Memorandum by Leo Burnett Limited (OB
89)
MARKETING FOOD TO CHILDREN
INTRODUCTION
1. Leo Burnett founded his advertising agency
nearly 70 years ago in Chicago and built a reputation as a practitioner
of talent and charisma. The organisation expanded worldwide and
the British agency is today in the UK top five, ranked by client
income. In 2003, Leo Burnett Limited became part of the international
Publicis Groupe with a portfolio of many leading brands including
Tetley, Procter & Gamble, Heinz, McDonald's Restaurants and
Kellogg's. We play a significant role in the marketing of food
to people of all ages and consider ourselves well placed to comment
on the issue of marketing food to children. Leo Burnett is therefore
delighted to be asked to contribute to the Select Committee's
inquiry.
2. In this memorandum, Leo Burnett comments
on obesity (briefly by way of context), regulation and control
of advertising in the UK, the effect of advertising, and finally
what we consider to be the sensible way forward. We have kept
our comments brief, as requested, and would be pleased to provide
more detail or comment on other issues if requested.
3. We and each of our clients strive to
make advertising for food—as for every other product—"Legal,
Decent, Honest and Truthful".
OBESITY—CONTEXT
4. Leo Burnett is not qualified to give
helpful evidence to the Committee on the various causes of obesity.
However, in providing our comments on marketing food to children
and in particular on the question of the extent to which there
may be a link between the advertising of certain food products
and childhood obesity it is necessary to make one or two general
observations to place those comments in their proper context.
5. It is generally accepted that obesity
is a complex issue and that it is caused by a number of different,
interlinked and related factors. Diet is only one of these factors.
Others include, for example, the amount of physical activity undertaken
by the individual and his or her lifestyle, occupation and genetic
make-up.
ADVERTISING—CONTEXT
6. The UK has highly sophisticated consumer
protection laws which effectively prevent the abuse or exploitation
of consumers. These are broadly harmonised at the European level.
In addition, UK advertisers are subject to what are amongst the
world's most stringent Codes of Practice. These go far beyond
a requirement on advertisers to make their advertising legal,
decent, honest and truthful. Depending on the choice of media,
the Codes prevent for example:
— Any advertising that takes advantage
of children's inexperience and sense of loyalty, or that raises
unrealistic expectations.
— Any direct appeals to children to
purchase, or to ask their parents to purchase, products.
— Any advertisements which imply that
children will be inferior if they do not purchase a particular
product or service.
— Children in advertisements commenting
on products in which children of their age would not usually be
interested.
— Any direct response advertising aimed
at children.
— Any material which could cause children
psychological harm.
— 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.
7. Principles for the high standards adhered
to by the British advertising industry are set out in the Code
of Advertising Practice and the various other regulatory bodies
responsible for broadcast and non-broadcast advertising. We develop
each and every advertisement with due regard to these codes and
guidelines and in the knowledge that the International Chamber
of Commerce International Code on Advertising Practice requires
that advertising "should be prepared with a due sense of
social responsibility and should conform to the principles of
fair competition, as generally accepted in business"
8. Leo Burnett is a founder member of the
Food Advertising Unit (FAU) and shares its view that advertisers
should and do take responsibility for the advertising of their
food products, within the Codes of Practice.
9. The advertising industry can only act
responsibly if it listens to public concern and, where applicable,
modifies its practices accordingly. For example, Leo Burnett was
very prominent as a leader in the setting up of the Food Advertising
Unit that monitors issues surrounding food, and promotes good
practices.
10. The very strict system of self-regulation
has worked in this country. All parts of the industry are aware
that the strict maintenance of ethical standards is vital if the
public's trust in advertising is to be retained and strengthened.
Put simply, advertisements must not impair public confidence in
advertising.
EFFECT OF
ADVERTISING
11. The effect of many advertisements for
established products is not to cause a consumer to change from
one category to another but simply to swing buying from one brand
to another. This is particularly the case when it comes to food
advertising because consumption of food is so closely related
to other lifestyle elements. For example, a busy working mother
will be attracted to the convenience of certain products over
others regardless of the way in which they are advertised.
12. As we have mentioned above, advertising
of a product intended for consumption by children is heavily regulated.
Such advertising is designed to show the features of the product
in a way that children will understand. Children learn from an
early age that an ad is there both to inform them and influence
choice. In our experience, children can be very discriminating
and they do not simply submissively accept the messages. Some
heavily advertised products have not succeeded in the marketplace.
Popeye promoted spinach for years without ever making it a favourite
vegetable! On the other hand, some products that have not been
advertised have become best sellers, including the UK's two most
popular toys at Christmas 1998 (the Furbee and yo-yo's).
13. Moreover, it is very important to remember
that, in the case of pre-school and many other young children,
purchase decisions are made by a parent. Whilst children may prefer
certain products or brands, control of children's meals and of
their diets is exercised by, and we respectfully suggest is the
responsibility of, their parents. Parental eating habits are also
material influences on a child's eating habits (as indeed their
exercise levels will affect their children's exercise levels).
It is therefore vital that parents understand the true causes
of obesity and the benefits of a healthy, active lifestyle. Older
children should be encouraged to develop a similar understanding.
14. Leo Burnett does not believe that the
marketing of food to children is responsible for the increased
incidence of obesity in children in the UK. As we have said, it
is generally recognized that obesity is a complex problem, and
that solution will not be simple.
THE WAY
FORWARD
15. Leo Burnett will work with our clients
to continue to advertise in compliance with all applicable Codes
of Conduct. Together with our clients, we will continue to set
high standards through responsible conduct. We will continue to
take account of any public concern on relevant issues.
16. Leo Burnett believes that all of society,
young people—and some older ones, including parents—could
benefit from new and clear advertising messages to encourage them
to lead a healthy, active lifestyle. We believe that empowering
and motivating consumers to make positive lifestyle changes can
lead to a society that is more aware and responsible for their
own health. We know that the power of the advertising industry
has an important role to play in the communication of appropriate
messages and we believe that most advertisers would be pleased
to engage in sensible initiatives.
October 2003
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