Children’s Health
or Corporate
Wealth?
The battleground for kids’
hearts, minds and tummies
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Children’s Health or Corporate Wealth?
Food Marketing to Children in Australia
2014
Contact
Cancer Council NSW, email: junkbusters@nswcc.org.au
Acknowledgements
This document is an extension of Coalition on Food Advertising to Children (2006) Children’s health or corporate
nd
wealth? The case for banning food advertising to children 2 edition. We would like to acknowledge the Coalition
on Food Advertising to Children for the original concept. We would like to acknowledge the work of Leva Azadi
and Boyd Swinburn in the previous edition.
Suggested citation
Watson W, Johnston A, Hughes C, Wellard L, Chapman K. Children’s Health or Corporate
Wealth? The battleground for kids’ hearts, minds and tummies. Sydney: Cancer Council NSW;
2014
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Children’s Health or Corporate Wealth?
Food marketing to children: the context
Reducing children’s exposure to unhealthy food marketing has been recognised by the
World Health Organization (WHO) as important for helping to prevent a range of health
problems associated with unhealthy food choices. WHO has produced a set of
recommendations to member governments for the restriction of marketing of food and
beverages to children,1 and have developed a framework2 to support governments to
translate these recommendations into effective regulations.
Parents want support from the government to protect their children from unhealthy food
marketing and promote healthy habits by introducing regulations to restrict unhealthy food
marketing to children across a variety of media.3
In 2009, the Australian National Preventative Health Taskforce recommended several
strategies to reduce exposure of children and others to marketing, advertising, promotion
and sponsorship of energy-dense nutrient-poor foods.4 The Australian government’s
response committed to monitoring the effectiveness of current self-regulatory initiatives and
to consider government regulation if these proved ineffective.5
We need to protect children’s health over corporate interest. Children are targets for
marketers because they have their own money to purchase products, they can influence
their parents, and they are the consumers of tomorrow.
This report provides an overview of the research into the nature and extent of food marketing
to children and its impact on children’s food preferences, their diet and their health. The
report also outlines current mandatory, co-regulatory and voluntary approaches in Australia
and around the world to reduce food marketing to children and makes a series of
recommendations to improve regulation and more effectively reduce children’s exposure to
the unhealthy influence of food marketing.
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Children’s Health or Corporate Wealth?
Contents
Common abbreviations ...................................................................................................... 5
Obesity in Australia ............................................................................................................ 6
The effects of food marketing to children ......................................................................... 8
The role of food marketing ................................................................................................. 9
Media literacy .................................................................................................................... 11
The power of advertising- tricks of the trade .................................................................. 13
Exposure: Advertising is everywhere! ............................................................................ 18
Food marketing regulation in Australia; confusing, not comprehensive ..................... 23
Loopholes and limitations in the self-regulatory initiatives ........................................... 27
The International situation ............................................................................................... 33
Support for Government action ....................................................................................... 35
Recommendations for action ........................................................................................... 39
Appendix A: Current Regulatory Framework in Australia.............................................. 40
Appendix B: Sth Australian food marketing to children discussion paper guidelines 43
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Children’s Health or Corporate Wealth?
Common abbreviations
AANA
Australian Association of National Advertisers
ACCC
Australian Competition and Consumer Corporation
ACMA
Australian Communications and Media Authority
AFGC
Australian Food and Grocery Council
ASB
Advertising Standards Bureau
CTS
Children’s Television Standards
HFSS
High fat, sugar and salt foods
QSRI
Quick Service Restaurant Initiative
RCMI
Responsible Children’s Marketing Initiative
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Children’s Health or Corporate Wealth?
Obesity in Australia
The waistlines of Australians are increasing. Almost Sixty-three percent of Australian adults
are overweight or obese.6 Children are also affected. National surveys show that 23% of
Australian children are either overweight or obese.7 Overweight children are more likely to
become overweight adults, with 75-86% who are overweight at 8 years of age or older likely
to be overweight at age 20.8 This means it is incredibly important to do whatever we can
during childhood to set healthy habits for life. Obese children are at a greater risk of
developing chronic diseases, like cardiovascular disease and type 2 diabetes, and health
problems like high blood pressure, sleep apnoea, depression and eating disorders.9
23% of children are either
overweight or obese
Over 60% of those are likely
to be overweight
at age 20
Obesity is also a risk factor for many cancers, including cancers of the bowel, kidney,
oesophagus, pancreas, endometrium and breast (post-menopause).10 Cancer Council
recognises the need for individuals, businesses and government to
take action to prevent Australians becoming overweight or obese. The
World Cancer Research Fund reviews evidence relating to food,
nutrition and cancer, and has provided a number of recommendations
to minimise cancer rates worldwide, including through promoting a
Obesity is a risk
healthy weight and physical activity.11 This may be achieved by a
factor for bowel,
range of activities, such as designing built environments that promote
physical activity, selling meals of a high nutritional standard at schools
kidney,
and recreational facilities, and ensuring nutritious foods are
oesophageal,
competitively priced in the marketplace. Government restrictions on
unhealthy food marketing to children are one of the many approaches
pancreatic,
recommended, recognising the link between food marketing, obesity
endometrial and
and cancer risk.11
Premature death from a variety of consequences related to obesity
will soon become the norm, with six million Australians projected to be
obese by 2020.12 If we can halt or stabilise obesity levels in Australia,
half a million lives could be saved by 2050.12 Changes in diet and
physical activity levels could prevent 25% of the cancers projected to
be diagnosed by 2023.13
breast cancer.
If we can halt or stabilise obesity levels in Australia,
half a million lives could be saved by 2050.
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Children’s Health or Corporate Wealth?
Energy-dense nutrient-poor foods or foods that are high in kilojoules but offer
little nutritional value make up over a third of children’s daily energy intake.
The 2007 Australian National Children’s Nutrition and Physical Activity Survey found sugars
contributed 22-26% and saturated fat contributed 13-14% of children’s daily energy,
exceeding recommendations in both cases.7 Energy-dense nutrient-poor foods or foods that
are high in kilojoules but offer little nutritional value make up over a third of children’s daily
energy intake.14 This is alarming given that these foods including cakes, biscuits, fast foods
and confectionery are considered discretionary foods, that should only be included
sometimes in a healthy diet.15
Across the population, overweight and obesity represent a
significant health problem, including nearly a quarter of Australian
children. The risks related to obesity are alarming and include a
range of chronic diseases, including type 2 diabetes,
cardiovascular disease and some cancers.
Restricting unhealthy food marketing to children is one way of
reducing the burden of obesity on society and individuals. Food
marketing restrictions should be part of a comprehensive and
sustained approach to improving the health of Australian children
and reduce obesity amongst adults in the future.
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Children’s Health or Corporate Wealth?
The effects of food marketing to children
A recent summary of systematic reviews of the evidence brings together almost 40 years of
evidence on the influence and effect of food marketing to children.16 Food promotion
influences children’s nutrition knowledge, food preferences and purchase behaviour;
encourages them to ask their parents to purchase foods they have seen advertised;
influences the food they eat and ultimately impacts on their health.16 The majority of foods
promoted to children are energy-dense nutrientpoor.16 There is now a body of evidence that indicates
food marketing is a modifiable risk factor for children’s
The high exposure of
health.16
children to unhealthy food
marketing in Australia is
one element among a
complex set of factors that
contribute to the growing
waistlines and poor health
of Australia’s children.
The high exposure of children to unhealthy food
marketing in Australia is one element among a
complex set of factors that contribute to the growing
waistlines and poor health of Australia’s children.
Measures to limit unhealthy food marketing to children
need to be part of the range of strategies implemented
to reduce obesity rates.17 Studies comparing potential
interventions to address obesity have been identified,
and restricting unhealthy food marketing on television
has the greatest overall effect (although small per
child)18 and would be the most cost effective
intervention.19
Effects of food marketing on children: summary of the evidence.
Weight of
evidence
Effects on food purchases
Strong
Effects on category sales and/or brand switching
Strong
Effects on food knowledge
Modest
Effects on food preferences
Modest
Effects on food consumption
Modest
Effects on diet-related health
Modest
Extent relative to other influences
Modest
Adapted from Cairns G, Angus K, Hastings G, Caraher M. Systematic reviews of the evidence on
the nature, extent and effects of food marketing to children. A retrospective summary. Appetite
2013; 62:209-215
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Children’s Health or Corporate Wealth?
The role of food marketing
Research has consistently linked increased television viewing with the risk of becoming
overweight or obese. Conventional wisdom would suggest that this is due to the inherently
sedentary nature of watching television, rather than engaging in more active pursuits.
However research has revealed that television viewing does not displace physical activity,
with people who watch high amounts of television participating in as much (or as little)
physical activity as people who don’t watch television.20 Low physical activity levels and high
screen time have been independently linked with increased risk of overweight and obesity in
Australian children.21
Commercial television viewing (i.e. television with advertisements)
has been associated with obesity in young children.
Commercial television viewing (i.e. television with advertisements) has been associated with
obesity in young children, but similar levels of non-commercial television viewing is not
associated with obesity.22 Children also hold positive attitudes to unhealthy food when they
watch commercial television.23 This suggests that unhealthy food advertising on television,
rather than or in addition to the sedentary nature of the activity itself, contribute to the link
between television viewing and obesity.
We now know that television food marketing can explain (at least part of) the link between
watching television and poorer diet/obesity. The mechanisms through which this occurs are:



Immediate, by influencing snacking habits and choices;
Short term, by altering attitudes to unhealthy foods and food requests; and
Long term, by changing foods eaten and overall
dietary patterns.
Attitudes to unhealthy foods
The unhealthy diet promoted through advertising
undermines parents’ attempts to create an understanding
of a healthy diet in their children. Australian children who
view more television are more likely to hold positive
attitudes towards unhealthy foods, including the perception
that their peers consume high amounts of these foods.23
These children are also more likely to consume unhealthy
food.23 This provides evidence that an unhealthy diet is
influenced by exposure to unhealthy advertising and the
perception that eating these foods is normal.
The unhealthy diet
promoted through
advertising undermines
parents’ attempts to
create an understanding
of a healthy diet in their
children.
Decreasing unhealthy food marketing to children
may help improve their diet in the long term.
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Children’s Health or Corporate Wealth?
Brand loyalty refers to the creation of a relationship with a customer, so that they repeatedly
purchase a company’s product over competitors. Brand loyalty can therefore create positive
attitudes towards unhealthy foods. Brand loyalty develops at a young age, with one study
finding that three to five year olds prefer branded foods over identical non-branded foods24.
This loyalty is aided by exposure to branded advertising on television.
Australian children are estimated to spend an average of
2.5 hours watching TV each day.
Snacking whilst watching television
Watching television is often associated with snacking.25 Food
marketing is associated with increased snack consumption
amongst children, with children who view food advertisements
consuming more than those who view other advertisements.26
Australian children are estimated to spend an average of 2.5
hours watching TV each day.7 Over the course of a year, the
unhealthy food advertising they are exposed to and the
increased snacking associated with television viewing adds
up to additional energy intake that can contribute to weight
gain. Television snacking can contribute a large amount to
diet, approximately 15 to 20% of total daily energy intake.20
International evidence
has found that food
advertising leads to
‘pestering’ by children
that results in parents
buying the less
healthy products
requested.
Longer term effects on diet
Parents will attest to advertising’s success in creating ‘pester
power’ amongst children, and research consistently agrees. International evidence has
found that food advertising leads to ‘pestering’ by children that results in parents buying the
less healthy products requested.27
Studies have found after viewing food advertisements, children are more likely to select
unhealthy products28 and to select these products often despite parental encouragement to
choose healthier options.29
In another study, three year old children who watched more television had higher intakes of
energy and fat and lower intakes of beneficial nutrients, such as calcium and fibre. For each
extra hour of television viewing, there was an increased intake of soft drinks, fast foods and
snack foods and decreased intake of fruit and vegetables.30
Parental experience and a variety of research clearly implicate food
advertising in unhealthy diets of children. Food advertising impacts on
children’s diets by promoting consumption of snack foods whilst
watching television, influencing the foods children request from their
parents and is associated with a poor diet in the long term.
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Children’s Health or Corporate Wealth?
Media literacy
Given the evidence that unhealthy food marketing can have such a dramatic impact on a
child’s diet and understanding of a healthy lifestyle, it is important to consider how and when
they develop an understanding of the true intent of marketing. Media literacy has been
defined as the ability to access, understand and create communications in a variety of
contexts.31 For children this includes the development of skills to critically analyse media,
including advertising and its tactics, to protect them from harmful messaging.32
A detailed understanding of TV advertising, particularly in relation to
persuasive intent, doesn’t develop until early adolescence.
Evidence suggests there are a number of stages involved in the gradual increase in
understanding advertising, with the age and rate at which this develops varying widely
between children, like other aspects of cognitive development.33;34
In the past, some researchers believed an understanding that advertising is designed to sell
products was enough to guard against advertising. For this reason, an age of 12 years was
typically suggested as an age at which advertising restrictions could be relaxed. However,
whether children can distinguish advertising from programming or other content does not
necessarily mean that they also understand its
persuasive role and are not influenced by
advertisements.35 It is recognised that children
It is recognised that
understand the intent of advertising by about the age of
children understand the
eight but not that the advertiser’s intent is to convince the
viewer to buy something they would not otherwise buy.
intent of advertising by
Children may recognise that Ronald McDonald is trying to
make them purchase a product, but they fail to recognise
about the age of eight
the methods he uses or the fact that they may otherwise
but not that the
not have purchased these products.33
Psychologists argue that it is not until the reflective stage
of cognitive development (age 11-16 years) that children
are able to fully understand other people’s perspectives
and the complexities of communication. The associated
ability to make rational judgements and question what
they are being told is needed to make judgements about
the persuasive intent of marketing.34 Therefore
restrictions on food marketing to children should extend
into early adolescence.36;37
advertiser’s intent is to
convince the viewer to
buy something they
would not otherwise
buy.
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Children’s Health or Corporate Wealth?
Although children may understand that advertisements are
attempting to sell products to them, they do not use this knowledge to
protect themselves from the techniques employed.
Improving children’s knowledge of advertising does not always impact upon their preference
for advertised products. Although children may understand that advertisements are
attempting to sell products to them, they do not use this to protect themselves from the
techniques employed.26;37 A study of Australian children suggested that even though they
were aware of the persuasive intent and lack of truth in advertising, they still requested
advertised products from their parents.38
Even though children are
aware of the persuasive intent
and lack of truth in
advertising, they still request
advertised products from their
parents.
In recent years, internet use has increased
dramatically and with this, newer forms of
advertising have emerged. The bulk of research
into media literacy exists for traditional media,
including television food marketing. However the
development of media literacy may be altered for
newer media. For example, when children were
given printed copies of web advertisements, only
10-12 year olds were able to identify a majority of
the advertisements,39 suggesting a delay in
recognition when compared with television
advertising.
Like all cognitive development, children will be able to
recognise and understand marketing at different ages.
Research suggests a detailed understanding of
television advertising, particularly its persuasive intent,
does not develop until at least early adolescence.
In newer media, understanding of advertising
is believed to develop even later.
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Children’s Health or Corporate Wealth?
The power of advertising- tricks of the trade
It has been found that when people are exposed to a high-imagery advertisement they have
a favourable attitude to that product as they falsely believe they have experienced the
product before.40
Across all media, a variety of techniques are used to engage children in food marketing and
persuade them to purchase the advertised products. The number of techniques used is
continually increasing and becoming more and more sophisticated.
Techniques may relate to:



Themes and language to promote the product, like fun or adventure;
External validation of product value, through sponsors, cartoon characters or
competitions; and
Properties of the food itself, like nutrition or taste.
Imagery appealing to children
In 2010, Nestle developed the ‘Allen’s Makes Smiles’ campaign for its Allen’s lollies range.
The campaign included a television advertisement, where a 9m doll walked through city
streets and showered crowds with Allen’s lollies. The advertisement created a sense of
fantasy, with bubbles transforming into lollies, used children and a children’s doll in the
advertisement and used a nursery rhyme (This old man) as the background music. It is
reported that the $2.45 million investment in the campaign created $2.32 of additional
revenue for every $1 spent.41
Advertisements use many different features that attract children including:






Animation – Many advertisements use animation to create a child-like world. The
Cadbury ‘Wouldn’t it be nice’ campaign included an animated world made of
chocolate, even chocolate people and animals.
Bright colours and bold graphics attract adults and
children alike.
Advertisements use
Images of animals, toys, cars – A Kellogg’s LCMs
features that attract
snack bar advertisement featured cartoon style
snails
children including:
Music, songs or jingles – Most parents would
animation, bright
remember the ‘I like Aeroplane Jelly’ of yesteryear.
A 2012 Arnott’s Tiny Teddy biscuit advertisement
colours, images of
included an upbeat soundtrack with dancing ‘Tiny
animals, toys, cars;
Teddy’ and friends.
music, songs or jingles,
Starring children – Many advertisements include
images of children talking about or eating products.
other children; branded
A Kraft Oreo biscuit advertisement showed two
toys; novelty designs;
young children eating Oreo biscuits with a glass of
milk and fighting over the third biscuit.
fun and fantasy, flavour
Branded toys – For example, Chupa Chups
and health benefits.
lollipops feature on branded money tins and the
Mars Company sells branded M&M’s dispensers
shaped like yellow and red M&M’s animated
characters.
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Children’s Health or Corporate Wealth?




Novelty design of food product or food packaging – For example, dinosaur shaped
chicken nuggets or plastic jewellery rings with confectionery as the edible stone.
Emphasis on fun or fantasy – Examples include a McDonald’s hamburger
advertisement where a kettle boiled after resting on a McDonald’s chilli burger38; a
Unilever Paddle Pop advertisement set in the jungle; a Ferrero Kinder Surprise
advertisement where a dad and daughter point out clouds which look like a rabbit
and a monkey; a Nando’s advertisement in which a boy playing with his toys sees his
dinosaur takes a bite out of a car and his plane fly over the chips.
Flavour or taste or a description that implies desirable taste – Mamee noodles
snacks are described as “the crunchiest snacks ever”.
Nutrition or health benefits – For example, Nutri-grain is marketed as ‘Iron man food’
and for boys dreaming of becoming sports people.
Many food companies make use of a company character
to create appeal to children and brand loyalty.
Personalities or characters
Many food companies use company characters to create appeal to children and brand
loyalty. Parents will remember many such characters associated with foods from their
childhood. These characters are often animated and represent children or animals, like
Snap, Crackle and Pop (Kellogg’s Rice Bubbles breakfast cereal) and Freddo Frog (Cadbury
chocolate).
Young children have
been found to prefer
foods from packages
with characters. Even
children who prefer
the taste of other
products will alter
their choice to the
product that includes
a character
A 2011 Australian study in the supermarket found over 350
packages used promotional characters on packages to target
children.42 These included company characters (e.g. Nesquik
Bunny), licensed characters (e.g. children’s entertainers The
Wiggles) and sports stars, celebrities or movie characters.42
Kellogg’s Nutrigrain cereal uses champion athletes and Iron
Men series surfing professionals. Cartoon characters may be
licensed characters such as toys in McDonald’s Happy Meals
which have recently included Nickelodeon characters like
Teenage Mutant Ninja Turtles or characters from the movie
Despicable Me 2. They can also be company-owned
characters, like Coco the Monkey on Kellogg’s Coco Pops
cereal packaging and Paddle Pop Lion on a Streets Paddle
Pop children’s website. Some food packaging features
characters from TV programs or movies, e.g. Willy Wonka
branded chocolates.
Young children have been found to prefer foods from
packages with characters. Even children who prefer the taste
of other products will alter their choice to the product that
includes a character.43
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Children’s Health or Corporate Wealth?
Premiums and competitions
A premium is defined as anything offered with or without additional cost that is intended to
induce the purchase of an advertised product or service.44 The most common example is
toys sold with children’s fast food meals. Other examples include prizes that come in a
breakfast cereal box.
Pairing toys with healthy meals could be used to encourage children
to choose healthier meals, and could therefore be an effective means
of improving their diets.
The fast food industry spent $360 million purchasing toys for children’s meals in 2006, in the
USA alone.45 One study showed that young children choose meals that contain a toy,
regardless of whether these meals are healthy or unhealthy.46 The effect increased when
toys were part of a collectible set46 or run as limited time only.47 Pairing toys with healthy
meals could be used to encourage children to choose healthier meals, and could therefore
be an effective means of improving their diets.48;49
In Australia in 2011, fried chicken chain KFC announced that it would remove toys from all
children’s meals.50 The move has been welcomed by parents and public health
organisations alike. In 2013 Red Rooster did the same, saying on their website, “Red
Rooster has listened to customer feedback and taken the decision to remove toys from our
children’s meals”. McDonald’s and Hungry Jack’s are yet to follow. Both stores still provide
popular figurines or movie characters such as My Little Pony and Transformers with
children’s meals.
Ferrero’s Kinder Surprise chocolate egg contains a toy, presently The Smurfs characters.
According to the Kinder Surprise Australia New Zealand Facebook, the toy “is developed to
appeal to children aged over 3 years of age for their
themes, colouring and assembling”.
Each year, Streets (part of the Unilever) runs a Paddle
Pop lick-a-prize competition which offers prizes linked
to the purchase of product and requiring contestants to
sign in to the Paddle Pop website.
Sports celebrities and sports sponsorship
Many elite athletes
believe they should not
promote unhealthy foods,
but are less supportive of
restriction on food
manufacturers sponsoring
sports organisations.
Sport celebrities and organisations are increasingly
associated with food companies. Olympic swimmer,
James Magnussen fuels his training with Subway. KFC
sponsors Australian Cricket. Kellogg’s Nutrigrain
breakfast cereal is associated with the Iron Man Series.
Cadbury is the ‘official confectionery’ of the Australian
Open (tennis). Research shows that parents misjudge the nutritional content and quality of
products that have sports celebrity endorsements.51
McDonald’s, Coca-Cola and Cadbury were main sponsors of the London 2012 Olympic
Games. Coca Cola led the torch relay and provided samples and branded merchandise to
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Children’s Health or Corporate Wealth?
onlookers. McDonald’s opened the world’s largest fast food restaurant inside the Olympic
village.52 In Australia, each company had special products or packaging tied in with the
Olympic Games, including Green & Gold Cadbury blocks, collectible McDonald’s Olympics
cups and Olympic branded Coke cans. Partnering with the Olympics provided international
exposure to these unhealthy foods.
Many elite athletes believe they should not promote unhealthy foods, but are less supportive
of restriction on food manufacturers sponsoring sports organisations, based on concerns
that reduced funding would be available to support these organisations.53 Parents have also
indicated support for restrictions on unhealthy food and drink sponsorship of elite sport.54
Unhealthy sponsorships are not restricted to the elite level, with food companies supporting
junior sports programs. Nestle runs Milo In2Cricket and McDonald’s sponsors Little Athletics,
where children compete in official vests that feature the McDonald’s logo. Food and
beverage company’s contribution is small with an average of 18% of sponsorship funding for
junior sports clubs.55 This provides an opportunity to create brand loyalty towards these
products from a young age. Most parents are not supportive of their child’s club being
sponsored by unhealthy foods like soft drinks, fast food, snack foods and chocolate or
confectionery.54
Companies use a combination of games, mobile device apps,
websites, social networking sites and sponsorship of anything popular
with children, to create a powerful and engaging advertisement.
Games and other ways to engage
Games using features that appeal to children such as company characters are often not
openly recognisable as advertising and have the potential to engage children beyond that
provided by a 30 second television commercial. Integrated unhealthy food marketing
campaigns that involve character development and stories are not classical advertising but
when presented through a variety of media can influence the food environment as seen
through children’s eyes. These techniques include:



Games – These include games on product packages, like mazes on Kellogg’s Coco
Pops packages, as well as more sophisticated games on-line. The Donut King
website has a Pacman style game where lips chase donuts.
Smartphone/mobile device apps – e.g. Hungry Jack’s Check-in and win app offers
free food when phone owners ‘shake’ their phone in-store. To collect the prize,
people are required to sign in to Facebook which then broadcasts their ‘win’ to their
friends. Lol-a-Coaster is a free game for mobile devices from Stuart Alexander, the
makers of Chupa Chups (lifelessserious.com.au). The game requires lollipops to be
gathered while riding a rollercoaster.
Product based websites - McDonald’s Happy Meal website
(www.happymeal.com.au) has over 35 different games to play. The YoGo Alley
website (www.yogoalley.com.au) by Lion features the character YoGorilla, the
character pictured on YoGo dairy desserts. The website has over 20 games,
encourages membership to unlock special features and levels of games and
promotes interaction through editing your own avatar and posting your game score.
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Children’s Health or Corporate Wealth?


The Unilever Paddle Pop website (www.paddlepop.com.au) has movies featuring the
Paddle Pop lion and friends, competitions, games with a leader board and a
membership portal.
Social networking sites engage users in discussions – a post on the Kinder Surprise
Australia New Zealand Facebook says, “Dreamy Smurf has been sleepwalking again
- hit 'like' to send him down the right path!” and Hungry Jack’s Facebook asked the
question, “What else could possibly make HJ's burgers even better?! We have
something in mind…”
Sponsorship of products, people or events popular with children – Cadbury and
Krispy Kreme promote their products as fundraisers for schools.
Companies use a combination of these techniques to create a powerful and engaging
advertisement, often with a co-ordinated campaign on the web, television, billboards and
magazines, as well as on food packaging.
A range of sophisticated marketing techniques
are used to attract the interest of children.
These include themes of fantasy and fun, novelty,
taste and nutrition.
Toys are frequently sold with children’s meals and given away with
other packaged foods to encourage their purchase,
and sponsorship of community and professional sport allows
exposure to brands and feature popular sporting role models
endorsing unhealthy products.
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Children’s Health or Corporate Wealth?
Exposure: Advertising is everywhere!
The large amount of unhealthy food marketing in Australia distorts the perception of a
healthy diet, particularly for impressionable children. The poor diet encouraged by food
advertising is one low in fruits and vegetables and high in fast food, chocolate and snack
foods.56
Children are exposed to large amounts of advertising in many aspects of daily life, including
television, internet, magazines and billboards. Supermarkets have long been heralded as a
battle ground for parents, particularly check-outs, where child friendly confectionery is in
easy reach.57 However parents are less aware of other, newer forms of advertising to
children, particularly on the internet.58
The advertised diet is mainly confectionery, sugary breakfast
cereals, ready prepared snacks and fast food meals
Television
Australians love their television. On average, 50% of our free time is spent watching
television.59 The average Australian spends over 100 hours watching television each
month.60 Four year olds have been found to spend an average of 2.3 hours watching
television each day.61 Primary school students in NSW spend 1.5 to 2 hours per day on
weekdays and 2.5 to 4 hours per day on weekends in small screen recreation.62
These levels exceed the Department of Health recommendations for appropriate screen
time, which includes all time spent participating in screen-based leisure activities such as
watching TV or DVDs, playing computer games and using the internet. They recommend
that children aged 2 to 5 years have screen time limited to less than one hour per day, whilst
children aged 5 to 12 years should have screen time limited to less than two hours per day.63
Recommendations
Hours/day on screen based
activity
Under 2 year olds
0
2-5 year olds
<1 hour
5-12 year olds
<2 hours
Four year olds spend an average of 2.3 hrs watching television each
day. Primary school students spend 1.5 to 2 hrs per day on weekdays
and 2.5 to 4 hours per day on weekends.
The Department of Health recommends less than two hours per day be
spent on all screen-based activity.
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Children’s Health or Corporate Wealth?
Advertising restrictions most often apply during
dedicated children’s television shows, which are rated
P for Preschool or rated C for Children. Times that
these programs are shown include Saturday mornings
and weekday afternoons. However, the largest
numbers of children actually view television during
traditional prime time hours, from 6 to 9pm,64 watching
programs like Junior Masterchef, Funniest Home
Video Show, The Simpsons and family movies.
Unhealthy food advertisements feature prominently
during these peak television viewing times of
Australian children.65
Over the course of a year, the average child will see
35 hours of food advertising on television alone.
Twenty of these hours or over three school days will
be filled with advertisements for unhealthy foods.56
The most common foods advertised in children’s peak
viewing hours are fast food and confectionery.66
The largest numbers of
children actually view
television during
traditional prime time
hours,
from 6 to 9pm.
Unhealthy food
advertisements feature
prominently during
these times.
A CSIRO study found that the most common techniques specifically designed to appeal to
children in television advertising were nutrition claims, promotional characters and premium
offers. These techniques were used more commonly for unhealthy foods than healthy
foods.67
Internet
“The genius of Internet marketing is that it immerses children in branded environments,
exposes them by stealth to marketing messages that they are only peripherally aware of,
and enrols them as viral agents to extend the reach of marketing to yet more children”.68
The internet is used increasingly by food companies as another avenue to promote food
brands and products to children. The techniques used to advertise to children over the
internet remain similar to those used elsewhere, including fun, fantasy, nutrition and taste.
However the vehicles used for advertising vary widely, and are not always as obvious.
Analysis of food company websites popular with Australian children shows 79% of websites
used ‘advercation’, where information about the company or its foods is presented as
educational material and 28% used ‘advergames’, where branded products and characters
are embedded in interactive computer games.69 Some food manufacturer or fast food chain
websites also feature a kids’ club, where children can sign up to receive special offers and
alerts, reinforcing the importance of creating an ongoing relationship between the child and
the company.69
The interactivity of the internet engages users for several minutes and
enhances the power of the advertisement, extending the consumer
experience beyond the 30 seconds of television advertising.
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Children’s Health or Corporate Wealth?
When visiting food company websites, children are exposed to multiple forms of branding
like logos, products, brand or product spokespersons and brand characters. This heightens
their experience of the brand and creates brand loyalty.70 The interactivity of the internet
engages users for several minutes and enhances the power of the advertisement, extending
the consumer experience beyond the 30 seconds of television advertising.71
‘Advergaming’ is now a common marketing technique,
where food companies create games in which their products,
characters and logos prominently feature.
Advergaming
Young children use the internet most commonly for educational activities but the next most
common activity is to play games.72 Advergaming is now a common marketing technique,
where food companies create games in which their products, characters and logos
prominently feature.70 Children are less aware of the branded content of games and video
clips and that this constitutes advertising.73 A child is more capable of recognising overt
marketing messages, including banners and pop-up advertisements.68
Although a child may not be aware that the game is a form of
advertising, this does not mean it is ineffective. Children may
process the associated branding more deeply than in an
obvious advertisement because they are preoccupied with the
game70 and are trusting and uncritical of its messages.74
Advergames are also effective because positive feelings are
associated with game play, including a sense of achievement,
fun or adventure, and these feelings become associated with
the brands.75
When children play advergames featuring unhealthy foods,
they are more likely to choose unhealthy foods for a snack.
The effect increases with increased exposure,76 which is
encouraged by games having multiple levels, high score
boards and play again options.71
Viral marketing through social media
Advergames are
effective because
positive feelings are
associated with
game play,
including a sense of
achievement, fun or
adventure, and
these feelings
become associated
with the brand
An important element of internet marketing is electronic word
of mouth, more commonly referred to as viral marketing. This
involves prompting website visitors to use email, e-cards or
social media to share information about the product or brand. This is a powerful medium –
on Facebook, Coca-Cola Australia has almost a million likes. Internet engagement is
particularly effective with children, who are more internet and technology savvy than ever
before.
Internet engagement is particularly effective with children,
who are more internet and technology savvy than ever before.
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Children’s Health or Corporate Wealth?
Advertising regulators have determined that
the content of a company Facebook page is considered advertising
and companies are responsible for all content, even fan content.
Popular Australian food companies use marketing techniques like brand logos, viral
marketing, product images and links to company websites on their Facebook pages.
Although Facebook use is restricted to those over the age of 13, it is suspected that younger
children lie about their age to ensure access to this popular social networking site.
Communication techniques used to engage people who ‘like’ a food company’s Facebook
page include news stories, advertisements, surveys, games, competitions and shopping
opportunities. When users become fans of company pages, their friends are immediately
notified and prompted to also become fans, creating the electronic word of mouth associated
with social media and social networking.77
Australian advertising regulators have determined that the content of a company Facebook
page is considered advertising and companies are responsible for all content, even fan
content, as this should be moderated by the company.78;79 This means endorsements from
children or others to consume unhealthy food products, or otherwise engage in an unhealthy
lifestyle, will need to be closely monitored to ensure compliance with advertising codes.
Packaging
Food packaging influences purchase decisions for children and adults alike. A range of
techniques are used by food companies to draw
children’s attention to products and lead them to believe
that these products will taste better than competitor
The most common
products.80
The most common techniques used to target children on
food packages are bright colours, cartoon-like script,
cartoon characters and educational or fun captions.
Other techniques include novelty packaging, celebrity
endorsement, puzzles and movie tie-ins.42;81 Nutrition and
health claims are used on many packages82 to suggest
benefits of the food, even if they are not healthy products.
For example, some breakfast cereals claim they contain
‘no artificial colours and flavours’ but fail to mention that
they also contain large amounts of sugar.
techniques used to
target children on food
packages are bright
colours, cartoon-like
script, cartoon
characters and
educational or fun
captions.
Magazines
Popular Australian children’s magazines contain frequent
references to food. Few of these references are direct advertisements, with many more
subtle mentions of food in recipes, competitions and editorial content. The majority of these
references are for unhealthy foods.83 Children are not aware that these references constitute
marketing. They perceive that products are recommended by editors based on what is
popular or good quality, and do not understand that it is a paid endorsement.84
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Children’s Health or Corporate Wealth?
These forms of advertising are effective, and are known to override children’s natural
choices for foods. Children suggest that taste and healthiness are major influences, yet
children who read magazines filled with unhealthy food marketing are more likely to choose
unhealthy options.85
One Australian study found primary schools had
an average of 57 food billboards nearby, with
80% of food advertisements for unhealthy foods,
like soft drink, alcohol, coffee and ice cream.
Billboards
Outdoor advertising is highly visible, ubiquitous and unlike
television, cannot be turned off. Outdoor advertising is
increasingly using electronic media, links to websites and
interactive marketing.86 Recognising community concern over
outdoor advertising and the potential for exposure of children to
inappropriate content, the Commonwealth House of
Representatives Standing Committee conducted an inquiry into
the regulation of outdoor advertising in 2011.87 One of the
recommendations was that outdoor advertising be included in the
definition of ‘advertising’ used to regulate marketing to children.87
The areas around schools are of particular concern, given the
likelihood of exposure of large numbers of children. One
Australian study found primary schools had an average of 57
food billboards nearby, with 80% of food advertisements for
unhealthy foods, like soft drink, alcohol, coffee and ice cream.88
It has been
recommended that
outdoor advertising
be included in the
definition of
‘advertising’ used to
regulate marketing
to children
Food marketing to children is not just confined to television.
Food marketers are increasingly utilising a range of media
in a single campaign, including more subtle forms like advergaming,
advercation and product placement.
These methods are used in magazines,
on billboards and on the internet.
Worryingly, these are the very areas that parents are
less aware of, less likely to monitor
and hence less able to protect their children from.
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Children’s Health or Corporate Wealth?
Food marketing regulation in Australia; confusing, not
comprehensive
In Australia, food marketing to children is regulated under a combination of government
regulation and voluntary codes, implemented by the communications regulator as well as the
advertising and food industries. This may give the false impression that food advertising to
children is well regulated. However, the loopholes, gaps and continued exposure of children
to advertisements for unhealthy foods suggest that the current approach is inadequate.
More detail of the regulations is provided in Appendix A and a summary is provided below.
Government Regulations
All P-rated programs must
be free of advertising,
whilst C-rated programs
may contain five minutes
of selected advertising per
30 minutes with a single
advertisement broadcast
no more than twice in that
period
The Children’s Television Standards (CTS 2009)44
sets regulations regarding the placement of
advertising in children’s programs. There are
specifications on the number, type and content of
advertising in Preschool (P or P-rated) programs and
Children’s (C or C-rated) programs. All P programs
must be free of advertising, whilst C programs may
contain five minutes of selected advertising per 30
minutes with a single advertisement broadcast no
more than twice in that period. Advertising must be
clear, free of commercial characters and not suggest
that a child who owns or consumes a product is
superior to their peers. Complaints relating to the
CTS are lodged with the Australian Communication &
Media Authority (ACMA).
The Australian Consumer Law is part of the
Australian Competition & Consumer Act (2010)89 and
applies to all advertising in all media. It aims to protect all consumers from misleading and
deceptive advertising. Complaints against products or advertisements are submitted to the
Australian Competition and Consumer Commission.
Co-Regulation
The Commercial Television Industry Code of Practice
(2010)90 is administered by the free-to-air commercial
television industry, through Free TV Australia, and applies
to advertising outside of P and C programs. The Code
covers classification, content and placement of programs
and advertisements, and includes a small number of
provisions relating to the promotion of food and
beverages. Television advertisements directed to children
“should not encourage or promote an inactive lifestyle”
and “should not encourage or promote unhealthy eating
and drinking habits”, which is further defined as
“excessive or compulsive consumption”. The nutrition
value of products should also not be misrepresented.
Television advertisements
directed to children
“should not encourage or
promote an inactive
lifestyle” and “should not
encourage or promote
unhealthy eating and
drinking habits”.
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Children’s Health or Corporate Wealth?
Complaints about the content of advertisements must be lodged firstly with the television
station on which the advertisement was shown, then with the ACMA if the response is not
adequate. The Code is classified as co-regulatory because ACMA has the authority to apply
the government regulations (CTS), if these are deemed applicable.
Industry Self-regulatory Initiatives – Advertising Industry Codes
The Australian Association of National Advertisers (AANA) represents the advertising,
marketing and media industry in Australia. The AANA has
developed three codes which relate to marketing across all
platforms:



AANA Code For Marketing and Advertising
Communications To Children91
AANA Food & Beverages: Advertising and Marketing
Communications92
AANA Code of Ethics93
All three codes include a range of specific clauses relating to
marketing to children. Advertisements must not encourage or
promote an inactive lifestyle and unhealthy eating or drinking
habits amongst children. There are also provisions relating to
use of premiums, statements regarding price and creating a
sense of advantage over other children when owning
products.
There are also
provisions relating to
use of premiums,
statements regarding
price and creating a
sense of advantage
over other children
when owning
products
Complaints can be lodged with the Advertising Standards Bureau (ASB) if companies are
suspected of breaching one of the AANA codes.
Industry Self-Regulatory Initiatives – Food Industry Codes
In what appears to be a response to increasing pressure from parents, public health
organisations and the broader community, the Australian food and beverage industry has
created two voluntary initiatives designed to demonstrate responsible practices in food
marketing to children. Self-regulation is favoured by the industry, and is often implemented
as a first step, prior to government regulation.94
Responsible Children’s Marketing Initiative
The Australian Food and Grocery Council has developed the Responsible Children’s
Marketing Initiative (RCMI) to provide “a common framework to ensure that only food and
beverages that represent healthier choices are promoted directly to Children”.95 It was first
implemented in January 2009 and applies to 17 major food company signatories.
The Responsible Children’s Marketing Initiative signatories
agree to restrict marketing to children under the age of 12
unless products represent healthy dietary choices.
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Children’s Health or Corporate Wealth?
The RCMI signatories agree to restrict marketing to children under the age of 12 unless
products represent healthy dietary choices. Companies set their own nutrition criteria in a
Company Action Plan to categorise products that represent healthy dietary choices. The
RCMI covers a range of media, including television, radio, print and cinema. An updated
initiative took effect in January 2014.95
Quick Service Restaurant Initiative
The Australian fast food industry, in collaboration with the AANA, also developed the Quick
Service Restaurant Initiative for Responsible Advertising and Marketing to Children (QSRI)
in August 2009, with similar aims to those of the RCMI.96 Participants to this initiative include
some of the most popular fast food companies in Australia (image below).
The core principles of the QSRI state that any marketing targeted to children, defined as
under 14 years of age, must represent healthy foods in the context of a healthy lifestyle
(including physical activity and a healthy diet).96 Marketing to children covers multiple
media, including television, radio, magazines, newspapers, billboards, emails, internet sites
and cinemas.96 A standardised set of nutrient criteria define children’s meals that can be
advertised.96
This initiative is now managed by the Australian Food and Grocery Council. An updated
Initiative was implemented in November 2012 and another update took effect in January
2014.96
All complaints about the QSRI and RCMI are assessed by an independent body, the
Advertising Standards Bureau (ASB).
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Children’s Health or Corporate Wealth?
Limited impact of Self-regulatory Initiatives
Studies examining the impact of the food manufacturers’ self-regulatory initiatives have
found that signatories have reduced the number of unhealthy food advertisements per hour
since the initiatives were introduced. However, the majority of food advertising continues to
be for unhealthy foods, with signatories overrepresented amongst those advertising
unhealthy foods.97
Since the introduction of the QSRI, the amount of fast food advertising on television has
actually increased. Although there have been some changes in the types of foods or meals
advertised by fast food companies, children remain exposed to large amounts of fast food
advertising.56;98
There are discrepancies between independent studies and company reports on their activity.
This has been recognised worldwide culminating with the publication of a systematic review
of initiatives which found scientific peer-reviewed papers showed high levels of advertising of
less healthy foods but industry sponsored reports showed high adherence to voluntary
codes.99 A 2012 study of compliance with Australian regulations and industry initiatives
found 301 breaches of the RCMI, 29 breaches of the QSRI and
619 breaches of the Children’s Television Standards over a two
month period.100
In 2012, the Australian National Preventive Health Agency
found that 57% of all food advertisements shown during
children’s programs were for unhealthy foods, despite current
self-regulatory initiatives.101
The continued exposure of children to large amounts of
unhealthy food advertisements is due to a number of loopholes
and gaps that exist within the current regulatory framework
which will be discussed in the next section. This is also
supported by the 2013 systematic review that concluded
adherence to voluntary codes may not reduce the advertising of
unhealthy foods or the exposure of children to that advertising.99
Since the
introduction of the
QSRI, the amount
of fast food
advertising on
television has
actually increased.
A mixture of government regulation, co-regulation and industry self-regulation
is currently in place, which aims to ensure only healthy foods are marketed to
Australian children. Yet research monitoring the impact of these voluntary
initiatives demonstrates that the current fragmented system is failing to
reduce children’s exposure to advertising for unhealthy foods and beverages,
therefore failing to limit the unhealthy influence of these advertisements on
children’s preferences and their diet.
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Children’s Health or Corporate Wealth?
Loopholes and limitations in the self-regulatory initiatives
Experience since the implementation of self-regulatory initiatives has demonstrated that they
are ineffective in reducing children’s exposure to advertising for unhealthy foods. Reading
complaints made by community members to the ASB and the responses by the advertiser
and ASB demonstrates a disparity between the community’s understanding of the intent
behind the initiatives and the intentions of those who administer them.
Self-regulatory initiatives are ineffective
in reducing children’s exposure to advertising for unhealthy foods.
Industry initiatives don’t apply to all companies
Although many of the largest food and beverage companies are signatories to the selfregulatory initiatives, they are still voluntary. A study in 2009 found that 11 of the 36
companies who advertised on television were signatories.97 The RCMI has 17 signatory
companies, with many major food and beverage companies.102 However, common
advertised foods such as the Natural Confectionery Company range of products, Lindt
chocolates and Chupa Chups are not covered as the company is not a signatory. There are
seven signatories to the QSRI102 but this does not include large companies such as Nandos,
Donut King and Subway.
Media is only covered where the audience is predominantly children and/or
having regard to the theme, visuals, and language used are directed primarily
to children.
Under the definitions of the RCMI and the QSRI,
regulations are applicable to all advertisements screened
in P- and C-rated programs, selected G programs and
some other programs popular with children.
These conditions allow unhealthy food advertisements to
appear during programs which are popular with children,
if the programs are also popular with other audiences.
This means that complaints made about advertisements
in family shows like Masterchef and Home & Away are
dismissed. Ratings data reveals that the highest
numbers of Australian children watch television at these
times.64
Unhealthy food
advertisements are
allowed to appear during
programs which are
popular with children, if
the programs are also
popular with other
audiences.
For example, in 2012 Oporto screened an advertisement
during a number of movies that were rated G and most
would argue, are children’s movies. These included
Shark Tale, The Lion King & Bee Movie. Ratings data revealed that 41% of the Shark Tale
audience, 36% of the Lion King audience and 39% of the Bee Movie audience were under
the age of 18. Even at these levels, the child audience fails to reach the 50% threshold set
under the new QSRI.96 Data from 2006 shows that the percentage of 0-14 year olds in the
free-to-air television audience peaks at just over 30% in the 8-9am timeslot and 16% in the
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Children’s Health or Corporate Wealth?
7-8pm timeslot.64 Therefore very few programs would have an audience of over 50% under
12 year olds.
Only advertisements ‘directed primarily to children’ are covered
The QSRI and RCMI state that for advertisements to be considered under these initiatives
they must be ‘directed primarily to children’. The wide variety of techniques used to appeal to
children, and the lack of specificity in the initiatives in this regard, make it difficult to identify
which advertisements are targeted to children and hence to which advertisements
restrictions apply. Advertisements which aren’t directly targeted to children but may still
appeal to them slip through this loophole. In one study of television advertisements, only 3%
of advertisements made a direct address to children, whilst many more used techniques that
would appeal to children, such as images of children enjoying themselves, consuming the
advertised product and playing with friends.103
Advertisements which aren’t directly targeted to children
but may still appeal to them slip through this loophole.
A complaint regarding an Oreo television commercial where two children, who are brother
and sister, eat Oreo biscuits together and go through the ritual of ‘twist, lick and dunk’ was
dismissed. Kraft is a signatory to the RCMI. The complaint was dismissed under the RCMI
because the ASB found that although “there were elements of the advertisement that would
draw the attention of children to the advertisement”, “the theme, visuals and language are
adult in theme and not primarily directed to children but rather to the main grocery buyer.”
(Case report 0225/12).
Advertisements for fast
food often depict children
consuming fast food
products with their family.
A complaint regarding the Kids Club section of the
Cold Rock website was dismissed by the ASB
because “the overall website is directed primarily at
the main grocery buyer” even if “young children may
enjoy some of the components of the site”. (Case
report 0234/12).
Advertisements for fast food often depict children
consuming fast food products with their family.
Whilst clearly showing children consuming fast food
products, these advertisements are not considered
as advertising to children, because they are
primarily targeted to their parents. For example, a 2012 advertisement for a KFC family
dinner box clearly showed two children eating KFC. After a complaint was made, KFC stated
that “the advertisement’s primary purpose is to appeal to mothers over the School Holiday
period and assist mothers come up with a dinner solution”. The ASB agreed that the
advertisement was ‘not directed to children’ and hence dismissed the complaint (Case report
0178/12).
In 2012 Lindt broadcast a TV advertisement that featured a young girl being prompted by a
Lindt ‘chocolatier’ to find the chocolate gold bunnies. Animated bunnies then came to life,
twitching their noses and hopping about. The young girl carried away a 1kg chocolate bunny
at the end of the advertisement. The advertisement used young children and created a
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Children’s Health or Corporate Wealth?
sense of imagination to appeal to children. It was screened during movies popular with
children, including Bee Movie (rated G) and Harry Potter and the Goblet of Fire. A complaint
was lodged with the ASB, however the advertisement was determined to be “directed more
to adults”, and hence the children’s advertising initiatives were not applicable (Case report
0139/12).
If the product is not primarily a children’s product, then the advertisement
is not considered to be directed primarily to children
Only advertisements for ‘children’s products’ are considered under AANA
codes
The AANA codes only consider advertisements which are targeted to children and that are
for children’s products. Food products are often determined to appeal to a wide range of
people, rather than being a dedicated children’s product. If this is the case and the product is
not primarily a children’s product, then the advertisement is not directed primarily to children.
For example, in referring to a Chupa Chups complaint, the company said that Chupa Chups
are “enjoyed by many adult consumers including famous celebrities such as Madonna,
David Beckham, Kirsty Alley and the 1970’s television character Kojak” (Case report
0136/12).
Nutrient criteria vary widely and some unhealthy products qualify as healthy
There are currently 17 different companies signed up to
the RCMI, thus there are 17 different nutrient criteria
The company defined
used to assess the ‘healthiness’ of foods advertised to
criteria consider many
children. This makes it difficult for consumers to
determine which nutrient criteria apply to
chocolates, confectionery,
advertisements and hence whether they are in breach
of the self-regulatory initiatives. Signatories to the
snack foods and sugar
RCMI establish their own nutrient criteria, which results
sweetened drinks as
in lenient criteria that allow companies to promote the
majority of their products including less healthy
healthy enough to be
products such as Kellogg’s Coco Pops. The company
promoted to children
defined criteria consider many chocolates,
confectionery, snack foods and sugar sweetened drinks
as healthy enough to be promoted to children although
this would not be the case using widely accepted nutrition criteria such as the Heart
Foundation Tick.104
While the QSRI has standardised nutrition criteria for all companies, the criteria only apply to
‘children’s meals’. Therefore the healthiness of fast foods promoted to children, other than
dedicated children’s meals, is not covered by the initiative. This means that family meals and
individual menu items such as special burgers are not covered as they are not considered as
product marketed to children. Studies looking at family meals at fast food restaurants have
found that a child’s portion of the meal exceeds the maximum proportion of unhealthy
nutrients that a meal should provide, based on recommendations for maximum daily
consumption of these unhealthy nutrients.98
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Children’s Health or Corporate Wealth?
Regulations on food marketing to children in the United Kingdom utilise a nutrient profiling
model to determine which foods are healthy and unhealthy.105 This scientifically robust tool
has been adapted for use in Australia106 regarding health claims on food packaging, and
could be utilised to regulate food marketing to children. The World Health Organization
recommends that where a food classification system already exists the same system should
be used to avoid inconsistencies and repetition.2
Advertisements can promote unhealthy products
if they are shown in the context of a ‘healthy
lifestyle’
Complaints about advertisements are often dismissed
because the food advertised is represented in the context
of a healthy lifestyle. For example a complaint about
Oreo’s chocolate cookies depicting an unhealthy snack in
a lunchbox alongside a sandwich and piece of fruit was
considered to promote a ‘healthy lifestyle’ because the
rest of the lunchbox was healthy. Placing a football on the
seat next to children was considered to promote physical
activity, even if the focus of the advertisement was the
children arguing about who gets to eat the Oreo biscuit
(Case Report 0363/10).
Placing a football on the
seat next to children is
considered to promote
physical activity, even if
the focus of the
advertisement is the
children arguing about
who gets to eat the Oreo
biscuit
A 2012 television advertisement for Haribo gold bears depicted a young girl conducting a
mock experiment, while dressed in a white lab coat and glasses. The experiment tested
whether a series of young children could resist eating the lollies. The girl concluded “The
evidence is clear, Haribo is just too good”. In response to a complaint to the ASB, it was
found that although the advertisement “appealed primarily to children” and the product
advertised was of “principal appeal to children”, children were only seen to consume 4 or 5
lollies which does not constitute an unhealthy eating habit under the AANA codes (Case
report 0406/12).
Use of brands are not considered food advertising
Although the
advertisement was
considered to be directed
primarily to children, there
were no food products
shown, only the
McDonald’s brand. Thus
the QSRI was not applied
and the complaint was
dismissed.
Food companies are able to advertise the company (i.e.
McDonald’s) or product range (i.e. Happy Meal) if food
products are not present. For example, a 2011
complaint about the Happy Meal website was dismissed
because there was “only one substantive reference to
McDonald’s or Happy Meals” and the website does not
“actively encourage children to buy the product”.
In 2012, McDonald’s ran a promotional competition
known as ‘MacPack’ which included television
commercials. The advertisement included children
travelling to and from the MCG to play football, whilst
wearing McDonald’s caps and jerseys. Children could
be heard cheering in the background. Although the
advertisement was considered to be directed primarily to
children, there were no food products shown, only the
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Children’s Health or Corporate Wealth?
McDonald’s brand. Thus the QSRI was not applied and the complaint was dismissed (Case
report 0324/12).
In 2011 a print advertisement for a ‘Paddle Pop Adventure Park’ was dismissed. The
advertisement was a flyer featuring cartoon animals standing on a beach in front of a jungle,
with text “Are you ready to ride the wild slide? The world's longest slip-n-slide. The Paddle
Pop Adventure Park comes to Sydney these school holidays.” In the case report, the ASB
noted “Although the Paddle Pop branding appears on the advertisement there is no
depiction of the product and no mention of consuming the product… The advertisement did
not discourage good dietary habits as it makes no mention of consumption” (Case Report
044/12).
Food companies are permitted to market unhealthy products
on their own websites without restrictions
Company owned websites require 35% of users to be children
Until 2014, the definitions of the RCMI do not cover company-owned websites, only
advertisements on third party websites. This allowed food companies to market unhealthy
products on their own websites without restrictions. A complaint regarding the YoGo Alley
website, where children are able to play a range of games featuring YoGo characters and
find information about YoGo products, was found to not breach the RCMI. “The theme,
visuals and language are primarily directed to children”, however “as the website appears on
the advertiser’s own website and not a third party website, the requirements of the RCMI do
not apply”107 (Case report 0196/12).
The revised initiatives mean that all websites, including company-owned websites, will be
covered under the RCMI and QSRI, provided that 35% or more of website visitors are
children.108
The initiatives apply to websites provided that 35% or more of website
visitors are children
Food packaging and supermarket advertising is not restricted
Current regulations do not cover food packaging or supermarket displays. Company-owned
characters like the Nesquik bunny, Freddo Frog, Paddle Pop Lion and Coco the Monkey
(Coco Pops) are common on packages, in fact 90% of the characters found on supermarket
products in 2011 were company-owned.42
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Children’s Health or Corporate Wealth?
The delay between the broadcast of the advertisement,
the complaint being submitted and the ASB considering the complaint
means that the advertising campaign has finished and
any advertising impact and commercial benefit has been achieved.
The complaints process deters consumer complaints but fails to deter
breaches
Few complaints lodged with the ASB regarding the RCMI and QSRI have been upheld even
when logic would suggest that a particular advertisement was promoting unhealthy food to
children. Even when complaints regarding the self-regulatory initiatives are upheld, the
repercussions are minimal. In most cases, the delay between the broadcast of the
advertisement, the complaint being submitted and the ASB considering the complaint means
that the advertising campaign has finished and any advertising impact and commercial
benefit has been achieved (Case reports; Hero or Villain Paddle Pop 0454/11, Nestle
Smarties 0407/10, Hungry Jack’s print ads 0428/10 & 0427/10).
In other cases where a breach was found, the advertisement may be removed from use (i.e.
McDonald’s website banner – Case Report 0523/10) or only minor adjustments are made,
including altering the programs in which the advertisement can appear (i.e. Oreos Sippy Cup
– case report 0136/11, Nestle Drumstick – Case Report 0482/10, Oreos Playground Boys –
Case Report 0409/10). There are no financial consequences for companies to effectively
deter breaches in the first place.
For example, a 2009 complaint regarding a Hungry Jack’s advertisement for its Kids Club
Meals was upheld by the ASB (Case report 573/09), yet the advertisement was repeatedly
used in 2010. Further complaints were made and upheld (Case reports 32/10, 0427/10 and
0428/10), but there were no repercussions for Hungry Jack’s for these continued breaches.
The current regulations are not effective.
They do not cover all media in which children are exposed to
advertising and do not cover all techniques used.
Weak definitions minimise the effect the regulations can have on
reducing both the exposure and power of unhealthy food marketing
to Australian children.
The slap on the wrist approach used in enforcing the regulations
further limits the ability to drive compliance
amongst signatory companies.
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Children’s Health or Corporate Wealth?
The International situation
Unhealthy food marketing is an area of concern to governments and health authorities in
many countries, with reference to food marketing to children contained within government
plans, policies and strategies to reduce obesity and promote healthy eating habits among
children. Most countries have supported self-regulatory measures to curb unhealthy food
marketing to children, where food industry groups develop guidelines or codes for member
companies. Many governments, including the Australian government, have demonstrated
their support for self-regulation.5
As of 2011, some form of statutory regulations existed in only eight countries, including the
United Kingdom, South Korea, Ireland and France.109 No country has comprehensive
statutory regulations in place to protect children from all forms of food marketing.
No country has comprehensive statutory regulations
in place to protect children from all forms of food marketing.
In France, the Public Health Law includes a regulation that requires messages on
advertisements for foods and drinks.109 Ireland has banned the use of celebrities in
children’s food advertising and has required warnings on fast food and confectionery
advertisements since 2005.109 Malaysia, has a statutory regulation that restricts the
advertising of fast food to children aged 4 – 9 years.109
The UK experience
In 2007 the Office of Communication and the Food Standards Agency in the UK jointly
implemented regulations designed to restrict the marketing of unhealthy foods to children
under the age of 14 on television.110 Foods are categorised into high fat, salt, sugar products
(HFSS) or non-HFSS using a nutrient profiling model. This
model determines the nutritional quality of foods, based on the
comprehensive range of nutrients considered and the use of a
standard portion – 100g. HFSS products cannot be advertised
In the UK high fat, salt
to children in and around children’s television programs or on
and sugar products
dedicated children’s channels.
A 2010 review found that children’s exposure to
advertisements for unhealthy HFSS products had reduced by
37% since regulations began. However, there had been a
complementary increase in exposure to marketing of
unhealthy HFSS products outside of children’s programs and
an overall increase in children’s exposure to HFSS
marketing.110 Unfortunately, whilst the regulations have been
effective in gaining compliance, they are not comprehensive
enough, as unhealthy food marketing is not restricted outside
of children’s programs when large numbers of children are
watching.
cannot be advertised
to children in and
around children’s
television programs or
on dedicated
children’s channels.
Page | 33
Children’s Health or Corporate Wealth?
The Quebec case
Since 1980, all forms of commercial advertising to children under the age of 13 has been
restricted in the Canadian province of Quebec.111 This includes children’s products across a
range of media. Television advertisements for
children’s products are banned in programs where
children constitute more than 15% of the audience.112
It seems no accident that children from Quebec have
rates of obesity lower than the national average for
Canada (23% vs. 26%).113;114 French speaking
children are more affected by the advertising ban
than their English speaking counterparts, because
they have less access to media from outside
Quebec.115 Those households in Quebec with
children consume less fast food115 which suggests
these children consume a healthier diet, based on
reduced exposure to unhealthy foods via marketing.
This ban would be more effective if media markets
did not overlap in Quebec and the ban applied to all
media.115
In Quebec, television
advertisements for
children’s products are
banned in programs
where children constitute
more than 15%
of the audience.
Children from Quebec
have rates of obesity
lower than the national
average for Canada.
Some argue that the regulations are not as effective
as they could be, as restrictions only apply to
programs where more than 15% of the audience is
children and the product advertised is a children’s
product. Thus, children continue to be exposed to
some unhealthy food marketing that occurs during
family viewing periods and that advertises products that appeal to a range of ages.111
South Korea
In South Korea, the Special Act on Safety Management of Children’s Dietary Life came into
effect in September 2010. It restricts TV advertising of energy-dense nutrient-poor foods
between 5pm and 7pm.116
Other countries
Some countries, including Norway and Spain have government approved self-regulations.117
Around the world a number of countries have expressed concern
about the levels of food marketing to children on television and in
other media. However, few countries have produced government
regulations, with self-regulation currently the most common.
Government regulations have been implemented in the United
Kingdom and the Canadian province of Quebec, with some success.
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Children’s Health or Corporate Wealth?
Support for Government action
Government action to strengthen regulation will not occur without strong support from range
of stakeholders. Public health organisations will need to demonstrate that regulation will be
effective in reducing the unhealthy influence of food advertising on children’s eating habits.
Governments must recognise the importance of regulating food marketing to children and be
genuinely committed to reducing their exposure. Equally important will be cooperation from
the food and advertising industries to implement restrictions and market food responsibly.
The Australian public is generally supportive of restrictions designed to support parents to
promote the health of their children and reduce the future burden of overweight and obesity
on Australian society.118
Governments must recognise the importance of regulating food marketing
to children and be genuinely committed to reducing their exposure.
World Health Organization
The World Health Organization (WHO) has officially
recognised the importance of restricting unhealthy
food marketing to children. In 2010 a Set of
recommendations on the marketing of foods and nonalcoholic beverages to children1 was produced.
Regulations are required to reduce children’s
exposure to unhealthy food advertising and to ensure
the power of marketing communications is reduced,
through restrictions on the techniques used to appeal
to children. In 2012 the WHO published a framework
that outlines a set of recommendations to support
governments to implement policies and regulations
that would reduce the impact of food marketing on
children.2
The Australian public health community
“Efforts must be made to
ensure that children
everywhere are protected
against the impact of such
marketing and given the
opportunity to grow and
develop in an enabling
environment – one that
fosters and encourages
healthy dietary choices
and promotes the
maintenance of weight”
(Dr Ala Alwan, Assistant DirectorThere is strong support among public health groups
General of WHO, 2010)
in Australia for improved government regulation of
unhealthy food marketing to children across all
media. These groups see food marketing restrictions
as one of a number of strategies that need to be
implemented to reverse rising rates of overweight and obesity in Australia, by modelling
healthy eating habits to children.
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Children’s Health or Corporate Wealth?
There is strong support among public health groups in Australia
for improved government regulation
of unhealthy food marketing to children across all media.
The Australian Chronic Disease Prevention Alliance is a collaboration of five leading chronic
disease groups –Cancer Council Australia, the Heart Foundation, Kidney Health Australia,
Diabetes Australia and the Stroke Foundation. The Australian Chronic Disease Prevention
Alliance aims to work together to reduce the burden of chronic disease by reducing risk
factors like poor nutrition, physical inactivity, overweight and obesity. The group is supportive
of government regulations on food marketing to children and in 2011 the Chair stated: “If we
really want to reduce our children’s exposure to unhealthy food advertising then the
government must bite the bullet and introduce effective mandatory restrictions as soon as
possible”.119 Individual Australian Chronic Disease Prevention Alliance member
organisations have detailed position statements supporting stronger government regulation
of food marketing to children.
Cancer Council has been advocating for better regulation of food marketing to children for
over a decade as just one of a number of steps to promote healthier choices. Evidence
shows that the current self-regulatory system has failed to protect children from the
unhealthy influence of food marketing of fatty, sugary, salty and high-kilojoule foods and
drinks.
The Australian Medical Association is also supportive
of restrictions on unhealthy food marketing to
children, as indicated in its 2009 Position Statement
on obesity.120 The Association also believes that
current self-regulatory initiatives have not been
effective and government regulation is required.121
The Obesity Policy Coalition identifies, analyses and
advocates for evidence based policy and regulation
to reduce overweight and obesity at all government
levels. In its report, Exposing the Charade, The
failure to protect children from unhealthy advertising,
the Obesity Policy Coalition calls for national
legislation to restrict unhealthy food marketing at
times when large numbers of children are watching
television.122
“As a community we must
help young people make
the right choices about the
foods they eat, and this
will help to reduce levels
of overweight and obesity
among young Australians”
(Dr Andrew Pesce, AMA
President, 2011)
The Public Health Association of Australia Marketing of food and beverages to children
policy calls for Commonwealth legislation to ban all food advertising on television when
children comprise the majority of the audience. They are also supportive of the development
of regulations on food marketing across other media.123
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Children’s Health or Corporate Wealth?
In 2009, the Australian government’s
National Preventative Health Taskforce recommended
a comprehensive, multi-faceted approach to
reduce levels of childhood obesity and create a healthy environment.
Australian Government
In 2009, the Australian Government’s National Preventative Health Taskforce recommended
a comprehensive, multi-faceted approach to reduce levels of childhood obesity and create a
healthy environment. They recognised restrictions to unhealthy food marketing to children as
one element of this approach in Action 5.1.4
Action 5.1 stated “Phase out the marketing of energydense nutrient-poor food and beverages on free-toair television and Pay TV before 9 pm within four
years. Phase out premium offers, toys, competitions
and the use of promotional characters, including
celebrities and cartoon characters, to market EDNP
food and drink to children across all media sources.
Develop and adopt an appropriate set of definitions
and criteria for determining EDNP food and drink.”4
In 2010, the response to this recommendation by the
Australian government suggested “change is
currently being achieved through a combination of
Government regulation, industry self-regulation and
new television initiatives… The Commonwealth
Government will continue to monitor the impact of
these initiatives to ensure their effectiveness …
allowing for voluntary measures to be trialled with
action to follow if necessary.”5
“The Commonwealth
Government will continue
to monitor the impact of
these initiatives (voluntary
industry codes) to ensure
their effectiveness ….
allowing for voluntary
measures to be trialled
with action to follow if
necessary.”
Taking Preventative Action – the
Government’s response to the
report of the National
Preventative Health Taskforce
2010.
In 2012, a review on behalf of the Australian National
Preventative Health Agency examined the
effectiveness of the current self-regulatory initiatives
in reducing food marketing to children in Australia. It
found that 57% of all food advertisements shown
during children’s programs were for unhealthy foods.
The report recognised that the high level of unhealthy food advertising on Australian
television is problematic.101
Staff from all levels of government have recognised restrictions on unhealthy food marketing
as a potential strategy for promoting a healthier environment. This approach has also been
given the most support over other interventions, although potential barriers are frequently
mentioned, including lack of support from the food industry, the need for more solid evidence
and conflicting government priorities.124
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Children’s Health or Corporate Wealth?
A 2011 survey of South Australian parents found that the
overwhelming majority were in favour of the government regulating
the way in which food and beverages are marketed to children.
Support among parents and Australian community
A 2011 survey of South Australian parents found that the overwhelming majority were in
favour of the government regulating the way in which food and beverages are marketed to
children. Parents suggested that television advertising was effective at creating purchase
requests from their children, particularly advertisements for chocolate, lollies and fast food.3
Broader surveys of the Australian population, conducted in 2010, have revealed similar
support for regulations on unhealthy food marketing to children. These include regulations
for television, websites, email and SMS and for sponsorship arrangements. The public is
more supportive of these initiatives than taxation.118
Regulation of unhealthy food marketing to children is
recommended by the World Health Organization,
Australia’s leading public health groups and the Government’s
own National Preventative Health Taskforce.
Stronger regulation on unhealthy food marketing to children
is widely supported by the Australian population,
with the majority favouring government intervention.
Page | 38
Children’s Health or Corporate Wealth?
Recommendations for action
If Australia is to be successful in reducing the impact of unhealthy food marketing to our
children, some key changes will have to be made to the current regulatory environment. In
May 2012, key stakeholders gathered for a seminar on food marketing to children in
Australia arranged by the South Australian Health minister and the National Preventive
Health Agency.125 Twenty-one recommendations were presented in a discussion paper on
the issue, providing further detail on how a comprehensive approach to regulation could be
achieved. These guidelines can be viewed in Appendix B. Cancer Council Australia has
developed recommendations in their Food Marketing to Children Position Statement.126
Cancer Council Australia policy recommendations130
Cancer Council believes reform of food marketing regulations is a priority public
health goal. Children should be protected from the potential harms of food
marketing and parents should be able to raise their children in an environment that
is conducive to the development of healthy eating practices.
To better protect children from unhealthy food marketing, Cancer Council
recommends that Government develop a specific food marketing policy framework
and embed this in statutory regulation. This government regulation should:
1. Prioritise the protection of children from the unhealthy influence of food
marketing.
2. Significantly reduce children’s exposure to food advertising that promotes
unhealthy foods.
3. Apply to any unhealthy food advertisement that is intended or likely to
appeal to children (whether or not the advertisement is also intended or
likely to appeal to older age groups) and apply to all advertisements
screened on television between 7am to 9am and 4pm to 9pm weekdays
and 7am to 9pm on weekends, independent of whether they are shown in a
designated children’s program or not.
4. Apply to all media and forms of marketing, including TV, radio and print
advertising, online marketing, food company websites, social media, sports
sponsorship, on-pack and in-store promotions and outdoor advertising,
which is directed to children aged under 16 years, or to which a high
number of children under 16 years are likely to be exposed.
5. Include limiting persuasive techniques that are used to promote unhealthy
food to children such as the use of promotional characters and premium
offers.
6. Use independently-developed and consistent nutrition criteria to ensure
only healthy foods are promoted to children, such as the nutrient profiling
scoring criteria in the Australia New Zealand Food Standards Code,
Standard 1.2.7 - Nutrition, Health and Related Claims.
7. Include independent, clear and transparent monitoring and enforcement
processes.
8. Ensure open and transparent regulatory and governance processes which
are easy for the public to engage with.
9. Subject regulations to regular reviews to ensure they cover emerging
technologies and techniques used to reach children.
10. Include significant and meaningful penalties that deter companies from
breaching regulations.
Cancer Council supports government regulation of food advertising to children, asPage | 39
industry self-regulation of food marketing has not adequately addressed children’s
high level of exposure to unhealthy food advertising or the persuasive marketing
techniques commonly used by food companies to target children.
Children’s Health or Corporate Wealth?
Appendix A: Current Regulatory Framework in Australia
Regulation
level
Government
Legislation
Co-Regulation
Self-regulation
Regulatory
Body
Australian
Competition
and
Consumer
Commission
(ACCC)
Australian
Communicati
ons and
Media
Authority
(ACMA)
Free
television
Australia
Australian
Association
of National
Advertisers
Code
Media
Key Points
Australian Competition
& Consumer Act
(formerly the Trade
Practices Act)
All media
Misleading and deceptive advertising
Complaints
process
ACCC
Children’s Television
Standards
Television
Number, type and content of ads in C classified periods.
ACMA
No ads in P classified periods.
Commercial television
Industry Code of
Practice
Television
Food & Beverage
advertising and
marketing
communications
All media
(section 3 refers
specifically to
children and
advertising)
Rules on classification and placement of advertisements.
Not encourage or promote inactive lifestyle or unhealthy
eating and drinking habits.
2.1 Not misleading or deceptive with nutrition or health
claims.
Advertising
Standards
Bureau or
ACMA
Advertising
Standards
Bureau
2.2 Not encourage excess consumption or undermine
healthy diet and active lifestyle.
3.2 Not exploit children’s imaginations to encourage
excessive consumption.
3.6 Premiums not used unless integral element of product.
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Children’s Health or Corporate Wealth?
Regulation
level
Regulatory
Body
Code
Media
Key Points
Complaints
process
3.5 Not encourage children to urge parents for products.
3.4 Not undermine parents.
Advertising and
marketing
communications to
children
All media
(Also covers
safety,
sexualisation,
etc.)
3.3 Not suggesting advantage over other children when
owning product.
2.1 Not contravene community standards.
2.2 Fair representations, not misleading or deceptive.
Advertising
Standards
Bureau
2.7 Not undermine parental authority or ask children to
appeal to parents for products.
2.8 Not minimise price by using ‘only’ or ‘just’
2.12 Not utilise premiums to promote excessive
consumption
Ethics
Australian
Food and
Grocery
Council
Responsible Children’s
Marketing Initiative
All advertising
Television,
radio, print,
cinema, third
party websites.
2.15 Not promote unhealthy eating or drinking habits or
inactive lifestyle
All forms of marketing communications are decent, honest
and truthful
Relevant marketing will comply with other codes, as above
Only healthy dietary choices are to be advertised to
children and to be advertised in the context of a healthy
lifestyle (diet & physical activity)
Advertising
Standards
Bureau
Advertising
Standards
Bureau
Limits on premiums, characters, product placement,
games and school advertising unless healthy as above.
Nutrition criteria set in individual company action plans
Page | 41
Children’s Health or Corporate Wealth?
Regulation
level
Regulatory
Body
Code
Media
Key Points
Quick Service
Restaurant Initiative
Television,
radio, print,
cinema,
billboards,
games, emails
and internet.
Only healthy dietary choices are to be advertised to
children and to be advertised in the context of a healthy
lifestyle (diet & physical activity).
Complaints
process
ASB
Limits on premiums, characters, product placement,
games, school advertising, sporting events and product
placement unless healthy as above.
Standardised nutrition criteria set by group.
Page | 42
Children’s Health or Corporate Wealth?
Appendix B: South Australian food marketing to children
discussion paper guidelines 125
Guideline 1: Policy aim
Codes on food marketing to children should articulate the aim of reducing children’s exposure to the
marketing of energy-dense nutrient-poor foods and beverages.
Guideline 2: Specifying the foods and beverages
Agreed criteria* defining energy-dense nutrient-poor foods and beverages should underpin codes on
food marketing to children. An unhealthy food is any food or beverage that fails to meet the agreed
criteria.
*To be developed, but interim arrangements apply
Guideline 3: Defining age groups
At a minimum, as the first step, restrictions on the marketing of unhealthy foods and beverages
should apply to those under 14 years of age; with a second step defining children as up to age 17
years.
Guideline 4: Defining an unhealthy food advertisement, food brand and marketing directed to children
Codes on food marketing to children should incorporate the following definitions of an unhealthy food
advertisement (including food brands) and marketing directed to children. An ‘unhealthy food
advertisement’ includes any visual or audio message that publicises or promotes one or more
unhealthy food products. It also includes any visual or audio message that publicises or promotes a
food brand, unless one or more healthy food products are the dominant feature of the message (i.e. a
food brand advertisement). A ‘food brand’ is a trade mark or design registered in respect of a food
product or food range; the name of a manufacturer of a food product or food range; or the name of a
food range, or any other words, designs or images, that are closely associated with a food range. An
unhealthy food advertisement ‘directed to children’ should include any unhealthy food advertisement
that is intended or likely to appeal to children (whether or not the advertisement is also intended or
likely to appeal to older age groups), and any unhealthy food advertisement that is likely to be seen or
heard by children. Assessment of whether an unhealthy food advertisement is directed to children
should involve consideration of the circumstances in which the advertisement is published, broadcast,
displayed or communicated, the nature of the advertisement and the nature of the food product
advertised.
Guideline 5: Ensuring a comprehensive approach
Codes on food marketing to children, in minimising children’s exposure to the marketing of unhealthy
food, should take a comprehensive approach. This will include targeting all media channels,
broadcast and non-broadcast media, settings where children and families with children gather,
marketing methods used to reach children and brand promotion.
Guideline 5.1: Television advertising
Free to air television
Unhealthy foods are not advertised if the advertisement is:

directed to children, or
Page | 43
Children’s Health or Corporate Wealth?


broadcast during the following times
– weekdays 6-9am and 4-9pm
– weekends and during school holidays: 6am-12pm and 4-9pm, or
on a designated children’s channel
Subscription television
Unhealthy foods are not advertised if the advertisement is:


directed to children, or
broadcast on channels regularly watched by significant numbers of children,

during the following times:

– weekdays-6-9am and 4-9pm
– weekends and during school holidays: 6am-12pm and 4-9pm, or
on a designated children’s channel.
Guideline 5.2: Food marketing in children’s institutions or services
Unhealthy foods are not marketed in or in association with events or activities of



childcare (long day care, out of school hours care, vacation care), preschools (kindergarten)
and schools (primary and secondary); or
other institutions or services that provide services primarily to children (including medical,
care,
educational or recreational).
Guideline 5.3: Food marketing in conjunction with children’s events and activities, including children’s
sport
Unhealthy foods are not marketed at or in association with events or activities in which primarily
children are involved or participate (e.g. children’s sport or school fairs).
Guideline 5.4: Cinemas and theatres
No screening of an unhealthy food advertisement in a cinema before, during or after a G film, or
before, during or after a PG film that is directed to children; and
No unhealthy food advertising directed to children inside or outside the premises of a cinema or
theatre.
Guideline 5.5: Public places and transport
Unhealthy food advertisements directed to children are not visible or audible in or from a public place
or public transport.
Guideline 5.6: Internet sites
No unhealthy food advertising through the internet, if the advertisement is:


directed to children
uploaded on, or linked directly to a website or webpage that is directed to children
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Children’s Health or Corporate Wealth?
This applies to both company owned websites and third party websites.
Guideline 5.7: Print publications
No unhealthy food advertising in a print publication (such as a magazine or comic) that is directed to
children.
Guideline 5.8: Radio
No advertising of unhealthy food or beverages on radio, if the advertisement is directed to children.
Guideline 5.9: Recordings, toys and other items and objects
No supplying, distributing, hiring or selling, or offering anything that constitutes or contains an
unhealthy food advertisement directed to children (such as visual or audio recordings, computer
disks, clothes, toys, materials, equipment or other items or objects).
Guideline 5.10: Product placement
No promotion or publicising of unhealthy food, during, within or as part of the content of a media
product (such as a film, television program, radio program, print publication, computer game or
website) that is directed to children.
Guideline 5.11: Premiums (including competitions and give-aways)
No supply of or offering to supply a premium* for the purpose or with the effect of promoting unhealthy
food to children.
*Premium means a good, service, prize, voucher, competition entry, product give-away or product
sample, offered or supplied with or without charge.
Guideline 5.12: Use of popular personalities and characters
No direct or indirect promotion or endorsement of an unhealthy food by, or in association with, a
personality or character that is popular with or likely to appeal to children.
Guideline 5.13: Direct marketing to children, including electronic
Direct mail
Children are not sent by addressed mail anything that constitutes, includes or contains an unhealthy
food advertisement.
Direct electronic marketing (email, SMS, voicemail)
Direct electronic messages that constitutes or contain unhealthy food or beverage advertisements are
not sent to a child.
Guideline 5.14: Product packaging
Unhealthy food is not packaged in a manner directed to children (such as featuring colours, graphics,
pictures, cartoons, personalities, competitions, activities or references to films, television programs,
games or sports, that are intended for or likely to appeal to children).
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Children’s Health or Corporate Wealth?
Guideline 5.15: Unsolicited documents
Unsolicited documents (such as flyers, leaflets or pamphlets) that constitute or contain
advertisements for unhealthy food or beverages directed to children are not distributed to the public.
Guideline 5.16: Retail outlets – point of sale
Point of sale advertising (retail premises)
No displaying or communicating an unhealthy food advertisement directed to children inside or
outside retail premises where unhealthy food products are sold.
(This does not encompass advertisements that are in, on or part of product packaging, which is dealt
with in a separate guideline).
Point of sale display and placement of products (retail premises)
No placing or displaying an unhealthy food product in a retail outlet in a manner intended or likely to
attract the attention of children, for example
–
–
below a height of 1 metre from the floor; or
within a distance of 2 metres from the point of sale (cash register or checkout
counter).
Page | 46
Children’s Health or Corporate Wealth?
Reference List
(1) World Health Organization. Annex. Set of recommendations on the marketing of
foods and non-alcoholic beverages to children. Prevention and Control of Noncommunicable Diseases; Implementation of the Global Strategy.Geneva: World
Health Organization; 2010.
(2) World Health Organization. A framework for implementing the set of
recommendations on the marketing of foods and non-alcoholic beverages to children.
Geneva, Switzerland: World Health Organization; 2012.
(3) SA Health. South Australians' views on the television advertising of unhealthy food
and beverages during children's television viewing time. Government of South
Australia 2011 April [cited 2013 Dec 9]; Available from: URL:
http://www.sahealth.sa.gov.au/wps/wcm/connect/e9eec38049110a37b777f77675638
bd8/SA+attitudes+to+food+advertsing-PHCS-HPB201111.pdf?MOD=AJPERES&CACHEID=e9eec38049110a37b777f77675638bd8
(4) National Preventative Health Taskforce. Australia: The healthiest country by 2020.
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(7) Australian Government Department of Health and Ageing. 2007 Australian National
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discussion paper. Canberra: Commonwealth of Australia; 2008.
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