it pays to advertise: junk food marketing to kids
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Junk Food Marketing to Childre
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Food & Water Watch works to ensure the ood, waterand fsh we consume is sae, accessible and sustainable
So we can all enjoy and trust in what we eat and drink,
we help people take charge o where their ood comes
rom, keep clean, aordable, public tap water owing
reely to our homes, protect the environmental quality
o oceans, orce government to do its job protecting
citizens, and educate about the importance o keeping
shared resources under public control.
Food & Water Watch Caliornia Ofce
1616 P St. NW, Ste. 300 25 Stillman St., Ste. 200
Washington, DC20036 San Francisco, CA 94107
tel: (202) 683-2500 tel: (415) 293-9900
ax: (202) 683-2501 ax: (415) 293-8394
[email protected] [email protected]
www.oodandwaterwatch.org
Copyright November 2012 by Food & Water Watch.
All rights reserved.
This report can be viewed or downloaded
at www.oodandwaterwatch.org.
About Food & Water Watch
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Execuive Summary. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2Inroducion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
Childhood Obesiy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
Youh Exposure o Food and Beverage Adverising . . . . . . . . . . . . . . . . . . . . . . . . . . 5
Adverising Conen . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
Television Advertising. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
Online Advertising. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
Impac o Adverising on Childrens Dies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
Do Children and Adolescents Understand Food Advertisings Intent?. . . . . . . . . 10
Regulaion o Food Markeing o Youh . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
Federal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
Local and State. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
Indusry Sel-Regulaion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
Childrens Food and Beverage Advertising Initiative. . . . . . . . . . . . . . . . . . . . . . . 13
Evaluating the Childrens Food and Beverage Advertising Initiative . . . . . . . . . . 14
Improving Industry Self-Regulation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
Inernaional Regulaion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
Recommendaions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
Endnoes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
Junk Food Marketing to Children
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Executive Summary
Food markeing is pervasive in he lives o children and
adolescens. Food and beverage companies spen $1.6
billion in 2006 o reach his imporan marke.1 On elevi-
sion, online and even in schools, youh are regularlyexposed o messages encouraging hem o ea unhealhy
oods, a a ime when hey need o esablish healhy eaing
habis. One in hree American children and adolescens
is overweigh or obese, condiions ha conribue o poor
healh over heir whole lieimes.2 Resricing unhealhy
ood markeing o youh is one imporan sep in
addressing his crisis.
Television adverisemens aimed a children predomi-
naely eaure unhealhy oods, ofen served in unhealhy
setings. A die composed o oods markeed o children
on elevision would consis mainly o cereal, as ood and
snacks eaen ouside o normal mealimes in large serv-
ings. Ouside o elevision, he Inerne oers ood compa-
nies he chance o engage youh in games and aciviies
ocused on heir brands. Online adverising provides
companies wih a much cheaper mehod or youh o
spend longer periods o ime exposed o adverising or he
same unhealhy producs seen on elevision.3
Food adverising on elevision impacs childrens preer-
ences or paricular caegories and brands o ood,4
increases heir requess o parens or he adverised oods
and leads o increased consumpion o unhealhy oods. 6 In
one sudy, children ae more snacks while waching showswih ood adverisemens, wheher or no hey repored
eeling hungry.7
Research on media lieracy indicaes ha i akes repeaed
menal eor o resis adverisemens or emping
oods. Because youh are exposed o so many markeing
messages and because even older children need promping
o hink criically abou adverisemens, i is hard o argue
ha youh can consisenly igh o hese messages on
heir own.8
The Federal Trade Commission (FTC) considered rule-making in he lae 1970s o limi markeing sugary oods
o children, bu Congress pu a sop o i. In response
o renewed atenion o childhood obesiy, several ood
companies have chosen o sel-regulae under he Chil-
drens Food and Beverage Adverising Iniiaive (CFBAI),
bu acual reducions in unhealhy oods markeed o
youh have been quie limied.
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The ederal governmen in 2011 issued preliminary, volun-
ary Principles o recommend a consisen nuriion san-
dard or indusry sel-regulaion. The ood indusry heavily
criicized he Principles as oo sric and burdensome,
even hough, i enaced, hey would have been enirely
volunary. Some o he very companies paricipaing in he
sel-regulaory eors lobbied o weaken he Principles,9
and ulimaely Congress blocked he proposal, leaving no
signiican ederal regulaion or even guidance on oodmarkeing o children.10
The public healh challenge o increasing childhood obesiy
mus be addressed. Improving he nuriional environmen
or youh will require many policy changes. Is ime o ask
he quesion: Is i appropriae o adverise unhealhy oods
o children and adolescens? While he FTCs proposed
volunary Principles oered a srong se o guidelines, his
volunary proposal should no be he exen o he debae.
Broader resricions are necessary o proec youh rom
he inluence o ood and beverage markeing.
Speciically, Food & Waer Wach recommends ha:
The FTC should be able o regulae any unair or
decepive markeing, bu Congress has limied he
FTCs auhoriy o resric markeing o youh.
Congress should provide he FTC wih he ull
auhoriy o regulae ood and beverage markeing.
Congress should also give he FTC he auhoriy o
creae mandaory nuriion sandards or ood and
beverages markeed o youh.
The FTC should coninue is monioring o indusry
spending and sel-regulaory eors in ood markeing
o youh.
Food and beverage companies should reduce adver-
ising o unhealhy oods and beverages o children
and reormulae producs o make hem healhier.
The U.S. Deparmen o Agriculure should issue
srong nuriion sandards or compeiive oods sold in
schools as sipulaed in he Healhy, Hunger-Free Kids
Ac o 2010.
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Introduction
Food markeing is pervasive in he lives o children and
adolescens.a On elevision, online and even in schools,
youh are regularly exposed o messages encouraging hem
o ea unhealhy oods. These oods are ull o sal, sugar
and a, a riumvirae o addiives ha rigger he brains
pleasure ceners and encourage eaing more.11 Children andadolescens are quie vulnerable o markeing o unhealhy
oods a a ime when i is imporan o be developing
healhy eaing habis. The physical damage o a poor die
in youh can aec healh over a lieime.
Food and beverage companies in he Unied Saes spen
$1.6 billion in 2006 on markeing o youh12 o capure he
more han $100 billion in ood purchases (including hal o
all cereal purchases) ha children inluence every year.13
Adolescens hemselves wield an annual purchasing power
o $80 billion.14 Beween 1994 and 2004, ood companies
inroduced more new ood producs aimed a youh han
hose argeing he general populaion.15 Parens and
healh providers have a hard ime compeing wih hese
pervasive, persisen messages. I is hard o imagine a
public healh campaign o promoe healhy eaing wih
anyhing close o he resources he ood indusry possesses
o adverise is producs.16
Currenly, he U.S. governmen does no have any nuriion
sandards or he oods markeed o children, alhough a
volunary sandard was proposed and rejeced, nor does
he governmen resric ood markeing direced a youh.Wih increased public atenion ocused on obesiy among
youh, he ood indusry has begun some sel-regulaion,
wih companies volunarily pledging o limi adverising
o he unhealhies oods o children under 12. The bulk o
oods adverised o youh sill ail o mee he sandards o
a healhy die. I is ime or he governmen o sep in and
limi ood markeing o youh.
Childhood Obesity
In he las 30 years, he percenage o overweigh and
obese children in he Unied Saes has ripled.17 One in
hree American youh is overweigh or obese.18 Nearly 17
percen o children and adolescens aged 2 o 19 years
more han 9 million American youh19 are obese. Obesiy
is lower among children aged 2 o 5, a 10 percen, andcloser o 20 percen or youh aged 6 o 19.20 Trends in
childhood overweigh are similar, wih nearly 14 percen
o children aged 2 o 5, 19 percen o children aged 6 o 11,
and 17 percen o adolescens acing overweigh.21
Childhood obesiy sresses childrens bodies, causing
derimenal eecs in he shor and long erm. Obese
youh ace a higher likelihood o high blood pressure, high
choleserol, ype 2 diabees, breahing problems (such as
sleep apnea), join aches and digesive problems (such as
gallsones and relux). The prevalence o ype 2 diabees,
ormerly known as adul-onse, has doubled among
youh in he las 10 years.22
In addiion o hese physical problems, obese youh
can experience social discriminaion and psychological
disress. All o hese healh problems pose a huge burden
or children and adolescens, direcing energy away rom
he normal asks o learning and growing up. Overweigh
and obese children are likely o coninue o ace signiican
healh problems as aduls, including obesiy, hear disease,
diabees and some ypes o cancer.23
Ofen people wih hese condiions are blamed or having
poor sel-conrol or overeaing. In he case o children, i
is ofen he parens who are blamed.24 Ye he dramaic
increases in childhood obesiy and overweigh poin o
causes ha occur across he populaion, as opposed o
individual ailures.25 One imporan acor, as noed by
he Ceners or Disease Conrol (CDC) and ohers, is he
markeing o less-healhy oods o youh.26
a For the purposes of this report, child refers to ages 2 to 11, adolescent to ages 12 to 17 and youth to ages 2 to 17.
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Food markeing compounds oher acors ha conribue
o childhood obesiy and overweigh.27 Foods high in sugar,
sal and a rigger pleasurable responses in he brain
ha make people wan o ea more o hem.28 Since 1970,
overall caloric inake among Americans has increased by
16 percen, or more han 500 calories per day. 29 Youh ages
2 o 18 drink more han wice as much soda and one-
hird less milk han hey did in he lae 1970s.30 A recen
U.S. Deparmen o Agriculure (USDA) repor ound anassociaion beween ood prices and childrens body mass
index (BMI), a measure o overweigh, such ha childrens
BMI increased when less-healhy oods were cheaper and
decreased when healhy oods were cheaper.31
Low-income consumers in paricular lack access o healhy
oods. Several sudies o low-income peoples purchasing
habis show an associaion beween lack o access o
supermarkes and ewer purchases o healhy oods.32
Lower soda prices are associaed wih higher BMI in
children, especially i heir household makes less han 200percen o he ederal povery line.33
Foureen percen o low-income preschoolers are obese,
compared o he naional average o 10 percen. 34 And all
Americans are eaing more meals ouside he home, ofen
a as ood resaurans, which leads o higher caloric
inake in children.35
Obesiy and is relaed illnesses require muliple seps o
address, including beter nuriional lieracy, increased
access o healhy oods and increases in physical aciviy.
One logical irs sep is o sop promoing unhealhyoods o children and adolescens. Widespread markeing
campaigns leave millions o amilies wih a harder igh o
esablish healhy eaing habis in heir children.
Youth Exposure to Food
and Beverage Advertising
Todays youh spend many hours day and nigh in ron
o screens. The Naional Academies o Science repor ha
nearly every American child has a elevision in he house-
hold, and many children do no have resricions on how
much elevision hey are allowed o wach.36
According o a repor by he Kaiser Foundaion, young
peoples ineracion wih media is signiican and
increasing. The repor deines media broadly, including
ime spen waching elevision, using any kind o media via
cell phone, using he compuer and playing video games.
Uniquely, i measures muli-asking, recognizing ha
young people migh lisen o music rom heir phone while
suring he Inerne, or insance. In 2004, young people
ages 8 o 18 spen nearly 6.5 hours consuming 8.5 hours
o media conen a day, when including muli-asking.
By 2009, ha number had increased o 7.5 hours spen
consuming nearly 11 hours o conen.37
Tweny percen o media consumpion occurs on mobile
devices. On average, an hour and a hal o ime is spen
on he compuer or leisure. Eighy-our percen o 8 o 18year-olds have Inerne access a home; 33 percen have
Inerne access in heir bedrooms.38 Media use spikes
during he ween years o ages 11 o 14. Tweens consume
nearly 12 hours o media conen daily in jus under nine
hours, including ive hours o elevision and movie conen
and an hour and a hal o video games.39
Mos research on childrens exposure o markeing
analyzes elevision. The Federal Trade Commission (FTC)
compared childrens exposure o elevision adverising in
1977 and 2004. This rame o reerence is useul as he
signiican increases in childhood overweigh and obesiyare ofen daed rom he lae 1970s and early 1980s. The
FTC esimaes ha children under he age o 12 viewed
25,600 elevision adverisemens in 2004. Jus over 5,500 o
hose adverisemens were or ood, a 9 percen decrease
compared o he number o ood adverisemens in 1977.
This igure amouns o 15 ood adverisemens per day
and 38 hours o ood adverising per year.40 Cereals and
dessers were he mos common caegories o ood adver-
ised, ollowed by resauran and as ood and sweeened
drinks.41 In neiher 2004 nor 1977 did he array o oods
adverised o children in any way represen a balanced
die.42
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A 2010 sudy by he Rudd Cener or Food Policy and
Obesiy made similar indings abou youh exposure o
ood and beverage adverisemens on elevision. The sudy
ound ha children viewed an average o 13.4 elevision
ood adverisemens daily, and adolescens viewed an
average o 16.2, amouning o nearly 5,000 elevision ood
adverisemens or children annually and nearly 6,000
or adolescens. Fas ood adverisemens were he mos
commonly viewed, wih cereals, candy and non-as-oodresaurans among he oher op caegories.43
According o he FTC sudy, mos childrens elevision
adverising exposure occurred in he afernoons (26
percen) and evenings (29 percen), ar more han Saurday
mornings (4 percen), he sereoypical domain o young
childrens caroon shows.44 Children see he vas majoriy
o ood adverisemens on cable raher han broadcas
neworks.45 Hal o childrens elevision ood adverising
exposure comes rom childrens shows, in which children
are a leas 50 percen o he audience.46
Mos indusrysel-regulaory eors ocus only on childrens program-
ming, leaving aside he issue ha he oher hal o chil-
drens ood adverising exposure comes rom non-childrens
programming.47
When daa is no available on childrens acual exposure
o media, i is helpul o examine indusry expendiures on
dieren caegories o media. The FTC released a repor
o Congress, Marketing Food to Children and Adolescents:
A Review of Industry Expenditures, Activities, and Self-
Regulation, in 2008. Wih congressional backing, he FTC
required companies o submi daa abou heir adverising
pracices and spending. Food and beverage companies
repored o he FTC ha hey spen $1.6 billion markeing
ood o children in 2006.48 Nearly $750 million, or 46
percen, was spen on elevision adverising, wih hal
o ha spen on adverising direced o children younger
han 12.
New media, including websies, e-mail, ex messaging
and viral markeing, consiued only 5 percen o oal
spending in 2006, alhough ha money goes much urher
because hose orms o adverising are cheaper han elevi-
sion adverisemens. Two-hirds o companies repored
using some orm o online markeing. Approximaely
wo-hirds o oal spending ocused on hree caegories o
oods: soda, resauran and as ood, and cereal. Nearly
all o he markeing money or soda was aimed a adoles-cens, wih 24 percen o i spen on in-school markeing.
Companies spen $360 million on oys included in chil-
drens meals. Including oys, cross-promoions and TV
adverising, resauran companies spen jus over hal-a-
billion dollars markeing heir producs, wice he spending
o any oher ood caegory.49
Advertising Content
Television Advertising
Television adverisemens aimed a children predominanlyeaure unhealhy oods, ofen served in unhealhy setings.
A die composed o oods markeed o children on elevision
would consis mainly o cereal, as ood and snacks eaen
ouside o normal mealimes in large servings. For insance,
according o he FTC, 85 percen o cereal adverisemens
direced a children in 2004 were or highly sugared cereals. 5
These adverisemens use emoional appeals o porray
heir brands as un or cool. Adverisemens less requenly
address ase, qualiy or nuriion acual characerisics
o he ood isel. I almos goes wihou saying ha headverisemens do no address any negaive oucomes o
unhealhy eaing; i is assumed ha any one ood adverised
will be consumed in moderaion. The oaliy o adverising
exposure, however, represens nohing moderae a all.51
A 2005 sudy o commercials shown during Saurday
mornings ound ha hal o all he adverisemens were or
ood. The mos common ood adverised was cereal and
cereal bars (27 percen o ood adverisemens), ollowed by
resaurans and snack oods a nearly 20 percen each o
adverisemens. When evaluaed agains he U.S. Dieary
Guidelines, 91 percen o he oods adverised ailed in aleas one measure o nuriional qualiy, including high levels
o a, sodium or added sugars, or low levels o nuriens.52
Nearly 60 percen o he ood adverisemens porrayed
oods high in sugar.
While 78 percen o he oods adverised me basic guide-
lines or viamin and mineral conen, his was ypically
due o oriicaion. Only 7 percen o he adverisemens
porrayed oods wih a leas hal a serving o ruis or
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vegeables. Mos o he adverisemens (86 percen) used
emoional appeals o marke heir producs. Nearly hree-
quarers o he adverisemens included movie, caroon,
animaed, or cosumed characers, and a quarer included
menion o a giveaway wih purchase o he produc.53
Anoher 2005 sudy reviewed elevision adverisemens
aimed a children during programming hroughou he
week. As wih he previous sudy, he vas majoriy o oodsadverised (83 percen) were convenience oods and swees.
The oods ended o be high in a and sodium and low in
iber and some viamins and minerals. I was more common
o see oods depiced as snacks han as par o any oher
meal, and all he kids in he commercials were porrayed a
a healhy body weigh no mater wha hey were eaing.54
Mos adverisemens o children porray he oods as un,
an eecive appeal given childrens early developmenal
needs.55 An analysis o nearly 150 commercials shown in
childrens programming ound ha 85 percen associaed he
ood wih un or happiness, and nearly 60 percen associ-aed he ood wih play.56 Only 8 percen o adverisemens
represened he oods as healhy, wih nearly 20 percen o
cereal adverisemens using healh claims, and no as ood
resaurans doing so.57 Fas ood commercials ofen appeal
o peer accepance, an appeal also eecive or adolescens.58
Online Advertising
Whereas children passively wach elevision, he Inerne
oers ood companies he chance o engage children in
games and aciviies ocused on heir brands. Online
adverising provides companies wih a much cheaper
mehod or children and adolescens o spend longer
periods o ime exposed o adverising or he same
unhealhy producs seen on elevision.59
One common orm o online markeing is he advergame,
a video game based enirely on he ood brand ha blurs
he line beween program conen and adverising.60 The
games are ofen he same kind o simple, addicive game
you migh ind on your compuer or smarphone, bu
based around he brand wih a piece o cereal as he game
piece, or insance. Television commercials las on average30 seconds, so a game ha capures a childs atenion
or a ew minues o hal an hour represens a subsanial
period o brand exposure.61
Children use he Inerne rom a young age, mos
commonly o play games.62 Food companies websies
atrac hundreds o housands o children. Two o McDon-
alds major sies, HappyMeal.com and McWorld.com,
received 350,000 visiors under he age o 12 in February
2011.63 Two popular cereal websies, FrooLoops.com and
AppleJacks.com, received 216,000 and 175,000 unique visi-
ors under he age o 17 each monh in 2011.64
Sudies have ound ha he oods promoed on ood
company websies and advergames are primarily
unhealhy. In a sudy o 28 childrens websies, 49 o he 77
adverised ood producs me Insiue o Medicine (IOM)sandards o oods o avoid, while only ive me he san-
dards or oods o encourage.65 Anoher sudy o 130 major
ood and beverage websies ound ha nearly hal had
designaed childrens sies, 85 percen o which included
advergaming. The vas majoriy (87 percen) o oods and
beverages markeed in hose childrens sies were o low
nuriional qualiy.66
Only 15 percen o he 130 major websies sudied included
a parenal permission saemen, and 35 percen included
an ad break warning message, indicaing ha he sieswere adverising. Ad break warnings are considered good
pracice, as children canno always disinguish beween
programming and adverising conen.67 A sudy o ood
indusry websies adverised on he Caroon Nework and
Nickelodeon ound ha nearly all oods adverised were
high in sugar and a, wih resauran oods and ready-
o-ea oods comprising 42 percen and 32 percen o he
oods adverised.68 Jus over 80 percen o he websies
used advergaming o promoe heir producs.69
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Impact of Advertising
on Childrens Diets
The ubiquiy o unhealhy ood adverising in childrens
lives is undeniable. The ood indusry claims ha adver-
ising aecs only childrens brand preerences, bu
scieniic evidence indicaes ha adverising inluences
childrens eaing preerences and habis more broadly.70
Childrens exposure o healhy oods in heir early years
helps se he sage or healhy eaing, and parens play
a criical role in modeling and enorcing good habis a
home.71 Ye our brains are wired o preer oods high in
sugar, a and sal72 he very oods ypically markeed
o children and childrens peers and he media gain
increasing inluence on eaing habis in he ween and
eenage years. Some argue ha elevision viewing hurs
children because he aciviy is sedenary as opposed o
playul and acive, and cerainly higher elevision viewing
is associaed wih higher weigh.73 Bu sudies also indicae
ha i is he ood adverisemens hemselves ha nega-
ively impac childrens dieary preerences and consump-
ion, conribuing o he public healh crisis o childhood
obesiy.b
Viewing large amouns o elevision during childhood has
been associaed in muliple sudies wih unhealhy dieary
habis and high body mass indexes laer in lie.74 Alhough
many acors aec childrens dies and ood preer-
ences, several sudies have ound ha ood adverising
has a speciic eec separae rom hose acors.75 Foodadverising on elevision impacs childrens preerences or
paricular caegories and brands o ood76 and increases
heir requess o parens or he adverised oods.77 Addi-
ionally, ood adverising leads o increased consumpion
o unhealhy oods,78 including bu no limied o he oods
adverised.79
Two governmen repors urher deail he impac o ood
adverising on children. In 2006, he IOM released Food
Marketing to Children and Youth: Threat or Opportunity?,
which included a review o 123 scieniic sudies o ood
adverisings role in childrens lives. 80 The repor divided
is evidence base ino wo caegories: children (ages 2 o
11) and adolescens (ages 12 o 18). In he case o children,
srong evidence exiss ha elevision adverising impacs
childrens ood and beverage preerences, purchases,requess o heir parens and caregivers, and shor-erm
consumpion habis. Overall, he IOM repors, i can be
concluded ha elevision adverising inluences children o
preer and reques high-calorie and low-nurien oods and
beverages.81
There is moderae evidence ha adverising aecs he
usual, day-o-day eaing habis o 25 year-olds, and weak
evidence ha his is so or 611 year-olds.82 Wih adoles-
cens, he siuaion is less clear, in par because here is
less research on he opic. The IOM concluded ha hereis insuicien evidence o conclude ha ood adverising
impacs he ood and beverage preerences and purchase
requess o adolescens, alhough he research ha does
exis suggess ha here is an impac.83
For boh children and adolescens, here is a srong asso-
ciaion beween exposure o elevision adverising and
obesiy. Ye he available research does no suicienly rule
ou miigaing acors o deermine i exposure o elevi-
sion adverising causes childhood obesiy.84 High exposure
o elevision adverising correlaes wih high levels o
waching elevision, or insance, and quesions such as
how much elevision impacs exercise and snacking mus
be addressed more horoughly.85 The IOM noes ha even
i elevision adverising plays a small conribuing role
oward obesiy, reducing ha paricular impac across he
populaion would be signiican. 86
In he FTC repor, Marketing Food to Children and Adoles-
cents: A Review of Industry Expenditures, Activities, and Self-
Regulation, companies shared heir research abou wha
makes adverising work wih children. Speciically, children
like commercials ha ell a un, exciing sory and link owebsies wih games and prizes. Children like animaed
characers, wheher rom a popular TV show or movie
or associaed wih he brand isel. Whereas appealing
o children involves un, adolescens are more likely o
respond o appeals ha he ood ases good. Boh children
and adolescens respond o prizes and sweepsakes. Wha
b d -
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doesn work? Commercials ha claim ha he produc is
nuriious are less eecive because children and adoles-
cens hen conclude ha he ood mus no ase good.87
In an experimen o examine ood adverisemens and
snacking, researchers ound ha children ae nearly 50
percen more ood when waching a show wih ood adver-
isemens as opposed o a show wih non-ood adverise-
mens. The snacks made available were no even relaed o
hose in he adverisemens, and he children ae he snacks
wheher or no hey repored eeling hungry.88 Children
consumed, on average, jus under 100 calories during he
30-minue show. I children snacked ha much exra every
day, hey would gain 10 exra pounds over he course o
a year.89 The sudy suggess ha simply waching ood
adverising has a broader impac in encouraging immediae
eaing, no only in creaing desire or he paricular brand.
In-School MarketingSchools present a special case in the world
of food marketing to youth. Unlike televi-
sion programs and websites, the audience
share of youth is very clear at schools. Food
and beverage marketing at schools comes in
a variety of forms: vending machines, free
educational materials, extracurricular sponsor-
ships and fundraisers, among others.180
In theheight of irony, McDonalds, Coca-Cola and
3HSVL&RKDYHDOOVSRQVRUHGLQVFKRROWQHVV
programs,181 promoting the message that exer-
cise is the solution to diet-related illnesses.
Schools rely on corporate partnerships as a source of funds and free materials.182 Schools earn money from vending
machine contracts based on the amount of products that students purchase.183 If the vending machines are full of
VRGDDQGMXQNIRRGDVLVW\SLFDOWKHVFKRROVVKRUWWHUPQDQFLDOEHQHWVDUHSLWWHGDJDLQVWWKHORQJWHUPKHDOWK
impacts to the students from consuming extra junk food at school. Additionally, the presence of junk food sales and
advertising in schools directly contradicts any classroom nutrition lessons.
In 2006, the William J. Clinton Foundation and the American Heart Association partnered with several food and
beverage companies to create a new industry self-regulatory initiative, the Alliance for a Healthier Generation. The
project focuses on competitive foods, any food sold in a school outside of the federal school meal programs.184
Among other projects, the Alliance has worked with the Coca-Cola Company, Dr Pepper Snapple Group, PepsiCo and
the American Beverage Association to improve the nutritional quality of beverages sold in schools.185 According to its
progress report, the Alliance has achieved an 88 percent decrease in calories shipped to schools in the form of bever-
DJHVEHWZHHQDQG7KHUHGXFWLRQZDVDFKLHYHGWKURXJKDFRPELQDWLRQRIFKDQJLQJSURGXFWRHULQJVDQG
reducing portion sizes.186
7KH$OOLDQFHVDFKLHYHPHQWVLQLPSURYLQJWKHTXDOLW\RIEHYHUDJHVVROGDUHVLJQLFDQWEXWWKHUHLVVWLOOPXFKIXUWKHU
to go. According to the CDC, 65 percent of middle and high schools sell sweetened drinks, 51 percent sell less-healthy
foods and 49 percent allow advertising of less-healthy foods.187 Over 60 percent of elementary school students attend
schools where beverages are sold on campus, but only 16 percent attend schools in which the only competitive bever-
ages, those sold outside of the school meal program, are water, 100-percent juice or low-fat milk.188
)RUWKHUVWWLPH&RQJUHVVKDVSDVVHGOHJLVODWLRQWRDGGUHVVWKHQXWULWLRQDOTXDOLW\RIFRPSHWLWLYHIRRGV7KH86'$already determines nutrition standards for federal school meals, and the most recent school meal reauthorization,
the Healthy, Hunger-Free Kids Act, provided the USDA with the additional authority to set nutrition standards for any
foods sold in schools at any time during the school day.189 It does not address advertising and promotions, but does
LQFOXGHIXQGUDLVHUVDVZHOODVYHQGLQJPDFKLQHVVQDFNEDUVDQGODFDUWHRHULQJVGXULQJPHDOV
7KLVOHJLVODWLRQIRUWKHUVWWLPHSURYLGHVPDQGDWRU\DXWKRULW\WRFKDQJHKRZIRRGDQGEHYHUDJHVDUHPDUNHWHGWR
youth, in the limited context of competitive foods sold in schools. It is an important step toward improving the food
environment in schools.
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In an eor o disinguish beween he eecs o viewing
elevision and viewing elevision adverisemens specii-
cally, one sudy analyzed obesiy among children who
wached commercial elevision versus elevision wihou
adverisemens, such as DVDs or cerain educaional
programming. The sudy also accouned or inluences
ha migh have inerered wih he sudy, such as parenal
educaion level, which allowed he sudy o evaluae causa-
ion. Commercial viewing was a signiican predicor ochildhood obesiy. Viewing elevision wihou commercials
was no. The relaionship beween commercial viewing and
obesiy was sronger or children under he age o seven.90
Do Children and Adolescents
Understand Food Advertisings Intent?
Adverising aecs children and adolescens hrough
dieren menal processes. Children have lower media
lieracy and are hereore inluenced by simpler argu-
mens. Research suggess ha adolescens are more likely
o undersand ha adverisemens are rying o sell hem
somehing and so require more complex argumens o be
convinced.91
Young children ofen ruly canno ell wha is a commercial
and wha is no, bu he adverisemens do inluence hem.
Children as young as wo can recognize brand logos92;
preschoolers have shown preerences or oods placed
in McDonalds packaging, even i he oods are no he
producs ha McDonalds sells.93 According o he IOM,
children aged our and under canno disinguish beween
elevision programs and commercials, and children underhe age o eigh do no undersand ha adverising is
designed o persuade hem.94
Because o his lack o undersanding, he American
Academy o Pediarics has called or a ban on junk ood
markeing o children, and a ask orce o he American
Psychological Associaion has recommended ha all elevi-
sion adverising o children under age eigh be resriced.95
Advergames and websies urher exploi childrens vulner-
abiliies, as he boundary beween conen and program-
ming can be ar less clear han ha beween a elevisionprogram and a commercial.96
Adolescens are much more likely o undersand ha
commercials are designed o persuade hem and may
approach adverising wih a more wary perspecive.97
Because o his undersanding, resricions on ood
markeing o youh are ofen aimed a children under he
age o 12.98 Ye, wih repeaed exposure, he adverise-
mens sill work ofen wihou conscious percepion o he
markeing simulus.99 Adverisers also arge eenagers
wih new online markeing echniques such as produc
placemens and viral markeing ha are more likely o
undermine he viewers skepicism.100 Coupled wih adoles-
cens endency oward weak impulse conrol,101 he role
ha adverising plays in adolescen purchasing and dieary
habis should no be dismissed.
Media lieracy describes he process o learning abou
uses o media and undersanding is commercial inen.102
Deenders o ood markeing someimes argue ha chil-
dren should learn media lieracy rom heir parens or
schools and ha his knowledge will proec hem rom
he wors eecs o junk ood adverising. The argumen is
problemaic, however, as adverising can inluence children
well beore hey undersand wha adverising is. Addiion-
ally, here is litle evidence o suppor he claim ha media
lieracy signiicanly reduces he impac o adverising onchildren.103
In wha is known abou media lieracy, he mos impor-
an acor appears o be consisency. In oher words, i
akes repeaed menal eor o resis adverisemens or
emping oods. Because youh are exposed o so many
markeing messages, and because even older children need
promping o hink criically abou adverisemens, i is
hard o argue ha youh can consisenly igh o hese
messages on heir own. Finally, even i youh can coun-
erac he messages o junk ood markeing, hey may nowan o do so. Junk ood ases good, afer all, and eaing
somehing speciically disallowed by parens or eachers
can hold is own appeal.104
Alhough parens can each heir children o hink criically
abou adverising and make healhier choices, children
can wear down heir parens wih repeaed requess or
unhealhy oods.105 The media lieracy argumen essenially
relies on parens and schools o counerac a negaive
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inluence in childrens lives. I raises an obvious quesion:
Raher han each youh o deend hemselves agains
markeing messages, isn i more eecive o resric he
adverising in he irs place? Cerainly, children should
learn o hink criically abou media and adverising, bu
on a mater as imporan as heir healh, hey deserve
proecion.
Regulation of Food Marketing to YouthFederal
The concep o regulaing ood markeing o children is no
new. The Federal Trade Commission Ac bans unair or
decepive acs aecing inersae commerce and allows
he FTC o sue companies or acions ha violae his provi-
sion and even o creae regulaions or common problems.
In 1978, he FTC examined regulaing ood markeing o
children in par due o concern over he impac o sugary
oods on childrens denal healh.
106
During KidVid, as heprocess was known, he FTC considered banning all elevi-
sion markeing o children under age eigh and argeed
sugary oods as unaccepable o marke o children under
age 11.107 The FTC repored evidence ha childrens sel-
conrol and undersanding o he healh impacs o sugary
oods could no overcome heir more immediae desire o
consume hem.108 The ood indusry ough hese regula-
ions, spending $16 million lobbying agains hem.109
In 1980, in response o he signiican pressure rom
indusry, Congress passed he FTC Improvemens Ac,
which speciically removed he FTCs auhoriy o regu-lae markeing o children as unair. However, i lef he
FTC he abiliy o regulae decepive pracices in ood
markeing o children. The FTC ended he rule-making
process wihou creaing any regulaions in 1981.110 Regula-
ors aced many diiculies, such as lobbying by he ood
indusry, bu pracical acors impaced he process as
well. A he ime, here was insuicien evidence ha ood
adverising negaively impaced childrens eaing habis.
Addiionally, regulaors aced challenges deining wha
markeing was aimed a children versus older children or
aduls. Alhough many programs are speciically markeed
o children, children also wach programs wih signiican
adul audiences, such as evening sicoms.111
The governmen did no address he issue o ood
markeing o children again unil over 30 years laer, whenchildhood obesiy became prominen on he naional
agenda. In 2005, he FTC and he Deparmen o Healh
and Human Services (HHS) sparked he debae wih a
public workshop on he issue. Due o lack o inormaion
abou he exen o markeing, he FTC subpoenaed 44
ood and beverage companies o obain inormaion on
money spen on various mehods o markeing ood o
youh.The resuling repor, Marketing Food to Children
and Adolescents: A Review of Industry Expenditures, Activi-
ties, and Self-Regulation, included a review o indusry sel-
regulaion eors promped by he governmens renewedineres in he issue.112
The American Recovery and Reinvesmen Ac, known
more commonly as he simulus package, required he
FTC, he CDC, he Food and Drug Adminisraion (FDA)
and he USDA o esablish an Ineragency Working Group
on Food Markeed o Children. The legislaion charged he
Working Group wih developing sandards by July 2010
or wha ypes o oods were appropriae o marke o
children.113
The Working Group released he iniial se o sandards inhe spring o 2011 or public commen. The Preliminary
Proposed Nuriion Principles o Guide Indusry Sel-Regu-
laory Eors (Principles) ook wo approaches or evalu-
aing oods based on he 2010 Dieary Guidelines.114 Foods
and beverages would eiher need o provide a meaningul
conribuion o healhy die or mee sandards on nuri-
ens o limi, including sal, sauraed a, rans as and
added sugar.115
The Principles argeed he 10 caegories o oods mos
heavily markeed o children: breakas cereals; snack
oods; candy; dairy producs; baked goods; carbonaed
beverages; rui juices and non-carbonaed beverages;
prepared oods and meals; rozen and chilled dessers; and
resauran oods.116 The deiniion o markeing mirrored
ha o he 2008 FTC repor spanning all markeing o
youh ages 2 o 17, including no jus elevision and prin
media bu also online markeing, social media and indirec
orms o markeing such as produc placemens, celebriy
endorsemens and coness.117
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The Principles earned praise rom public healh orga-
nizaions or providing a srong baseline sandard
and addressing he loopholes ofen ound in indusry
sel-regulaory eors (discussed below).118 Mos oods
currenly markeed o children did no mee he Principles
sandards, and mos processed oods would need o
be reormulaed o mee hem.119 Various ood indusry
organizaions proesed ha he Principles would disallow
markeing or some soups, vegeable juices, cereals and
yogurs,120 alhough public healh advocaes counered
ha hese claims were exaggeraed.121 Tha any osensibly
healhy ood would no mee he Principles sandards
brings ino quesion jus how common added a, sugar
and sal are in processed oods.
The Grocery Manuacurers Associaion (GMA) claimed
ha he Working Group creaed needlessly sric regula-ions, ignoring signiican progress already made in
improving he qualiy o oods markeed o children.
According o GMA represenaive Scot Faber, In recen
years, we have changed he recipes o more han 20,000
producs o reduce calories, sugar, sodium, and a and
have pledged o annually remove 1.5 rillion calories rom
commerce by 2015.122 The Associaion o Naional Adver-
isers argues, Despie calling hese proposals volunary,
he governmen clearly is rying o place major pressure
on he ood, beverage and resauran indusries on wha
can and canno be adverised.123 An FTC atorney saedha he agencys ambiion isn ha ood companies sop
markeing o kids bu ha hey reormulae heir producs
and marke more healhul oods.124
The FTC made muliple public deenses o he Principles
and saed a willingness o revise he sandards, and he
vas majoriy o he 29,000 public commens suppored
hem.125 Bu Congress blocked he Principles by requiring
a cos-benei analysis, a nearly impossible ask or a
volunary measure, as he reques pre-supposes ha he
Principles are binding. The FTC has since decided no o
pursue he Principles.126 In his mos recen case, as in
every oher atemp o limi ood markeing o children,
indusry pressure rumped public healh.
Local and State
Local and sae regulaions o address ood markeing
o youh have been ew. The Ciy o San Francisco has
passed an ordinance ha bans resaurans rom oering
oys in childrens meals ha are high in calories, sugar and
a. Any childrens meal ha oers a ree oy mus also
include ruis and vegeables. In essence, he ordinance
has been dubbed a ban on McDonalds Happy Meal oys.
Sana Clara Couny, Caliornia, has passed a similar law.12
Some sae legislaures, in response o San Franciscos
ordinance and oher nuriion-relaed ordinances, such as
rans a bans and menu calorie-labeling requiremens,
have passed sae laws ha would supersede any suchlocal law. These bills give only he sae he auhoriy o
pass such laws. Arizona, or insance, speciically disallows
owns and counies rom banning consumer incenives in
ood markeing, which includes oys in childrens meals,
and Ohio gives he sae direcor o agriculure he sole
auhoriy o regulae consumer incenives, among oher
relaed issues. Sae resauran associaions have lobbied
or he sae bills, arguing ha varying local ordinances
applying o heir markeing pracices creaes an unair
regulaory burden.128
Industry Self-Regulation
The 2011 exercise o proposing Principles o guide indusry
sel-regulaion gave he ood indusry he opporuniy o
ou is progress in improving he healh o ood markeed
o children. Ye sel-regulaion has occurred only under
he hrea o governmen regulaion, and he eors so
ar have no done nearly enough o proec children rom
he wors eecs o ood markeing. Signiican indusry
sel-regulaory eors began in response o he FTC and
HHS 2005 workshop and 2006 repor on markeing, sel-
regulaion and childhood obesiy,129 and a new indusryagreemen on uniorm nuriion sandards ollowed in
response o he proposed Principles.130
Sudies o indusry sel-regulaory eors worldwide have
ound ha hey are ypically creaed in response o poen-
ial governmen inervenion and are eecive in achieving
basic conrols o he mos irresponsible adverisemens,
bu no changing much beyond ha.131 The researchers
o one sudy describe: As wih he obacco and alcohol
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indusries, ood indusry sel-regulaion appears o be
moivaed more by exernal hreas: negaive public
atiudes, governmen acion ha resrics key business
pracices, and liigaion. Where indusry and public healh
objecives conlic, an indusry has incenives o creae a
public image o concern and o promise change, bu hen
o creae weak sandards wih lax enorcemen.132
Childrens Food andBeverage Advertising Initiativec
In response o he ederal governmens renewed scruiny
o ood markeing o youh, he Council o Beter Business
Bureaus (BBB) sponsored he volunary Childrens Food
and Beverage Adverising Iniiaive (CFBAI) in 2006, wih
he goal o promoing adverising messaging o children
o encourage healhier dieary choices and healhy
liesyles.133 The sandards or he CFBAI apply o all
markeing o children under he age o 12 and rely on each
ood company o se is own sandards or wha consi-
ues beter-or-you oods ha are appropriae o marke
o young children.134 As o December 2013, paricipaing
companies will be required o ollow a uniorm nuriion
sandard.135
As o 2012, he companies paricipaing are Burger King
Corporaion, Campbell Soup Company, Coca-Cola
Company, ConAgra Foods, Inc., The Dannon Company,
General Mills, Inc., Hershey Company, Kellogg Company,
Kraf Foods Global, Inc., Mars Snackoods US, LLC,
McDonalds USA, Nesl USA, PepsiCo, Inc., Pos Foods,
Sara Lee Corp. and Unilever Unied Saes.136 Three compa-nies Coca-Cola, Hersheys and Mars have sopped
markeing direced o children under 12 years o age.137 The
remaining companies have developed individual pledges
o improve he healh conen o oods hey marke o
children. The pledges apply o all orms o adverising.
Mos companies consider programs wih a 35 percen or
greaer audience share o children ages 2 o 11 o be child-
direced, and mos companies have also chosen no o
marke o children under he age o 6.
A a minimum, under he CFBAI, he companies mus: Devoe 100 percen o heir child-direced adverising
o beter-or-you oods, or o no engage in such
adverising;
Esablish nuriion sandards, consisen wih esab-
lished scieniic and/or governmen sandards and
recommendaions and subjec o BBB approval, ha
govern wha oods hey may adverise o children;
Limi he use o hird-pary licensed characers, celeb-riies and movie ie-ins in child-direced adverising
consisen wih he companys adverising commi-
men;
No pay or or acively seek o place heir ood and
beverage producs in he program/ediorial conen o
any medium ha is child-direced or he purpose o
promoing he sale o hose producs;
c ^,
Better-for-You FoodsHere are a few of the foods considered better-for-
you options and therefore appropriate to market
to children under age 12 by the Childrens Food and
Beverage Advertising Initiative:139
Cereal
Apple Jacks
Cinnamon Toast Crunch
Cocoa Pebbles
Froot Loops
Fruity Pebbles
Kelloggs Frosted Flakes
Lucky Charms
Trix
Fast Food
Burger King Kids Meals with Fresh Apple Slicesand fat-free milk or apple juice
McDonalds Happy Meals with fries, apple slices
and fat-free chocolate milk
Prepared Meals
Kid Cuisine Meals, including the Carnival Corn
Dog, Kickin Ravioli and KCs Primo Pepperoni
'RXEOH6WXHG3L]]D
&KHI%R\DUGHH2YHUVWXHGWDOLDQ6DXVDJH5DYLROL
and Pepperoni Pizza Ravioli
Snacks A variety of Unilever Popsicles, including products
named after Dora the Explorer, Marvel Super
Heroes, Spider Man and SpongeBob SquarePants
Honey Maid Grahamfuls Filled Crackers Peanut
Butter and Chocolate
Beverages
Kool-Aid Singles
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Include only he companys beter-or-you oods or
healhy dieary choices in ineracive games ha
incorporae a companys ood producs; and
No adverise heir branded oods o children in elemen-
ary schools (his limiaion does no apply o chariable
undraising, displays o ood producs, public service
messaging or iems given o school adminisraors).138
Evaluating the Childrens Foodand Beverage Advertising Initiative
The Grocery Manuacurers Associaion and he Asso-
ciaion o Naional Adverisers have promoed a sudy
o elevision adverising aimed a children ages 2 o 11,
comparing adverising levels in 2004 versus 2010, o
evaluae he CFBAIs eeciveness in reducing childrens
exposure o ood adverising.140 According o he sudy, he
average child in his age span viewed approximaely 1,250
ood and beverage adverisemens on childrens elevision
in 2010, compared o 2,500 in 2004, and ood and beveragecompanies spen $200 million on elevision adverising o
his demographic, compared o $600 million in 2004. Tha
amouns o hal he adverising views on childrens elevi-
sion, and wo-hirds less spending.
In he sudy, hese impressive igures are ollowed by
graphs revealing drasic reducions in elevision adverising
o children in cerain ood caegories, including cookies,
snack bars, candy and sof drinks. In hese caegories,
elevision adverisemens direced speciically a children
have been all bu eliminaed. Addiionally, adverisemens
or ruis and vegeables have increased over 150 percen,
in par because here were so ew o hem o sar.141
These reducions in adverising are noeworhy. Ye
compared o he goals se ou in he Ineragency Working
Groups Principles, here are signiican gaps. Foremos
among hem are age and orm o media. The sudy does
no address exposure o youh ages 12 o 17, nor does he
sudy address childrens exposure o elevision adverise-
mens ouside o childrens programming. Recall ha
anoher 2010 sudy esimaed ha childrens oal elevi-
sion ood adverising exposure including all shows, nojus childrens shows was 5,000 viewings per year, ar
higher han he oals described above.142 The sudy also
leaves ou adverising online, where much adverising has
shifed in recen years.143
Cerainly, reducing adverising or junk oods makes he
adverising mix less unhealhy, bu hese eors do no
reach ar enough. The Working Group has indicaed ha
mos oods currenly adverised o youh would no mee
heir proposed Principles.144 Three sudies urher evaluae
he CFBAI agains hird-pary nuriion sandards and
conirm ha, even afer aking ino accoun he indusrys
sel-regulaory eors, mos o he ood markeed ochildren is no healhy.
An evaluaion o ood markeed o children beore and
afer implemenaion o he CFBAI ound only a sligh
decrease in he markeing o unhealhy oods o children.
In 2009, 72.5 percen o oods markeed o children were
Whoa oods, hose ha should be consumed only occa-
sionally as reas (as deermined by he HHS Go-Slow-
Whoa ood raing sysem), compared o 84 percen in
2005.145 O adverising by companies paricipaing in he
CFBAI, 68.5 percen o adverisemens eaured Whoaoods, while only 1 percen o ood adverising by hose
companies me he sandards o healhier Go oods ha
children should be encouraged o ea on a regular basis.
Addiionally, hal he adverisemens using licensed
characers were or Whoa oods.146 And, ye, according o
he sudy, he companies involved were all meeing heir
pledges, and nearly hree-quarers o he ood adverise-
mens were rom companies paricipaing in he iniia-
ive.147 The eors have simply no been enough o make a
subsanial change in he overall conen o ood markeing
o young children.148 The auhors speciically ideniy he
lack o a uniied sandard as a weakness o he CFBAI: A
is roo, his siuaion suggess ha each company ailors
is unique nuriional guidelines o deine healhy oods by
careully weighing he implicaions o each acor or is
paricular produc porolio. I implies ha shades o grey
in close call decision-making may be shaped a leas in
par by a companys sel-ineres in qualiying more o is
producs in he healhy caegory.149
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The Cener or Science in he Public Ineres evaluaed
CFBAI-approved beter-or-you oods agains he nuri-
ion sandards or he Naional Alliance or Nuriion and
Aciviy (NANA)s Model School Wellness Policies on
Physical Aciviy and Nuriion. O he 452 beter-or-
you producs approved by he CFBAI as o 2009, only 41
percen me he NANA sandard. Producs mos likely o
mee he sandard included yogur and juices.150
The sudy also analyzed ood adverisemens on he
childrens cable channel Nickelodeon in 2005 and 2009
o observe any dierences since he CFBAI wen ino
eec. Overall, adverisemens or nuriionally poor oods
decreased rom 88 percen o 79 percen o he oal, a
saisically insigniican dierence. The percenage o
adverisemens or oods high in added sugars acually
increased over he ime rame, while adverisemens high in
oal a, sauraed and rans as, and sodium decreased.
Three-quarers o he adverisemens were rom companies
paricipaing in he CFBAI. Adverisemens rom compa-nies paricipaing in he CFBAI were much more likely
o mee he NANA sandards, wih 28 percen o hose
adverisemens meeing he NANA sandard and virually
no adverisemens rom he non-CFBAI companies doing
so.151 Thus, CFBAI-approved adverisemens represen a
higher likelihood, bu no guaranee, o healhul conen.
Yale Universiys Rudd Cener or Food Policy and Obesiy
has analyzed cereal and beverage adverisemens o
children.152 A sudy o cereal adverisemens rom CFBAI-
paricipaing companies ound ha hese companies endo marke heir leas-healhy opions o children.153 For
example, in 2011, children ages 2 o 11 on average saw
hree imes as many ads or CFBAI-approved Honey Nu
Cheerios compared o regular Cheerios.154
The cereals markeed direcly o children in he sudy
conain 56 percen more sugar, 52 percen less iber and
50 percen more sodium han cereal markeed o aduls.
Companies ypically markeed heir healhier cereals o
aduls or he aduls consumpion.155 There is perhaps no
beter example o mixed messaging: he same company is
markeing one se o cereals o children, and anoher se o
cereals o he parens o buy or he children. On he one
hand, cereal companies can promoe heir involvemen inhe CFBAI, while on he oher hand, hey are seting up
parens o ail wih heir conradicory markeing pracices
The Rudd Cener also ound ha children and eens
viewed wice as many ads or regular soda in 2010 as
in 2008.156 While youh exposure o sugary drink ads
rom PepsiCo declined, exposure doubled o ads rom
Coca-Cola, Dr Pepper Snapple Group drinks and 5-hour
Energy.157 Noe ha PepsiCo and Coca-Cola are boh
members o he CFBAI.158 Coca-Cola also appears as
a produc placemen in primeime elevision showscommonly wached by youh.159 These placemens repre-
sen a loophole in he CFBAI sandards, which require
limiing produc placemens only in childrens program-
ming.160
Improving Industry Self-Regulation
While here have been some improvemens, he overall
qualiy o ood markeed o youh is sill quie unhealhy.
Indusry sel-regulaion is clearly insuicien o make he
necessary changes o improve he healh o ood markeed
o children. One consisen criicism o indusry-led regula-ory eors has been he lack o a uniorm nuriion san-
dard or oods and beverages adverised o youh.161 The
Principles represened he irs saemen by he ederal
governmen o creae bes pracices or such a sandard o
recommend o indusry, in lieu o indusry acion on he
mater. On he very las day o submi commens on he
Principles,162 he CFBAI counered wih is own uniorm
nuriion sandard, which paricipaing companies mus
implemen by he end o 2013.
The CFBAI sandard se limis on sodium, sauraed a,rans a, sugar and calories or each o 10 broad ood
caegories.163 This nuriion sandard is weaker han he
Principles sandard and applies o ewer ypes o adver-
ising.164 While mos oods currenly accepable under he
CFBAI would no mee he Principles sandard, wo-hirds
would mee he CFBAIs new uniorm sandard. Mos
producs ha do no mee he sandard would require
minimal adjusmens o do so.165
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In oher words, he CFBAIs new sandard does no acu-
ally make signiican improvemens over he curren siu-
aion. A leas hree o he companies paricipaing in he
CFBAI General Mills, Kellogg and PepsiCo lobbied o
weaken he Principles as par o a media and ood indusry
eor called he Sensible Food Policy Coaliion.166 As he
earlier evaluaions sugges, a srong nuriion sandard
is necessary o reduce childrens exposure o unhealhy
ood adverising. The ood and beverage indusry shouldsuppor a sronger sandard.
Furher improvemens o indusry-led programs like he
CFBAI would include:
Elimination o junk ood marketing during
certain contexts167: As recommended by he World
Healh Organizaion, setings where children gaher,
such as schools and afer-school programs, should be
ree o junk ood markeing.
Outside evaluation o industry eforts168: The
FTCs repor, Marketing Food to Children and Adoles-cents: A Review of Industry Expenditures, Activities, and
Self-Regulation, provides one example o a horough
evaluaion o indusry spending on dieren ypes o
markeing.
Targeted goals to improve health outcomes or
youth: Some public healh advocaes have called or
oucome-based evaluaions wih goals or reducing
childrens consumpion o unhealhy oods or improve-
mens in childhood overweigh and obesiy.169
Inclusion o media companies, such as television
networks and social media websites170: Sel-
regulaion would be srenghened i media companies
agreed no o show adverisemens, include produc
placemens or allow heir characers o endorse oods
ha do no mee a common nuriion sandard.
Participation by additional ood and beverage
companies171: For indusry sel-regulaory eors o
work mos eecively, every company should parici-
pae.
The Whie House Task Force on Childhood Obesiy has
recommended a number o improvemens o indusry
sel-regulaory iniiaives o make hem more ar-reaching
and consisen. The Task Force allows or he possibiliyha indusry eors will make a signiican dierence
in youhs exposure o unhealhy ood markeing, bu i
recommends revised ederal rules should hese eors no
work as enough. Speciically, he repor recommends
Does the First Amendment Protect Commercial Speech?For the most part, the U.S. Supreme Court has interpreted the First Amendment as protecting commercial speech,
leaving this form of expression largely unregulated.190 Commercial speech is expression related solely to the economic
interests of the speaker and its audience and speech that proposes a commercial transaction. Yet, based on the
1980 case Central Hudson Gas & Electric Corporation v. Public Service Commission of New York, commercial speech can beregulated if it is deemed false, misleading or deceptive.191
The central question about whether food marketing to kids is protected under the First Amendment naturally follows:
Is it inherently false, misleading or deceptive? Can children understand the marketing as advertising? What if some
advertisements are considered misleading and others are not? At what age does it apply?
The restriction on misleading advertising does not allow for the elimination of whole categories of advertising if it is
possible for the advertising to be done in a way that is not misleading.192 Researchers and advocates have argued that
advertising to young children is inherently misleading because children cannot understand the persuasive intent of
advertising. There is no non-misleading alternative in this case, as even disclosure statements are beyond childrens
understanding.193
7KH6XSUHPH&RXUWKDVDOVRLGHQWLHGFKLOGUHQVULJKWVWRSURWHFWLRQDVGLHUHQWIURPWKDWRIDGXOWVDVFKLOGUHQDUH
SDUWLFXODUO\YXOQHUDEOHWRPDUNHWLQJLQXHQFH194
QSUDFWLFHDVVHHQLQWKH)7&VHRUWVWRUHJXODWHPDUNHWLQJWRFKLOGUHQDSSO\LQJWKHVHGHQLWLRQVLVFRPSOLFDWHGQWKHFDVHRI Lorillard v. Reilly, for instance, the Supreme Court
ruled that Massachusetts could not restrict tobacco advertising near schools and playgrounds because it interfered
with companies ability to market to adults.195 Distinguishing between adver tising directed at children and especially
adolescents versus adults complicates attempts to regulate food marketing.
Certain programs and websites are clearly aimed at children, but there is also much content whose audience is mixed.
7KH)LUVW$PHQGPHQWSURWHFWLRQLQWKHVHFDVHVKDVQRWEHHQFOHDUO\GHQHG7KH6XSUHPH&RXUWODVWUXOHGRQD
commercial speech case in 2002.196 The FTC has developed its own guidelines to determine what fraction of the audi-
ence must be made up of children or adolescents to determine whether the programming is aimed at that age group,
but those regulations have only been proposed for voluntary restrictions on food marketing to children.197
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ha, wihin hree years, he majoriy o ood adverising
direced a children should be or healhy oods and
beverages, and licensed characers should be used only o
promoe healhy producs.172 I seems highly unlikely ha
he ood and beverage indusry will mee hese goals.
The suggesed improvemens would make indusry sel-
regulaory eors sronger, bu, ulimaely, he problem is
ha ood markeing works.173 Indusry sel-regulaory
eors may have removed adverisemens or some ohe unhealhies producs, bu here are many inconsis-
encies, and he majoriy o ood in adverisemens o
youh remains unhealhy. The IOM saes ha ood and
beverage companies, resaurans, and markeers have
underuilized poenial o devoe creaiviy and resources
o develop and promoe ood, beverages, and meals ha
suppor healhul dies or children and youh.174 Unor-
unaely, wihou regulaions or he hrea hereo, he
indusry remains wihou suicien incenive o do so.
International RegulationThe World Healh Organizaion (WHO) recenly passed
recommendaions o reduce he impac on children o
markeing o oods high in sauraed as, rans-aty
acids, ree sugars, or sal, wih he larger goal o reducing
he prevalence o diseases o which unhealhy dies
conribue.175 Acknowledging member naions varying
capaciy o enac markeing resricions, he WHO recom-
mends ha naional governmens should deine wha
ypes o markeing o resric and wha nuriional san-
dards are appropriae or oods markeed o children, and
oversee all implemenaion and evaluaion.176 In paricular,
he recommendaions call or banning markeing o oods
high in sal, sugar and a in schools and oher places
requened by children.177
Worldwide, as o 2006, 36 counries had implemened
regulaions addressing ood markeing o youh on elevi-sion, mos aimed a children under age 12, and 21 coun-
ries regulaed markeing in schools.178 A he ime, only
Finland and Spain limied produc placemens, and only
Brazil limied Inerne markeing. The Unied Kingdom has
enaced some o he mos sringen requiremens, banning
all junk ood markeing on childrens elevision saions
and programming aimed a youh under age 16 as o
2008.179 Many ood corporaions sell heir producs globally
and have hereore had experience meeing he regulaory
requiremens o dieren counries.
Recommendations
The public healh challenge o rising childhood obesiy
mus be addressed. Improving he nuriional environmen
or youh will require many policy changes. Is ime o ask
he quesion: Is i appropriae o adverise unhealhy oods
o children and adolescens? While he FTCs proposed
volunary Principles oered a srong se o guidelines, his
proposal should no be he exen o he debae abou
improving he nuriional value o oods markeed o
youh. Broader resricions are necessary o proec youh
rom he inluence o ood and beverage markeing.
Speciically, Food & Waer Wach recommends ha:
The FTC should be able o regulae any unair or
decepive markeing, bu Congress has limied he
FTCs auhoriy o resric markeing o youh.
Congress should provide he FTC wih he ull
auhoriy o regulae ood and beverage markeing.
Congress should also give he FTC he auhoriy o
creae mandaory nuriion sandards or ood and
beverages markeed o youh.
The FTC should coninue is monioring o indusryspending and sel-regulaory eors in ood markeing
o youh.
Food and beverage companies should reduce adver-
ising o unhealhy oods and beverages o children
and reormulae producs o make hem healhier.
The USDA should issue srong nuriion sandards or
compeiive oods sold in schools as sipulaed in he
Healhy, Hunger-Free Kids Ac o 2010.
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