Australia: the healthiest country by 2020
National Preventative Health Strategy – the roadmap for action

Key action area 5: Reduce exposure of children and others to marketing, advertising, promotion and sponsorship of energy-dense nutrient-poor foods and beverages

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It is now accepted by international health agencies such as WHO that restrictions on food and beverage marketing directed to children should form part of a comprehensive and multifaceted strategy to address the growing problem of childhood obesity. WHO has recognised that food marketing to children, particularly television advertising, is an important area for action to prevent obesity,[63] and has called upon governments to implement policies and strategies that reduce the impact of foods high in fat, sugar and salt, and promote the responsible marketing of foods and beverages to children.[26]¹⁰

There is also growing international consensus that food advertising influences children’s food preferences, diet and health, and that this influence is harmful to children’s health, as most advertising to children is for products high in salt, sugar and fat.[136] International reviews have concluded that heavy marketing of fast food outlets and energy-dense micronutrient-poor foods and beverages is likely to be causative in weight gain or obesity.[63] Statistical evidence indicates that exposure to television advertising is associated with adiposity or body fatness in children aged 2–11 years and young people aged 12–18 years.[137] US research examining the effects on childhood obesity of television fast food restaurant advertisements targeted at children has found a strong association between exposure to fast food restaurant advertising and the probability of children being overweight.[138] Similarly, modelling to estimate the potential effects of reducing the exposure of 6–12-year-old US children to television food advertising on overweight and obesity prevalence predicts that reducing the exposure to zero would lower the prevalence of obesity from 17.8% to 15.2% for boys and from 15.9% to 13.5% for girls.[139]

Australian children’s exposure to television food advertising is amongst the highest in the world,[140] and a large proportion of these advertisements are for non-core or extra (EDNP) foods.[141-143] Australian children watching 20 hours of television or more per week (two hours and 51 minutes per day) are twice as likely to be overweight or obese as children who watch less television.[144] Evidence indicates higher rates of high-fat/high-sugar food advertisements on Australian television during children’s viewing hours, compared with adults’, and during popular children’s programs.[141]

The Taskforce has noted that the Australian Communications and Media Authority (ACMA) has released its draft Children’s Television Standards 2008 for public and industry comment. At this stage, ACMA is not proposing to introduce general restrictions on food and beverage advertising to children.

The draft standards do not impose general restrictions in relation to food and beverage advertising, arguing it would be a blunt form of regulatory intervention. However, they do propose to strengthen certain provisions regulating advertising to children. These proposals would further restrict the use of licensed characters, popular personalities and celebrities to promote and endorse products immediately before, during and after ‘C’ and ‘P’ periods. They would also clarify rules for premium offers, such as toys offered with food and beverage purchases.

The Taskforce believes there is a need to address persuasive marketing techniques (including premium offers, such as competitions, and the use of promotional characters, including celebrities and cartoon characters) to children. Persuasive marketing techniques are frequently used to advertise non-core foods to children, to promote children’s brand recognition and preference for advertised products. Recent Australian research examined children’s exposure to the use of persuasive marketing (within television food advertisements). The study found that significantly more food advertisements were broadcast during children’s peak viewing times, compared to non-peak times, contained promotional characters and premium offers. During programs most popular with children, there were 3.3 non-core food advertisements per hour containing premium offers, compared to 0.2 per hour during programs most popular with adults. The majority of advertisements containing persuasive marketing during all viewing periods were for non-core foods.[145]
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The Taskforce believes that restrictions on the advertising and promotion of unhealthy food and drink are required to reduce children’s overall exposure to the marketing of EDNP foods. In addition, the Taskforce also believes there is a need to curtail the use of specific persuasive marketing techniques in the marketing of these foods. A staged approach will be required, commencing with the phasing out of marketing of these products on free-to-air and Pay TV before 9 pm. Television advertising has significant reach, and has been shown to independently influence children’s food preferences and purchasing requests.[137, 146] Food advertising to children affects their food choices and influences their dietary habits.[146]

Phasing out the marketing of unhealthy foods during peak viewing periods and during periods when children and young people are likely to be watching television would help to reinforce and normalise healthy eating for Australian children, and enable them to make healthier food choices. Children are a distinct group of media consumers whose cognitive abilities require special consideration in relation to the content and presentation of advertising.

Displacement of advertising

Experience from tobacco control indicates that when restrictions do not cover all media, marketing is likely to become concentrated in those media that are not covered, or not as heavily restricted.[147] This will need to be monitored carefully over time.

Research indicates that food marketers are responding to pressures to reduce television advertising by increasingly using print and new technologies, such as the internet, mobile phone text messaging and email to target children.[148] These other non-broadcast media are often used by children without parental supervision, making them more difficult for parents to monitor and control.[149]

Current industry self-regulation in Australia

The Responsible Children’s Marketing Initiative,[150] developed by the Australian food and beverage industry, came into effect in January 2009, with the stated aims:

‘to ensure that a high level of social responsibility in marketing communication and marketing food and beverage products in Australia is maintained’¹¹

‘to provide a framework for food and beverage companies to promote healthy dietary choices and lifestyles to Australian children’.[150]


Responsible Children’s Marketing Initiative
Member organisations of the Australian Food and Grocery Council (AFGC) have voluntarily committed to the initiative, with 15 companies signed up at 24 April 2009.

Participating companies are required to publish individual company action plans outlining how they will meet the core principles of the initiative, including publicly committing to marketing food and beverages to children under 12 only when the products are healthy dietary choices consistent with government standards, AND when they are presented in the context of a healthy lifestyle encouraging good dietary habits or physical activity. The standards by which their products are assessed include Dietary Guidelines for Australians and School Canteen Guidelines.

This initiative applies to marketing communications directed to children under 12 in media where the audience is predominantly children and/or the programs are directed primarily to children. The key to determining whether programs are designed for children is whether the themes, visuals, language and concepts are those that are appropriate to children under 12. This includes all ‘P’ and ‘C’ programs, but also includes a number of G-rated programs which, based on the criteria outlined above, are considered to be designed for children.

The program is supported by an independent complaints resolution mechanism run by the Advertising Standards Bureau, with The George Institute for International Health acting as an independent arbiter.

Independent evaluation of this initiative will be important to assess the effect on children’s exposure to food marketing and promotion. The AFGC has announced it will commission a study over a period of 12 months from the commencement of the initiative, to monitor advertising to children and assess industry response. Industry is currently working on an independent monitoring project. Participating companies have also agreed to report our marketing activity and communication against their plans on an annual basis.

Source: Information provided by the AFGC
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The limitations of this approach include:

• Specific times when the code applies are not specified, and the onus is on individual companies to ensure that they do not advertise in programs where the audience is predominantly children and/or having regard to the theme, visuals, and language used are directed primarily to children.¹² Some companies define ‘targeting children under 12 years’ on television to be when the majority of the audience is under 12 years, which is extremely rare.¹³
• Only some companies in the food industry are represented, due to the voluntary nature of the scheme.[151]¹⁴
• There are no specified nutrient criteria used to define healthy and unhealthy foods; making monitoring difficult.
• While complaints and compliance systems have been developed, including a public complaints program, there are no specified deterrents to ensure food companies will comply with the industry’s code. However, the AFGC advises that sanctions are to be developed.[152]
• The code does not cover food marketing on food companies’ own websites, only paid advertising on third-party websites.
• The code does not cover forms of promotion such as sports sponsorship

The AFGC has announced it will commission a study over a period of 12 months from the commencement of the initiative, to monitor advertising to children and assess industry response. However, independent evaluation of this initiative will be important to assess the effect on children’s exposure to food marketing and promotion, and determine whether there is a need for further action.

International regulation

There are extensive legislative prohibitions on advertising to children in Sweden and Norway, and in the Canadian province of Quebec. In Sweden and Norway, commercial advertising directed to children on television is prohibited, while in Quebec the commercial advertising (of all products and services, not just food) targeted at children via any medium is prohibited. In all of these countries, the ban is enforced by a government agency.[153]

The UK’s broadcasting regulator Ofcom began phasing in restrictions on the advertising of food products high in fat, salt and sugar (HFSS products) to children in 2007, in response to concerns about child obesity. HFSS advertisements were banned from children’s programming (aimed at children aged under 16 years) on most channels, and progressively reduced on children’s channels. The first review of these restrictions compared children’s exposure to HFSS advertising in 2005 with that in July 2007–June 2008. The review estimated that over this period the amount of HFSS advertising seen by children on television fell by 34%. Children were also reportedly exposed to less food and drink advertising using licensed characters such as cartoon and film characters, and fewer advertisements with brand equity characters, free gifts and health claims, while advertising featuring celebrities had increased.[154]

Ofcom expects further reductions in children’s exposure to advertising to have occurred following the implementation of the final phase of restrictions which occurred in January 2009, when all remaining HFSS advertising on children’s channels (on Pay TV) was required to be removed.[154]

In the United States, legislation was passed in March 2009 establishing an Interagency Working Group on Food Marketed to Children.[155] The group will examine how food is marketed to children, develop recommendations on food marketing standards to children under the age of 17 and establish which products are suitable to be advertised to this age group, as well as the scope of the media to which the standards should apply. Members will come from the Federal Trade Commission, Food and Drug Administration and the Centers for Disease Control and Prevention, as well as the Secretary of Agriculture. The group is to report by July 2010.
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Community views

There is strong community support for the introduction of restrictions on advertising to children. Significant concern about the frequency and nature of unhealthy food advertising targeted at children and support for restrictions has been demonstrated in numerous state and national community surveys in Australia,[156, 157] including strong support for government regulation.[156, 158]

In 2007, the Coalition on Food Advertising to Children (CFAC) led a campaign supporting the need for better regulations to protect children from food advertising. Member organisations collected over 20,000 postcards signed by community members supporting the campaign.[159] Several state jurisdictions are considering regulating the marketing of unhealthy food and beverages to children. For instance, the South Australian and Queensland governments announced consultations into television food and drink advertising for children in late 2008. In South Australia, the government has indicated a preference for national action, but will consider the introduction of state-based restrictions if national agreement is not reached. Health ministers in New South Wales and Western Australia have also called for restrictions on unhealthy food advertising to children.[160]

In Summary

In the area of food advertising to children, a topic that has been the subject of much controversy and community debate, several important new studies and reviews have been published (referred to above). These add to the substantial body of evidence that has been accumulating since the 2007 publication of the review of children’s television advertising prepared for ACMA. The Taskforce also commissioned work in this area.

The Taskforce finds that, on balance, the weight of evidence of the negative effects of inappropriate food advertising on children’s knowledge, attitudes, food preferences and consumption is now sufficiently compelling to recommend ameliorative action.

The Taskforce notes that reducing children’s exposure to the promotion of unhealthy foods alone will not solve the obesity problem, but in concert with the other actions recommended we believe – based on the available evidence – that it will make a significant contribution.

The Taskforce therefore recommends that a phased approach to reduce the exposure of children and others to marketing, advertising, promotion and sponsorship of EDNP foods and beverages is required as one of the key areas of action needed to tackle the obesity epidemic.

The Taskforce proposes that the marketing of EDNP foods and beverages on free-to-air and Pay TV before 9pm should be phased out within four years.

The Taskforce proposes that this measure should be accompanied by a focus on phasing out the use of premium offers, toys, competitions and promotional characters, including celebrities and cartoon characters, to market EDNP food and drink to reduce the exposure of children to this advertising across all media sources.

The Taskforce also proposes that the advertising of EDNP food and drink across other media sources is monitored as restrictions come into place across television to determine if there is a need to develop additional measures across other media sources.

To inform the implementation of this process, an appropriate set of definitions and criteria for determining EDNP food and drink will be developed and adopted.
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The phased approach would include:

• Monitoring and evaluating the impact of self-regulation in reducing children’s exposure to unhealthy food advertising
• Identifying shortfalls and any other issues in the current voluntary approach, and addressing these through the introduction of a co-regulatory agreement; monitor and evaluate the effectiveness of co-regulation
• Introduce legislation if these measures are not effective in phasing out
  • Marketing of EDNP food and beverages on free-to-air and Pay TV before 9 pm
  • Premium offers such as toys, competitions and the use of promotional characters, including celebrities and cartoon characters, to market EDNP food and drink to children
• Consider whether there is a need for additional measures to address EDNP advertising across other media sources

Action 5.1
Phase out the marketing of energy-dense nutrient-poor food and beverages on free-to-air television and Pay TV before 9 pm within four years. Phase out premium offers, toys, competitions and the use of promotional characters, including celebrities and cartoon characters, to market EDNP food and drink to children across all media sources. Develop and adopt an appropriate set of definitions and criteria for determining EDNP food and drink.

¹⁰ WHO is currently drafting recommendations on food and non-alcoholic beverage marketing to children, to be presented to the World Health Assembly in May 2010. See www.who.int/dietphysicalactivity/marketing-food-to-children/en/index.html.
¹¹ www.afgc.org.au/index.cfm?id=726.
¹² www.afgc.org.au/index.cfm?id=770.
¹³ For example, OzTAM ratings data for January–June 2006 indicate no time slots across weekdays or across weekends when children 0–14 years comprise the majority of the overall viewing audience across commercial channels.
¹⁴ This covers the majority of food and beverage companies that produce HSFF products and that advertise to children.

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