Evaluating the Option of Self-Regulating Food Marketing to Young People

1. Evaluating the Option of Self-Regulating Food Marketing to Young People Corinna Hawkes Research Fellow International Food Policy Research Institute Washington DC

2. What is Self-Regulation of Advertising and Marketing Communications? • A system whereby industry actively participates in & is responsible for its own regulation • Led, funded & administered by the industries concerned, comprising (1) Code of practice governing the content of marketing campaigns; (2) Process for the establishment, review and application of the code of practice, usually in the form of a “self-regulatory organization” • Usually exists independently of government regulation, but may be mandated by government STRUCTURE OBJECTIVE • To promote advertising/MC that are legal, decent, honest & truthful, & do not exploit the credulity of children (consumer protection) • Thus promoting trust in advertising/MC among consumers & government • Thereby protecting advertising /MC from external regulation (protection of industry freedom) • So facilitating the proliferation of more & effective advertising/MC Diet, Physical Activity and Health – A European Platform for Action

3. Recent Developments in Self-Regulation of Food Marketing to Young People Countries with statutory and self-regulations specific to marketing food to children – changes April 2004-December 2006+ • Increasing worldwide, especially in Europe (faster than statutory regulation) • Shows industry concern, advantage of speed, responsiveness • But also shows efforts to deflect statutory regulation: growth in countries and techniques where with legislative threats (expect development in Asia, product placement) + Hawkes, C. Marketing Food to Children: Changes in the Global Regulatory Environment 2004-2006, forthcoming, WHO Diet, Physical Activity and Health – A European Platform for Action

4. Form of Self-Regulatory Codes (I)General codes concerned with content (follow ICC, CIAA) (almost all countries)e.g. food and drink advertising should not • Promote “excessive” consumption; • Undermine the importance of a healthy diet; • Undermine role of parents in providing nutritional advice; • Mislead children about the quality and value of the food (II) Codes that impose limited restrictions on participating companies (only three countries) • E.g. Spain, Netherlands, United States, no (or limit) characters popular with children; no product placement (III) Voluntary codes developed by individual food companies (several) • Content (general) & restrictions e.g. no advertising to children under age 12 • …but not strictly self-regulation, since they generally lack a process for the establishment, review and application of the code Diet, Physical Activity and Health – A European Platform for Action

5. How Well is Self-Regulation of Food Marketing to Young People Working? I • What is the evidence? Depends on how the effectiveness of self-regulation is defined, implemented and monitored?* 3 types: • 1) Monitoring through complaints:traditional approach • Child-targeted advertising not subject to much complaint; food advertising subject to relatively large number of complaints mainly on the basis they mislead consumers about the nature of the product (claims) (but most not upheld) • 2) Compliance monitoring:becoming more widespread • Europe: WFA/EASA, ICC Framework - 96.2% compliance • US: 97% compliance • Spain: pre-vetting (unusual) recommended that 12.5% (29) were withdrawn & 19.8% (46) modified *DG SANCO Green Paper “Promotion of Healthy Diets and Physical Activity” (p.8) Diet, Physical Activity and Health – A European Platform for Action

6. How Well is Self-Regulation of Food Marketing to Young People Working? II • So by these standards, self-regulation can work… • … but do not measure whether self-regulation is “working” as an adequate tool for limiting food marketing to young people?* For that, a third type of monitoring is needed • 3) Monitoring of whether substantially reducesextent and impact of food advertising and marketing communications+ • No evidence, and in fact would counter the aim of self-regulation – facilitate the proliferation of marketing communications, provided are legal, decent, honest, truthful • Concerned with restrictions, not content • Not just advertising, but all marketing communications *DG SANCO Green Paper “Promotion of Healthy Diets and Physical Activity” (p.8) + WHO EURO Obesity Charter Diet, Physical Activity and Health – A European Platform for Action

7. What are “satisfactory results” needed from self-regulation?* • If the result needed is legal, honest, decent and truthful, marketing, which does not exploit the credulity of children, nor directly promote excessive consumption etc, self-regulation can work • If the result needed is to limit the extent and impact of food marketing to young people, self-regulation cannot work, and statutory-regulation is needed (e.g. UK) *DG SANCO Green Paper “Promotion of Healthy Diets and Physical Activity” (p.8) Diet, Physical Activity and Health – A European Platform for Action

8. Thank you! Diet, Physical Activity and Health – A European Platform for Action