Sustainable Food: Government Response to the Committee's Eleventh Report of Session 2010-12 - Environmental Audit Committee Contents

Appendix 2—Letter to the Chair of the Committee from the Advertising Standards Authority

I'm writing to you on behalf of the Advertising Standards Authority (ASA) regarding the Environmental Audit Committee's report, published in May, on Sustainable Food.

The report recommends that: The Government should consider stricter advertising limits, to extend the protection for children from junk food marketing on children's television to all media viewed by children, including the internet. (Paragraph 56)

The ASA is the UK's independent regulator for ensuring that advertising in all media is legal, decent, honest and truthful, for the benefit of consumers, business and society. This year the ASA is 50 years old.

The purpose of this letter is to provide you with a brief overview of the ASA's role regulating food advertising—particularly in new media and online—and to address the specific point raised in evidence to the Committee about the difference between the broadcast and non-broadcast food advertising rules.

I would start by emphasising that the ASA system recognises the social imperative that food and soft drink advertising must be responsible. To that end, we enforce strict, evidence-based rules governing the content, placement and scheduling of ads and that are applicable across all media, both broadcast and non-broadcast.

Your Report highlights a potential weakness in the advertising rules with respect to the difference between the regulation of food advertising on TV compared to other media. I'd like to address this point by briefly explaining the background to the current rules in place.

In 2007, Ofcom (in concert with BCAP, the industry rule writing body) took a significant step in prohibiting advertising of certain food products from appearing around television programming of particular appeal to children. This was done for very specific reasons connected with the characteristics of television as a medium and the evidence specific to it that demonstrated that TV advertising has a modest direct effect on children's dietary preferences when compared to other factors such as parental influence, schools policy, public understanding of nutrition, the impact of food labelling and trends in exercise. TV advertising, consequently, requires special regulatory arrangements to protect children from potential harm. When radio and non-broadcast media was considered, the evidence simply did not show the same effect. Nonetheless, it is important to note that the non-broadcast Code, applicable to online advertising, was also strengthened in 2007 and includes strict rules that govern the content of food marketing. Principally, marketing communications must not:

  • Condone or encourage poor nutritional habits or an unhealthy lifestyle in children;
  • Disparage good dietary practice;
  • Encourage excessive consumption.

Building on these rules, the Code writing bodies introduced further, more targeted rules to protect pre-school and primary school children, for example with regard to the use of celebrities, licensed characters and pester power.

These protections are evidence-based, proportionate and administered independently by the ASA.

As your Report notes, we took a major step forward in March 2011 when our online remit was extended so that we now cover marketing on companies' own websites and in social media under their control. This means that food brand pages are now covered by the non-broadcast advertising rules, as is a brand's presence in social media. We will, also, shortly be undertaking research looking specifically into young people's experience of advertising in social media to identify whether further regulatory action is necessary, such as the whether we are applying the rules correctly. We know that food advertising will continue to come under scrutiny to ensure the rules are providing adequate protection. Changes in technology mean ads are reaching people on new platforms and in different ways, and we are responding to this challenge on a constant basis. We take concerns over the strength or application of the advertising rules, particularly as they relate to children and young people, seriously and try, at all times, to be as transparent as possible in explaining the work we do and rationale behind the rules in place today.

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Prepared 12 September 2012