The United Kingdom (U.K.) recently announced new regulations that limit unhealthy food advertising to children. But nutrition experts worry that loopholes will obstruct meaningful change. “The devil is in the details,” Dr. Jennifer L. Harris, Senior Research Advisor for Marketing Initiatives at the Rudd Center, tells Food Tank.
New regulations, set to take effect in 2023, prohibit the advertising of foods high in fat, salt, and sugar (HFSS) online and on television before 9:00 PM. Paid advertisements on social media sites including Facebook, Instagram, and Twitter are also included in the online ban.
Researchers at the National Institute for Nutrition and Health in Beijing, China identify screen time as a risk factor for diseases associated with childhood obesity, and U.K. children average 6.3 hours of screen time per day. Additionally, 87 percent of children in the U.K. use social media, often with less parental oversight than television. Given such high levels of screen exposure, digital media advertising regulations may improve child health outcomes.
U.K. government analysis estimates that unhealthy digital food advertisements make 0.73 billion impressions annually, but independent researchers find that calculations used for this figure significantly underestimate spending. According to a study published in the International Journal of Environmental Research and Public Health, unhealthy food makes 10.95-17.5 billion digital impressions to U.K. children per year.
During the same year in the U.S, fast food companies combined spent nearly US$5 billion on advertising, according to the UConn Rudd Center for Food Policy and Obesity. And while social media advertising exposure per day varies, Facebook reported 10 million active advertisers in 2020.
While the U.K.’s new restrictions seem to address concerns about HFSS marketing to children, several loopholes disappoint food policy experts. Companies with fewer than 250 employees will still be permitted to plainly advertise HFSS products across all platforms. Larger companies can still share brand-only advertising. For example, a candy manufacturer can advertise with their product logo, if the candy itself is not pictured. Brand-only advertising may not promote specific items, but experts argue it increases familiarity and brand loyalty.
There are also no limits to the posts that brands can share on their own social media accounts. McDonalds and Coca-Cola have 4.1 and 2.7 million Instagram followers respectively, who may see unpaid HFSS-related content in their regular newsfeed. According to Senior Vice President and Chief Marketing Officer Deborah Wahl, McDonald’s considers social media a “two-way street allowing dialogue, kinship and collaboration.” In 2019, McDonald’s spent nearly US$205 million on advertising in the U.K.
Experts also worry that the regulations do not address podcasts, which is an emerging advertising platform. Research from Ipsos shows that one in four children are podcast listeners.
“Product placements and user-generated content from brands and influencers account for so much of what young people see online. How are they regulating that?” Harris asks Food Tank.
Because advertisers use algorithms to tailor their content based on browsing history, Harris believes it is easy for children to get trapped in an HFSS exposure spiral after one or two interactions with HFSS content.
A report from the American Psychological Association finds that children cannot distinguish between advertisements and programming as easily as adults can. And while time caps limit the number of advertisements that can be included per hour of television, no limits exist for online videos. Research from Common Sense Media finds that the majority of children’s screen time is spent watching online videos. This places them in the “Wild West of advertising on digital platforms,” Anna Lappé, Founder of Real Food Media, tells Food Tank.
High levels of digital HFSS advertising may disproportionately affect historically marginalized communities. Research from the Rudd Center finds that children in low-income U.S. households spend nearly two hours more per day on screens than children in high-income households. Black youth viewed 75 percent more advertisements due to targeted marketing and more screen use than their white counterparts, and investment in Spanish language fast food advertisements is significantly increasing. Similar studies should be conducted in the U.K, due to considerable risk of similar disparities.
Lappé believes that policymakers must strengthen regulations. She points to 2016 regulations in Chile that prohibit HFSS marketing to children under 14 across all platforms. Analysis shows that exposure to unhealthy advertising was reduced by 58 percent one year after implementation. Officials in Oaxaca, Mexico, are taking similar action, banning the sale of junk food to children in 2020 and enforcing new front-of-package labeling.
“[Federal agencies] could and should play a decisive role in cracking down on marketing to kids,” Lappé tells Food Tank. “The need to do so has never been greater.”