Indian J Pediatr DOI 10.1007/s12098-014-1480-x
REVIEW ARTICLE
Food Marketing to Children in India: Comparative Review of Regulatory Strategies Across the World Nidhi Bhatnagar & Ravneet Kaur & Puja Dudeja
Received: 2 September 2013 / Accepted: 30 April 2014 # Dr. K C Chaudhuri Foundation 2014
Abstract Food marketing directed to children is an issue of concern in the present day society. Revolution in food industry, increasing globalization and boom in information technology has introduced various types of food products and the way they are placed in front of likely consumers. This has resulted in rising trend of obesity and switch from communicable to noncommunicable diseases, which is not cost effective for nation as a whole. Multinational companies have targeted children as a naïve audience to boost their sales. In-ethical practice of misleading claims in the advertisements is instrumental in many cases. Food marketing to children has been assumed a public health threat since times of yore. World Health Organization has resolutions and recommendations on this subject. Member countries, including India are a signatory to this declaration. However, much needs to be done to counter these multinational food giants. Regulations and policies need to be enforced at national and institutional levels. Parents must be educated; schools and social organizations to be made proactive on this aspect. Keywords Food . Marketing . Regulations . Children . India
Introduction “Advertising is a non-moral force, like electricity, which not only illuminates but electrocutes. Its worth to civilization depends upon how it is used.” J. Walter Thompson Marketing is a business principle which uses research and other methods to promote products and services. Through N. Bhatnagar (*) : R. Kaur : P. Dudeja Department of Community Medicine, Post Graduate Institute of Medical Education and Research, Chandigarh 160012, India e-mail: [email protected]
market research, demand for product or service, can be assessed along with potential competition and other factors, such as pricing, customer satisfaction and sale trends. Advertising aids in promoting goods among likely consumers and is a component of the entire process of marketing. Modern media and captivating advertisements establish product in the minds of viewer. Food marketing, in present times has gained momentum with increasing globalization, breaking up of joint family system, working parents, influence of media etc. Growing restaurant business, attractive food combos, party packages and meals at heavily discounted rates add branded and competitive touch to food advertisements. Introduction of fast foods and ready to eat food mixes offer unhealthy choice to consumers. Advertising places product within the reach of consumer creating a felt need simultaneously. Children have been identified as easy targets in this process. Their purchase choices are easily influenced by advertisements shown in televisions and other promotional offers [1]. Wants and needs are negotiated within the family, in the form of repeated requests (pester power), [2] subsequently translated into major purchase decisions of family [3]. More than 50 % parents in a multi country survey agreed for children to be an important factor in influencing purchase decisions [4]. A Systematic review by WHO (World Health Organization) highlighted prioritization of children in marketing strategies of food companies [5]. Thus, there arises a major concern for regulating food marketing targeting children. Majority of literature on this subject originates from developed countries. Very less research and practice has been done in India. Rising middle income group, reach of technology and sound market research strategies is bolstering the threat in developing economies like India. This article attempts to highlight the need for regulatory restrictions on food marketing in India. Current status of regulations in India are compared across nations and commented upon with evidence gathered from studies done across the world.
Indian J Pediatr
Material and Methods This is a narrative literature review which took an iterative approach in finding relevant literature. This was done to capture exhaustive literature on the topic. Comprehensive coverage of published work, policies, reports and legislations related to the subject was done. Language restriction to English was done for search, however no time restriction was entered. Pub med, IndMed, Directory of Open Access Journals and Google Scholar were used to identify published and unpublished/in-progress studies, references and citations of articles of interest. Search terms that were used in the process were: “food”, “marketing”, “children”, “India”, “legislations”, “dietary preferences” and “television”. In addition, manual search of articles was done from institute library to collect relevant information. Systematic search of pertinent journals e.g., Public Health Nutrition, American Journal of Public Health, Nutrition Reviews, Preventing Chronic Disease and Indian Pediatrics was done.
Targeted Marketing and it’s Impact India offers fertile ground for investment by multinational food and beverage giants. Aggressive marketing strategies are adopted to attract consumers. Advertising industry amounts to nearly Rs.16,300 crore, out of which snack food market constitutes Rs.4500 crore (28 %), and branded food advertizing constitutes Rs.1300 crore (8 %). Only 2 % of company’s budget is earmarked for research and development and nearly 50 % into product advertising [6]. Children today are potential consumers. Marketing techniques are designed to appeal to them directly e.g., use of celebrities, catchy slogans, brand owned or licensed cartoon characters, inclusion of free gifts, toys or collectible items, inclusion of competitions, vouchers or games and changing shape or novelty value of food. This strategy is often targeted at places children visit frequently e.g., school canteens, children centers, exhibitions, cultural events, fetes, family and child clinics. Availability and prominent visibility provides an easy buy. Food market is segmented to capture every type of child consumer e.g., for small children (birth - 3 y) parents are targeted and product is shown to enhance health and immunity of children. Complan, a common nutrient powder in India strongly claims increase in growth in the advertisement based on study which is methodologically incorrect and lacks scientific rigor. Age, socio-economic class were confounders with gross errors in the methodology of study. Moreover, the study was financially supported by manufacturers of the product which would have resulted in conflict of interest. Such flawed study cannot form basis of strong recommendations given by the company in advertising products on television [7].
Pester power is created among younger ones to force parents for purchase. For teenagers, peer pressure is generated using prominent youth icons for promotion. Sanskritization, influences children from lower socioeconomic classes. Castes lower in hierarchy seek upward mobility by emulating rituals and practices of upper or dominant castes [8]. This makes children buy low cost food items that they see in advertisements or go for cheap alternative that they can afford which is nutritionally poor and even hazardous to health. With rising penetration of mass media in community, television commercials are employed extensively for the process of marketing and promoting food among children. In urban slums of north India, nearly 96.3 % children had access to television. Mean age of onset of television viewing was 2.96 y and mean hours of television viewing was 3.56 h [9]. Another study conducted in south India found 49 % children viewing television for more than two hours per day and 7 % more than 4 h per day. During weekends 71 % children were watching television for more than two hours and 24% for more than 4 h daily. Most (44 %) of the children were influenced by the advertisements of food items [10]. Significant association between obesity and television viewing was found in a study conducted in urban and semi urban south Indian children [11]. Study done in urban south Indian children in Bangalore found increased consumption of bakery items, increased television viewing, decreased sleep duration and eating while watching television, significantly related to waist circumference [12]. Impact of television commercials on children was observed to be consistent across age groups and gender [13-19]. However, advertisements are instrumental in influencing mind of children less than 8 years of age as there is paucity of knowledge of persuasive intent [20]. Cognitive research indicated that young children cannot effectively recognize the persuasive intent of advertising or apply the critical evaluation required to comprehend commercial messages [21]. A study found significant correlation between brand logo recognition (a measure of marketing exposure) and higher BMI, independent of socioeconomic group, age and gender. Children’s preferences were found oriented towards unhealthy options and preference reported to increase with age. More purchase request behavior was reported in children with higher socio-economic status [22]. Another study used food products advertised and children viewing time to construct a food pyramid. Sweets and confectionaries were the base of the pyramid, reverse of what is required for a balanced diet [23]. With increasing number of channels primarily viewed by children and other modes of audio-visual media e.g., internet available to them, there arises a major concern for regulation of the quantity and quality of these food advertisements and promotions. This brand consciousness and aggressive food marketing is creating a society of obese people [5]. Obesity pandemic is a serious public health challenge of 21st century. There is
Indian J Pediatr
predicted 27.5 % rise in overweight children of South East Asian region between 2005 and 2010 [24]. Anemia and multivitamin deficiencies have increased despite several preventive and curative strategies. NFHS (National Family Health Survey) III has shown that 79 % children are anemic, irrespective of the socio economic status [25]. Obese youth are more likely to have been identified as risk factors for cardiovascular disease [26, 27]. There is greater risk for bone and joint problems, sleep apnea, social and psychological problems such as stigmatization and poor self-esteem [28, 29]. Studies have documented increased association of periodontal problems with television viewing [30]. Increased risk of cancer now accounts for 60 % of global deaths. Junk foods are proposed to act as endocrine disruptors, leading to obesity and other pubertal disorders [31].
Regulatory Strategies: Past and Present Concerns for child directed advertising was present since ancient times. British Parliament in 1874 passed legislation to protect children from merchants who induce them to buy products and assume debt. In 1970s, Federal Communications Commission proposed to ban advertising to young children but limited amount of advertising time and certain advertising practices. Federal Trade Commission considered banning all television advertising to young children but yielded under the pressure of advertising industry [32]. After a long gap, in 2002–03 publication of Government Chief Medical Officer’s Report, United Kingdom highlighted this issue. Food Standard Authority (FSA) of UK conducted a systematic review of studies on food promotion and gave the nutritional profiling model for labeling high in fat, salt and sugar (HFSS) foods to be placed under advertising regulations. UK Food Standards agency, 2007 defined HFSS food with fat 20 g, sugar 15 g, and saturates 5 g per 100 g [33]. In 2004 global strategy on diet, physical activity and health was the first to draw global attention on this agenda. In May 2007, World Health Assembly adapted Resolution WHA60.23, to develop recommendations on the marketing of foods and non-alcoholic beverages to children. Global regulatory policy on marketing food to children was released by WHO in 2006 [34]. In 2009, WHO Secretariat developed recommendations on ‘Marketing and Advertising of Foods and Non-Alcoholic Beverages to Children’, endorsed by 63rd World Health Assembly in May 2010. This was followed by report, ‘Recommendations on the Marketing of Foods and Non-alcoholic Beverages to Children’ in 2011 [35]. WHO recommended ‘Overall policy objective should be to reduce both the exposure of children to, and power of, marketing of foods high in saturated fats, trans-fatty acids, free sugars, or salt.’ This was approved by the member states and India stands signatory to this declaration. Issue of advertising to young children is of public concern. Advertising industry has recognized the sensitivity and has its
own self-regulatory advertising guidelines but till date the code is vague, compliance voluntary and enforcement not actively pursued [34]. In most of the countries including India, self regulatory measures are adopted by food and beverage companies for regulating child directed food advertising. However, there are several inadequacies in the industry’s voluntary measures [13, 14, 26, 21]. A study done in Canada, to assess self-regulatory marketing initiative, CAI (Children’s Food and Beverage Advertising Initiative) found voluntary participation in self-regulation code to curb child directed marketing, resulting in competitive disadvantage. Moreover, extent of following the self regulatory code was unequal and many felt short of achieving the desired objectives. There is a pressing need of well framed regulations, enforced in the society and supplemented with policy level measures in schools along with educating parents [36]. There is an imminent need to check the misleading claims made in advertisements. Claims made by food supplements in advertisements should be based on sound studies rigorously evaluated by independent agencies. There should be laws governing the process. In United States, Food and Drug Administration (FDA) has regulatory responsibility for dietary supplements. Federal Trade Commission (FTC) of US regulates advertising of dietary supplements in print and audio-visual media. Similarly in European Union, article 16 of the general food law has recommendations on the same [37]. Advertising Standards Council of India (ASCI) facilitates general public to file an online complaint against misleading advertisements and to track the progress of same. Measures have been introduced recently in 2013 to hasten the processing of the complaints using FTCC (Fast Track Intra Industry Complaint) and SPI (Suspension Pending Investigation). To improve closer monitoring of adverti sements NAM S (National Advertising Monitoring Service) has been set up which monitors nearly 1500 advertisements per month [38]. Public health interventions, focused on changing environment through policy and regulation have successfully targeted reducing health risk behaviors such as tobacco and alcohol consumption [39]. Such stringent measures are needed in food industry as food marketing environment is contributing to health crisis with members unlikely to voluntarily make changes in this aspect. A study done in Australia to gauge policy level interventions that support healthier food choices revealed interventions directed to advertisements as most well accepted (83 %) compared to taxation and control on sponsorship of sports and education programs. Moreover, more adults approved selected ban of advertisements during children viewing time [40]. One European country, fifteen American states and six Canadian provinces have already implemented statutory guidelines for marketing of HFSS foods to children. In Brazil, law restricting sale of energy dense, nutrient-poor foods in the Federal district was implemented, adding to
Indian J Pediatr
restrictions already in force. Philippines and South Korea have strict laws pertaining to the advertisements of fast food and confectionery. Sweden has the strictest controls in Europe and in 1991 instituted a ban on television and radio advertising targeted at children under the age of 12. In Belgium, it is forbidden to broadcast commercials during children’s programs and 5 min before and after them. Commercial TV Code formulated by Australian Communications and Media Authority (ACMA) does not allow ads during television programming for preschoolers. However, it does not place complete ban on other forms of marketing [24]. In UK, OFCOM (Office of Communications) is the regulating body and has completely banned all forms of advertisements in children under 9 y of age. In USA, children’s Advertising Review Unit (CARU) established by the National Advertising Review Council (NARC) is a self- regulatory program to check advertising directed to children . The CARU guidelines apply only to children under 12 y of age and are mild in nature. Canadian code of advertising standards have placed complete ban on all forms of food marketing to children under 13 y of age in Canada [41]. India has regulations by the Information & Broadcasting Ministry and Ministry of Consumer Affairs. Most of the SelfRegulation Organizations around the world base their work on the codes prepared and published by the International Chamber of Commerce (ICC). ‘Advertising Agencies Association of India’, and the ‘Advertising Standards Council of India (ASCI)’, are business organizations and can put moral pressure on advertisers and companies to withdraw objectionable advertisements [34]. Its main objective is to promote responsible advertising, enhancing public confidence. ASCI’s Code for Self-Regulation in advertising is now part of ad-code under Cable TV Act’s Rules. The act and ASCI code is applicable to all states. Program and Advertising Codes prescribed under the Cable Television Network Rules, 1994 state that ‘No advertisement which endangers the safety of children or creates in them any interest in unhealthy practices or shows them begging or in an undignified or indecent manner shall not be carried in the cable service.’ It further mentions that ‘Care should be taken to ensure that programs meant for children do not contain any bad language or explicit scenes of violence. Programs unsuitable for children must not be carried in the cable service at times when the largest numbers of children are viewing.’ However, no clear reference to marketing of unhealthy food to children or exact time regulations were made in this act. Self regulation guidelines for Broadcasting Service Provider (BSP) state that ‘BSP should take reasonable steps to protect minors. It should be vigilant in gaining an understanding of how material shown on television could impact the development of minors. It is therefore necessary for BSP to exercise judgment on the capacity of minors in different age groups in coping with the
depiction and treatment of material, which may not be suitable for them. There is a progressive decline in the proportion of minors present as television audience through the evening and during the night. The restrictions on the broadcast of program unsuitable for minors should be relaxed on a gradual and progressive basis after 8 pm. The assumption is that after 8 pm parents are expected to share responsibility for what their children are permitted to watch on television [42]. The Food Safety and Standards Act, 2006 has clause 53 in section 56 that clearly states that any person who publishes or is a party to the publication of an advertisement which-a) Falsely describes any food or b) is likely to mislead as to the nature or substance or quality of any food or gives false guarantee, shall be liable to a penalty which may extend to ten lakh rupees. Authorities entrusted for food safety will be responsible for enforcing the law [43]. Professional bodies like Indian Academy of Pediatrics (IAP) have passed resolutions to prevent sponsorship from companies that manufacture products covered under Infant Milk Substitutes Act 1992. Initiatives like this preserve the sanctity of medical profession, nevertheless are diluted with the passage of time [44]. Impact of restrictive ban on advertisements and marketing of HFSS products needs to be deliberated. A recent publication stated that exposure of children to HFSS food advertising, as a proportion of all advertising seen, did not change despite adherence to advertising restrictions [3]. Hence, there is a need to enforce regulations in marketing and advertising along with measures like educating parents and developing code for the same in schools.
Conclusions Surging obesity rates and steep rise in non-communicable diseases call for an immediate attention to this topic. Regulations in India are weak, non specific and left to the will of company’s self regulation code. Rising competition is further weakening the code and ethical conduct of companies. Inter-sectoral and multi-stakeholder intervention should be established to ensure adherence with norms. Policy level changes and legislations should focus on schools, food industry and tele-communication industry simultaneously. ASCI should collaborate with relevant industries and emerge as a stronger body in censoring and verifying the content of advertisements. Health promotional messages like “Fresh fruits and vegetables are best for your child health” should be present on the packaging of every junk food in the market. Schools should be accredited based on their adherence to food and nutrition policy. These ‘Health Promoting Schools’ should have detailed food and nutrition policy. This should enlist functioning of canteens, school’s policy on corporate
Indian J Pediatr
sponsorships and promotion campaigns. Innovative technologies like fruit vending machines should be installed in schools to attract students providing them with healthier options. Special class breaks like fruit break should insist on regular fruit intake. Parents should be educated and made aware of such accreditation and the need of healthy eating through parent teachers meeting and awareness drives conducted in schools. Parents and schools should assume the role of gatekeeper to social influences of child’s eating and access to media. Civic bodies like RWA (Residents Welfare Associations) should assume regulatory stand against marketing in communities, retail establishments, restaurants and schools. This multidimensional approach is needed to urgently tackle the surging public health problem. Acknowledgements The authors would like to thank Mr Sukhwinder Singh, Food Safety Officer, UT Chandigarh for providing relevant literature and Dr Manoj Grover for technical assistance and guidance in manuscript writing. Contributions NB: Review of literature, manuscript writing; RK: Concept of manuscript, review of literature and manuscript review; PD: Manuscript review and editing. Dr Amarjeet Singh, Professor, Department of Community Medicine, PGIMER, Chandigarh, will act as guarantor for this paper. Conflict of Interest None. Source of Funding None.
References 1. Wilcox BL, Kunkel D, Cantor J, Dowrick P, Linn S, Palmer E. Report of the APA Task Force on Advertising and Children. Washington, DC: American Psychological Association; 2004. Available at; https:// www.apa.org/pi/families/resources/advertising-children.pdf (Accessed on April 25, 2014). 2. Marshall D, O’Donohoe S, Kline S. Families, food, and pester power: beyond the blame game? J Consum Behav. 2007;6:164–81. 3. Kaur P, Singh R. Children in family purchase decision making in India and the West: A Review. Academy of Marketing Science Review. 2006;8. Available at: http://www.amsreview.org/articles/ kaur08-2006.pdf (Accessed on April 25, 2014) 4. International C. The Junk Food Trap, marketing unhealthy food to children in Asia Pacific. September 2008. Available at http://www. consumersinternational.org/media/540310/junk_food_trap.pdf. 5. Hastings G, Laura Mc D, Angus K, Stead M, Thomson S. The extent nature and effects of food promotion to Children: A review of the evidence. Technical Paper prepared for World Health Organization: WHO; 2007. Available at: http://www.who.int/dietphysicalactivity/ publications/Hastings_paper_marketing.pdf. 6. Nawathe A, Rohan GR, Sudhir DS. Impact of Advertising on Children’s Health. Proceedings of International Marketing Conference on Marketing & Society, 8–10 April, 2007. Available from: URL: http://dspace.iimk.ac.in/bitstream/2259/356/1/ 303–311. pdf. (Accessed September 10, 2010). 7. Karan J. Advertisement of “Complan”. Indian Pediatr. 2011;48: 412–3.
8. Srinivas MN. A Note on Sanskritization and Westernizatiuon. Journal of Asain Studies (Far Eastern Quarterly). 1956;(15) 4:481–96. 9. Raghav P, Kumar R. The influence of television on children and adolescents in an urban slum. Indian J Community Med. 2010;35: 447. 10. Nayak BS. Television viewing and health behavior of children in south India. Nurs J India. 2011;C11: 11. Kuriyan R, Bhat S, Thomas T, Vaz M, Kurpad AV. Television viewing and sleep are associated with overweight among urban and semi-urban South Indian children. Nutr J. 2007;6:25. 12. Kuriyan R, Thomas T, Sumithra S, Lokesh DP, Sheth NR, Joy R, et al. Potential factors related to waist circumference in urban south Indian children. Indian Pediatr. 2012;49:124–8. 13. Crespo G, Smit E, Troiano R, Bartlett S, Macera C, Anderson R. Television viewing, energy intake and obesity in US children. Arch Pediatr Adolesc Med. 2001;155:360–5. 14. Dietz WH, Gortmaker SL. Do we fatten our children at the TV set? Obesity and television in children and adolescents. Pediatrics. 1985;75:807–12. 15. Borzekowski DL, Robinson TN. The 30-s effect: an experiment revealing the impact of television commercials on food preferences of preschoolers. J Am Diet Assoc. 2001;101:42–6. 16. Gortmaker SL, Must A, Sobol AM, Peterson K, Colditz GA, Dietz WH. Television viewing as a cause of increasing obesity among children in the United States, 1986–1990. Arch Pediatr Adolesc Med. 1996;150:356–62. 17. Lowry R, Wechscler H, Galuska DA, Fulton J, Kann L. Television and its association with overweight, sedentary lifestyle and insufficent consumption of fruits and vegetables among US High school students: Difference in Race. Ethnicity and Gender. J Sch Health. 2002;72:413–21. 18. Proctor MH, Moore LL, Gao D, Cupples LA, Bradlee ML, Hood MY, et al. Television viewing and change in body fat from preschool to early adolescence: The Framingham Chid Study. Int J Obes. 2003;27:827–33. 19. Ruangdaraganon N, Kotchabhakdi N, Udomsubpayakul U, Kunanusont C, Suriyawongpaisal P. The association between television viewing and childhood obesity: a National Survey in Thailand. J Med Assoc Thai. 2002;85:S1075–80. 20. Chernin A. The effects of food marketing on children’s preferences: testing the moderating roles of age and gender, SAGE Study. Ann Am Acad Pol Soc Sci. 2008;615:101–18. 21. Graff S, Kunkel D, Mermin SE. Government can regulate food advertising to children because cognitive research shows that it is inherently misleading. Health Aff. 2012;31:392–8. 22. Ueda P, Tong L, Viedma C, Chandy SJ, Marrone G, Simon A, et al. Food marketing towards children: brand logo recognition, foodrelated behavior and BMI among 3–13-year-olds in a south Indian town. PLoS One. 2012;7:e47000. doi:10.1371/journal.pone. 0047000. 23. Pellai A, Vetrano S, Nobile M, Luti C. The reverse pyramid: a qualiquantitative study about food advertising inside children’s television programmes. Minerva Pediatr. 2012;64:15–26. 24. Wang Y, Lobstein T. Worldwide trends in childhood overweight and obesity. Int J Pediatr Obes. 2006;1:11–25. 25. Government of India. National Family Health Survey, India. NFHS-3 Fact Sheets for Key Indicators Based On Final Data. Available at http:// www.rchiips.org/nfhs/factsheet.shtml Accessed on 25 April, 2014. 26. Freedman DS, Zuguo M, Srinivasan SR, Berenson GS, Dietz WH. Cardiovascular risk factors and excess adiposity among overweight children and adolescents: the Bogalusa Heart Study. J Paediatr. 2007;150:12–7. 27. Li C, Ford ES, Zhao G, Mokdad AH. Prevalence of pre-diabetes and its association with clustering of cardiometabolic risk factors and hyperinsulinemia among US adolescents: NHANES 2005–2006. Diabetes Care. 2009;32:342–7.
Indian J Pediatr 28. Dietz WH. Overweight in childhood and adolescence. N Engl J Med. 2004;350:855–7. 29. Kushi LH, Byers T, Doyle C, Bandera EV, McCullough M, Gansler T, et al. American Cancer Society guidelines on nutrition and physical activity for cancer prevention: reducing the risk of cancer with healthy food choices and physical activity. CA Cancer J Clin. 2006;56:254–81. 30. Ghimire N, Rao A. Comparative evaluation of the influence of television advertisements on children and caries prevalence. Glob Health Action 2013, 6: 20066 - Http://Dx. Doi. Org/10.3402/ Gha.V6i0.20066 DOI:10.3402/gha.v6i0.20066 31. Hari Kumar KVS, Baruah MM. Nutritional endocrine disorders. J Med Nutr Nutraceut. 2012;1:5–8. 32. Wilcox B, Cantor J, Dowrick P, Kunkel D, Linn S, Palmer E. Report of the task force on advertising and children 2004. Summary of the findings and conclusions. Available at http://gaia.adage.com/images/ random/childrenads022404.pdf 33. HFSS Advertising Restrictions-Final Review OFCOM 2010. Available at http://stakeholders.ofcom.org.uk/binaries/research/tvresearch/hfss-review-final.pdf Accessed on 24-9-12. 34. Hawkes C. Marketing food to children, changes in the Global Regulatory Environment 2004–2006. WHO 2007. Available at http://www.who.int/dietphysicalactivity/regulatory_environment_ CHawkes07.pdf (Accessed on 10 April 2012) 35. World Health Organization, European Region. Code on marketing of food and non-alcoholic beverages to children. Prepared by the European Network on reducing marketing pressure on children. August, 2009. Available at: http://www.euro.who.int/en/what-wedo/health-topics/disease-prevention/nutrition/policy/member-statesaction-networks/reducing-marketing-pressure-on-children
36. Kent MP, Dubois L, Wanless A. Self-regulation by industry of food marketing is having little impact during children’ s preferred television. Int J Pediatr Obes. 2011;6:401–8. 37. Dadhich JP. Misleading health claims for food products need to be banned. Indian Pediatr. 2011;48:413–5. 38. Available at http://www.ascionline.org/index.php/faqs.html [Accessed on March 20, 2014] 39. Morley B, Martin J, Niven P, Wakefield M. Public opinion on foodrelated obesity prevention policy initiatives. Health Promot J Austr. 2012;23:86–91. 40. Haby MM, Vos T, Carter R, Moodie M, Markwick A, Magnus A, et al. A new approach to assessing the health benefit from obesity interventions in children and adolescents: the assessing cost-effectiveness in obesity project. Int J Obes. 2006;30: 1463–75. 41. Oommen VG, Anderson PJ. Policies on restriction of food advertising during children’s television viewing times: an international perspective. In: Proceedings Australian College of Health Service Executives 2008 Conference, Going for Gold in HealthMotivation, Effort, Performance. Gold Coast, Australia. 2008. 42. Programme and Advertising Codes prescribed under the Cable Television Network Rules, 1994. Available at http://www.mib.nic. in/WriteReadData/documents/pc1.pdf. (Accessed on 14 December 2013) 43. Penalty for misleading advertisement. In: The Food Safety and Standards Act, 2006. IInd ed. New Delhi: Commercial Law Publishers; 2012. p. 41 44. Vashishtha VM. Advertisement of food products for children: a tale of legality, ethics and indifference. Indian Pediatr. 2010;47:857–9.
REVIEW ARTICLE
Food Marketing to Children in India: Comparative Review of Regulatory Strategies Across the World Nidhi Bhatnagar & Ravneet Kaur & Puja Dudeja
Received: 2 September 2013 / Accepted: 30 April 2014 # Dr. K C Chaudhuri Foundation 2014
Abstract Food marketing directed to children is an issue of concern in the present day society. Revolution in food industry, increasing globalization and boom in information technology has introduced various types of food products and the way they are placed in front of likely consumers. This has resulted in rising trend of obesity and switch from communicable to noncommunicable diseases, which is not cost effective for nation as a whole. Multinational companies have targeted children as a naïve audience to boost their sales. In-ethical practice of misleading claims in the advertisements is instrumental in many cases. Food marketing to children has been assumed a public health threat since times of yore. World Health Organization has resolutions and recommendations on this subject. Member countries, including India are a signatory to this declaration. However, much needs to be done to counter these multinational food giants. Regulations and policies need to be enforced at national and institutional levels. Parents must be educated; schools and social organizations to be made proactive on this aspect. Keywords Food . Marketing . Regulations . Children . India
Introduction “Advertising is a non-moral force, like electricity, which not only illuminates but electrocutes. Its worth to civilization depends upon how it is used.” J. Walter Thompson Marketing is a business principle which uses research and other methods to promote products and services. Through N. Bhatnagar (*) : R. Kaur : P. Dudeja Department of Community Medicine, Post Graduate Institute of Medical Education and Research, Chandigarh 160012, India e-mail: [email protected]
market research, demand for product or service, can be assessed along with potential competition and other factors, such as pricing, customer satisfaction and sale trends. Advertising aids in promoting goods among likely consumers and is a component of the entire process of marketing. Modern media and captivating advertisements establish product in the minds of viewer. Food marketing, in present times has gained momentum with increasing globalization, breaking up of joint family system, working parents, influence of media etc. Growing restaurant business, attractive food combos, party packages and meals at heavily discounted rates add branded and competitive touch to food advertisements. Introduction of fast foods and ready to eat food mixes offer unhealthy choice to consumers. Advertising places product within the reach of consumer creating a felt need simultaneously. Children have been identified as easy targets in this process. Their purchase choices are easily influenced by advertisements shown in televisions and other promotional offers [1]. Wants and needs are negotiated within the family, in the form of repeated requests (pester power), [2] subsequently translated into major purchase decisions of family [3]. More than 50 % parents in a multi country survey agreed for children to be an important factor in influencing purchase decisions [4]. A Systematic review by WHO (World Health Organization) highlighted prioritization of children in marketing strategies of food companies [5]. Thus, there arises a major concern for regulating food marketing targeting children. Majority of literature on this subject originates from developed countries. Very less research and practice has been done in India. Rising middle income group, reach of technology and sound market research strategies is bolstering the threat in developing economies like India. This article attempts to highlight the need for regulatory restrictions on food marketing in India. Current status of regulations in India are compared across nations and commented upon with evidence gathered from studies done across the world.
Indian J Pediatr
Material and Methods This is a narrative literature review which took an iterative approach in finding relevant literature. This was done to capture exhaustive literature on the topic. Comprehensive coverage of published work, policies, reports and legislations related to the subject was done. Language restriction to English was done for search, however no time restriction was entered. Pub med, IndMed, Directory of Open Access Journals and Google Scholar were used to identify published and unpublished/in-progress studies, references and citations of articles of interest. Search terms that were used in the process were: “food”, “marketing”, “children”, “India”, “legislations”, “dietary preferences” and “television”. In addition, manual search of articles was done from institute library to collect relevant information. Systematic search of pertinent journals e.g., Public Health Nutrition, American Journal of Public Health, Nutrition Reviews, Preventing Chronic Disease and Indian Pediatrics was done.
Targeted Marketing and it’s Impact India offers fertile ground for investment by multinational food and beverage giants. Aggressive marketing strategies are adopted to attract consumers. Advertising industry amounts to nearly Rs.16,300 crore, out of which snack food market constitutes Rs.4500 crore (28 %), and branded food advertizing constitutes Rs.1300 crore (8 %). Only 2 % of company’s budget is earmarked for research and development and nearly 50 % into product advertising [6]. Children today are potential consumers. Marketing techniques are designed to appeal to them directly e.g., use of celebrities, catchy slogans, brand owned or licensed cartoon characters, inclusion of free gifts, toys or collectible items, inclusion of competitions, vouchers or games and changing shape or novelty value of food. This strategy is often targeted at places children visit frequently e.g., school canteens, children centers, exhibitions, cultural events, fetes, family and child clinics. Availability and prominent visibility provides an easy buy. Food market is segmented to capture every type of child consumer e.g., for small children (birth - 3 y) parents are targeted and product is shown to enhance health and immunity of children. Complan, a common nutrient powder in India strongly claims increase in growth in the advertisement based on study which is methodologically incorrect and lacks scientific rigor. Age, socio-economic class were confounders with gross errors in the methodology of study. Moreover, the study was financially supported by manufacturers of the product which would have resulted in conflict of interest. Such flawed study cannot form basis of strong recommendations given by the company in advertising products on television [7].
Pester power is created among younger ones to force parents for purchase. For teenagers, peer pressure is generated using prominent youth icons for promotion. Sanskritization, influences children from lower socioeconomic classes. Castes lower in hierarchy seek upward mobility by emulating rituals and practices of upper or dominant castes [8]. This makes children buy low cost food items that they see in advertisements or go for cheap alternative that they can afford which is nutritionally poor and even hazardous to health. With rising penetration of mass media in community, television commercials are employed extensively for the process of marketing and promoting food among children. In urban slums of north India, nearly 96.3 % children had access to television. Mean age of onset of television viewing was 2.96 y and mean hours of television viewing was 3.56 h [9]. Another study conducted in south India found 49 % children viewing television for more than two hours per day and 7 % more than 4 h per day. During weekends 71 % children were watching television for more than two hours and 24% for more than 4 h daily. Most (44 %) of the children were influenced by the advertisements of food items [10]. Significant association between obesity and television viewing was found in a study conducted in urban and semi urban south Indian children [11]. Study done in urban south Indian children in Bangalore found increased consumption of bakery items, increased television viewing, decreased sleep duration and eating while watching television, significantly related to waist circumference [12]. Impact of television commercials on children was observed to be consistent across age groups and gender [13-19]. However, advertisements are instrumental in influencing mind of children less than 8 years of age as there is paucity of knowledge of persuasive intent [20]. Cognitive research indicated that young children cannot effectively recognize the persuasive intent of advertising or apply the critical evaluation required to comprehend commercial messages [21]. A study found significant correlation between brand logo recognition (a measure of marketing exposure) and higher BMI, independent of socioeconomic group, age and gender. Children’s preferences were found oriented towards unhealthy options and preference reported to increase with age. More purchase request behavior was reported in children with higher socio-economic status [22]. Another study used food products advertised and children viewing time to construct a food pyramid. Sweets and confectionaries were the base of the pyramid, reverse of what is required for a balanced diet [23]. With increasing number of channels primarily viewed by children and other modes of audio-visual media e.g., internet available to them, there arises a major concern for regulation of the quantity and quality of these food advertisements and promotions. This brand consciousness and aggressive food marketing is creating a society of obese people [5]. Obesity pandemic is a serious public health challenge of 21st century. There is
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predicted 27.5 % rise in overweight children of South East Asian region between 2005 and 2010 [24]. Anemia and multivitamin deficiencies have increased despite several preventive and curative strategies. NFHS (National Family Health Survey) III has shown that 79 % children are anemic, irrespective of the socio economic status [25]. Obese youth are more likely to have been identified as risk factors for cardiovascular disease [26, 27]. There is greater risk for bone and joint problems, sleep apnea, social and psychological problems such as stigmatization and poor self-esteem [28, 29]. Studies have documented increased association of periodontal problems with television viewing [30]. Increased risk of cancer now accounts for 60 % of global deaths. Junk foods are proposed to act as endocrine disruptors, leading to obesity and other pubertal disorders [31].
Regulatory Strategies: Past and Present Concerns for child directed advertising was present since ancient times. British Parliament in 1874 passed legislation to protect children from merchants who induce them to buy products and assume debt. In 1970s, Federal Communications Commission proposed to ban advertising to young children but limited amount of advertising time and certain advertising practices. Federal Trade Commission considered banning all television advertising to young children but yielded under the pressure of advertising industry [32]. After a long gap, in 2002–03 publication of Government Chief Medical Officer’s Report, United Kingdom highlighted this issue. Food Standard Authority (FSA) of UK conducted a systematic review of studies on food promotion and gave the nutritional profiling model for labeling high in fat, salt and sugar (HFSS) foods to be placed under advertising regulations. UK Food Standards agency, 2007 defined HFSS food with fat 20 g, sugar 15 g, and saturates 5 g per 100 g [33]. In 2004 global strategy on diet, physical activity and health was the first to draw global attention on this agenda. In May 2007, World Health Assembly adapted Resolution WHA60.23, to develop recommendations on the marketing of foods and non-alcoholic beverages to children. Global regulatory policy on marketing food to children was released by WHO in 2006 [34]. In 2009, WHO Secretariat developed recommendations on ‘Marketing and Advertising of Foods and Non-Alcoholic Beverages to Children’, endorsed by 63rd World Health Assembly in May 2010. This was followed by report, ‘Recommendations on the Marketing of Foods and Non-alcoholic Beverages to Children’ in 2011 [35]. WHO recommended ‘Overall policy objective should be to reduce both the exposure of children to, and power of, marketing of foods high in saturated fats, trans-fatty acids, free sugars, or salt.’ This was approved by the member states and India stands signatory to this declaration. Issue of advertising to young children is of public concern. Advertising industry has recognized the sensitivity and has its
own self-regulatory advertising guidelines but till date the code is vague, compliance voluntary and enforcement not actively pursued [34]. In most of the countries including India, self regulatory measures are adopted by food and beverage companies for regulating child directed food advertising. However, there are several inadequacies in the industry’s voluntary measures [13, 14, 26, 21]. A study done in Canada, to assess self-regulatory marketing initiative, CAI (Children’s Food and Beverage Advertising Initiative) found voluntary participation in self-regulation code to curb child directed marketing, resulting in competitive disadvantage. Moreover, extent of following the self regulatory code was unequal and many felt short of achieving the desired objectives. There is a pressing need of well framed regulations, enforced in the society and supplemented with policy level measures in schools along with educating parents [36]. There is an imminent need to check the misleading claims made in advertisements. Claims made by food supplements in advertisements should be based on sound studies rigorously evaluated by independent agencies. There should be laws governing the process. In United States, Food and Drug Administration (FDA) has regulatory responsibility for dietary supplements. Federal Trade Commission (FTC) of US regulates advertising of dietary supplements in print and audio-visual media. Similarly in European Union, article 16 of the general food law has recommendations on the same [37]. Advertising Standards Council of India (ASCI) facilitates general public to file an online complaint against misleading advertisements and to track the progress of same. Measures have been introduced recently in 2013 to hasten the processing of the complaints using FTCC (Fast Track Intra Industry Complaint) and SPI (Suspension Pending Investigation). To improve closer monitoring of adverti sements NAM S (National Advertising Monitoring Service) has been set up which monitors nearly 1500 advertisements per month [38]. Public health interventions, focused on changing environment through policy and regulation have successfully targeted reducing health risk behaviors such as tobacco and alcohol consumption [39]. Such stringent measures are needed in food industry as food marketing environment is contributing to health crisis with members unlikely to voluntarily make changes in this aspect. A study done in Australia to gauge policy level interventions that support healthier food choices revealed interventions directed to advertisements as most well accepted (83 %) compared to taxation and control on sponsorship of sports and education programs. Moreover, more adults approved selected ban of advertisements during children viewing time [40]. One European country, fifteen American states and six Canadian provinces have already implemented statutory guidelines for marketing of HFSS foods to children. In Brazil, law restricting sale of energy dense, nutrient-poor foods in the Federal district was implemented, adding to
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restrictions already in force. Philippines and South Korea have strict laws pertaining to the advertisements of fast food and confectionery. Sweden has the strictest controls in Europe and in 1991 instituted a ban on television and radio advertising targeted at children under the age of 12. In Belgium, it is forbidden to broadcast commercials during children’s programs and 5 min before and after them. Commercial TV Code formulated by Australian Communications and Media Authority (ACMA) does not allow ads during television programming for preschoolers. However, it does not place complete ban on other forms of marketing [24]. In UK, OFCOM (Office of Communications) is the regulating body and has completely banned all forms of advertisements in children under 9 y of age. In USA, children’s Advertising Review Unit (CARU) established by the National Advertising Review Council (NARC) is a self- regulatory program to check advertising directed to children . The CARU guidelines apply only to children under 12 y of age and are mild in nature. Canadian code of advertising standards have placed complete ban on all forms of food marketing to children under 13 y of age in Canada [41]. India has regulations by the Information & Broadcasting Ministry and Ministry of Consumer Affairs. Most of the SelfRegulation Organizations around the world base their work on the codes prepared and published by the International Chamber of Commerce (ICC). ‘Advertising Agencies Association of India’, and the ‘Advertising Standards Council of India (ASCI)’, are business organizations and can put moral pressure on advertisers and companies to withdraw objectionable advertisements [34]. Its main objective is to promote responsible advertising, enhancing public confidence. ASCI’s Code for Self-Regulation in advertising is now part of ad-code under Cable TV Act’s Rules. The act and ASCI code is applicable to all states. Program and Advertising Codes prescribed under the Cable Television Network Rules, 1994 state that ‘No advertisement which endangers the safety of children or creates in them any interest in unhealthy practices or shows them begging or in an undignified or indecent manner shall not be carried in the cable service.’ It further mentions that ‘Care should be taken to ensure that programs meant for children do not contain any bad language or explicit scenes of violence. Programs unsuitable for children must not be carried in the cable service at times when the largest numbers of children are viewing.’ However, no clear reference to marketing of unhealthy food to children or exact time regulations were made in this act. Self regulation guidelines for Broadcasting Service Provider (BSP) state that ‘BSP should take reasonable steps to protect minors. It should be vigilant in gaining an understanding of how material shown on television could impact the development of minors. It is therefore necessary for BSP to exercise judgment on the capacity of minors in different age groups in coping with the
depiction and treatment of material, which may not be suitable for them. There is a progressive decline in the proportion of minors present as television audience through the evening and during the night. The restrictions on the broadcast of program unsuitable for minors should be relaxed on a gradual and progressive basis after 8 pm. The assumption is that after 8 pm parents are expected to share responsibility for what their children are permitted to watch on television [42]. The Food Safety and Standards Act, 2006 has clause 53 in section 56 that clearly states that any person who publishes or is a party to the publication of an advertisement which-a) Falsely describes any food or b) is likely to mislead as to the nature or substance or quality of any food or gives false guarantee, shall be liable to a penalty which may extend to ten lakh rupees. Authorities entrusted for food safety will be responsible for enforcing the law [43]. Professional bodies like Indian Academy of Pediatrics (IAP) have passed resolutions to prevent sponsorship from companies that manufacture products covered under Infant Milk Substitutes Act 1992. Initiatives like this preserve the sanctity of medical profession, nevertheless are diluted with the passage of time [44]. Impact of restrictive ban on advertisements and marketing of HFSS products needs to be deliberated. A recent publication stated that exposure of children to HFSS food advertising, as a proportion of all advertising seen, did not change despite adherence to advertising restrictions [3]. Hence, there is a need to enforce regulations in marketing and advertising along with measures like educating parents and developing code for the same in schools.
Conclusions Surging obesity rates and steep rise in non-communicable diseases call for an immediate attention to this topic. Regulations in India are weak, non specific and left to the will of company’s self regulation code. Rising competition is further weakening the code and ethical conduct of companies. Inter-sectoral and multi-stakeholder intervention should be established to ensure adherence with norms. Policy level changes and legislations should focus on schools, food industry and tele-communication industry simultaneously. ASCI should collaborate with relevant industries and emerge as a stronger body in censoring and verifying the content of advertisements. Health promotional messages like “Fresh fruits and vegetables are best for your child health” should be present on the packaging of every junk food in the market. Schools should be accredited based on their adherence to food and nutrition policy. These ‘Health Promoting Schools’ should have detailed food and nutrition policy. This should enlist functioning of canteens, school’s policy on corporate
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sponsorships and promotion campaigns. Innovative technologies like fruit vending machines should be installed in schools to attract students providing them with healthier options. Special class breaks like fruit break should insist on regular fruit intake. Parents should be educated and made aware of such accreditation and the need of healthy eating through parent teachers meeting and awareness drives conducted in schools. Parents and schools should assume the role of gatekeeper to social influences of child’s eating and access to media. Civic bodies like RWA (Residents Welfare Associations) should assume regulatory stand against marketing in communities, retail establishments, restaurants and schools. This multidimensional approach is needed to urgently tackle the surging public health problem. Acknowledgements The authors would like to thank Mr Sukhwinder Singh, Food Safety Officer, UT Chandigarh for providing relevant literature and Dr Manoj Grover for technical assistance and guidance in manuscript writing. Contributions NB: Review of literature, manuscript writing; RK: Concept of manuscript, review of literature and manuscript review; PD: Manuscript review and editing. Dr Amarjeet Singh, Professor, Department of Community Medicine, PGIMER, Chandigarh, will act as guarantor for this paper. Conflict of Interest None. Source of Funding None.
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