60.The prevalence of stereotypes in media and advertising based on appearance including race, age, weight, visible difference and sexual identity can perpetuate significant health and social inequalities. Studies have shown that viewing media promoting cosmetic surgery results in increased body dissatisfaction, and that exclusively promoting thin, white, or gendered appearance ideals is detrimental to positive body image. Research also shows that diverse appearances and body positive content in the media can have a beneficial impact on consumers and was beneficial for company profits and corporate reputation. The Centre for Appearance Research states that adverts and campaigns can have a negative impact if they promote unrealistic appearance ideals, contribute to diet culture which harms how people think and feel about their body, and if they perpetuate racism, weight stigma, the objectification of women, or other forms of oppression on a marginalized group.
61.The overwhelming number of images in the media and advertising can itself be problematic, particularly if a majority of images depict specific appearance ideals and that don’t represent the consumers of media and advertising.
62.The Committee has seen a broad collection of written evidence criticising media and advertising for the lack of diversity of images in terms of age, gender and sexual orientation, body size, ethnicity and ability as well as from participants in our body image survey. Certain adverts are more likely to cause harm around body image than others; for example, TV shows focused on losing weight or adverts for cosmetic surgery. These can be triggering for people who are vulnerable to or already suffer with eating disorders, body dysmorphia or depression. Changing Faces states that 1 in 5 people live with a ‘visible difference’ but there is lack a of visible conditions in the media. The overwhelming number of images in the media and advertising can itself be problematic, particularly if the majority of images depict specific appearance ideals and is not representative of the consumers of media and advertising.
63.The Advertising Standards Authority (ASA) is the UK’s independent advertising regulator and ensures advertisements adhere to the advertising rules (the Advertising Codes). The Committee of Advertising Practice (CAP) is the sister organisation of the ASA and is responsible for writing the Advertising Codes. Ofcom also share responsibility for broadcast advertising.
64.The ASA informed us that it takes the issue of body image very seriously and that it sets and enforces standards to ensure that advertisements are not likely to cause physical, mental or moral harm to audiences, within their wider role of ensuring adverts are socially responsible. Advertisers should ensure that they don’t portray particular body types in an irresponsible manner, for example by depicting in an aspirational manner a model who appears to be unhealthily thin. Advertisers should also not exploit insecurities, create pressure to conform or present an unhealthy body image as aspirational. The ASA indicated that whilst it supports diversity in advertising, its rules do not mandate diversity in advertisements and that responsibility sits with companies advertising their goods and services.
65.The UK Advertising Codes contain an overarching principle that ads should be prepared with a sense of responsibility to consumers and to society. The ‘social responsibility’ clause sits alongside theme-based and product specific rules and enables the ASA to act where an advert breaks the spirit in which the rules are intended, for instance by being inappropriate or harmful.
66.The ASA told the Committee that it provides advice and resources for advertisers including on Social Responsibility: Body Image. It makes reference to the introduction of a new rule for adverts that came into force in 2019 after a review of gender stereotyping. This rule states that adverts ‘must not include gender stereotypes that are likely to cause harm, or serious or widespread offence’ and that all marketing communications should be prepared with a sense of responsibility to consumers and society. It also states that advertisers should ensure they don’t portray particular body types in an irresponsible manner, imply people can only be happy if they look a certain way, or present an unhealthy body image as aspirational. In November 2020, the ASA released guidance for companies advertising cosmetic services, from non-surgical interventions to major surgery, which state that issues relating to body image must be handled sensitively. Advertisers should ensure that their adverts do not imply that one body type or specific trait is preferable over another, as this may exploit those with body insecurities. In August 2020, the ASA also released guidance for advertisers on the Habits of impeccably groomed male beauty ads which referenced being mindful of body image.
67.The ASA also has enforcement responsibilities and the power to remove adverts. Consumers can complain to the ASA, but it takes steps to ‘proactively monitor ads across different sectors and media to make sure standards are being maintained’. In its evidence, the ASA told the Committee of adverts which had an adverse impact on body image and were subsequently banned, including a TV ad for breast enlargement surgery on the grounds it exploited young women’s insecurities about their bodies, trivialised breast enhancement surgery and portrayed it as aspirational (MYACosmetic Surgery Ltd) and a women’s clothing retailer promoted summer and swimwear in a way that objectified women and was likely to cause offence (Missguided Ltd). Additionally, the ASA banned an Instagram post by a TV personality promoting a weight loss food supplement for encouraging an unsafe practice, namely consuming products during pregnancy that were intended to aid weight loss (The White Star Key Group Ltd).
68.We questioned the ASA on its work on protecting the public from adverts that could provoke negative body image as well as the cumulative impact of advertising on body image. Malcolm Phillips, Regulatory Policy Manager for the ASA told us that they are aware there is concern about potentially subtle or insidious effects of advertising connected with concerns about the volume of advertising that people see. It told us it was keen to understand more about the role that advertising plays in negative body image and was planning its own call for evidence on body image and advertising in 2021, building on the work it has done on gender stereotyping. Also, we discussed with the ASA the lack of diversity of ethnicities, abilities, body shapes etc in advertising. We heard that the regulatory system is set up to tell people what not to do, rather than what to do, but that further work is planned to prevent racial stereotyping, and to build into its work on body image targeted engagement with specific communities to better understand whether there is a role for the ASA in helping mitigate those higher risks through our work.
69.Many organisations and academics have advocated for greater levels of regulation for media and advertising to protect the public from content damaging individuals’ body image. The Centre for Appearance Research requests that the ASA to expand its policies to include protecting harmful content around body image and appearance-based discrimination. Currently the ASA review adverts on a case-by-case basis which doesn’t address the potential harm caused by the cumulative effect of seeing numerous adverts perpetuating appearance ideals and stereotypes on a daily basis.
70.Body image experts at Newcastle University want to see the ASA enforce the inclusion of diverse healthy bodies in media by legislating minimum model BMIs and/or requiring public media producers to audit and perhaps meet targets on body diversity. The Mental Health Foundation argued that advertising, if left unregulated, is driven by incentives to present unattainable ‘idealised’ bodies as aspirational to increase the desirability of certain consumer products or lifestyles, including cosmetic surgery. It wants the ASA to consider more stringently vetting high-reach broadcast adverts from high-risk industries—such as cosmetic surgery companies and weight-loss products and services—to ensure all advertising abides by its codes at the time they are on-air. The ASA should also make greater use of its ability to proactively instigate investigations.
71.Hundreds of respondents to our body image survey informed us that a major driver of negative body image, particularly for young people, is the prevalence of edited and ‘filtered’ photos in advertising and across social media. This included edited photos of pregnant models advertising maternity clothes online, airbrushed billboards showing flawless skin, and the array of filters used across social media to ‘improve appearance’.
72.The Mental Health Foundation informed us of the widespread availability of image-editing apps which allow individuals to digitally alter their appearance. Possible changes include colour filters and teeth whitening, and more extreme edits that can dramatically change one’s body shape, skin tone, height, or muscular complexion.
73.We found that worries around image editing and its impact on body image has been furthered during the pandemic by the so called ‘Zoom Boom’ in which demand for cosmetic surgery increased 70% in the UK, reportedly due to people spending more time observing themselves while videoconferencing. Zoom has a function where you can use to a filter to give your face a softer look and minimise ‘imperfections’. Prior to the pandemic, ‘injectables’ were the most-asked-for treatments, followed by more invasive procedures such as breast augmentation and liposuction. UK-based practitioners say that the Zoom Boom is driving interest in non-invasive facial procedures, like Botox, fillers or skin resurfacing that correct lines caused by the facial expressions we notice on video calls as well as to tackle wrinkles.
74.In addition to inspiring requests for cosmetic surgery, the huge numbers of digitally-altered images are also referenced by those with negative body image as contributing towards a lack of self-esteem as well as the development of mental health conditions, such as BDD and eating disorders. Girlguiding UK told us that the bombardment of perfected images every single day takes its toll, having found that 45% of 11–16 year olds regularly use apps or filters to make themselves look different.
75.One approach to countering this trend proposed to us in evidence is to ensure that digitally altered images are watermarked to indicate they have been edited. In France, legislation to this effect was introduced in 2017, which requires any digitally altered commercial image to be marked with “edited photograph”. Fines are levied if these rules are flouted.
76.However, a significant body of research has demonstrated that the addition of such warning labels is not effective in reducing the body dissatisfaction on traditional media images or on social media. We heard that most young people are aware that images are digitally enhanced but still aspire to the projected ideals.
77.Girlguiding proposed a multifaceted approach, as evidence was indicating that image labelling alone would not necessarily go far enough to inspire cultural and societal change. The Mental Health Foundation told the Committee that what might be more effective than simply labelling altered images would be to explain, particularly to young people, that digitally enhanced advertising is in place to convince them to buy products rather than feel confident in their own appearance.
78.Based on the concerns outlined above, we questioned Sport England, Boohoo, Dove and L’Oréal on use of digitally altered images in advertising. All three companies informed us that they do not airbrush images. Boohoo said:
[ … ] We do not retouch body shape or size [ … ] Things like scars, freckles and stretch marks will always stay in. For us, similarly, we want our models to be reflective of our customers at home.
79.These companies recognised that consumers want to see themselves reflected in advertising and digitally-altering images to remove perceived flaws on the bodies of men and women is not popular. However, we are aware, that many companies still regularly digitally alter their images to ‘improve’ the appearance of their models. Additionally, digitally altered images are constantly available on social media; Snapchat, Facebook, Instagram and TikTok all contain hundreds of filters that change the appearance of the user. A young witness with lived experience of body dysmorphia said:
It is a moral responsibility of social media companies to label these images to bring back a sense of reality on social media [ … ] Young people looking at that have no idea that that image has been edited, especially as 13 and 14-year-olds. [ … ] that leads to people like me when I was younger developing body image difficulties. It is morally imperative that social media companies take responsibility and actually label these photos.
80.There have been positive developments in this area. For example, in early 2021 the ASA asked influencers to not use ‘misleading’ beauty filters and ruled that filters should not be applied to social media adverts if they exaggerate the effect of the products. The Government acknowledged that there is increasing demand from consumers for more authentic and representative images on social media and beyond, and they want to work with companies to support that demand.
81.Transport for London’s (TfL) advertising estate is one of the largest in the world and makes up 20 per cent of all out-of-home advertising in the UK and 40 per cent of the London market. The Committee received numerous written evidence submissions concerning TfL’s advertising policies and body image. In 2016, TfL changed its advertising policy to prohibit the approval any adverts which could reasonably be seen as likely to cause pressure to conform to an unrealistic or unhealthy body shape, or as likely to create body confidence issues, particularly among young people.
82.The Centre for Appearance Research said that TfL’s change in policy has been successfully implemented while not affecting the revenue of the TfL estate, thus demonstrating that media and advertising regulation in relation to body image and appearance diversity is possible and commercially viable.
83.We questioned TfL on the impact of the change in advertising policy and heard that until the recent pandemic impact there had been a rising level of advertising revenue for TfL’s estate. We also questioned TfL on the success of the body image clause and were told that there had been no market research directly into the policy, but there has been a lack of controversy, complaints and concerns about it, and in that way it was a success. When we asked the ASA its view on TfL’s policy it told us that it’s open to each media owner to establish its own standards and views on what it wants to carry in advertising in it channels and it would be a very different matter for a regulator to impose controls that will then be enforced on a mandatory basis. In 2021, the ASA announced a call for evidence on body image in addition to the work it has already done on cosmetic interventions and gender stereotyping in relation to body image.
84.In November 2020 as part of the Government’s Obesity Strategy, it launched a consultation into banning online adverts for foods high in fat, sugar and salt (HFSS) in the UK. Research shows that exposing children to these adverts can increase the amount of food children eat and shape their preferences from a young age. The intervention from Government on the advertising of HFSS food based on shows that the Government can and do intervene in advertising when there is a concern to wider society as follows:
Government may intervene in markets to change consumer behaviour where such behaviour has adverse effects on society or because of fears of adverse consequences for the individual consumer over the long-term. An example of such behaviour is excessive alcohol consumption which has been linked with antisocial behaviour and health risks and imposes significant costs to the police and the health care system.
85.The harms from advertising featured heavily in the GEO’s 2019 research on body image. The research also found that there is a desire for less harmful media and more ‘responsibility’ from advertising companies for the types of content they broadcast, and that it is important for brands and advertising aiming to promote body positivity to be truly inclusive. Its research indicated that brands are not doing enough to be inclusive of audiences, particularly of LGBT and non-binary audiences. However, Minister Dinenage told the Committee that the ban on HFSS food adverts is at odds with the approach that the Government take more broadly in terms of digital regulation.
86.We also questioned the Government on its position on widespread image-editing and the damage this is causing to people’s body image. The Government accept that image-editing and the labelling of digitally altered images is an important issue and it wants to respond to the demand from consumers for more authentic images both on and offline by ensuring any Government intervention in this area is effective. As demonstrated above, academic research suggests that labelling images that have been altered is unlikely to be effective as a standalone move. In oral evidence, the Government pledged to consult on this issue as part of the online advertising programme in the Spring with a view to introducing multiple interventions and working closely with the advertising industry and the ASA.
87.The Government told us that it is working on identifying and developing interventions around body image, which it will consult on later this year including as part of their online advertising programme. The ASA is well equipped to support existing traditional media by reviewing adverts on a case-by-case basis, but body image harms can be caused by more of a cumulative effect, the ASA recognised this and want to improve their regulation of online advertising in connection with body image harms. The Government told us that it works very closely with the ASA to ensure any policy changes in advertising are well-informed and that the ASA and DDCMS are keeping in contact around concerns on body image in advertising.
88.The Committee is disappointed about the lack of diversity in adverts both on and offline. We urgently want to see more companies advertising with real images of people from a diverse range of ethnicities, abilities, sexualities, genders, body shapes and sizes. We know that advertising is a powerful driver of consumer behaviour and protecting people from adverts, which can be pervasive online, needs to be a priority if the Government wishes to reduce negative body image. We recommend that the Government works with companies and the ASA to further encourage the use of diverse and representative images of people in advertising.
89.We commend the Government for launching a consultation on online advertising in the Spring and are encouraged that the ASA will be consulting on body image as well as racial stereotyping in 2021. We recommend that the Government works closely with the ASA to ensure its future work on body image is inclusive and that substantial changes are implemented after its consultation.
90.Whilst the Committee was pleased to see that TfL has taken steps to protect Londoners from advertisements that could promote body dissatisfaction and bolster diverse advertising on their network, we were disappointed it had not been fully evaluated to properly assess the impact of their policy, both on their consumers and their advertising revenues. We recommend that the Government works with the advertising industry and TfL to consider what impact banning adverts has on protecting people from developing negative body image. It should update us within 6 months.
91.We were pleased to hear from companies who are committed to advertising their products by using real, honest images. However, a significant number of advertisers continue to rely heavily on image editing. It is clear that the constant bombardment of editing images both on and offline is detrimental to mental health and contributes to the development of poor body image. The Government should bring forward legislation to restrict or ban the use of altered images in commercial advertising and promotion.
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