Defending the right to advertise – a response from the Ad Association, IPA and Isba

We are indeed concerned. Such measures will have considerable impact on jobs, industry, the economy and – yes – consumers, but there’s very little evidence they will address the obesity problem.

Let’s make one thing clear. We support the need to tackle the rising trend in obesity. Advertising has a role to play. This was recognised in 2008 when rules on food advertising were first introduced, and then in 2017 when, as a result of the industry’s own decision-making, the Committees of Advertising Practice (Cap) tightened the rules even more. As a result of the rules, children’s exposure to high fat, salt and sugar ads on TV has declined by 70% since 2008 and they now see only five or six ads a week. Online, where the advertiser can use controls to target away from children and is encouraged to do so through Cap’s guidance note, their exposure to HFSS ads is minuscule. Yet obesity trends among children have continued to rise over this time.

The government’s own impact assessment published last year gives some insight as to why this is the case. It shows that a TV watershed ban would only result in 1.7 calories being cut from a child’s daily diet, which amounts to less than half a Smartie. This is central to the argument about why it – and an online equivalent – are not appropriate measures.

When asked recently on The Today programme about the effectiveness of a pre-9pm watershed ban, Tam Fry, the chairman of the National Obesity Forum, described it as “scanty”. For his part, professor Graham MacGregor, chairman of Action on Salt and Action on Sugar, said that these restrictions are not about advertising but “screwing the industry down” through red tape. Reason and evidence seem to matter far less than headlines.

We support ambitions to create a healthier and more active society through an evidence-led approach targeted at the root causes of obesity. But this is an industry that now faces the very serious challenge of further job losses and reduced budgets for media owners. The irony should also not be lost that government schemes such as ‘Eat Out to Help Out’ are currently subsidising many of the types of food that these proposals would seek to ban from being marketed.

We also need to junk the term ‘junk food’ in this debate. The food and drink products classed as high in fat, sugar or salt according to the government’s Nutrient Profile Model cover a variety of items everyone would find in their kitchen – from olive oil, butter, cheese and mustard to stock cubes, soy sauce and much more in between. There will be no special protections. The NPM doesn’t distinguish between multinationals and SMEs or the international and the artisan.

With childhood obesity rates differing across the UK depending on age, socio-economic status, ethnicity, region and gender, several projects have shown that a localised and multi-faceted approach works. For example, the Henry project in Leeds, where this intervention charity promotes a healthy start in life and lays foundations for the future by focusing on babies and children aged 0-5 and their families. This has led to decreased consumption of energy-dense food and sugar-sweetened drinks and increased family physical activity.

Industry initiatives to encourage healthy lifestyles also make an important and valuable contribution. There’s Outsmart’s ’Get Smart, Outside’ campaign and ITV’s support for the Daily Mile, which is also supported by the cinema industry. There’s ITV’s ’Eat Them to Defeat Them’ campaign, supported by Channel 4 and Sky as well as retailers, and Media Smart’s new educational resource to encourage young people to lead healthier lifestyles through creating an advert to promote eating more vegetables to their peers. The list goes on.

Industry is playing its part and the government could do more to back existing very successful programmes, like Henry and like The Wakefield Programme.

But we must also not miss a much bigger point. Food is a legal product, required to live. It’s not prohibited, age-restricted and, consumed in a balanced way, will not harm us.

We are in danger of advertising being seen as an easy target for governments that wish to be seen to be doing something about a societal problem. We are willing to play our part, but not if that involves measures that will both be ineffective and damaging for industry, jobs, the economy and, ultimately, consumer choice.