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.

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Background

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. There are specific TV scheduling rules that apply to food and soft drink – (i.e. only food and drink that are not high in fat, salt and sugars are allowed to be advertised in and around programs of appeal to children). These foods are defined by the Food Standards Agency (see The nutrient profiling model - Publications - GOV.UK).

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 and specific rules that cover advertising to children.

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

Aligning CAP and BCAP Codes to restrict HFSS Adverting to Children

In December 2016, the Committee on Advertising Practice announced new rules aligning the CAP and BCAP codes. Specifically, the new rules ban the advertising of foods high in fat, salt or sugar in media targeted at under 16s. The rules will apply across all non-broadcast media, including in print, cinema and online (including social media and advergames). A regulatory statement and associated annexes are available on the CAP website.

The rules will come into effect on 1 July 2017. In summary:

  • Ads that directly or indirectly promote an HFSS product cannot appear in children’s media
  • Ads for HFSS products cannot appear in other media where children make up over 25% of the audience.
  • Ads for HFSS products will not be allowed to use promotions, licensed characters and celebrities popular with children; instead, advertisers may now use those techniques to better promote healthier options.
  • The Ofcom / Department of Health nutrient profiling model will be used to classify which products are HFSS.

On brand advertising, CAP has published new joint guidance with the Broadcast Committee on Advertising Practice. The guidance builds on that originally developed by BCAP and addresses the fact that HFSS products might also be promoted indirectly through branding synonymous with a HFSS product.

CAP and ASA Review on Online Marketing to Children

Independent research into online marketing of food and drink to children was published in February 2015. The literature review was commissioned by the Committee of Advertising Practice (CAP) and Advertising Standards Authority (ASA) and gives a picture of the scope and effect of online marketing practices.

The literature review was conducted by independent consultancy ‘Family Kids & Youth’. It found that the extent and quality of the evidence base around the impact of online food and drink marketing to children is limited. From the available evidence, the reviews main findings are:

  • Products high in fat, salt and sugar are advertised via digital methods, and children have access to these methods. However there is a little information about impact of exposure on behaviour.
  • Advergames can influence brand awareness and short term food preference after playing. However, there is a lack of evidence to show long term effects of advergames on eating habits or indeed how many children play them.
  • Children are more likely to choose a branded snack featured in an advergame over a healthier snack directly after playing a game. Similar studies using games based on healthy snacks are inconclusive.
  • Children’s ability to understand advertising content online appears to happen later than with TV advertising due to its integrated and entertaining nature.

In response to the review, CAP has concluded that current advertising rules are providing the right level of protection for children. However, CAP will be taking action in a number of areas; one of which is asking advertisers to review their online communications so children recognise the commercial intent of their advertisements. (See CAP’s response to the review).

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.

Children's Ethical Communications Kit (CHECK)

Getting marketing right with children can be difficult. With different regulations covering different aspects of the commercial world, it can be hard to keep up with which rules apply where. Check is a practical website with all the regulations, for every marketing and communications technique, simply explained and in one place.

Notes
1. Ofcom (2004) Children's food choices, parents' understanding and influence, and the role of food promotions.

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Last reviewed: 26 Jun 2017