Will The National Food Alliance's call for tighter regulation on food advertising to children succeed? Donu Kogbara looks at the organisation's burgeoning influence
Thou shalt not consume two bars of chocolate on TV. Thou shalt not covet Harry Enfield's supermarket trolley full of Dime bars. The Independent Television Commission introduced these, and other, commandments to its Code of Advertising Standards and Practice last month, taking its lead from the consumer protectionist organisation, the National Food Alliance.
The bad news for food advertisers and their agencies is that the NFA has ambitions, which are beginning to be realised, to bring about further regulation on the advertising of "unhealthy foods". Its grand plan is, nobly, to improve the dietary intake of Britons; its ill-chosen target is advertising.
The ITC's Code, according to the NFA, doesn't go far enough and it would like children's TV to become an "advertisement-free zone". "The ITC has failed to address the cumulative effects of broadcast advertising on children," says Susan Dibb, the NFA's project officer.
The NFA describes itself as an "association of voluntary, professional, health, consumer and other public interest organisations". Its support comes from a diverse range of members and endorsers, from the British Dental Association and Children's Society to Friends of the Earth and the Vegetarian Society. It is partly funded by the Department of Health and Health Education Authority, and claims to broadly echo parental, medical and governmental concerns about health and diet.
Another source of income for the NFA had, until last week, been the Baring Foundation (an offshoot of Baring Brothers, Britain's oldest and now ruined merchant bank). The foundation had been paying for the NFA's controversial Food Advertising Project, but a foundation spokesperson says that its beneficiaries will soon have to find funds elsewhere.
Despite NFA co-ordinator Jeannette Longfield's claim that her organisation is under-resourced, only interested in health issues, willing to work with big business and not half as influential as some people think, its critics remain unconvinced. There are dark mutterings in the ad industry about concealed funding sources, wild-eyed monomania, conspiracies, censorship and a hidden agenda. "I do not believe that the NFA's only aim is to improve our eating habits," says one adman.
Such antagonism comes, in part, as a reaction to the provocatively titled report "Children: Advertisers' Dream, Nutrition Nightmare", penned by Dibb. The report claims that "children are more responsive to, and influenced by, advertising than adults", and that "advertising not only directly influences children's food preferences and choices, but also does so indirectly through its influence on parents and peers". From these assumptions the NFA goes on to recommend an array of measures that include: advertisement-free children's TV; a "levy on particular food advertisers" to be put toward subsidies for advertisers of foods such as fresh fruit and vegetables; and restrictions on the content of advertising snack foods to children.
Simon Bullimore, UK managing director of Mars Confectionery and president of the Incorporated Society of British Advertisers, is one of many who have reacted strongly to the attack. At ISBA's policy conference Bullimore wondered where "nutritional correctness" might lead. "What," he asked, "about those who drink or like driving fast cars or enjoy eating meat? Their turn may come."
But Dibb counters: "As the MD of a company that produces sweets purely for the purpose of making a profit, he can hardly be regarded as impartial."
Bullimore's broadside against the NFA was based on comments made by Professor Barwise of London Business School - in a study commissioned by the Advertising Association. According to Barwise, Dibb's arguments are "dangerously one-sided... and the NFA's case falls down because its logic is weak... it exaggerates or misrepresents much of the evidence it cites, and, above all, it neglects most of the extensive published research on the issue of children and advertising... If implemented, the [NFA] report's proposals on advertising would not achieve their objectives and would lead to costs, inefficiencies and other side-effects... quite apart from being an unwarranted curtailment of freedom." He adds: "The NFA's logic is weak (for example, it fails to distinguish between categories and brands, a crucial distinction in this context)."
"Barwise appears to have misunderstood food habits and was rather selective in the way he interpreted published research. But he was paid to write that report, wasn't he? So we don't consider it to be an independent academic document," says Dibb.
Meanwhile, Matti Alderson, director general of the Advertising Standards Authority, shares many of Barwise's concerns, saying: "people aren't naive - the public should be free to choose from a wide range of foods".
For the NFA Longfield says: "The issue of freedom is a red herring. The Fresh Fruit and Vegetable Information Bureau has less than [pounds]5m a year to spend on advertising, which is petty cash compared to the over [pounds]100m confectioners spend.
"If you want to give the public a free and fair choice, you have to reduce advertising for unhealthy foods or subsidise producers of healthy foods so they can advertise to the same extent."
This is, perhaps, the crux of the argument. Barwise argues advertising generally affects the brands people buy and not complete product categories. It is the quality of a person's diet - from all food types - that influences their health, not the temptation of a particular chocolate bar or fizzy drink. Commercials can persuade both adults and children to buy Twix rather than Kit Kat, or Walkers rather than Smith's crisps, without increasing the overall consumption in such static markets.
"Those who claim to represent public attitudes should have a mandate for doing so. And I'd like to ask what proper research the NFA has done into the public's eating habits? If the NFA is solely concerned about changing our eating habits, why doesn't it focus on education instead of sniping at food manufacturers and firing off buckshot from the sidelines in all directions?" asks Alderson.
Or why, when the NFA could be targeting parents who have a more direct mechanism of control over their children's diets, is it concentrating instead on the influence of advertisers?
"Middle-class mothers tend to find it easier to say 'no' when children exert 'pester power' and demand too many unhealthy foods because they can satisfy their children in other ways," says Dibb. "But low-income mothers fear their children might be stigmatised by economic deprivation and since they can afford small items like crisps or chocolate bars, they'll cave in when it comes to lunch box contents."
Both Longfield and Dibb swear that they are committed to education and have no grudge against commerce. Longfield points to the NFA's "Get Cooking" schools project. And Dibb says: "I realise that the advertising and other industries have a right to fight for their interests. And I'm very disappointed and surprised that some of our critics have ignored my offers to meet for what could be a very positive, democratic dialogue."
Andrew Brown, director general of the Advertising Association sympathises with NFA objectives and has no patience with conspiracy theories. "I do not view the NFA as sinister or malign... I simply disagree with the Draconian methods they suggest and am suspicious about issues such as why advertisers were not, like the NFA, invited to join the Government's Nutrition Task Force."
It was the Nutrition Task Force that, in March 1994, advised the ITC and ASA to review their codes of advertising relating to children. The Nutrition Task Force, in turn, was the first often bodies established to advise the Government on the implementation of its Health of the Nation White Paper. The NFA, consequently, has had an influence on both.
Longfield and Dibb insist the Government is not in the NFA's back pocket. Dibb talks about "fence-sitting" and gloomily observes that Health Secretary Virginia Bottomley (by not going far enough) appears willing to sacrifice public health to the interests of potentially troublesome business cabals.
Longfield says that she's "pretty sure the Department of Health won't touch most of our Food Advertising recommendations with a barge pole." The Department, she claims, restricts its support of the NFA to nice, safe areas like universally agreed health guidelines and the schools projects.
An approach such as this from the Department Of Health is consistent with a Tory government committed to the free market and individual liberty. To go any further than it already has in its support of an organisation that may be well-meaning but nevertheless has a nannying, interventionist approach to the nation's nutritional problems would be neither correct nor in keeping.
Ultimately, the tussle between the NFA and its detractors boils down to an ideological row about the merits and demerits of unadulterated capitalism.
Whereas Dibb and Longfield want to defend the nation's health with an arbitrary control of the market, many partial or total libertarians believe individuals are capable of making their own choices in their own interests.
To restrict the advertising of some foods and allow others free access to the media would constitute an unjustifiable limitation of the public's freedom to choose. If those who sell sugary and fatty foods have more money to spend on advertising, so be it. Regulating and restricting advertisers will not stop children - or adults - from wanting sweets, crisps and fizzy drinks.
If Mars Bars are more extensively advertised than potatoes and tofu, the average Briton will not be tempted to exist solely off snack-food.
The bottom line is that there is enough unbiased scientific information available for parents - and adults in general - to realise nutritionally unsound foods should not be consumed to excess. Or, when we do indulge, we should know that such foods should only be consumed within the context of a varied and healthy diet.
The NFA is undeterred by such arguments. It is currently in touch with the European Commission and other continental bodies that are calling for a complete ban on all ads for all products during children's viewing hours. Some organisations' plans go beyond food to toys and everything in between. Given that Norwegian TV has already "decommercialised children's lives" in this way, UK manufacturers and advertisers would be well advised to view the future with some trepidation.
RELATED ARTICLE: The NFA's Successes and Failures
* The ITC was moved to revise its Advertising Code, from February 1, in relation to food to read: advertisements "must not encourage or condone excessive consumption of any food", "must not disparage good dietary practice", "must not encourage frequent consumption throughout the day... in bed after retiring for the night or children's 'midnight feasts'".
* The ASA backed the NFA's complaint on the Butter Council' ad, which challenged claims about cholesterol and its damaging effects. The NFA said the ruling had come "too late to clear up the confusion".
* NFA member Action and Information on Sugars complained to the ITC in 1991 that Mars' "Work, rest and play" line was an unsubstantiated health claim. The ITC rejected the claim and was accused of "bias in favour of Mars".
* The NFA condemned a Lucozade TV ad showing relay runner Daley Thompson passed a "baton" of Lucozade and being instantly energised, although a time lapse was shown. No viewers had complained and when the ITC rejected the NFA complaint it was accused of a "very literal interpretation of its rules".
* The NFA won a 1992 complaint on a Kellogg's press ad "that in a single bite of brown toast with low-fat spread there's more fat than you find in an entire bowl of Kellogg's Corn Flakes with skimmed milk". The NFA it was attempting to "mislead by omission". The ITC's ruling was based on the undetermined size of the bite.…