CAP’s Consultation on Food and Soft Drink Advertising to Children, launched last week, is a bold move. The size of the document itself – nearly 60 pages – shows how seriously CAP have taken the issue of advertising’s role in childhood obesity. Open for responses until 17:00 on Friday 22 July 2016, the consultation is likely to receive a volume of reactions.
The consultation asks whether a distinction should be introduced for non-broadcast ads between food and soft drink products high in fat, salt or sugar (HFSS products) and non-HFSS products. Currently, that distinction is made only in respect of broadcast ads.
It proposes a new rule which would prohibit the placement of ads in media targeted at or likely to appeal particularly to children (U16s or U12s – to be decided). And it proposes changing one of the existing rules – which prohibits any food ads (except those for fresh fruit and vegetables) targeted at U12s from including promotions, licensed characters or celebrities popular with children – so that the rule will apply only to HFSS product ads, thereby enabling the promotion of ‘healthier’ food and drink products.
These changes are in addition to the rules which already apply across all non-broadcast media on the creative content of food and soft drink advertising. For example, advertising targeted at children under 16 must not:
- condone or encourage poor nutritional habits or an unhealthy lifestyle in children;
- disparage good dietary practice;
- promote consumption of a food purely to obtain a promotional offer; or
- encourage excessive consumption.
The central purpose of the proposed restrictions is to help protect the health and wellbeing of children, even though CAP considers that “no significant new evidence on non-broadcast advertising’s effect on children has emerged, which might present a clearly evidence-driven basis for regulatory change”.
So why consult?
Because of the public policy imperative to try to deal with the public health and economic impacts of obesity – a “multifactorial issue which demands action from a range of different stakeholders” – coupled with the way children interact with the commercial world now through their use of new media. CAP explains that even a very small, positive impact from new ad restrictions could equate to a meaningful mitigation of harm to children.
The effect on advertisers and agencies if the proposals are implemented will be significant, limiting the opportunities to promote HFSS products to children across all non-broadcast media. The proposals would effectively remove HFSS product ads from all forms of non-broadcast media directed at children or where children make up or are likely to make up more than 25% of the audience (“targeted at or likely to appeal particularly”).
Cap considers its proposals are proportionate and “strike the right balance” suggesting that the potential rule changes will help protect children while still allowing businesses to advertise their products responsibly.
What this consultation does show – like it or not – is that the self-regulatory system is able and willing to adapt to new pressures and that CAP is not afraid of taking bold decisions likely to provoke a significant reaction from the industry.
IPA members can access a guideline document that highlights the proposed changes and outlines the questions in the consultation
Last updated 19/05/2016