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Marketing Food to Children and Adolescents - Federal Trade ...

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<strong>Food</strong> <strong>Marketing</strong> Activities Directed <strong>to</strong> <strong>Children</strong> <strong>and</strong> <strong>Adolescents</strong><br />

III. <strong>Food</strong> <strong>Marketing</strong> Activities Directed <strong>to</strong><br />

<strong>Children</strong> <strong>and</strong> <strong>Adolescents</strong><br />

A. Introduction<br />

In response <strong>to</strong> the Special Order, the Commission received thous<strong>and</strong>s of samples <strong>and</strong><br />

descriptions of advertising <strong>and</strong> promotional activities from the 44 target companies. These<br />

samples covered the entire spectrum of advertising <strong>and</strong> promotional categories covered by<br />

the Special Order: television, radio, <strong>and</strong> print advertising; company-sponsored websites, ads<br />

on third-party Internet sites, <strong>and</strong> other digital advertising, such as email <strong>and</strong> text messaging;<br />

packaging, labeling, point-of-purchase displays <strong>and</strong> other in-s<strong>to</strong>re marketing <strong>to</strong>ols; advertising<br />

<strong>and</strong> product placement in movies, videos, <strong>and</strong> video games; premium distribution, contests, <strong>and</strong><br />

sweepstakes; cross-promotions <strong>and</strong> celebrity endorsements; marketing activities in schools;<br />

viral <strong>and</strong> word-of-mouth marketing; sponsorship of events, sports teams, <strong>and</strong> athletes; <strong>and</strong><br />

philanthropic activity tied <strong>to</strong> br<strong>and</strong>ing opportunities.<br />

The companies provided samples for those activities for which they had reportable<br />

expenditures, as discussed in Section II, as well as for activities that met the Commission’s<br />

criteria for marketing directed <strong>to</strong> children <strong>and</strong> adolescents but for which there were no reportable<br />

expenditures. In some cases, particularly for new media such as the Internet, promotional<br />

activities may have required little or no financial investment in order <strong>to</strong> reach the intended<br />

audience.<br />

Broadly speaking, nearly every food product category engaged the full spectrum of<br />

advertising <strong>and</strong> promotional activity formats. One exception was the fruits <strong>and</strong> vegetables<br />

product category, which tended not <strong>to</strong> use the traditional media of television, radio, <strong>and</strong> print.<br />

Fruit <strong>and</strong> vegetable companies did, however, use licensed characters <strong>and</strong> marketed them in<br />

much the same way as other food <strong>and</strong> beverage companies: via company websites, in-s<strong>to</strong>re<br />

displays, <strong>and</strong> product packaging. Third-party licensed characters <strong>and</strong> company proprietary<br />

“spokescharacters” – animated versions of animals, people, or even the food itself – were used<br />

heavily in marketing <strong>to</strong> children, but also were used <strong>to</strong> reach teens. Celebrity endorsers, on the<br />

other h<strong>and</strong>, were almost exclusively employed in advertising directed <strong>to</strong> teens <strong>and</strong> “tweens”<br />

(those between the ages of 8 or 9 <strong>and</strong> 13 or 14). For the most part, other promotional activities<br />

reported were used <strong>to</strong> reach both children <strong>and</strong> teens. 55<br />

The responses <strong>to</strong> the Special Order show that product marketing campaigns directed <strong>to</strong><br />

youth typically are fully integrated: a child might first see an ad on television for a food product;<br />

27

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