Ad Ban for Junk Food

June 19, 2019 , 0

Food for Thought, or Reheated Argument?

By Colin Ward

Deputy Director, CMF

Is an extension of the ‘junk food’ ad ban a positive step for children’s media?

Over the last few weeks, a group of us have been working on the CMF’s response to a government consultation on a proposed extension of the ‘junk food’ ban.  It was an interesting exercise,  because although some of us disagreed about whether the original ban should have happened, everyone thought it was a piece of grandstanding that was never, on its own, going to make a big difference to children’s eating habits. The only thing the original ban really changed was the children’s TV production sector. It triggered a sharp decline in the commissioning of commercially-funded, UK-originated TV shows for children. ITV, in particular, seized the moment and announced they were removing children’s programmes from ITV1, leaving the BBC to dominate the market as a near-monopolistic commissioner. Some shows were cancelled in mid-production and although many survived the storm, talented colleagues were forced to look for work outside the sector.

One of the problems with the original ‘junk food’  ban was advertising displacement. The ban made the news and helped kick-start a wider debate about child obesity, but the food manufacturers just took the opportunity to switch to digital advertising.  Children were still exposed to sophisticated campaigns for HFSS food and drink, they just weren’t on ITV or Channel 5. The main thrust of the government’s latest proposal is to address that problem. New legislation would extend the ban to cover children’s pre-watershed viewing and could even include their online media experience, whether that’s gaming, social media or streaming.

The detail on how the government hopes to implement an extension of the ban is complex and if you want to see the full proposals, and our response, you can view them here.  For example,  they are considering whether the new TV ban should apply to channels with a large children’s audience pre-watershed or to individual programmes.  If it was applied to programmes that might prevent Hollyoaks from carrying HFSS adverts in the breaks, but Channel Four News would be exempt. They are also consulting on which measurements they should use to define a channel or programme that appeals to a children’s audience. And, crucially, they are consulting on how wide the ban should be.  Should it include other forms of media?

The CMF’s response to the consultation has been to encourage the government to make the ban as a wide as possible. We have suggested they include print, poster and radio advertising as well as online and broadcast. There are three, connected reasons for this approach. First, a ban that extends to any media with the potential to reach a children’s audience will reduce the options for advertisers and avoid advertising displacement, which was the big problem with the original ban.  Secondly, shutting off those advertising channels may encourage food manufacturers to reformulate their products and reduce the amounts of fat, sugar and salt, which is, after all, the main objective. Although if that is the objective then surely it would make sense to regulate the food industry directly and impose limits on those ingredients.  Finally, if the ad money can’t go to other advertising channels, and food manufacturers are allowed to advertise lower FSS foods on pre-watershed TV, then that will, hopefully, reduce the economic impact of an extended ban on UK broadcasters and producers.

The nightmare scenario is that we end up with a watered-down, ineffectual extended ban that simply encourages broadcasters to commission primetime shows that don’t appeal to a children’s audience. The government will publish its response to the consultation in due course. Watch this space.

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