Five reasons why we need a 9pm watershed on broadcast TV and online #JunkFoodAds

Five reasons why we need a 9pm watershed on broadcast TV and online #JunkFoodAds

Food Active has #AdEnough of #JunkFoodAds!


That’s why we are submitting a response in full support of introducing further restrictions to broadcast TV and online advertising on less healthy food and drink, as part of the latest Department of Health and Social Care/Department for Culture, Media and Sport consultations outlined in the Childhood Obesity Plan Chapter 2. We are pleased to see the Government recognising this issue and taking a first step towards much-needed action in this area.

Food Active has been part of the wider campaigning efforts over the past few years, alongside campaign groups including the Obesity Health Alliance, the Children’s Food Campaign and Jamie Oliver’s Food Foundation, calling on the Government to introduce further restrictions to ensure children’s exposure to the advertising of less healthy food and drink is kept to a minimum. In 2018, we spoke to 380 parents in the North West – the majority of whom recognised #junkfoodads as an issue and wanted to see action from the Government.

In our latest blog, we highlight the five most important reasons why we think a 9pm watershed on #JunkFoodAds is warranted.

Five reasons why we need a 9pm watershed on #JunkFoodAds

  1. Current restrictions don’t work: We believe that current restrictions on TV broadcast and online simply do not go far enough to protect children from exposure to food and drink that is high in fat, sugar and salt (HFSS) advertising. Current TV advertising restrictions, that were introduced in 2006, state that HFSS food and drink cannot be shown on children’s media. Regulators Ofcom claim that the introduction of these restrictions have reduced children’s exposure to less healthy food and drink – however, research published in 2012 found that the restrictions did not change relative exposure to HFSS advertising in children, and also found that there was an increase in relative exposure to all audiences. Another loophole with the current restrictions is that children do not just watch child-orientated programmes. There are a whole host of programmes such as Britain’s Got Talent, the X-Factor, Great British Bake Off etc. that are general audience viewing, but many children will watch with their families. A report by the Obesity Health Alliance found that during general audience viewing TV, the majority (59%) of food and drink adverts shown during family viewing time would be banned from children’s TV, yet hundreds of thousands of children are exposed to these ads every week. The research found that children were bombarded with nine HFSS adverts in just a 30-minute period. Furthermore, we question how effective current non-broadcast media restrictions are, which were introduced by the Committee for Advertising practice in 2018. These restrictions follow the same loopholes as children’s broadcast media restrictions, whereby restrictions only apply to websites with more than 25% child audiences but also work on a reactive basis. Current restrictions simply allow far too many children to continue to be exposed to HFSS advertising across all types of media.
  2. #JunkFoodAds contribute towards obesity: The advertising of less healthy food and drink was recognised in the 2007 Foresight report as a driver of the obesity epidemic[1] – and there is a wealth of evidence that supports this. Exposure to less healthy food and drink advertises negatively affects children’s dietary health – it creates an increased preference for junk food, normalises junk food, increased pestering from children, greater intake of junk food and lower intake of healthy food and more[2]. This evidence is also recognised by the World Health Organisation, who have recommended that Governments across the globe attempt to minimise children’s exposure to the advertising and marketing of less healthy food and drink to help prevent NCDs[3]. The Government has outlined its ambition to halve childhood obesity by 2030 – if we are to face any chance of coming even close to this ambition, introducing this policy measure is a crucial step in the journey.
  3. It will nudge industry to start reformulating food and drink: Public Health England are currently operating two voluntary reformulation programmes; sugar reduction programme launched in 2017 and the calorie reduction programme, launched in 2018. One year progress reports from the sugar reduction programme has indicated that there has been little progress and the ambition to reduce the sugar content by 20% by 2020 is increasingly unlikely. Preliminary results from the calorie reduction programme have not been released as of yet, but it wouldn’t be unreasonable to suggest they might follow a similar pattern given that it is also a voluntary programme. But what has this got to do with the 9pm watershed? Well – if a 9pm watershed is introduced, many products that are HFSS will no longer allowed to be advertised between the hours of 5:30am-9pm. With the prospect of being allowed to advertise during peak TV and online viewing hours, this may prompt more businesses to finally get their act together and start to reformulate their line of products to meet the reduction challenges set by Public Health England. This could go a long way in helping to finally make some much needed progress in these programmes, which form a crucial part of the Government’s childhood obesity strategy.
  4. A 9pm watershed will have the most impact: The Government have proposed a series of different policy options for both broadcast TV and online restrictions, including a 9pm watershed (with exemptions for low child audiences) and ladder approaches with varying degrees of legislation, or simply do nothing – see this link to find out more about the options proposed. According to the Impact Assessments produced by the Department for Health and Social Care, a 9pm watershed will result in lower calorie consumption by children over their lifetimes – expected to generate health benefits at around £1.9bn. There would be additional health benefits to the population from reinvesting cost savings back into the NHS, estimated to be worth around £0.8bn. Social care savings are estimated at around £52m and reduced premature mortality would be expected to deliver an additional £41m of economic output.
  5. The public support it: A nationally representative poll conducted by YouGov on behalf of the Obesity Health Alliance found that 72% of adults supported the introduction of a 9pm watershed on the advertising of less healthy food and drink[4]. In addition, our own research of parents perceptions of junk food marketing to children in the North West, found that two thirds of parents support a ban on the advertising of unhealthy food and drink on family time TV programmes (64%, n=235)[5]. It is clear to see that this policy is a no-brainer for health professionals, campaign groups and the public alike.

 

You can view our official response to the consultation via the button below.

 

Food Active Response: Introducing further restrictions on the advertising of HFSS food and drink online and TV broadcast

 

Responding to the consultation

If you would like to respond to the consultation, there are only three days left to respond before the deadline of 11:59pm on Monday 10th June. If you do not have the time to respond to the whole consultation, you are able to send a summary response to indicate your support for the policy. However, in order for your response to count you must make reference to the actual options that you are supporting in the consultation. Below are some tips on how you can submit to make sure your voice is heard:

  • Email Childhood.Obesity@dhsc.gov.uk
  • Introduce yourself and who you are (responding on behalf of an organisation, a parent etc.)
  • Thank the Government for the opportunity to respond to the consultation.
  • Remind the Government that they have committed to halving childhood obesity in England by 2030 and why you think tackling junk food ads will help towards achieving this (you are welcome to use some of the evidence and reasons cited in this article and our official response, as well as any of your own personal experiences of the impact exposure to junk food ads has on your children).
  • If you think that restrictions should be introduced not only on broadcast TV and online, but other media such as outdoor advertising, sport, print etc. then say so and why. Again, you are welcome to provide any of your own experiences.
  • You must tell the Government which of the Options for restrictions on TV and online you support. See below for the options that are being presented. Food Active are submitting a response in support of Option 1 for broadcast TV and online restrictions, but raising concerns that exemptions for low child audiences may result in thousands of children still being exposed to junk food ads. If you want to see concerted action to finally tackle junk food ads, then we recommend you respond the same. You can see a summary of the different options presented in the two tables below.
  • You will see that doing nothing is an option proposed for both policies. This is also a chance for you to emphasise why it is unacceptable that the Government takes no action – you could mention that we are currently experiencing an obesity epidemic, trends are increasing, the gap is widening between the poorest and wealthiest children and bold action is required in order to finally tackle the issue in England.
  •  You must email your response to Childhood.Obesity@dhsc.gov.uk before the deadline of 11.59pm on Monday 10th June 2019. Thank you for your support!

 

TV Broadcast advertising restrictions

 

Option 1 Option 2 Option 3
A 5:30am – 9pm TV watershed

  • Products in scope of PHE sugar and calorie reduction programmes and Soft Drinks Industry Levy
  • 2004/5 NPM used to determine HFSS
  • All programmes in scope except where there are low child audiences.

 

A 5:30am – 9pm TV watershed

  • Products in scope of PHE sugar and calorie reduction programmes and Soft Drinks Industry Levy
  • Ladder based approach using 2004/5 NPM to define HFSS
  • Advertising freedoms granted when food and drink reaches a certain score in the NPM (but not less healthy or healthy)
  • All programmes in scope except where there are low child audiences.

 

Do nothing

 

Online advertising restrictions

 

Option 1 Option 2 Option 3 Option 4
A 5:30am – 9pm TV watershed

  • Products in scope of PHE sugar and calorie reduction programmes and Soft Drinks Industry Levy
  • 2004/5 NPM used to determine HFSS
  • Seeking views on an exception for advertisers who can show ‘exceptionally high’ level of evidence of who is watching.

 

Strengthen current restrictions

  • Inviting views on tightening 25% audience threshold
  • Inviting views on what evidence sources should be required to prove steps taken to ensure children not exposed

 

Mixed approach

  • Products in scope of PHE sugar and calorie reduction programmes and Soft Drinks Industry Levy
  • 2004/5 NPM used to determine HFSS
  • Seeking views on an exception for advertisers who can show ‘exceptionally high’ level of evidence of who is watching.

 

Do nothing

 

 

 References

[1] Government Office for Science (2007) Foresight: Tackling obesities: future choices [online] available at: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/287937/07-1184x-tackling-obesities-future-choices-report.pdf

[2] Boyland, E. (2017) Junk food marketing and childhood obesity: the evidence [online] Available at: http://obesityhealthalliance.org.uk/wp-content/uploads/2018/02/Junk-Food-Marketing-Evidence-Briefing-FINAL.pdf

[3] World Health Organisation (2015) Marketing of foods high in fat, sugar and salt to children. Geneva: WHO

[4] Obesity Health Alliance/You Gov (2019) Protect children from junk food ads – parents agree [online] Available at: http://obesityhealthalliance.org.uk/2019/02/28/protect-children-junk-food-advertising-say-health-experts-parents-agree/ [Accessed: 2nd May 2019]

[5] Food Active (2018) Parents perceptions of junk food marketing to children [online] Available at: http://www.foodactive.org.uk/wp-content/uploads/2018/06/Junk-Food-Marketing-to-Children-a-study-of-parents-perceptions.pdf [Accessed: 2nd May 2019]


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