Update on impact of restrictions on food and drink advertising to children
In February 2007, Ofcom published its final statement on the Television Advertising of Food and Drink to Children which launched a package of new rules aimed at reducing the impact of advertising of high fat, salt and sugar (HFSS) food and drink to children.
Ofcom carried out some initial analysis of the effectiveness of the first phase of restrictions and issued a summary of its findings in an Ofcom Update on 12 December 2007.
On 12 December 2007, Ofcom also briefed consumer, health and industry representatives on these early findings (using data from the first six months of the restrictions, April-September 2007).
In response to a request from stakeholders for further information on the findings set out in the summary, Ofcom is publishing the data which was presented to consumer, health and industry representatives at the briefing in December 2007.
Ofcom will be carrying out a full review of the effectiveness of the restrictions on the television advertising of HFSS food and drink products to children. The review will begin in July 2008, using data from the first six months of 2008. We aim to complete the review in the autumn.
This note summarises:
- the background to and nature of the advertising restrictions on the television advertising to children of HFSS products;
- the interim data made available to interested parties in December 2007; and
- the objectives of the review to be started in July 2008.
A growing body of research indicating that obesity was an increasing risk to the health of children and young people led the Government to ask Ofcom in December 2003 to consider strengthening rules on advertising food products to children (-1-). Towards the end of 2005, the Food Standards Agency (FSA) completed work on a nutrient profiling model designed with independent scientific input to help distinguish less healthy food and drink products from more healthy products for the purposes of distinguishing which products might be made subject to advertising restrictions (-2-).
Ofcom carried out wide-ranging research and in March 2006, published a consultation setting out in detail why it considered targeted action on food advertising was appropriate. It consulted on several options, including restrictions based on all foods or just those profiled as less healthy (-3-).
After carefully reviewing all responses to the consultation, Ofcom concluded that nutrient profiling based restrictions were the most appropriate and proportionate, and invited further views on a variation of one of the options, which would apply restrictions to advertising HFSS products in and around programmes aimed at and of special appeal to children aged 4 -15 (-4-), as opposed to the 4-9 year olds as originally proposed. It also decided that changes should be made to the ASA’s Code on Advertising Practice, to restrict the use of techniques that might make advertising of HFSS products particularly attractive to children.
In February 2007, Ofcom reached its final decision and announced that the scheduling restrictions would come into effect on a phased basis with effect from April 2007 (-5-).
Phase 1 (April 2007) comprised a total ban on HFSS advertisements in programmes aimed at children aged 4-9, or attracting disproportionately high child audiences (-6-). As a transitional measure, children’s channels were required to scale back HFSS advertising to 75% of 2005 levels. With immediate effect restrictions were introduced on advertising techniques in new promotions that might make HFSS advertising attractive to children at other times (-7-); they applied to all existing promotions with effect from 1 July 2007.
Phase 2 (January 2008) saw the ban extended to children aged 4-15, and HFSS advertising on children’s channels scaled back to 50% of 2005 levels. Phase 3 (from January 2009) will ban all HFSS advertising on children’s channels.
The Ofcom slide pack (PDF, 253.7 KB) was provided to consumer, health and industry stakeholders on 12 December. This explained that, while it is still too early to come to any firm conclusions about the success or otherwise of the new rules, there are clear signs that the new rules are having the intended effect on reducing the amount of food and drink advertising that children are exposed to on television.
The interim data reflects the partial introduction of the restrictions to date:
- The amount of HFSS advertising that children see has declined in line with Ofcom’s predicted forecasts;
- Television share of total core category advertising spend has fallen from 68% to 64% since 2005;
- The greatest decline in impacts has been in relation to children aged 4-9 years (down 27% since 2005) and down 57% in children’s airtime;
- Core category 4-15 year olds impacts on television fell by 20% between April and September 2005 and the corresponding period in 2007. This was driven by a 59% decline in impacts delivered during children’s airtime, most of which (53%) has taken place between 2006 and 2007, since the rules were introduced;
- Core category advertising on terrestrial children’s programming has fallen to negligible levels, and is declining markedly on dedicated children’s channels. The decline on dedicated children’s channels has been greater than the reduction required under Ofcom’s phased rules.
- Impacts on dedicated children’s channels fell by 49% from 2005 to 2007.
- Within that overall reduction, there has been an increase in 4-15 core category impacts in “adult” non-terrestrial airtime (up 26% since 2005), leading to an overall 2% increase in impacts delivered across all adult airtime. This reflects increased viewing of non-terrestrial ‘adult’ targeted channels by children.
When launching the rules, Ofcom committed to a full review during 2008 of how well the new advertising restrictions are working. In conducting the review, Ofcom will work with the Department for Culture, Media and Sport, with the Department of Health, which is collecting data about advertising across all media, and with the Food Standards Agency which will be reviewing the operation of the nutrient profile model used in the rules.
Ofcom has agreed to bring forward to July 2008 its review of how the restrictions are working. It is important to note that Ofcom will not look to see whether they are having effects on child obesity – it would not be realistic to expect short term changes in obesity, and in any case, television advertising is only one of a large number of factors that affect obesity. Rather, Ofcom will be looking at whether the restrictions are working as intended, and in particular, whether:
- scheduling restrictions are achieving the objective of reducing significantly the number of HFSS product advertising impacts (i.e. each occasion when a viewer sees an advert) among children aged 4-15 years;
- the impact on broadcasters has been broadly consistent with the effects that both Ofcom and the broadcasters expected;
- scheduling restrictions and revised content rules are being implemented as intended, or whether unexpected difficulties have emerged in interpretation, implementation and enforcement;
- advertisers are evading the spirit of the restrictions, by airing advertising and sponsorship in the names of brands commonly associated with HFSS products in children’s airtime; and
- advertisers have significantly increased the amount of HFSS advertising and sponsorship in periods outside children’s airtime, at times when significant numbers of children may be watching.
Ofcom’s review will draw on data from January to June 2008, which will show the effect of the first six months of Phase 2 of the restrictions.
In conducting its review, Ofcom will work closely with the Department of Health and the Food Standards Agency.
The Department of Health has commissioned work to examine the balance and nature of advertising for HFSS products across a range of media, including television, radio, press, outdoor and cinema advertising.
The FSA has commissioned an independent panel to review the nutrient profiling model in the light of experience. The panel’s draft conclusions are expected to be reviewed by the Scientific Advisory Committee on Nutrition towards the end of 2008, with a view to recommendations being made to the FSA Board in early 2009. If the FSA decides that changes should be made to the nutrient profiling model, Ofcom would need to consider whether corresponding changes should be made to the model used to identify products that are subject to advertising restrictions.
1.- More detail can be found in Section 2 of Television Advertising of Food and Drink Products to Children: Options for new restrictions, Ofcom, March 2006 (PDF, 1015.5 KB).
2.- More detail of this model can be found on the FSA website
3.- See document referred to in footnote 1.
4.- Television advertising of food and drink products to children: statement and further consultation - New food ads
5.- Television advertising of food and drink products to children: Final statement, Ofcom, 22 February 2007 (PDF, 200.4 KB)
6.- Where BARB data indicates the child component of the audience is 20% higher than its representation in the total viewing population, the programme is deemed to be of particular interest to children.
7.- Adverts aimed at children of primary school age or younger may not feature promotional offers (e.g. giveways), or cartoon characters and celebrities. Other rules applying to all products prohibit techniques that would exploit the credulity of children.