Select Committee on Health Minutes of Evidence


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.
TelevisionRadio Non-Broadcast
CodeIndependent Television Commission Codes of Advertising Standards Radio Authority Advertising and Sponsorship Code CAP Code of Advertising, Sales Promotion and Direct Marketing
Code TypeStatutoryStatutory 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 bodyIndependent Television Commission Radio AuthorityAdvertising Standards Authority
Regulatory processes and powersCodes 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
advertisingAdvertising 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/




 
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