Memorandum by the Advertising Association
(AA)/Food Advertising Unit (FAU) (OB 88A)
MARKETING FOOD TO CHILDREN
The AA/FAU believe that the advertising business,
together with the food and drink industries, can make a positive
contribution in the interests of society as a whole. The AA/FAU
is supportive of efforts to address issues relating to diet, physical
activity and health and our members are committed to playing a
positive role in this area. The AA/FAU has created and supported
initiatives that aim to help parents and children understand and
use advertising more effectively—examples include the ParentPower
series of booklets and the MediaSmart programme for schools. Furthermore,
the FAU commissions independent research and hosts an annual conference
for open discussions on issues surrounding advertising, children
and healthy lifestyles. We also recognise that the increasing
incidence of lifestyle-related chronic diseases is cause for concern
globally and will need to be addressed through a variety of policy
instruments.
Advertisers have a responsibility for the influence
marketing may have on children, they take this responsibility
seriously and abide by existing self-regulatory and statutory
codes of advertising practice which are amongst the strictest
in the world. The regulations are kept up-to-date in a changing
environment through a process of public consultation and the advertising
industry supports these reviews.
THE REGULATION
OF ADVERTISING
TO CHILDREN
Advertising to children is strictly regulated
in the UK. It is made up of a mixture of statutory and self-regulatory
codes (the latter backed by the Office of Fair Trade). Appendix
1 clarifies how advertising to children is regulated.
The codes of practice governing advertising
pay special regard to the child audience and contain lengthy and
detailed provisions specifically to ensure that children are not
exposed to inappropriate commercial messages. Those rules are
broadly similar across all media, although broadcast rules contain
additional provisions about timing and scheduling of advertisements
and the portrayal of toys and games. In particular such advertisements
should not contain anything that might cause children physical,
mental or moral harm. .
Provisions include prohibitions on:
— misleading advertising which takes
advantage of children's inexperience and sense of loyalty, or
which raises unrealistic expectations about the product;
— direct appeals to children to purchase,
or to ask their parents to purchase, products;
— advertisements which imply that children
will be inferior if they do not purchase a particular product
or service;
— direct response advertising aimed
at children;
— material which could cause children
psychological harm; and
— encouraging children to eat or drink
at or near bedtime, to eat frequently throughout the day or to
replace main meals with confectionery or snack foods.
With regard to marketing to children, advertisers
hold an exemplary record. For example, in non-broadcast advertising
the Advertising Standards Authority (ASA) recently found that
the overall rate of compliance, including "questionable"
communications, was 97%. Excluding questionable communications
and duplicates, the compliance rate was 99% (source: ASA Compliance
Report on Advertising to Children, 2003). For television advertising,
the latest Independent Television Commission estimates indicate
that only about 0.5% of all complaints relate to food advertising
to children.
CHILDREN'S
UNDERSTANDING OF
ADVERTISING
Children may enjoy and remember advertisements,
but this does not necessarily mean that they have an impact on
their behaviour. Children's favourite advertisement has long been
Andrex (because of the puppy), but they are users, not buyers.
Research conducted by Dr Brian Young of Exeter
University, has shown that children do understand the difference
between advertising and editorial or programme content from about
the age of three. From around the age of five children also begin
to understand the commercial intent of advertising—ie that
it is trying to sell you something. By the age of seven or eight
most children are fully aware of the persuasive nature of advertising
and have an understanding of it. Full understanding increases
with age, but before they are acting independently as purchasers,
they comprehend that advertising is there to sell to them. This
was supported by the recently published study by the University
of Strathclyde's Centre for Social Marketing, which the Food Standards
Agency commissioned earlier this year.
MEDIA LITERACY
Children today are exposed to a wider range
of influences, cultures and media than any other generation. Child
audiences watching adult television are larger than those watching
children's television. They see all kinds of commercial messages
in the high street when accompanying their parents and they have
crazes developed in the playground and with their friends—in
recent years, the best selling toys at Christmas have included
yoyos, hula hoops, furbies and tele-tubbies, all unadvertised.
Understanding the role of advertising and marketing
is an essential part of growing up and becoming a citizen in a
free market democracy. Children have to develop the ability to
make critical comparisons and informed decisions. The UK advertising
industry actively promotes this awareness through the FAU's ParentPower
publications and by supporting media literacy initiatives such
as Media Smart.
ADVERTISING AND
CHILDREN'S
PROGRAMMING
The introduction of further significant restrictions
or bans on advertising to children are likely to affect the choice
and programming quality of children's television. It is unrealistic
to expect a commercial broadcaster to invest in programming to
attract an audience to which they are denied commercial access.
The consequence is likely to be cheap imported material for some
channels that have public service commitments and serious financial
problems, and perhaps even closure, for those specialist child-focussed
cable and satellite channels.
There is a direct correlation between advertising
revenue generated during children's programme hours and expenditure
on children's programming. This is borne out in Sweden, where
commercial broadcasters do not exceed the five hours a week minimum
of children's programming and also ensure they do not exceed the
minimum (51%) quota for European-originated programmes. Thus there
would be a substantial reduction in the choice and quality of
programmes and television channels available to children.
ADVERTISING IS
ONLY A
MINOR INFLUENCE
ON OVERALL
DIETARY CHOICE
Advertising of snack foods directed at children
is much greater than that of fruit and vegetables. Some groups
claim this relationship becomes reflected in children's diets
causing diet-related problems such as overweight and obesity.
Overweight is a product of the imbalance between
energy in and energy out. Whereas calorific intakes amongst children
have fallen in the last decade (National Diet and Nutrition Survey
1999), levels of physical activity among children have declined
even further. For example, since 1986, the number of walking trips
made by young people has fallen by 17% for those aged between
five and 10 years and by 29% for those aged 11 to 15 years (National
Travel Survey 1999).
Major influences on children's diets do not
include advertising, especially amongst younger children who do
not make their own purchasing or dietary decisions. Dr Peter Stratton
of the Psychology Business of Leeds University in his study "Influences
on Children's Diet" (1994) investigated the relative influences
of television advertising in comparison with others: "The
findings are quite clear. Television advertising is recognised
by families as having a marginal influence on family food choices
(at the brand level TV programming may have a wider impact, but
this is not covered by this research). Influence from family members
accounts for more than three quarters of what families describe
as the important factors in shaping their children's diet. Children
were slightly more inclined to consider television influence as
important than their parents, though its influence was marginal
for both (7% and 4% respectively)".
Advertising promotes brand awareness and loyalty.
It does not drive consumption. It is primarily a tool of competition
between brands and not a means to secure category growth or overall
increases in market size. This is a conclusion of the 1996 Ministry
of Agriculture, Fisheries & Food commissioned 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 review
by Young, Webley, Hetherington and Zeedyk entitled "The role
of television advertising in children's food choice" 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.
Dr Young, 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. 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."
In 2003, Dr Young carried out an update of the
1996 review. This was completed in August of this year and is
currently undergoing peer review. It found that in respect of
attitudes to food within the family, practical considerations
and priorities prevail over economic or cultural considerations.
The basic issues of food provision and food choice are paramount.
The influence of advertising is very low and not generally considered
by parents to be significant on children's attitudes. However,
when directly asked whether TV advertising to children should
be more strictly controlled, most parents agree. The contrast
between results from these different research approaches is well
recognised—the phraseology of questions can lead to particular
responses. It is not possible to show that watching food advertising
per se has a direct effect on food choice. Dr Young also found
that television offers a generous range of images about food and
can shape food choices—representation of healthy and unhealthy
eating habits and different kinds of foods are shown, from a variety
of sources.
This may appear to be in contradiction of the
recent literature review carried out by the Centre for Social
Marketing, however, they also state that their report "does
not amount to proof of an effect" and that "incontrovertible
proof simply isn't attainable". The AA/FAU is examining their
report closely and has commissioned an independent academic analysis,
both for indications for future possible changes in marketing
and advertising practice, and for the strength of the conclusions
arrived at.
The advertising business, together with the
wider food and drink industry, want to be part of the solution
in tackling childhood obesity. Our understanding is that this
is an extremely complex issue that will need concerted efforts
from a range of stakeholders in order to effect lasting changes
towards healthier diets and lifestyles.
30 October 2003
APPENDIX 1
THE REGULATORY FRAMEWORK FOR CHILDREN'S ADVERTISING
Special protection is provided by the Broadcasting
Act 1990, the Communications Act 2003, the ITC Advertising Standards
Code (2002), the Broadcast Advertising Clearance Centre Guidelines
(1999), the Radio Authority Sponsorship and Advertising Codes
(2000) and the British Code of Advertising, Sales Promotion and
Direct Marketing (2003).
The table below briefly outlines the regulatory
framework governing children's advertising in the UK. All codes
of advertising and marketing practice are reviewed regulatory
through a process of public consultation. This allows the regulations
to adapt quickly to a changing environment.
The food and advertising industries understand
the need for these codes and their level of compliance is exemplary.
The level of complaints to regulatory bodies for food ads to kids
remains low.
| Television | Radio
| Non-Broadcast |
| Code | Independent Television Commission Codes of Advertising Standards
| Radio Authority Advertising and Sponsorship Code
| CAP Code of Advertising, Sales Promotion and Direct Marketing
|
| | |
|
| Code Type | Statutory | Statutory
| Self-Regulatory Backed by OFT, Compulsory |
| | |
|
| Subject to pre-vetting? | Yes, Broadcast Advertising Clearance Centre
| Yes, Radio Advertising Clearance Centre |
No, but advertisers can consult CAP's copy advice team
|
| | |
|
| Adjudication body | Independent Television Commission
| Radio Authority | Advertising Standards Authority
|
| | |
|
| Regulatory processes and powers | Codes subject to regular review/public consultation
|
| Codes informed by research into societal attitudes
| |
| | |
|
| Ruling and upheld complaints publicised
|
| | |
|
| Adjudicatory bodies can apply sanctions
|
| | |
|
| Examples of general provisions for children
| Advertising must not take advantage of children's inexperience or their natural credulity and sense of loyalty
|
| | |
|
| Advertising must not contain material which could lead to physical, mental or moral harm to children
|
| | |
|
| Advertising must not directly advise or ask children to buy or to ask their parents or others to make enquiries or purchases
|
| | |
|
| Advertising must not imply that children will be inferior to others, disloyal or will have let someone down, if they or their family do not use a particular product or service
|
| | |
|
| Examples of specific provisions for | Advertising must not condone inappropriate health standards for children
|
| advertising | Advertising must not encourage children to eat frequently throughout the day
|
| food to children | |
| |
| Advertisements must not actively encourage children to eat or drink near bedtime
|
| | |
|
| Advertising must not encourage children to replace main meals with confectionery or snack foods
|
| | |
|
| web reference to codes (links): | http://www.itc.org.uk/
| http://www.radioauthority. org.uk/ | http://www.cap.org.uk/
|
| |
| |
| 
