Memorandum submitted by the Advertising
Association and Food Advertising Unit
1. THE ADVERTISING
ASSOCIATION AND
FOOD ADVERTISING
UNIT
1.1 The Advertising Association (AA) is
a federation of 25 trade bodies representing the advertising and
promotional marketing industries including advertisers, agencies,
media and support services. It is the only body that speaks for
all sides of an industry that was worth over £17.2 billion
in 2003. Further information about the AA, its membership and
remit is available on our website at www.adassoc.org.uk
1.2 In 1995, the AA set up the Food Advertising
Unit (FAU) as a centre for information, communication and research
on food advertising, particularly television advertising to children.
Further information about the FAU, recent research, positions
and briefs is available on our website at www.fau.org.uk
2. SCOPE OF
THE SUBMISSION
2.1 The FAU welcomes the opportunity to
submit evidence to this inquiry. There has been a growing interest
in food and the provision of information about it in recent months.
Advertising and commercial communications form part of this "information
environment".
2.2 The FAU's remit is restricted to the
role of advertising and this will form the focal point of this
submission. Other areas covered in the Committee's Terms of Reference
for the Inquiry will not be discussed.
3. THE ROLE
OF COMMERCIAL
COMMUNICATIONS
3.1 Brand advertising is above all a competitive
tool. Advertising and commercial communications are of vital importance
for brands to differentiate themselves in their product offering,
whilst continuing to meet the demands of the consumer.
3.2 The ability to advertise in a suitably
regulated environment provides an incentive for business to provide
information to consumers about their product. It also provides
the means by which companies can communicate new product development
and improvements to differentiate further their products and to
meet consumer demand. Without the ability to communicate with
consumers, this incentive would be lost. For example, in markets
where advertising was once prohibited (such as for sanitary products),
new product development was stagnant and only flourished once
advertising regulations were liberalised. [61]
3.3 The advertising industry currently spends
around £513 million advertising food and soft drinks. [62]Contrary
to public opinion, the total amount of money spent on advertising
food has consistently fallen over the last 15 years, from around
15% of all advertising in 1986 to around 9% in 2002.
4. THE ROLE
OF THE
MEDIA IN
COMMUNICATING WITH
THE PUBLIC
4.1 Advertising also funds independent media,
thereby subsidising the cost of information more generally to
the public. For example, advertising provides 65% of the revenue
to daily broadsheet newspapers and some 36% to consumer magazines
with the cover price providing the remainder. [63]Free-to-air
commercial broadcasters could not exist without the revenues generated
from advertising. Furthermore, the media in general, through a
number of specialist programmes and publications, provide an important
reservoir of information about food to a wide range of consumers.
4.2 The media is a trusted source of information
and its coverage is widespread. For example in a recent survey
of parental attitudes to food commissioned by the FAU and carried
out by the parenting website Raisingkids.co.uk, [64]43%
of the 1,500 parents questioned said that their main sources of
information about children's diets and nutrition were books and
magazines.
5. THE ROLE
OF PUBLIC
EDUCATION CAMPAIGNS
5.1 Governments across the world have used
the creativity and expertise of the advertising industry to communicate
effectively with consumers. Successful examples in the UK include
public information campaigns on drink-driving, anti-smoking and
sexual health. [65]
5.2 In the USA, Canada and Australia, government
health education campaigns have been extended to promote healthy
living/eating messages more generally. This has not been the case
to date in the UK, but in the context of growing obesity levels,
this option is now being explored. Derek Wanless's report Securing
Good Health for the Whole Population, commissioned by HM Treasury,
[66],
calls for the Health Education Authority to be re-established
in order to facilitate such activity. The advertising industry
would support such a move.
6. REGULATIONS
GOVERNING FOOD
ADVERTISING
6.1 European regulations covering advertising
include the Misleading Advertising Directive, E-commerce Directive,
Distance Selling Directive, Food Labelling Directive and Television
Without Frontiers Directive. These Directives provide a certain
level of harmonisation across borders and protection against misleading
communications in general for the benefit of consumers across
the European Union (EU). If adopted, the proposal for a Regulation
on Nutrition and Health Claims, originally proposed in 2003, will
impact on the way that food is marketed and promoted across the
EU.
6.2 The UK codes on advertising, which include
many provisions relating to food, are amongst the strictest in
Europe. The Confédération de Industries Agro-Alimentaires
de l'Union Européenne (CIAA), the body which represents
the European Food Industry, has recently finalised voluntary guidelines
on food advertising and marketing. The "Principles of food
and beverage product advertising" are intended as recommendations
for drafting and updating individual company guidelines as well
as the codes of national self-regulatory organisations. Although
they are significantly more restrictive than current practices
in some countries, these guidelines do not add a significant level
of protection to consumers here than is already provided by the
UK codes.
6.3 The food advertising industry recognises
the need for responsible commercial communications. Levels of
adherence to the codes are exemplary and complaints to regulators,
whether statutory or self-regulatory, are low.
6.4 Table 1 below summarises the regulatory
framework within which advertising operates here in the UK.
Table 1
REGULATORY FRAMEWORK FOR ADVERTISING IN THE
UK
| Television | Radio
| Non-Broadcast |
| Code | Independent Television Commission (ITC)
Advertising Standards Code
| Radio Authority (RA) Advertising and Sponsorship Code
| Committee of Advertising Practice's (CAP) The British Code of Advertising, Sales Promotion and Direct Marketing
|
| Code Type | Statutory | Statutory
| Self-Regulatory Backed by Office of Fair Trading, Compulsory
|
Subject to
Pre-vetting? | Yes, by the Broadcast Advertising Clearance Centre (BACC) which has its own detailed guidelines
| Yes, by the Radio Advertising Clearance Centre
| Cinema: Yes, by an independent copy panel, prior to exhibition.
All other non-broadcast media: No, but advertisers are strongly encouraged to consult CAP's free and confidential Copy Advice Service
|
| Adjudication body | Office of Communications (Ofcom)
(Took over regulatory responsibilities of ITC and RA on 29 December 2003)
| Advertising Standards Authority |
| Regulatory processes and powers | Codes subject to regular review/public consultation
Codes informed by research into societal attitudes
Rulings and upheld complaints publicised
Adjudicatory bodies can apply sanctions
| |
| Web reference to codes (links): | http://www.ofcom.org.uk/
| http://www.cap.org.uk/
http://www.asa.org.uk/
|
| | |
|
6.5 Further to an instruction from the Secretary of State
for Culture, Media and Sport announced on 2 December 2003, Ofcom
is currently carrying out a review of the existing ITC code as
it relates to children in particular. The advertising industry
is co-operating with this review.
7. FUTURE INITIATIVES—HOW
THE ADVERTISING
INDUSTRY CAN
PLAY A
ROLE IN
FOOD INFORMATION
7.1 The advertising business wishes to continue communicating
responsibly with consumers and in the context of rising obesity
levels, wants to play its role in contributing to the solution.
In supporting and abiding by strict codes and seeking to improve
the quality of commercial communications to consumers throughout
Europe and beyond, it has already made much progress in this area.
Other future initiatives, for example campaigns to help inform
and educate consumers who may not otherwise have the information
they need, could be explored by the UK Government in partnership
with industry.
April 2004
61
Boyfield Keith, The Effects of Advertising on Innovation,
Quality and Consumer Choice. The Advertising Association Economics
Committee. Back
62
Nielsen Media Research Digest, 4th Quarter 2003. This figures
includes: food, soft drink and fast food retail but excludes supermarket
and other retail advertising for food. Back
63
Advertising Statistics Yearbook 2003. The Advertising Association. Back
64
Family Food Survey, carried out by Raisingkids.co.uk for
the Food Advertising Unit, August 2003. Back
65
Gallichan, Charles. Public Policy Advertising Campaigns: What
Works and what doesn't. The Food Advertising Unit. 2003. Back
66
Wanless, Derek. Securing Good Health for the Whole Population.
February 2004. Back
| 
