ADVERTISING TO CHILDREN - AN UPDATE AND REFLECTION ON THE OFCOM RECOMMENDATIONS

This article by Rosemary Duff appeared in the September 2006 issues of Soft Drinks International.

Introduction

Manufacturers who wish to market successfully to children are facing a seemingly ever-increasing series of obstacles and pitfalls.

Current concerns about health and obesity are causing changes in consumer behaviour and attitudes, with a growing interest in healthy food and drink alternatives, and less tolerance of products that fail to make the grade. This is particularly marked when we consider children.

There is now an established and powerful lobby whose aim is to improve young people’s diets. Children’s vulnerability and the potential for damage to their future health make them a particular cause for concern.

The restriction of junk food advertising to children, and in particular advertising on TV, has assumed a central prominence in the healthy eating campaign. Such a step has emotive appeal to the general public, presented as an obvious, easy and victim-free way to achieve results.

Other potentially more significant factors, which are implicated in children’s diet and health, are harder to address. For example, changing lifestyles, including less exercise and free play, changes in family eating habits and the growth in snacking and cafeteria style eating, and problems with the availability and cost of healthy alternatives.

Below, we look at the current position in the UK in relation to TV advertising, as set out in the Ofcom recommendations, plus the wider European context. We also consider the changing role of children’s media consumption, and the implications that this has for advertisers.

TV advertising to children – Ofcom recommendations

In March this year, Ofcom launched its consultation on food and drink advertising to children in the UK. Ofcom proposes a set of rules, drawn up by the Broadcasting Committee of Advertising Practice, to control the content of the advertising. These include:

- Celebrities and licensed characters must not be used in food and drink adverts targeted directly at children under 10
- Promotional offers in food and drink adverts must not be targeted at children under 10

Ofcom also set out three options designed to limit children’s exposure to advertising, over and above the new rules on content:

1. Timing restrictions on specific food and drink products – no HFSS (high in fat, sugar and salt) product advertising to be shown in children’s programming or other TV shows that particularly appeal to children up to 9 years old, also no sponsorship for such programmes by these brands.

2. Timing restrictions on all food and drink products – no food or drink advertising in, or sponsorship of, children’s programming or TV shows that particularly appeal to children up to 9 years old, apart from healthy eating campaigns supported or endorsed by the government

3. Volume based restrictions on all food and drink products – food and drink advertising and sponsorship to be limited at times when children are most likely to be watching, with a limit of 30 seconds per hour at peak child viewing time, 60 seconds per hour at family viewing time, and a complete ban during pre-school children’s programmes

The food and drink industry was also invited to propose an alternative package that would achieve broad support and which they believe would meet the objectives. Industry response to the consultation has been to put forward the Better Balance package. This proposes:

- an end to the use of cartoon characters, celebrities and collectibles in advertising directly targeted at children

- a ban on all branded food and drink advertising during children’s programming on terrestrial TV

- a limit of 30 seconds an hour for food and drink advertising on dedicated children’s channels.

This proposal covers all food and drink advertising, rather than just HFSS products, because the industry feels that the nutrient profiling model put forward by the Foods Standards Agency to define HFSS is neither accurate nor workable.

The four options are summarised in the table below

Table 1: Summary of options under consideration

	Option 1 – Timing restriction on HFSS	Option 2 – Timing restriction on all food and drink	Option 3 – Volume restriction on all food and drink	Option 4 – Industry proposal – Better Balance
Pre school programming	No ads or sponsorship for HFSS food / drink	No ads or sponsorship for any food or drink	No ads or sponsorship for any food or drink	No ads or sponsorship for any food or drink on mainstream channels, max. 30 seconds per hour on dedicated child channels
Children’s programming	No ads or sponsorship for HFSS food / drink	No ads or sponsorship for any food or drink	Ads / sponsorship for any food or drink limited to 30 seconds / hour *
Mainstream programmes with particular child appeal (up to 9)	No ads or sponsorship for HFSS food / drink	No ads or sponsorship for any food or drink	Ads / sponsorship for any food or drink limited to 60 seconds / hour **

* Time is defined as 6-9am, 3–6pm weekdays, 6am-1pm weekends
** Time is defined as 6-8pm weekdays, and 1-8pm weekends
For all options: No celebrities or licensed characters, and no promotional offers to under 10s, in relevant adverts

Ofcom was originally due to announce its final recommendation in October, but the introduction of this fourth option may delay this until the end of the year. Rules on content would take effect immediately, although this would not affect campaigns already under development, with a six months grace period. Rules on timings or volumes would come into force on 1 January 2007, with restrictions phased in over three years, in recognition of the impact on children’s channels.

European context

There have been a number of steps in other countries across Europe, including both legislation and self-regulation.

- Sweden and Norway have had bans on all advertising during children’s programmes, and on advertising targeted at under 12s, since 1991

- Ireland introduced a ban on TV ads for sweets and fast food in 2005, and also prohibits the use of celebrities and sports stars to promote junk foods to children

- In Greece, advertising bans for children are restricted to toys

- Portugal – self-regulatory code of good practice in commercial communication to children covers traditional media (TV and press), and also cinema, Internet, video games and telephone communications. This was released in September 2005 by the Portuguese Advertisers’ Association (APAN)

- Spain – self-regulatory code on food advertising to children (PAOS) came into force in September 2005

- France – mandatory display of nutritional warnings on all advertising of processed foods and sugary drinks, February 2006

In January this year, members of the Union of European Beverages Association (UNESDA) agreed a voluntary ban on advertising to children under 12. Members are also committed to stop direct commercial activity in primary schools, and to offer more low-calorie drinks.

Beyond TV

Restrictions in the UK are coming at a time in which children’s TV viewing is declining, whilst the Internet is assuming ever greater importance. Children aged 5-16 years claim to watch an average of 2.5 hours of TV per day, down from 2.7 hours a year previously, and 3.0 hours in 2001 (ChildWise Trends Report 2006).

The proportion of 7-16 year olds with access to the Internet at home has now reached 74%, up from 54% in 2001, using this on average almost four times per week, and spending an average of 1 hour 50 minutes on line (ChildWise Monitor Report 2005-06). Younger children are not far behind.

Many of the most popular websites for children are linked to TV – CBBC, Cartoon Network, and Nickelodeon, for example – whilst children look out for and enjoy sites connected with their favourite brands. There are concerns that marketing activity will migrate from TV to online, either as adverts or in other ways such as branded games, downloads, or areas of the site only accessible via a code which relates to a purchase. Some examples are listed below – all are designed to build brand awareness, whilst the acceptability of the product varies widely. This underlines the difficulties facing those who seek to set up an effective code of practice.

- McDonald’s branded version of MSN Messenger, containing adverts for special offers

- Branded fun activities, plus details of current premiums, on websites such as Burger King, Kellogg’s

- Drinks such as Panda Pops and Fruit Shoot have games to play, plus product details including nutrition and advice to parents

- Innocent – kids area complete with jokes and recipes, plus an Adult Alert button

The Food and Drink Advertising and Promotion Forum is looking at the role of other broadcast and non broadcast media in this context – New Media is one of the areas under examination, together with Radio, Press, Cinema, Sponsorship, Packaging and Point of Sale.

Conclusions

Regulation of UK TV advertising to children for food and drink will take effect over the next twelve months, with controls on content and screening. This will take its place alongside legislation and self-regulation already in place in other parts of Europe.

Because of the difficulties of defining junk food, restrictions may well apply to all food and drink advertising on TV directed towards young children, and not just to foods defined as high in fat, salt and sugar.

Children’s growing use of the Internet, from an ever younger age, makes this a popular alternative for manufacturers to promote their products – but there are serious risks that irresponsible marketing will bring equally tough regulation for this medium and for others.

The wider climate is moving towards a growing interest in healthier options, and children are not exempt from this. The success of products such as Innocent Smoothies for kids, and the way in which children’s soft drinks consumption has shifted from carbonates to water and fruit-based drinks, underlines the possibilities for healthy developments.

Promoting products to children requires an awareness of wider responsibilities. Manufacturers need to ensure that their messages support parents’ aspirations for their young children, rather than subverting these, whilst also creating a brand image that appeals directly to the child.

The Internet is likely to play an important role in promotion, but it is important that messages are checked to the same standard as for TV.

References:

Ofcom: Television advertising of food and drink products to children, 28 March 2006 – www.ofcom.org.uk

Food and Drink Federation Press Release, 5 July 2006 – www.fdf.org.uk

Advertising Education Forum – Latest News – September 2005, July 2006 – www.aeforum.org

UNESDA – contribution to the EU platform for action on diet, physical activity and health – www.unesda-cisda.org

www.burgerking.co.uk

www.kelloggs.co.uk

www.pandapops.com

www.fruitshoot.com

www.innocentkids.co.uk

Food and Drink Advertising and Promotion Forum – Department for Health – www.dh.gov.uk