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Sustain Children's Food Campaign

Junk Food Marketing

Junk food marketing to children encourages children to choose unhealthy products and undermines healthy eating messages. 

Children need to be protected from such marketing by a 9pm watershed on TV advertising and similar controls on non-broadcast types of marketing, including websites, sponsorship and promotions.

What's the problem?

Junk food advertising and marketing works!  Children are constantly bombarded with junk food marketing, both through traditional forms of advertising such as television and billboards, along with new techniques such as internet, sponsorship and in-store promotion.  According to the Department of Health, £838million was spent on food and drink advertising in the UK in 2007. 

Britain consumes 51% of all the crisps and savoury snacks eaten in Europe. (Joanna Blythman (2006) Bad Food Britain.  How a nation ruined its appetite)


Why is this important?

Junk food marketing contradicts all the messages about healthy eating children receive, undermining their ability to choose better food and their parents' efforts to feed them healthily.  Given the crisis in children's diet, it is vitally important that children are persuaded to eat more healthily, not less healthily due to being bombarded by junk food advertising.

Studies by the Food Standards Agency and others into the effects of junk food marketing shows that it works directly by influencing children's food preferences, and also –more powerfully – indirectly by influencing what family and friends consider to be a 'normal' diet. 

Food advertising and marketing, which is almost always for unhealthy products, plays an important role in encouraging unhealthy eating habits in children, which are likely to continue into adulthood.  According to a report by Compass, 70% of three year olds recognise the McDonalds symbol but only half of them know their own surname.  In addition, some advertisers take advantage of children's fears, for example by implying that they will be more popular, sporty or happier if they consume the advertised products.  The use of sports stars to promote unhealthy products, such as Wayne Rooney's promotion for Coca-Cola, is a good example of this.

It has been proven that advertisements affect food choices at both brand and category level, so a Burger King burger advert is likely not only to make a person more likely to buy a branded Burger King burger over another brand, but also more likely to buy a burger per se.

We believe it is wrong to allow the food industry to undermine the efforts of parents who are trying hard to persuade children to change their eating habits by advertising unhealthy products for financial gain.

About half a billion pounds is spent on food advertising in Britain each year.  (Joanna Blythman (2006) Bad Food Britain.  How a nation ruined its appetite)


What's the solution?

TV advertising

Current regulations prevent the advertising of “less healthy” products during children's TV programming.  However, around 70 percent of the television that children watch is outside the hours of 'children's TV' that these rules cover, with research from Which? in 2007 finding that that 18 of the 20 most popular programmes watched by children under 16 will not be covered.  This is why the Children's Food Campaign wants to protect children from junk food advertising before the 9pm watershed. 

A 9pm watershed for junk food adverts will:

  • Protect children: This will eliminate over 80% of instances of kids watching junk food TV advertising.  The current rules only protect children from half this much advertising.
  • Support parents: It will also provide clarity on when junk food adverts will be shown, allowing parents to exercise responsibility over whether their kids see junk food adverts.  
  • Improve children's health: Even highly conservative estimates show that the health benefits from a 9pm watershed for junk food TV adverts will save the nation up to almost a billion pounds a year - at a cost to industry of  £130 million a year, and no cost to the government.

A series of surveys have demonstrated that the majority of parents are in favour of a protecting their children from junk food advertising:

  • A British Heart Foundation survey found that 68% of parents were in favour of pre-9pm junk food advertising restrictions, with only 7% against.
  • Which? found in 2006 that 79% of parents believe unhealthy foods should not be advertised during the times children are most likely to be watching television.

In addition, a number of key government and parliamentary figures have expressed support for extending the restrictions on junk food advertising to children, including Gordon Brown, Alan Johnson when he was Secretary of State for Health, Lord Darzi of Denham and Baroness Royall of Blaisdon.


'Non-broadcast' marketing

There are currently no legal restrictions on non-broadcast junk food marketing aimed at children.  This category includes marketing through sponsorship, packaging, text messaging and the internet.  This is a growing form of advertising aimed at children and its omission from statutory regulation is an enormous loophole exploited by unscrupulous food companies.

Since there is no evidence to suggest that non-broadcast advertising marketing which targets children is any less effective than broadcast, it is inconsistent to regulate advertising of unhealthy foods on television while ignoring non-broadcast marketing aimed at children.  Regulations governing broadcast and non-broadcast advertising of unhealthy food to children must be brought into line with each other.  Both must reflect the need to protect children from undue pressure to choose unhealthy food over healthy food.

Non-broadcast food marketing is currently subject only to voluntary codes owned, developed and enforced by advertisers, such as the Committee of Advertising Practice (CAP).  Because the funding for the Code's development and enforcement comes from the industry it is meant to regulate, the Code never strays far from industry's interests.
There are several criticisms of this self-regulatory regime:

  • It is primarily designed to ensure advertising is “legal, decent, honest and truthful” and not to protect and promote health.
  • The rules mostly cover only advertising in a traditional, narrow sense and ignore the wider range of techniques used to promote a product.
  • The wording is vague and inconsistent. 
  • Enforcement is weak and retrospective and depends on complaints from members of the public or civil society groups.

Public interest groups including Sustain have long made the case that our current system of regulating non-broadcast (i.e. not on television or radio) marketing of unhealthy food to children is not adequate.  In 2008 we published a report, Protecting children from junk food marketing, setting out our concerns and attempting to design a statutory system of regulation for non-broadcast food marketing that protects and promotes children's health.

Our report proposes a regulatory system based on the principle that individuals and organisations must not act in a way where the purpose or effect is to promote an unhealthy food product to individuals under the age of 16.  This should be a statutory system enshrined in law, not a voluntary industry code.  The proposed law prohibits all marketing whose purpose or effect is to promote unhealthy food to children.  This covers not only traditional advertising methods but anything that acts as advertising, such as promotional websites, text messages, in-store placements and so on. 

The report proposed a practical way of protecting children from junk food marketing based on international experience.  In addition to this, Consumers International and the International Obesity Task Force have proposed Recommendations for an International Code on Marketing of Foods and Non-Alcoholic Beverages to Children.

A survey by Which? Found that nearly 90% of cereals targeted at children were high in sugar (Felicity Lawrence (2008) Eat your heart out.  Why the food business is bad for the planet and your health)]


Progress so far

Rules have now been introduced that prevent the advertising of high fat, salt or sugar foods around programmes “of particular appeal to children”, making them amongst the toughest on the world.  In order to advertise their product during children's airtime or dedicated children's channels, food companies must now show Ofcom, the broadcasting regulator, that the product passes the Food Standards Agency's nutrient profile model, which give points for fat, salt and sugar.  If the score is too high, the product is not allowed to be advertised.

While other programmes that are watched by large numbers of children, such as Coronation Street or The X Factor, are exempt from the restrictions, this represents a positive first step, and acknowledges the particular susceptibility of children to the influences of advertising.  We continue to push for a 9pm watershed for junk food advertising, and for equal protection for children from non-broadcast marketing.

In February 2010, following hard campaigning by the Children's Food Campaign, the Government announced that, while product placement would be introduced for most product categories, it would not allow product placement of junk food in any UK-made television programmes.  This decision further embeds the nutrient profile model and is the first time that the UK Government has acknowledged that children need protection from junk food marketing in all their viewing, not just children's programmes.


What can I do?

  • Write to your MP and tell them that you believe that children have a right to be protected from junk food advertising.  Ask them to raise this issue in parliament and with their party.
  • Complain to the Advertising Standards Authority if you see examples of advertising that you feel breach the rules.


Frequently Asked Questions

Will restricting advertising mean that some TV companies will stop making children's television programmes?
According to Ofcom 2007 review, it is disinvestment, rather than advertising revenue, that is the main threat to children's programming:

“Investment in first-run original programming by the commercial public service broadcasters – ITV1, GMTV, Channel 4 and Five - has halved in real terms since 1998. While the commercial children's channels (like Disney Channel, Nickelodeon and Cartoon Network) commission some UK programming, this represents only 10 per cent of total investment in new programmes. This decline in investment reflects the increasingly unattractive economics of some types of children's programming for the commercial public service broadcasters, relative to other output.”

In any case, there is likely to be replacement of junk food advertisements with advertisements for healthier products, for which there is likely to be increasing demand, and also for other goods and services.

Why a 9pm watershed?
A 9pm watershed is the established mechanism for protecting children from unsuitable material, both content and advertising, when they are most likely to be watching.  In August 2007, a voluntary pre-watershed restriction on TV advertising and sponsorship for bookmakers, gaming websites and casinos was required by the Government under new arrangements for gambling advertising under the 2005 Gambling Act.  This sends a clear message to advertisers and the viewers is that where strong protection for children is required, a watershed restriction is an appropriate and proportionate response.

Without a 9pm watershed, there is a risk that advertisers might simply re-schedule advertising for unhealthy food to early evening slots when large numbers of children are watching, leading to the reduction in impacts gained in children's airtime being cancelled out by an increase in impacts during family viewing.

Surely the occasional junk food product is perfectly okay within a balanced diet?
The food and advertising industries continue to argue that all foods can be part of a healthy diet. For example, the Food and Drink Federation (the food industry trade body) notes, "Foods high in fat, salt and/or sugar are not harmful per se. Fat, salt and carbohydrates are essential macronutrients. It is the balance of them that is important. All foods can fit into a balanced diet, which involves appropriate intake of all nutrients over a period of days."[1]

This is tantamount to saying that all foods, however bad their nutritional quality, can fit into a balanced diet, provided that you hardly ever eat them. Unfortunately, children eat large amounts of junk food all too frequently.

Moreover, the case for "balance" is spurious. If people eat a diet of healthy foods - a wide range of fruit and vegetables, plenty of a variety of whole grain cereals, pulses, nuts and seeds, and (if they are not vegetarian or vegan) small amounts of fish, dairy products and meat - there is no need to "balance" this with junk food. If, however, children are eating unhealthy foods - and all the evidence shows that they are - then what "balancing" their diet means is eating less of them, and more healthy food. Yet the foods children should eat more of receive little or no promotion.


For more information

Read more about our successful campaign to stop product placement of junk food.

Read the Children's Food Campaign's response to Ofcom's 2006 consultation on options for restrictions on television advertising of food and drink products to children. Response to Ofcom

1. Food and Drink Federation Response to the Department of Health's Choosing Health Consultation, 9 June 2004.

Children's Food Campaign: Better food and food teaching for children in schools, and protection of children from junk food marketing are the aims of Sustain's high-profile Children's Food Campaign. We also want clear food labelling that can be understood by everyone, including children.

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