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

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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. 64
• • • • • Assessment of Food Company Health Initiatives and Recommendations Require that 100% of food advertising directed to children under 12 promotes healthy dietary choices. • In cases where a product line contains some product varieties that meet a company’s nutrition criteria for a “healthy dietary choice” and others that do not, the company should strictly limit all components of a promotion or advertising campaign directed to children under 12 to those varieties that meet the criteria. Thus, for example, television or print advertisements promoting a sweepstakes would feature only the varieties of the product that represent healthy dietary choices, and licensed characters would appear only on packages of the varieties that are healthy dietary choices. Work toward standardizing the nutrition criteria for “healthy dietary choices” that may be marketed to children, such as by product category (e.g., for beverages, cereals, snack foods, soups, canned pastas, and frozen entrees). • In applicable cases, companies should re-examine whether the fact that a product has “less” of, or is “reduced” in, calories or certain nutrients (e.g., sodium, sugar, or fat) is, by itself, a sufficient basis for qualifying as a “healthy dietary choice.” Work toward developing meaningful, standardized definitions for what constitutes advertising “directed to children under 12.” In considering how to define “directed to children,” the CBBB and participating companies should consider, where relevant to the advertising medium, factors such as the percentage of the audience under 12; the total number of children reached; the time of day and venue in which the advertising appears; and whether the advertising features characters, performers, or celebrities who are popular with children, or contains themes, language, or other attributes designed to appeal to children. Require companies not to engage in, approve, or allow placement of their product in media directed to children under 12. Require participating companies to ensure that their franchisees are bound by the companies’ pledge commitments, such as by incorporating the pledge commitments into any franchisee contracts. 2. “Better for You” products As noted above, one of the recommendations from the 2006 Report encouraged companies to offer more products that are lower in calories and more nutritious. Since January 2006, many of the reporting companies have heeded the call by developing new or reformulated products designed to provide more nutritious – or “better for you” – options to consumers, including products marketed to children and adolescents. 107 For example, companies have improved the nutritional profiles of existing products by reducing calories, saturated and trans fats, sugar, and sodium, and/or by adding “positive” nutrients such as important vitamins and minerals, whole grains, and other fortifying ingredients. 65
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