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Following our statement on HFSS advertising to children, the Advertising Association’s CEO Stephen Woodford has answered questions posed by cross-party MPs from the Health and Social Care Committee. He used the opportunity to expand on the statement and fleshed out the argument against introducing a blanket ban on pre-watershed advertising of products that are classed as HFSS by the Department of Health. He has used the opportunity to correct some misapprehensions about the topic, as well as setting out the current collaborative relationship between advertisers and the Advertising Standards Authority that ensures the ads children are exposed to adhere to best practice and rules.
“We already have among the strictest rules in the world across all media, which have dramatically reduced the exposure of children to HFSS advertising.
“The 9pm watershed was rejected by Ofcom as disproportionate and ineffective 10 years ago and changing media consumption habits of children will make it even less likely to have an impact today. Obesity rates among young people vary significantly across the UK, correlating strongly to areas with increased deprivation. This suggests that effective action must be targeted at local level and that blanket nationwide restrictions across media are not the answer.”
Here are ten hard facts about HFSS advertising in the UK, along with some recommendations about how the industry can proceed following the review:
1. Existing UK rules mean that ads for HFSS products cannot be targeted at children in any media and are among the strictest in the world. Children are protected up to the age of 16 – significantly higher than most countries, where rules apply only to under 12s. The UK’s self- and co- regulatory system has been in place for over 50 years and is the international gold standard.
2. The current rules on advertising are comprehensive, effective, evidence-based and proportionate and apply wherever children might see ads, whether on TV, online, on social media, on the street or on public transport. Enforcement by the Advertising Standards Authority is effective and well-respected.
3. Broadcast rules have been in place for over a decade and from 2007 when they were introduced up to 2010, there was a 37% decline in HFSS ads seen by children. From 2010 to 2017, children saw 40% fewer food and drink ads. Despite this, obesity rates have not changed.
4. The self- and co- regulatory system is responsible and responds quickly to new evidence. Since July 2017 the same tough rules have applied in all other media including online, social media and public transport. These rules are being comprehensively reviewed one year on to ensure they are fit-for-purpose.
5. For online advertising, including social media, HFSS advertisers can use data, insights and age targeting to avoid their ads being seen by under 16s. By extension, they are also able to target only at adults.
6. A pre-9pm watershed ban would be disproportionate as it would remove adverts targeted at adult audiences and severely limit the ability of adults to view ads for products they wish to purchase. The majority of adult viewing takes place before 9pm, so a watershed ban limits their free choice. A pre-watershed ban may also cover products that consumers might find surprising such as cooking and salad oils, certain margarines and spreads, certain cheeses, and a number of store cupboard ingredients, such as stock cubes.
7. Further advertising restrictions of this nature would adversely impact the revenues of commercial media and the wider creative industries, but are unlikely to help address levels of obesity. Reductions in revenue for commercial media impact on investment in programming – as proven by the decline in investment in children’s programming since the rules were put in place.
8. Childhood obesity rates differ across the UK depending on age, socio-economic status, ethnicity, region and gender. This means a localised, targeted approach to tackling obesity will be more effective than ad bans. An independent 2014 report from McKinsey placed media restrictions near the bottom of a table of possible interventions to reduce childhood obesity. Portion control, reformulation and education by schools and parents were all found to be significantly more effective.
9. Changing behaviour would lead to a reduction in childhood obesity, and the UK advertising and media industries play a vital role in achieving this. Initiatives such as the Daily Mile – now being promoted by the UK’s biggest commercial broadcaster ITV – are practical and successful and show how simple, cost-free and social exercise initiatives in schools and communities can help tackle obesity and overweight among children.
10. Advertising supports nearly a million jobs across the length and breadth of the UK and finances British culture, media content and sport valued at £10 billion a year. Every £1 spent on advertising contributes £6 to UK GDP – over £120bn each year. Further advertising restrictions limit the ability of commercial media companies to generate advertising revenue. Furthermore, they will limit opportunities for businesses to grow through advertising as well as restrict consumer choice.
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