Responsible Marketing and Advertising to Children

Policy Position

Responsible Marketing and Advertising to Children

Policy Position

FDF members are committed to marketing their products in a responsible way. The UK food and drink industry and the wider advertising industry, have long shown this commitment through adherence to stringent codes of practice that exist at global, regional and national levels.

There are two advertising codes in use in the UK (one for broadcast advertising, one for non- broadcast advertising). Both codes include general rules that state advertising must be responsible, must not mislead, or offend and specific rules that cover advertising to children.

In relation to communications aimed at children, FDF members observe the following principles across all marketing channels, including company websites:

Communications should:

  • encourage healthy dietary habits and physical activity.

Communications should not:

  • take advantage of children's natural credulity and sense of loyalty.
  • make a direct appeal to children to buy advertised products.
  • encourage excessive consumption.
  • encourage children to eat or drink frequently throughout the day.
  • suggest confectionery or snacks should replace balanced meals.
  • ask them to persuade their parents / other adults to buy on their behalf (pester-power).
  • undermine parental authority.
  • imply children will be unpopular or disloyal if they don’t buy the product;

However, advertising restrictions alone will not solve the complex issue of obesity. For instance: Ofcom research shows that advertising has only a ‘modest direct effect’ on children’s food choice of approximately 2% [1].

That’s why industry is also undertaking a wide range of health and wellbeing initiatives, such as reformulating products, offering a choice of alternatives that are lower in fat, sugar or salt, providing clearer nutritional labelling on front of pack and promoting the importance of a balanced diet and healthy lifestyle.



Advertising Rules

The UK advertising industry is governed by strict codes of practice that are designed to protect consumers and create a level playing field for advertisers. Within these codes there are robust provisions relating to children. The codes are self-regulatory and cover all kinds of promotional communications. For both codes, a child is mainly defined as ‘anyone under 16’, although there are a small number of addition provisions for younger children.

The UK Code of Broadcast Advertising (BCAP Code) applies to the content and scheduling of television and radio advertisements. It also covers programme sponsorship credits on radio and television services but complaints about these are handled by Ofcom.

The UK Code of Non-broadcast Advertising, Sales Promotion and Direct Marketing (CAP Code) applies to advertisements across media including newspapers, magazines, billboards, posters, leaflets, mailings, e-mails, texts and on UK based company websites.

Both codes include general rules that state advertising must be responsible, must not mislead, or offend. Both codes also contain specific rules that apply to advertising of food and soft drink to children. Specifically, the advertising of products high in fat, salt or sugar (often referred to as ‘HFSS’) is not permitted in media of appeal to under 16, whether that be in and around children’s tv programs, on school buses, or on websites that may have a particular appeal to child audiences. A food or drink is defined as ‘HFSS’ or ‘non HFSS’ by using the UK nutrient profiling model.

The UK nutrient profiling model is currently under review, and a new model is not expected to be announced until the first quarter of 2019. CAP and BCAP will then consult on the usability, proportionality and credibility of the new model and how best to incorporate it into advertising codes. FDF has concerns about the newly proposed model - specifically that a free sugars criterion will make the model difficult to use, and that it would prevent the advertising of pure fruit juices and smoothies, most high fibre breakfast cereals and sweetened yogurts / fromage frais.


The Advertising Standards Authority (ASA) is the UK independent regulator for advertising across all media. ASA responds to complaints and proactively checks the media to take action against misleading, harmful or offensive advertisements, sales promotions and direct marketing. If ASA judges an advert to be in breach of the Codes, it must be withdrawn or amended and the advertiser must not use the approach again. Further information is available at ASA: About Regulation

Next Steps for Advertising Restrictions

In June 2018, the Government published Childhood obesity: a plan for action - Chapter 2. This sets a ‘national ambition to halve childhood obesity and significantly reduce the gap between children from the most and least deprived areas by 2030’. The plan announces that by the end of 2018, Government will consult on a 9pm watershed on TV advertising of HFSS products, and similar protection for children viewing adverts online.

Also in June 2018, the Scottish Government (SG) published its obesity prevention plan – A Healthier Future. It contains the overarching ambition, mirrored by England, to half childhood obesity by 2030 and reduce health in; equalities. With respect to advertising, SG will

  • renew its call to Westminster to ban broadcast advertising of HFSS foods before 9pm watershed
  • renew its call to Westminster to work together on online advertising restrictions
  • calls on UK Government to restrict use of licensed characters, brand equity characters and celebrities on HFSS products
  • engage with local authorities, transport companies and media agencies to develop a code of practice in 2019 to restrict advertising of HFSS foods on sites they manage such as bus shelters, stations and inside buses and trains
  • request that the ASA strengthen the implementation of its CAP code by removing advertising of HFSS foods within a radius of 800m of any site with 25% or more footfall by under 16 year olds, including schools

Further Detail on Industry Initiatives

EU Pledge

The EU Pledge is a voluntary initiative by leading food and beverage companies to change the way they advertise to children. This is a response to calls made by the EU institutions for the food industry to use commercial communications to support parents in making the right diet and lifestyle choices for their children. It is independently monitored and had a high compliance rate.

Together, EU Pledge member companies account for over 80% of food and beverage advertising expenditure in the EU. The EU Pledge is endorsed and supported by the World Federation of Advertisers.

Independent data gathered across the EU in 2013 shows that since 2005:

  • children are exposed to 31% less ads for EU pledge products on TV across all programming.
  • children see 47% less ads for products that do not meet the pledge nutrition criteria and 82% less for products not meeting the criteria in and around children’s programmes.

Media Smart

Many companies in the UK support Media Smart, the media literacy initiative for UK primary school children.

Media Smart provides free educational materials to primary schools that help children to interpret, understand and use information provided in adverts to their benefit.

Media Smart is now recognised by many as a world-class media literacy programme. It is the only programme in Europe that brings together the resources of the industry, expertise of leading academics and the advice of the Government into one comprehensive national programme.


Last reviewed: 10 Oct 2018