It is not just food and drink brands that have cause for concern following the publication of the Department of Health's study into the changes in food and drink advertising to children. Given the threats it contains and, more crucially, the disturbing methodology it uses, the report has wider implications.
The research, undertaken by Billetts, concludes with a promise that the DoH will continue to monitor changes in the nature and balance of food and drinks advertising, thereby making a curb on press, radio and internet activity promoting HFSS foods a real possibility. While the threat has yet to be acted upon, what is most worrying is the rather insubstantial evidence that the argument for such restrictions is based upon.
The report concedes that spend on child-themed food and drink ads (defined as those that 'use licensed characters, children's media connections, free gifts or novelty food design') has fallen every year since 2003, when public concern about food promotion came to the fore. In 2007, spend was 41% less than in 2003.
The study also recognises that 2007 brought the sharpest year-on-year decline, at 19% down, and that restrictions on TV ads meant children saw 66% fewer child-themed TV ads in 2007 than in 2003.
Selective vision
However, by selectively manipulating some increases in spend across the smaller media channels, and across inconsistent time periods, the government has attempted to justify further interference in marketing activity. For example, although child-themed adspend on internet and cinema was lower in 2007 than 2003, the DoH suggests that further restrictions on these media may be needed because, in some years in between, it increased above the 2003 level.
The combined annual child-themed adspend of radio, cinema and internet has grown by just £230,000 (or 11%), while the market share of these media has gone from 1.98% (2003) to 3.71% (2007). In context, total spend on child-themed advertising was down £41.7m.
Ian Twinn, director of public affairs at ISBA, explains that, while advertisers have taken their responsibilities seriously and ISBA has codes for internet advertising, comparing percentage points does not provide an accurate picture of the relationship between like-for-like absolute spends.
'ISBA has been supportive of the changes demanded by parents, but the government needs to realise that if we continue to reduce spend to children there will be less investment in products, less competition and fewer jobs,' he says. 'It is also worrying that the government gives the impression that children live in some kind of bubble of innocence.'
Some pressure groups welcome the possibility of further restrictions. 'It is illogical not to extend the restrictions on TV to other media,' says Richard Watts, co-ordinator for Sustain's children's food campaign. However, he takes issue with the DoH' s definition of what constitutes a 'child' for the purposes of ad targeting (currently defined as anyone up to the age of 15 years old). 'We would like to see the definition of a child extended to the age of 16,' he adds.
Whether the DoH will recommend further restrictions on media outside TV is still unknown. It is more worrying that government policy decisions - and threatening headlines - are made on the basis of fundamentally flawed and subjectively presented data.
Child-themed adspend
2003 2007 Change
(%)
All media £102.7m £61.0m -41
Press £4.7m £6.7m 42
Radio £0.84m £1.15m 37
Internet £0.15m £0.07m -53
Cinema £1.04m £1.0m -4
Source: Department of Health/Billets