US White House Obesity Task Force reveals action plan on food marketing
On 11 May, First Lady Michelle Obama unveiled the Interagency Task Force action plan: Solving the Problem of Childhood Obesity Within a Generation.
The Task Force, established by a presidential Memorandum on 9 February, spent the past 90 days reviewing the research and consulting experts, as well as the broader public, to produce a set of recommended actions that, taken together, aim to put America on track to solving the problem of childhood obesity.
The report makes a number of recommendations focusing on the four priority areas identified in the presidential Memorandum, which also form the pillars of the First Lady’s Let’s Move! campaign:
(1) empowering parents and caregivers;
(2) providing healthy food in schools;
(3) improving access to healthy, affordable foods; and
(4) increasing physical activity
The Task Force will now develop a strategy for implementing this plan, working in partnership with the First Lady to engage stakeholders across society.
Under the pillar “empowering parents and caregivers”, the report analyses the issues of food marketing to children and sets out a set of recommendations for action. The fundamental objective is to “reduce marketing of unhealthy products to children”.
The Evidence
• Food marketing to children and adolescents is a big business. Children and adolescents are an important demographic for marketers.
• While a causal link between marketing and increasing childhood obesity rates has yet to be firmly established, research indicates that advertising can have a strong influence on children. Young children in particular have difficulty distinguishing between television programming content and advertising, or comprehending the purpose of advertising. Older children, and even adults, are influenced by advertising too.
• The marketing of food products can also be a powerful tool to drive the purchase of healthy products and to communicate important information about healthy eating choices. Key actors—from food and beverage companies, to restaurants, food retailers, trade associations, the media, government and others—all have an important role to play in creating a food marketing environment that supports, rather than undermines, the efforts of parents and other caregivers to encourage healthy eating among children and prevent obesity.
• Television advertising is the dominant form of marketing to both children and adolescents, compris-ing almost half of total youth-directed marketing expenditures according to the FTC. However, food and beverage companies utilize a full range of other marketing techniques including print, internet advertising (such as advergames), product packaging, in-school marketing, cross-promotions, prizes and contests, and the use of popular licensed characters that appeal to children and adolescents. Notably, many advertising campaigns are fully integrated, using common themes across multiple promotional platforms.
• The use of licensed characters to market foods to children is particularly effective and pervasive. Not surprisingly, food marketers’ use of licensed characters in cross promotions target¬ing children has increased in recent years. At the same time, the nutritional quality of the products promoted by these characters has decreased.
The US Pledge Initiative
• Since its implementation, the efficacy of the CFBAI’s efforts has been subject to debate. FTC’s 2008 report noted that the participating companies’ nutritional standards, as well as their definitions of “child-directed,” vary by company. Within certain guidelines, each company developed its own nutritional standards for what constitutes a “better for you” food or a “healthy dietary choice.” Moreover, the FTC criticized the program for applying these standards only to certain forms of advertising. It recom¬mended, among other things, that the CFBAI improve the quality and consistency of the nutritional standards and extend those standards to all advertising and promotional techniques, including product packaging and “point-of-sale” advertising (such as displays near a check-out counter).
• A recent study[Kunkel et al 2009: http://www.childrennow.org/uploads/documents/adstudy_2009.pdf.] analyzed the effectiveness of the CFBAI and found that it had not substantially shifted advertising for children toward healthier products. Using one measure of nutritional quality, the study determined that, in 2009, advertisements for healthy products accounted for a very small fraction of all advertising by participating companies, while most advertising promoted foods of low nutritional value. The study also found that companies participating in the CFBAI nearly doubled the use of licensed characters over the past four years, increasing from use in 8.8% of advertisements in 2005 to 15.2% in 2009. Roughly half of all advertisements with these characters are for foods in the lowest nutritional category. The CFBAI has criticized this study, and argues that its voluntary efforts have led to significant improvements in foods advertised to children.
• Some media and entertainment companies have adopted policies limiting the types of foods for which they will license their popular characters. In addition, one company has set nutritional standards for the food advertising it accepts on child- directed programming. However, not all companies with popular entertainment properties have instituted similar policies, and the ones that have often use varying guidelines.
• Concern about the ineffectiveness of industry self-regulation led Congress in 2009 to direct the forma¬tion of an Interagency Working Group on Food Marketed to Children (IWG). This group, comprised of representatives of the FTC, FDA, CDC, and USDA, was tasked with developing recommendations for uniform standards for foods marketed to children ages 17 and under, as well as the scope of media to which such standards should apply. The group released tentative voluntary standards in December 2009 and is expected to publish proposed standards in the Federal Register for public comment in the near future.
• An examination of the food and beverage industry’s efforts to voluntarily limit marketing to children suggests the following conditions are necessary for meaningful improvement to occur through industry-directed initiatives:
> Self-regulatory groups must adopt a uniform set of nutritional standards. Without clear, consistent standards, there can be no objective basis for comparing different food products or measuring progress. The freedom of the CFBAI members to define what constitutes a “better-for-you” food product has resulted in variations in the nutritional criteria used from one com¬pany to the next. The IWG’s forthcoming recommendations on standards should be helpful here. More generally, Federal agencies with expertise in this area should work with industry to establish consistent standards based on the Dietary Guidelines that can be easily understood by both consumers and industry.
> Any framework for voluntary reform must provide a level competitive playing field within the industry. If compliance results in significant competitive disadvantages to participat¬ing companies, long-term compliance becomes unsustainable. It is therefore critical to have broad participation by all companies that market food and beverage products to children. These efforts must be supported by cooperation from the major media companies that target child audiences. Media companies can directly control the type and volume of advertisements shown on their platforms. Accordingly, they can impose limits on advertising, regardless of advertisers’ participation in a voluntary scheme. Media companies’ use of uniform nutritional criteria would facilitate these efforts.
> To create a meaningful impact, self-regulation must apply to all forms of marketing across multiple platforms. The current voluntary guidelines allow extensive marketing of non-nutritious foods in a myriad of ways that target children.
> Effective voluntary reform will only occur if companies are presented with sufficient reasons to comply. The prospect of regulation or legislation has often served as a catalyst for driving meaningful reform in other industries and may do so in the context of food marketing as well.
The Role of Federal Regulation
• The FCC has some direct authority to regulate advertising on children’s television programs. The Children’s Television Act limits the amount of commercial matter aired during children’s program-ming to no more than 10.5 minutes per hour on weekends and no more than 12 minutes per hour on weekdays. The Children’s Television Act authorizes the FCC to review and evaluate the advertising duration limitations, and to modify them in accordance with the public interest based on demonstrated need.
• The FTC’s ability to regulate child-directed advertising is limited. While new or revised rules to limit advertising during children’s programming may be helpful or even necessary to fully address the childhood obesity epidemic, such efforts must carefully consider freedom of speech interests. Furthermore, even if efforts to limit marketing to children are successful, they would only provide a partial solution given that children are heavily exposed to advertising not specifically directed to them. For example, half of the food advertisements children see on television occur on prime-time and other non-child directed programs. In addition, children are increasingly exposed to many forms of marketing other than television advertising, including billboards, point-of-purchase displays, and content accessed through the Internet, mobile phones, and MP3 players.
Recommendations
The Federal government can play a crucial role in improving the media environment for children with respect to the marketing of foods and beverages. It can do so while fully respecting the First Amendment right to free speech. Generally, this role includes:
••Bringing together key stakeholders to develop collaborative solutions;
••Providing guidance to industry on voluntary initiatives;
••Conducting consumer education and outreach campaigns; and
••Promulgating laws and regulations when other methods prove insufficient.
Recommendation 2.5: The food and beverage industry should extend its self-regulatory program to cover all forms of marketing to children, and food retailers should avoid in-store marketing that promotes unhealthy products to children. Currently, the CFBAI guidelines limit only certain types of child-directed advertising—including television, print, radio, and Internet—but do not apply to in-store advertising, product packaging, and many other forms of marketing. For truly meaningful and effective self-regulation, all forms of child-directed marketing should be covered. Retailers have an important role to play in this effort as well, since they control what products are placed at children’s eye level and can impact in-store advertising, including at the point-of-sale.
Recommendation 2.6: All media and entertainment companies should limit the licensing of their popular characters to food and beverage products that are healthy and consistent with science-based nutrition standards.
Recommendation 2.7: The food and beverage industry and the media and entertainment industry should jointly adopt meaningful, uniform nutrition standards for marketing food and beverages to children, as well as a uniform standard for what constitutes marketing to children. All nutrition standards should be based on the Dietary Guidelines. As part of this effort, the food and beverage industry should develop aggressive targets and metrics for increasing the proportion of advertisements for healthy foods and beverages across all marketing channels and platforms. The media and entertain¬ment industry should develop uniform guidelines to ensure that a higher proportion of advertisements shown on their networks and platforms are for healthy foods and beverages.
Recommendation 2.8: Industry should provide technology to help consumers distinguish between advertisements for healthy and unhealthy foods and to limit their children’s exposure to unhealthy food advertisements. The food and beverage industry and the media and entertainment industry should create an on-air labeling system that helps consumers easily distinguish between advertising for healthy and unhealthy foods. The FCC could also urge these industries to create innovative technolo¬gies that allow parents to block unhealthy food and beverage advertising from all programming. The nutritional standards should be uniform and based on the Dietary Guidelines.
Recommendation 2.9: If voluntary efforts to limit the marketing of less healthy foods and beverages to children do not yield substantial results, the FCC could consider revisiting and modernizing rules on commercial time during children’s programming.
Benchmarks of Success
A substantial yearly increase in the proportion of healthy food and beverage advertisements targeting children such that, within three years, the majority of food and beverage advertisements directed to children promote healthy foods.
A substantial yearly decrease in the use of licensed characters to promote foods and beverages that are not healthy such that, within three years, licensed characters are used only to promote healthy foods and beverages.
To measure progress, data-driven studies are needed to evaluate the nutritional content of foods advertised to children. The FTC’s follow up study, expected in 2011, will explore this issue, as well as shifts in consumption that have occurred following the implementation of industry self-regulation. It is critical to monitor and evaluate progress to support marketing efforts that reduce childhood obesity. If industries and government begin implementing recommendations immediately, meaningful progress could be achieved in three years.