyle messages,
in particular the need for balanced diets and taking exercise,
for example through the use of sponsorship, on-pack information
and interactive websites.
What are the responsibilities of the food industry
in respect of marketing?
21. The FAU and its members in the food
sector have long been involved in various healthy lifestyle promotional
initiatives, consumer communications on nutrition, nutritional
education programmes and media literacy programmes, in addition
to our long-standing support for strong self-regulatory mechanisms.
22. The food industry in the United Kingdom
has a wide range of responsibilities in respect of advertising
and marketing. Indeed, the advertising controls in the UK are
amongst the most stringent in the European Union. These controls
currently consist of statutory and self-regulatory codes for broadcast
and non-broadcast advertising respectively. The codes include
an explicit recognition that advertisers should not take advantage
of the natural credulity of children, and prohibit any attempt
directly to encourage children to ask adults for a product.
23. The food industry recognises the need
for these controls, and has a good record in complying with them.
For example, in the broadcast sector, less than 1% of the complaints
received by the Independent Television Commission in 1999 related
to food advertising. In the non-broadcast advertising sector,
overseen by the Advertising Standards Authority, the figure in
1999 was 1.1%. The number of inquiries about advertising received
by food companies' own customer care lines is negligible.
24. Those responsible for food marketing
are inherently responsive and sensitive to consumer demand and
perceptions. This is precisely and repeatedly reflected in the
development and marketing of new products. Unless products are
introduced that meet consumers' needs, they will of course neither
be purchased nor consumed.
How influential is the media?
25. The media plays a major role in raising
public awareness about public health, and is considered to be
an influential source of information about the constituents of
a healthy lifestyle. However, the media's impact is not easily
or scientifically measured in respect of behavioural change. Media
coverage cannot necessarily deliver behavioural results.
26. When considering the influence of the
media, it is also important to concentrate on comparing like with
like. Research shows that people react differently in particular
circumstances or categories. Advertisements are not viewed in
the same light as editorial copy or programming; breakfast television
is viewed in a completely different way to a local weekly newspaper.
Much research used to criticise marketing to children uses children's
recognition of images as a politically significant statistic,
whereas the real significance lies in how children act upon this
recognition. For example, several generations of children, after
decades of recognising that "Popeye" becomes stronger
upon eating spinach, should perhaps be more tolerant of spinach
as a result. But spinach has historically been one of the vegetables
most firmly spurned by children and doubtless will continue to
be for many generations to come, despite its undoubtedly positive
associations in the popular children's cartoon. In short, the
media is indeed probably influential, but no-one is ever quite
sure exactly how, where or why it exerts its influence.
What is international best practice?
27. It is possible that international best
practice may not be helpful in resolving the particular problems
of the UK. We have no certain knowledge of whether public policy
or special initiatives in some countries could be applied successfully
in others. It is the case that some countries appear to have particular
social, dietary, cultural or environmental conditions that generate
unusual or unique public health results. For this reason, we are
unwilling in this area to be specific in our response.
28. However, it would appear that Finland
has benefited from a successful health promotion strategy, according
to a 1999 study by Puska entitled "The North Karelia Project:
from community intervention to national activity in lowering cholesterol
levels and Coronary Heart Disease risk". The North Karelia
Project appears to have engineered a decrease in deaths from coronary
heart disease (CHD) by 73% between 1969 and 1995 in the region
of the same name. The initiative focussed on community-based programmes
that were extended nationally in the late 1970s. The programmes
incorporated nation wide media campaigns aimed at educating the
public, public health authority involvement, industry collaboration
and agricultural reform. Deaths from coronary heart disease between
the programme's national implementation and 1995 had decreased
by 64%, although it is important to add that CHD levels have also
been declining fast in most European countries since 1970.
29. In addition, there are several projects
internationally seeking to increase physical activity levels and
decrease calorie consumption. Many appear to have been successful,
and could usefully be further investigated by the UK Government.
Such programmes include Colorado on the Move (USA), Eat Smart,
Play Hard. (USA); Know Your Body Programme (USA); PowerKids (Germany);
Trim and Fit (TAF) Programme (Singapore); Out of School Hours
Sports Programme (Australia). The FAU would be willing to submit
more information about these programmes should the committee so
wish.
ARE THE
INSTITUTIONAL STRUCTURES
IN PLACE
TO DELIVER
AN IMPROVEMENT?
How effective are the structures for health promotion?
30. In mid-2002 the FAU commissioned Charles
Gallichan, former Head of Advertising at the Health Education
Authority (HEA), to consider which kinds of public policy advertising
campaigns worked and which failed in order to ascertain how health
promotion campaigns might be rendered most effective. He delivered
his conclusions at the seventh annual FAU conference in November
2002. Amongst his key findings were that:
(a) The messengers have to be credible—Government
or even NHS sources will be rejected. A campaign must be seen
to come from a source that is not Whitehall-controlled. It must
be seen to be a health-based issue and not a Government campaign.
(b) Research methodologies should be robust—campaigns
need to be informed by both qualitative and quantitative research.
On-going tracking studies are needed to develop strategy and content,
whilst a basic understanding of the research base in relation
not just to what people are eating, but when, where and why is
an essential prerequisite.
(c) Targets need to be realistic—all
too often the targets set for campaigns are overly ambitious,
especially in relation to behaviour change over an unrealistically
short time period.
(d) Messages need to be kept simple and relevant.
(e) Messages must not be evangelical or political
in tone but should seek to educate through empathy. This may influence
the choice of media when disseminating messages.
(f) Financial support for campaigns must
be consistent, regular and assured.
(g) The quality of the partnerships and alliances
between the various stakeholders is key. Public debate can end
up being confusing, as different examples of dietary advice can
appear to be mutually inconsistent or exclusive.
(h) Public relations and advocacy should
be measured and consistent. Success lies not in clever announcements
or stunts, but rather in solid advocacy work, with the media fully
comprehending the issues.
(i) In order to keep people motivated, not
least the funders, it is important to ensure that everybody involved
is aware of how matters are progressing, facilitating any adjustment
of content that may be necessary. Endorsements by academic journals
often appear too long after the event to inform policy-makers
or those involved with setting budgets.
31. As part of his study, Gallichan also
looked specifically at various public policy advertising campaigns
in the areas of food/diet and the promotion of physical activity.
In essence he found that the level of funding and the length of
campaigns were too thinly spread across too many complicated messages.
The FAU would be happy to supply the membership of the Select
Committee with a copy of Gallichan's report.
Can health promotion compete with huge food sector
advertising budgets?
32. Health promotion does not compete with
commercial advertisements in this or any other sector, and it
is a fundamental error in the assumptions of many of those preoccupied
with this issue. As such the question as drafted is prejudicial,
pre-supposing a set of relationships and consequences that are
neither valid nor relevant. It assumes, for example, that the
aims of all food advertising detract from, or otherwise are contrary
to, the aims of all health promotion: as if eating and being healthy
were mutually exclusive activities. It certainly assumes that
there are certain types of foods that are inherently bad for one's
health and cannot even form a small part of a balanced diet.
33. It is true that the amount of (private)
money spent on commercial advertising may be greater than the
amount of (public) money spent on health promotion, but this bald
assertion is moderated by several relevant factors:
— Persuasive communications about health
issues more often come from programming and editorial than from
marketing, and more often from peer groups, friends and family
than from organised campaigns. Most people consider themselves
to be beyond the influence of a 30-second commercial and would
identify other factors influencing their purchases as being more
important.
— The effect of advertising compared
to all persuasive communications is minimal in respective of behaviour.
This comes back to the real reasons for commercial advertising,
that are rarely, if ever to seek, to change behaviour or diet.
Each food advertisement seeks to persuade people to buy the advertised
product and no other of the same category.
— Health promotion occupies a completely
different area of communications, and is concerned not with getting
people to buy branded products but to encourage people to change
their lifestyle, behaviour or diet. These are completely different
objectives and simply cannot be compared on the same basis.
— As referred to above, Charles Gallichan
has provided those involved with health promotion campaigns with
indicators as to how they might create cost-effective communications.
He also noted that the Central Office of Information, the heaviest
single advertiser in the UK in 2001, spent £142 million in
2001 (Source: Nielsen Media Research). This expenditure was spread
across no less than 72 different subject areas including on health
promotion.
— Gallichan noted that funding health
promotion campaigns is not cheap, but if they are to be effective
funding for them must be consistent and assured. It would be better
to spend £40 million on a campaign spread over four years,
than the whole amount in one year. With respect to the promotion
of physical activity amongst the young, this is of relevance to
the Department of Health, the Department for Culture, Media and
Sport and the Department for Education and Science; it would be
best if all three could collaborate, pool their funding for this
area and run a single campaign. This would meet a number of the
criteria Gallichan identified as being likely to maximise the
chances of success.
— Finally, given the reference in the
question to "huge food sector advertising budgets" it
may also be helpful here to place into context some of the long-term
trends in expenditure on food advertising. In absolute terms the
amount of press and television advertising spent on food products
has declined from £652 million in 1989 to £459 million
in 2001 when measured in constant 1995 prices (Source: AC Nielsen-MEAL
/ Nielsen Media Research). Even more dramatic, however, has been
the decline in total press and television advertising of food
products. In 1984 food advertising accounted for 15.6% of total
press and television advertising in the UK, by 2001 this had declined
to just 8.2% (Source: AC Nielsen-MEAL / Nielsen Media Research).
To what extent can the food industry be part of
a solution?
34. Industry is already part of a solution
because of the years of work many food companies have undertaken
in consumer communications on nutrition education and healthy
lifestyles. Media literacy programmes for children can also be
effective. In the UK, the advertising industry has created and
supports Media Smart, a media literacy programme for primary school
children, initially focused on advertising. Media Smart's objective
is to provide children with the tools to help them understand
and interpret advertising, so that they are able to make informed
choices. The programme has been endorsed by the UK Government.
To what extent is the Food Standards Agency influential?
35. The Food Standards Agency (FSA) will
continue to be influential in the debate on how to tackle the
rising levels of obesity in the UK. With influence also comes
a responsibility, where public bodies are concerned, to be independent
and open-minded. It is therefore essential that on such a complex
issue as obesity, the FSA takes an overall view establishing it
within a multi-factorial context rather than simply a food-based
one. In other words, if the biggest influence on obesity is found
to be lack of exercise, we would suggest that the FSA needs to
work alongside other public and private bodies focused on exercise
and lifestyle changes, and thus continue to be part of the solution
in addressing obesity.
What are the policy options?
36. The FAU considers that the policy options
most likely to meet with success are those aimed at educating
children and adults about the pursuit of healthier lifestyles,
through, for example, the promotion of physical activity. The
FAU has laid out some of its recommendations in this area below.
37. A 1994 study by Stratton entitled "Influences
on Children's Diets" looked at the influence of advertising
on diet in comparison to the influence of parents (particularly
mothers) and playground peer groups. He quantified the overall
influence of advertising on food choice at between 4.5% and 5%.
38. In 1996, the Department of Health and
the then Ministry of Agriculture, Fisheries & Food commissioned
a world-wide literature review of the studies that had previously
been undertaken in order to ascertain the influence television
commercials had upon the food choice of children aged between
eight and twelve. The study was carried out by Young, Webley,
Hetherington and Zeedyk and is entitled "The role of television
advertising in children's food choice". The study concluded
that advertising is but one influence amongst many factors in
children's relationship to food, with food choice arising from
a range of physiological, psychological and cultural factors.
The authors of the report came to the conclusion that ".
. . there is no evidence to suggest that advertising is the principal
influence on children's eating behaviour. Indeed the opposite
is likely to be true, in that advertising is just one influence
amongst many factors." Interestingly, the study also found
that by the age of three children are ". . . following adult
cultural rules for eating patterns. By the time the child is old
enough to be influenced by advertising, the extent of this influence
should be considered against these established regularities in
eating." Dr Brian Young of Exeter University, one of the
report's authors, said subsequently of the study: "After
a rigorous examination of the research literature we concluded
that there is no serious and methodologically sound evidence that
shows that food advertising leads to an increase in the consumption
by children of whole categories of foods. Certainly, advertising
of particular brands can be related to more frequent consumption
of that brand as indicated by sales figures although this is not
a universal effect and there are cases where heavy advertising
does not affect sales. Another conclusion was that the model of
advertising influence that is often assumed in much of the research
in this area is what is known as an "effect" model,
ie advertising has a direct effect on behaviour. This model does
not do justice to the complex nature of advertising's influence
to the extent that children view advertising selectively and use
it as a cultural resource for many social activities unrelated
to purchase behaviour—they laugh about it, parody it, and
talk about it with friends."
39. In two studies "Advertising and
the Demand for Food in the United Kingdom" (1991) and "The
influence of advertising on the pattern of food consumption in
the UK" (1998), Duffy concluded that there is no measurable
effect of brand advertising on the total consumption of the equivalent
food category. The absence of such advertising would surely simply
lead to an increase in the power of "own label" rather
than a switch to different types of food.
40. Latterly, Dr Young in "Food Advertising,
Food Choice and Obesity: a survey of existing research" (2002)
found no evidence to demonstrate ". . . a link between exposure
to advertising for certain types of foods, and an increase in
consumption of those foods amongst adults and children".
Recommendations for the Government or others
41. In the Select Committee's guide to submitting
written evidence to it a request is made to include any recommendations
for action by the Government or others which we would like the
Committee to consider for inclusion in its Report.
— The FAU recommends that the Chairman
of the Select Committee on Health investigate with the Chairman
of the Select Committee on Culture, Media & Sport the possibility
of holding a joint inquiry into sport, fitness, diet and health
by the Committees they chair. This would be with a view to engendering
a consensus from Government across all Departments on this topic.
An inclusive and national plan of action could then be developed
with all interested stakeholders.
— The FAU recommends that the Select
Committee on Health commissions research parallel to that currently
being undertaken by the Food Standards Agency to ensure that physical
health, social and environmental aspects are properly represented
in the public debate about the causes of children's dietary preferences.
30 April 2003
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