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

Food marketing to children

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As discussed in the Technical Report, the most authoritative and comprehensive reviews of studies on the nature and extent of food marketing to children have been conducted in the United Kingdom, initially in 2003,[53] updated in 2006[54] and in 2008 (unpublished).[55] This work reviewed studies on the extent and nature of food marketing to children from over 25 countries. These reviews and updates indicate that children are exposed to high levels of food advertising and marketing, and that the advertised diet is dramatically different from recommended diets, as it predominantly promotes energy-dense nutrient-poor (EDNP) foods. These findings are consistent with evidence from the work conducted by the Institute of Medicine in the United States,[56] as covered in the Technical Report.

There is a substantial and accumulating body of Australian research on food marketing patterns, including studies related to television, magazines, the internet, outdoor settings and point-of-sale.[57-66] This research indicates that food marketing is pervasive, and that children are exposed to high levels in each of these media throughout daily life. The research shows consistently that the content of food marketing directed at children is predominantly for unhealthy foods.

Restrictions on unhealthy food advertising targeted at children and others are proposed as part of a comprehensive approach and only one of a large range of measures required to address obesity. While current evidence is not sufficient to assess the impact of comprehensive advertising restrictions on obesity prevalence in children, especially in conjunction with public education (as this has not occurred in any jurisdiction), even a small association between television advertising and adiposity means limiting advertising would have significant impact across the entire population of children and young people.[56] Small influences can be significant when they affect a large population, are ongoing and cumulative. It is important to note that food marketing has as much impact on food consumption as any other single factor, and is amenable to change.[67, 68]

Persuasive marketing techniques are frequently used to advertise non-core foods to children, as well as 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.[69]
Advertisements broadcast on all three commercial Australian television channels were recorded for an equivalent one-week period in May 2006 and 2007 (714 hours). Food advertisements were analysed for their use of persuasive marketing, including premium offers, such as competitions, and the use of promotional characters, including celebrities and cartoon characters. Advertised foods were categorised as core, non-core or miscellaneous foods. Commercial data were purchased to determine children’s peak viewing times and popular programs. A total of 20,201 advertisements were recorded, 25.5% of which were for food.[69]
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The study found that significantly more food advertisements broadcast during children’s peak viewing times contained promotional characters and premium offers, compared with food advertisements during non-peak times. During programs most popular with children, there were 3.3 non-core food advertisements per hour containing premium offers, compared with 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.[69]

Future debate relating to television advertising regulations must consider the need to restrict the use of persuasive marketing techniques to children, including premium offers such as competitions, and the use of promotional characters such as celebrities and cartoon characters.

Food marketing is linked to childhood obesity through its influence on children’s food preferences, purchase requests and food consumption. A study by Kelly, Cretikos, Rogers and King aimed to describe the volume and nature of outdoor food advertisements and factors associated with outdoor food advertising in the area surrounding Australian primary schools. Forty NSW primary schools in Sydney and Wollongong were selected using random sampling within population density and socioeconomic strata. The area within a 500-metre radius of each school was scanned and advertisements coded according to pre-defined criteria, including food or non-food product advertisement, distance from the school, size and location. Food advertisements were further categorised as core foods, non-core foods and miscellaneous drinks (tea and coffee). The number of advertisements identified was 9151, of which one-quarter (25% or 2286) were for food.

There were 1834 non-core food advertisements: this accounted for 80% of food advertisements. Soft drinks and alcoholic beverages were the food products most commonly advertised around primary schools (24% and 22% of food advertisements, respectively). Non-core food products were twice as likely to be advertised close to a primary school (95 non-core food advertisements per square kilometre within 250 metres compared to 46 advertisements per square kilometre within 250–500 metres). The authors concluded that the density of non-core food advertisements within 500 metres of primary schools, and the potential for repeated exposure of children to soft drink and alcoholic beverage advertisements in particular, highlights the need for outdoor food marketing policy intervention. The authors argued that outdoor advertising is an important food marketing tool that should be considered in future debates on the regulation of food marketing to children.[66]
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A 2009 review of existing knowledge regarding the impact of marketing addressed the value of various legal, legislative, regulatory and industry-based approaches to change.[70] While reducing food marketing to children has been proposed as one means for addressing the global crisis of childhood obesity, there are significant barriers (social, legal, financial and public perception) associated with this. According to the authors, scientific literature documents that food marketing to children is:
(a) Massive
(b) Expanding in number of venues (product placements, video games, the internet, mobile telephones)
(c) Composed almost entirely of messages for nutrient-poor, calorie-dense foods
(d) Having harmful effects
(e) Increasingly global and therefore difficult to regulate by individual countries

The food industry, governmental bodies and advocacy groups have proposed a variety of plans for altering the marketing landscape.[70]

A recent publication in the European Journal of Public Health reported on a mathematical simulation model that estimated the potential effects of reducing the exposure of 6–12-year-old US children to television food advertising on the prevalence of overweight and obesity.[71]

The study concluded that from one in seven up to one in three obese children in the United States might not have been obese in the absence of advertising for unhealthy food on television: 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. This study provides support for limiting the exposure of children to marketing of energy-dense food as a part of a comprehensive approach to improving children’s diets.[71]

The UK experience

Previously in the Technical Report we reported on the phasing in of restrictions on the advertising of food products high in fat, salt and sugar (HFSS products) to children in 2007 in the United Kingdom by the UK’s broadcasting regulator Ofcom. In summary, HFSS advertisements were banned from children’s programming (aimed at children aged under 16 years) on most television channels, and progressively reduced on children’s channels.

The first review of these restrictions compared children’s exposure to HFSS advertising in 2005 with July 2007–June 2008.[72] 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; there were fewer advertisements with brand equity characters, free gifts and health claims, but more with celebrities.
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Ofcom expects further reductions in children’s exposure to advertising to have occurred since the implementation of the final phase of restrictions in January 2009, when all remaining HFSS advertising on children’s channels (on Pay TV) was required to be removed.

The review also found that much of the HFSS advertising seen by children is broadcast between 6 pm and 9 pm. While the amount children saw in this period fell by an estimated 29%, the British Heart Foundation and other health and consumer groups have called for full bans due to limitations of the current regulations, which apply to programs aimed at under-16s13 rather than programs most popular with under-16s. The UK regulations are based on children as a proportion of the audience, and do not apply at times when the largest absolute numbers of children are watching. Programs with a small total audience, of which a high relative proportion are children, would be covered by the regulations, while a program with a large total viewing audience, with higher absolute numbers of children viewing but a relatively lower proportion of children compared to adults, would not be covered. A large number of children therefore are still exposed to food marketing on television[73], despite the specific intent of the restrictions to limit such exposure.

While children’s channels in the United Kingdom saw a decline in food and drink advertising revenue, this was more than offset by a growth in advertising revenue overall. The four main commercial channels saw an overall reduction in advertising revenues, with a 6% decline in food and drink advertising revenue. Most other digital commercial channels increased their revenue from food and drink advertising, and children’s exposure to HFSS advertising was increased by 7% on these channels.[72] This highlights the importance of applying restrictions across media, including free-to-air and Pay TV, as the latest Ofcom restrictions have been doing since 1 January 2009.

Voluntary regulation in Australia

In October 2008, the Australian Food and Grocery Council (AFGC) announced the Responsible Children’s Marketing Initiative of the Australian Food and Beverage Industry to ‘address community concerns about inappropriate advertising’ to children.[74] The initiative was developed in collaboration with the Australian Association of National Advertisers (AANA) as part of the system of advertising and marketing self-regulation in Australia.[75] The initiative commenced on 1 January 2009. Monitoring of food and beverage advertising to children over a period of 12 months from the commencement of this initiative is to be undertaken through a study commissioned by the AFGC, to be repeated periodically.[75] The study’s aim is to measure the industry’s response, determine the nature of improvements in performance and to report on the findings.
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The initiative is voluntary: 15 member organisations of the AFGC were signed up as of 4 June 200914 . The core principles to which participating companies must commit include:[75]
  • Participants will not advertise food and beverage products to children under 12 in media unless the products represent healthy dietary choices, consistent with established scientific or Australian Government standards; AND the advertising and/or marketing communication activities reference, or are in the context of, a healthy lifestyle, designed to appeal to the intended audience through messaging that encourages good dietary habits (consistent with established scientific or government criteria) and physical activity.
  • Other core principles relate to the use of popular personalities and licensed characters; product placement; use of products in interactive games; advertising in schools; and the use of premium offers.
Limitations of the initiative include:[75]
  • Its voluntary nature.
  • The lack of specific nutrient criteria to define healthy dietary choice foods and beverages (products covered by the code are as defined by individual participating organisations, making monitoring difficult).
  • While sanctions, complaints and compliance systems are to be developed, including a public complaints program, there are no specified deterrents to ensure food companies will comply with the code.
  • The code does not cover food marketing on food companies’ own websites, only paid advertising on third-party websites.
  • Specific times/program types when the code applies are not specified, and are to be interpreted by individual companies. The AFGC has specified definitions for Advertising or Marketing Communications to Children (for example, as defined by the AANA Code for Advertising and Marketing Communications to Children – advertising or marketing communications which, having regard to the theme, visuals and language used, are directed primarily to children) and definitions for Media (television, radio, print, cinema and third-party internet sites where the audience is predominantly children and/or having regard to the theme, visuals and language used are directed primarily to children). However, in some of the participating company’s action plans, ‘targeting children under 12 years’ on television is defined to be when the majority of the audience is under 12 years, which is extremely rare.15

Australian Communications and Media Authority (ACMA) review of the Children’s Television Standards (CTS)

Since the original Technical Report which described the ACMA review of the CTS (which regulate the content of children’s programs and advertising during designated children’s viewing times on commercial free-to-air television) there has been no further update of the standards. The final CTS are expected to be gazetted in mid-2009.16

The Taskforce also considered a review commissioned by the Foundation for Advertising Research for Frontier Economics and produced in December 2008, which examined the evidence for the effectiveness of introducing advertising bans on the consumption of targeted foods and beverages, and potential impacts on obesity, as well as the implications of the implementation of a ban in Australia. This analysis concluded that unintended consequences from regulation (due to substitution of advertising to other types of media) and the need to have an agreed set of definitions for EDNP foods cast doubt over the effectiveness of any such regulation.[76]
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This review highlighted for the Taskforce the need for any regulatory approach to restrictions on advertising and marketing of EDNP foods to be carefully developed and implemented in a comprehensive manner.

13For example, see www.telegraph.co.uk/health/healthnews/3812954/Call-for-full-ban-on-junk-food-adverts-for-children-after-Ofcom-says-part-ban-is-working.html
14Companies sign up to the initiative as a minimum commitment and must publish individual Company Action Plans outlining how they will meet the initiative’s core principles. See AFGC website for Company Action Plans at www.afgc.org.au/index.cfm?id=771 (Accessed 4 June 200).
15For example, the Coca-Cola, Pepsico, Nestlé and Cereal Partners Worldwide commitments each define ‘targeting children under 12 years’ on television as an ACMA classified C or P program, or where predominantly or >50% of the audience is under 12 years. 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. While specific programs (on particular channels and particular days) may have predominantly children in their audience, this is a very limited occurrence. Reference 10.
16See www.acma.gov.au/WEB/STANDARD/pc=PC_310262.


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