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Technical Paper 1:
Obesity in Australia: a need for urgent action

4.4 - Protect children and others from inappropriate advertising of unhealthy foods and beverages

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Television advertising has significant reach, and has been shown to independently influence children’s food preferences and purchasing requests.[79, 80] Food advertising to children affects food choices and influences dietary habits.[79] A ban on advertising unhealthy foods to children during peak viewing periods would help to reinforce and normalise healthy eating for Australian children, and enable them to make healthier food choices.

The Australian experience

Australian children’s exposure to television food advertising is amongst the highest in the world,[81] and a high proportion of these advertisements are for non-core or extra (energy-dense, nutrient-poor) foods.[83, 158, 159] 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.[82] Evidence indicates higher rates of high-fat/high-sugar food advertisements on Australian television during children’s compared with adults’ viewing hours; and during popular children’s programs.[83]

Australian research that models television food advertising under different regulatory scenarios suggests that simple regulatory restrictions such as restricting content and timing of advertisements would reduce children’s exposure to advertisements for non-core foods.[84]

The new draft of the Children’s Television Standards was released by the Australian Communications and Media Authority (ACMA) in August 2008 for public and industry comment.⁸ General restrictions on food and beverage advertising were not proposed.

ACMA cited limited evidence on the benefits of banning food advertising and questioned the body of research linking weight and television advertising. It considered that restricting food advertising without a tool to identify foods high in fat, salt and sugar (HFSS) would be a blunt form of regulatory intervention. ACMA indicated it would consider reviewing its position should a stronger association between food advertising and obesity be found or when there is a more established body of research illustrating the benefits of banning food and beverage advertising; and when an Australian-appropriate food identification standard is successfully introduced.

As part of the review, ACMA assessed the economic impact of restrictions on television food and beverage advertising. It should be noted that ACMA based its cost-benefits analysis on figures from the 2006 Access Economics report on the cost of obesity in Australia.[86] Since ACMA released its draft standard, these estimates have been revised by Access Economics.[13] As the more recent report estimated significantly higher costs to the Australian community of obesity, this would significantly alter the cost-benefit outcomes calculated for the ACMA review. The Taskforce believes that further research needs to be undertaken utilising the most recent Access Economics data to help us understand the association between advertising and children’s weight.

International recommendations conclude 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. The World Health Organization has recognised that food marketing to children, particularly television advertising, is an important area for action to prevent obesity[51] 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.[87]
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There is growing international consensus that food advertising works by influencing 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.[85] 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.[51] 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.[80] While current evidence is not sufficient to conclude a causal relationship between television advertising and adiposity, even a small association would have significant impact across the entire population of children and young people.[80]

Following the release of the new standards by ACMA, the South Australia and Queensland governments announced consultations into television food and drink advertising for children to consider bans or regulations on marketing of unhealthy food and beverages. In South Australia, the government has indicated a preference for voluntary restrictions from the advertising and food industries, as well as a preference for national action. However, the South Australian Government will consider the introduction of state-based restrictions if national agreement is not reached. In addition, at the national level, the Senate has recently referred the ‘Protecting Children from Junk Food Advertising (Broadcasting Amendment) Bill 2008’ to the Community Affairs Committee for inquiry and report by 25 November 2008.

Among other effects, it has been suggested that regulation may lead to lower levels of funding for children’s programs. While the evidence remains limited on the effects of advertising bans, impacts need to be assessed in practice and over a significant time period. However, there is some evidence from international jurisdictions where advertising restrictions have been enacted.

The international experience

There are extensive legislative prohibitions on advertising to children in Sweden and Norway, and 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. It has been argued that childhood obesity rates increased in Sweden and Quebec following the introduction of advertising restrictions to children, and that this provides evidence that food advertising is not a contributor to the obesity epidemic, and that the regulation of food advertising would not be effective in reducing obesity. These claims have been refuted for a range of reasons:[88]

• The argument fails to take into account the fact that there are multiple factors that contribute to the obesity crisis, and that restricting advertising targeted at children is proposed as only one of a large range of measures required to address obesity. It is not expected that the introduction of advertising bans alone would lead to significant reductions in obesity prevalence among children.
• There are several limitations to the advertising restrictions in these jurisdictions, including:⁹
  • Restrictions do not apply to broadcasters and advertisers outside the jurisdiction. As a consequence, significant levels of food advertising to children remain on Swedish television, since two of the three commercial television stations received in Sweden are broadcast from the UK. A similar situation occurs in Quebec.
  • The bans apply to advertisements that are directed at children in Sweden, or designed to attract the attention of children in Quebec. These stipulations allow advertisements with any component deemed to be ‘adult’ or in any way not designed for children to be considered exempt from the bans.
  • Lack of resources for the monitoring and enforcement of bans.
• It is not known what childhood obesity rates would have been in these jurisdictions if advertising bans had not been introduced: prevalence may have increased at an even greater rate.
• There is evidence that French-speaking children in Quebec have lower rates of obesity than English-speaking children, who can watch commercial television broadcast from outside the province.

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The UK experience

In the UK, Ofcom has introduced restrictions on broadcast food and drink advertising to children. These apply to the advertising of food products high in fat, salt and sugar within programming aimed at children aged under 16 years. The first review of these restrictions commenced in July 2008 and will be based on six months of data. Industry has also introduced new content rules for all food and drink advertising to children in non-broadcast media, with fruit and vegetable promotion excepted, under the Advertising Standards Authority (ASA). ASA is reviewing its advertising codes and will put out revised codes for public consultation later in 2008. The Institute of Standards in British Advertising (ISBA) has published best practice principles for advertiser-owned websites for marketing to children.[35]

The US experience

In the US, the Federal Trade Commission was asked by Congress to undertake a study of food and beverage marketing to children and adolescents in response to marked increases in childhood obesity.[89] The research examined expenditures and activities in 2006 across traditional media such as radio, television and print, as well as activities on the internet and in previously unmeasured marketing arenas such as packaging, in-store, event sponsorship and school promotions.

The 44 companies surveyed were the primary marketers to youth (2–17 years old) in categories including beverage manufacturers and bottlers; packaged/processed food producers; dairy marketers; fruit and vegetable growers; and quick-service restaurants. The survey found that food and beverage companies spent US$1.6 billion in 2006 on marketing their products to children; advertising to 2–17-year-olds made up 17% of their total 2006 marketing budgets. The majority (63%) of the total spent on advertising to youth was for soft drinks, breakfast cereals and restaurant foods. Television advertising was the dominant marketing technique used to promote foods and beverages to youth, comprising 46% of all reported youth marketing expenditures. Over half of this television advertising was targeted at children under 12; this was mostly advertising for breakfast cereals and restaurant food.[89]

While just over half of the spending was on traditional media forms of print, radio and television (53%), the remainder was concentrated in areas such as internet and digital promotions, expenditure on speciality items and prizes for children and adolescents (excluding toys distributed with children’s meals at quick service restaurants), packaging and in-store display materials, and other media such as event sponsorships; celebrity endorsement fees; cinema, video and video game advertisements; and product placements in films, television and video games.

Spending on cross-promotions comprised 13% of all reported youth marketing – this included the use of licensed characters and associations with television programs, movies, toys or other entertainment events. For some food categories, such as restaurant food and fruits and vegetables, cross-promotions represented almost half of spending targeted at children.[89]

This report and evidence from the UK highlights the increasing importance of non-traditional media and promotional activities in the marketing of food and beverage products to children and adolescents, including the use of the internet (for example, company-sponsored websites), digital promotions (for example, email and text messaging) and word-of-mouth/viral marketing. For example, large food companies in the UK are using social networking sites and text messaging competitions to market unhealthy food to children. A recent report by the Consumer group ‘Which?’ found that some companies that had pledged to stop marketing unhealthy food to children under 12 years have not done so, but have continued to use cartoon characters, film tie-ins, celebrity endorsements and free offers to target children aged under 12 years.[90]

Curb inappropriate advertising and promotion, including consideration of banning advertising of energy-dense, nutrient-poor foods on free-to-air television during children’s viewing hours (i.e. between the hours of 6.00am and 9.00pm), and reducing or removing such advertising in other media such as print, internet, radio, in-store and via mobile telephone.

⁸See www.acma.gov.au/WEB/STANDARD/pc=PC_310262
⁹Goldberg (1990) and Caron (1994), cited in Ofcom: Childhood Obesity – Food Advertising in Context, 22 July 2004,
www.ofcom.org.uk/research/tv/reports/food_ads/report.pdf.

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