"Interactive Food & Beverage Marketing" (PDF)

Adolescents may be
even more at risk of
consuming a “highcalorie,
low-nutrient”
diet than younger
children.
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Interactive Food & Beverage Marketing | Creating a Healthy Media Environment for the 21st Century
The government is spearheading a number of initiatives aimed at addressing
the role of food marketing in children’s heath. The Federal Trade Commission is in the
midst of completing an inquiry as a follow-up to its 2005 workshop on “Marketing, Self-
Regulation, and Childhood Obesity,” jointly sponsored by the Department of Health and
Human Services. 283 The FTC is expected to ask a number of food and beverage and
quick-service restaurant companies to provide data about their marketing practices, and
will be reporting back to Congress. 284 The Federal Communications Commission’s Task
Force on Media and Childhood Obesity, whose members include Senator Sam Brownback
(R-Texas) and other lawmakers, the chairman of the FCC and two of its commissioners, as
well as representatives of food companies, advertising groups, and nonprofit organizations,
will be issuing its recommendations within the next few months. 285 The emphasis
at both of these regulatory agencies is on encouraging better self-policing by the industry,
rather than on proposing new government rules to guide food marketing. (The FCC has
instituted some new rules to govern children’s advertising in digital broadcasting, but
none specifically addresses food products.) 286
The recent industry self-regulatory efforts are an indication of how seriously food
and advertising corporations view the problem. But while they are steps in the right direction,
they are not enough. The members of the Children’s Food and Beverage Advertising
Initiative, which account for an estimated two-thirds of children’s food and beverage television
advertising expenditures, has promised to
devote at least half their advertising directed to children on television,
radio, print and Internet to promote healthier dietary choices and/or to
messages that encourage good nutrition or healthy lifestyles; limit
products shown in interactive games to healthier dietary choices, or
incorporate healthy lifestyles messages into games; not advertise food
and beverage products in elementary schools; not engage in food and
beverage product placement in editorial and entertainment content;
reduce the use of third-party licensed characters in advertising that
does not meet the initiative’s product or messaging criteria. 287
How these commitments will translate into changes in business practices, however,
is not yet clear. The revised Children’s Advertising Review Unit guidelines do include
some provisions related to interactive marketing, but they are very narrow. For example,
they stipulate that advertising “should not be presented in a manner that blurs the distinction
between advertising and program/editorial content in ways that would be misleading
to children.” And on “websites directed to children, if an advertiser integrates an
advertisement into the content of a game or activity, then the advertiser should make