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Product Placement consultation sham slammed

Leading UK health and education groups, including National Union of Teachers, National Heart Forum, Association of Teachers and Lecturers and the Children’s Food Campaign have written to Culture Secretary Ben Bradshaw criticising the government’s arrangements for a consultation on product placement, which was announced last week.

The eight-week consultation period, which includes the Christmas period, breaches the government’s own Code of Practice on Consultation, which states that consultation should normally be a minimum of 12 weeks long, and that a longer consultation period should be considered when it takes place over holiday periods. 

Jackie Schneider, coordinator of the Children’s Food Campaign, which is leading a coalition of groups opposing product placement, said: “Why is the government failing to abide by its own guidelines? Is it because they want to rush the consultation over the festive season to try and get this through on the quiet? Maybe it’s because they know that nine out of ten of adults are against children being influenced by product placement.  Given how sneaky a form of marketing product placement is, maybe we shouldn’t be surprised that the consultation is being sneaked through too.

“We know that in the US, Coca-Cola is the biggest user of product placement.  Product placement in the UK will lead to our children being exposed to even more junk food marketing.  Children’s charities, parents’ organisations, doctors, alcohol concern groups and members of the public need a proper opportunity to voice their concerns about the proposed changes.” 

The health and education groups are calling on Culture Secretary Ben Bradshaw to extend the consultation for an additional six weeks to allow the public sufficient time to respond properly to the consultation.


For further information please contact the Children's Food Campaign

Notes to editors:

1. The letter is signed by:

2. The Children's Food Campaign works to improve children's health and well-being through better food - and food teaching - in schools, and protecting children from junk food marketing.  We are supported by over 300 national and local organisations and 12,000 members of the public.  The Children's Food Campaign is coordinated by Sustain: the alliance for better food and farming and is funded by the British Heart Foundation.  For more details see

3. The Children’s Food Campaign coordinates the “Protect children from product placement” campaign.  More information about the campaign and how to respond to the consultation are available at

4. Full details of the consultation are available at

5. The Government’s Code of Practice on Consultations is available at

6. A recent survey of 1,349 UK adults by Redshift Research found that 91%, do not think it is right to influence children with product placement.  See

7. In the US, Coca-Cola is the company paying for the most instances of product placement, with 2,990 instances in the first six months of 2008, more than 30% of all placements by the ten top brands. Link to PDF  

8.  The text of the letter is as follows:

Rt Hon Ben Bradshaw MP
Secretary of State for Culture Media and Sport
Department for Culture Media and Sport
2-4 Cockspur Street

13 November 2009

Dear Secretary of State,

We, the undersigned, are writing to express our concern at the arrangements for the recently published consultation on product placement on television.

We note that, despite your announcement on 16 September that you would be consulting on this issue “shortly”, it has taken until this week for the consultation to be published, and the public is now given only an eight week consultation period in which to respond.  This includes the Christmas and New Year holidays. 

We note that this contravenes the Government’s Code of Practice on Consultation, which states that
“Under normal circumstances, consultations should last for a minimum of 12 weeks. This
should be factored into project plans for policy development work.”  (Section 2.1)

It further states that: “If a consultation exercise is to take place over a period when consultees are less able to respond, e.g. over the summer or Christmas break…consideration should be given to the feasibility of allowing a longer period for the consultation.” (Section 2.2)

No reason has been given as to why it is necessary to have a shorter than twelve-week consultation period, nor has any account been taken of the festive period.

We can only conclude from this that the Government is intent on pushing through product placement without meaningful attempt to properly consult with the public on this issue. 

We urge you to extend the consultation by at least six weeks (to meet the guidance 12 weeks, taking into account the Christmas and New Year period), and look forward to hearing from you regarding this.

Yours sincerely,  

Christine Haigh and Jackie Schneider, Coordinator, Children’s Food Campaign
Christine Blower, General Secretary, National Union of Teachers
Dr. Mary Bousted, General Secretary, Association of Teachers and Lecturers
Jane Landon, Deputy Chief Executive, National Heart Forum
Jessica Mitchell, Director, The Food Commission
Patti Rundall, Policy Director, Baby Milk Action
Oliver Tickell, UK Campaign against trans fats in food
Prof Erik Millstone, Professor of Science Policy, University of Sussex
Andrew Dougall, Northern Ireland Chest Heart and Stroke
Dr Tam Fry, National Obesity Forum and the Child Growth Foundation