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

Marketing Food to Children and Adolescents
commends this effort. At the same time, however, the Commission also encourages the CBBB
and participants to strengthen the core principles of the Initiative. For example, the pledges
should be extended to cover all forms of advertising to children – not just television, radio,
print, and Internet advertising. As discussed in Section III of this Report, food and beverage
companies use a broad spectrum of advertising and marketing to target children, and, to be fully
effective, the pledges should address all of those techniques. The current product packaging
exception to the character licensing commitment is significant given the widespread use of
licensed characters on packaging. 105 The product placement provision does not limit “free” or
unsolicited placements. Expanding the scope of the pledges would address these issues. In
addition, variations among the companies’ definitions of what constitutes advertising “directed
to children” create an uneven landscape among the participants and pose a challenge to
monitoring compliance with the pledges. Similar challenges are posed by the variations among
the nutritional criteria for “healthy dietary choices” that may be marketed to children. The
Commission encourages the CBBB and participants to work toward more consistency in these
standards.
There also appear to be some limitations on the scope of the pledges with regard to QSR
franchisees. Independently owned and operated franchises (as opposed to company-owned
franchises) engage in promotional activities that are addressed by the Initiative, including
television, radio, and in-school advertising. However, the independent franchises are not
necessarily bound by the corporation’s pledge. 106
re c o m m e n d a t I o n s :
•
•
The CBBB should closely monitor participating companies’ compliance with their
pledges.
The CBBB and participating companies should enhance the Initiative in the
following ways:
•
Expand the scope of “advertising to children” beyond advertising on television
and radio, in print media, and on the Internet, to encompass all advertising and
promotional techniques, including but not limited to: product packaging and
labeling; advertising preceding a movie shown in a movie theater or placed on a
video (DVD or VHS) or within a video game; promotional content transmitted
to personal computers and other digital or mobile devices; advertising displays
and promotions at the retail site; specialty or premium items distributed in
connection with the sale of a product; promotion or sponsorship of public
entertainment events; product placements; character licensing, toy co-branding
and cross-promotions; sponsorship of sports teams or individual athletes; wordof-mouth
and viral marketing; celebrity endorsements; and in-school marketing.
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