Responsible Marketing and Advertising to Children
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:
- 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
- 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% .
That’s why industry is also undertaking a wide range of health and wellbeing
initiatives, such as reformulating products, offering a choice of alternatives
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
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
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
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
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
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
Both codes include general rules that state advertising must be responsible,
must not mislead, or offend and specific rules that cover advertising to
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
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
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
- 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
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
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
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
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
their online communications so children recognise the commercial intent of
advertisements. (See CAP’s response to the review).
Further Detail on Industry Initiatives
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
the EU institutions for the food industry to use commercial communications to
support parents in making the right diet and lifestyle choices for their
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
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
- 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
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
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
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
1. Ofcom (2004) Children's food choices, parents' understanding and influence,
and the role of food promotions.
Last reviewed: 07 Mar 2017