RepoRt CaRd on Food-MaRketing poliCies an analysis
oF Food and
enteRtainMent A CoMpany poliCies
RegaRding B+ FoAod a-nd BeveRage
MaRketing
to ChildRen F C B- D+ This study on corporate policies on the marketing of food to children was conducted, © MARCH 2010 and the report written, by Margo G. Wootan, DSc, Ameena Batada, DrPH, and Ona Balkus. Additional help with data collection and analysis was provided by Arianne For more information, Corbett, RD, Lauren McLarney, Seth Coburn, Lindsey Vickroy, and Annalisse Leekley. model policies, and other materials, contact: CSPI and the Nutrition Policy Project MARGO G. WOOTAN, DS c The Center for Science in the Public Interest (CSPI) is a nonprofit organization based in Washington, D.C. Since 1971, CSPI has been working to improve the CENTER FOR SCIENCE public’s health through its work on nutrition, food safety, and alcohol issues. IN THE PUBLIC INTEREST (CSPI) CSPI is supported primarily by the 850,000 subscribers to its Nutrition Action Healthletter and philanthropic foundations. PHONE: 202 777 8352 CSPI’s Nutrition Policy Project works with concerned citizens, health professionals, FAX: government officials and other nonprofit organizations to strengthen national, 202 265 4954 state, and local policies and programs to promote healthy eating and reduce obesity. EMAIL: Our goals are to help reduce the illnesses, disabilities, and deaths caused by [email protected] diet- and obesity-related diseases and conditions, such as heart disease, cancer, high blood pressure, and diabetes.
For more information on CSPI’s projects and other policies to promote healthy eating and reduce obesity, visit www.cspinet.org/nutritionpolicy.
Report Card on Food-Marketing Policies: An Analysis of Food and Entertainment Company Policies Regarding Food and Beverage Marketing to Children is available on-line, free of charge at www.cspinet.org/marketingreportcard .
Acknowledgements The Center for Science in the Public Interest deeply appreciates the financial support provided for this report by the Robert Wood Johnson Foundation’s Healthy Eating Research project and CSPI members.
We thank the members of the Food Marketing Report Card advisory committee for their advice in determining which companies to include in the study, evaluating our assessment/grading criteria, and reviewing the report: angela Campbell, Jd, llM Josh golin, Ma Georgetown University Campaign for a Commercial-Free Childhood sana Chehimi, Mph Prevention Institute Jeff Mcintyre, Ma Children NOW lisa Craypo, Mph, Rd Samuels & Associates, Inc. suzen Moeller, phd American Medical Association lori dorfman, drph Berkeley Media Studies Group ellen Wartella, phd University of California, Riverside Roberta Friedman, scM Rudd Center for Food Policy laurie Whitsel, phd and Obesity, Yale University American Heart Association Marvin goldberg, phd Makani themba-nixon Penn State University Praxis Project Food-MaRketing poliCy RepoRt CaR d1 gRade CoMpanies gRade CoMpanies
— Unilever (Popsicle, Skippy); Highlights for Children, A Inc.; Dannon Company; McDonald’s USA, LLC; H.J. C- Heinz Company (Bagel Bites); Viacom International B+ Mars, Inc. Inc. (Nickelodeon) Sunny Delight Beverages Co.; Krispy Kreme QUBO Venture, LLC; Doughnut Corporation; Cartoon Network; B Procter & Gamble Company (Pringles) D+ Ruby Tuesday, Inc.
Nestlé USA; Kraft Foods Global, Inc.; Cadbury Adams Doctor’s Associates Inc. (Subway); USA, LLC; Hershey Company; Dunkin’ Brands; Yum! Brands, Inc. (KFC, Pizza Hut, Taco Bell); B- General Mills, Inc. D CEC Entertainment Concepts, L.P. (Chuck E. Cheese’s)
Post Foods, LLC; PepsiCo Inc.; Public Broadcasting — C+ Service (PBS); Coca-Cola Company D-
Walt Disney Company (including ABC, Funschool, and Bob Evans Farms, Inc.; CBS Corporation; Pixar); Burger King Corporation; Campbell Soup American Dairy Queen Corporation; Discovery Company; Sesame Workshop; Hostess Brands, Inc.; Communications, LLP; Mattel, Inc.; NBC Universal, C Kellogg Company; ConAgra Foods, Inc. (Chef F Inc.; Univision Communications Inc.; Warner Bros. Boyardee, Kid Cuisine, Peter Pan) Entertainment Inc. (New Line Cinemas)
20th Century Fox Kerasotes ShowPlace Theatre Perfetti Van Melle S.p.A. (Airheads) Activision (Sierra Studios, video games) Kids Discover (magazine) Perkins & Marie Callender’s Inc. Alloy Media and Marketing (Channel One) Klutz (crafts and games) Pilgrim’s Pride Corporation F AMC Entertainment LFP Publishing, LLC Pinnacle Foods Group LLC o American Girl Magazine (Tips & Tricks Magazine) (Aunt Jemima, Lender’s, Duncan Hines) n American Greetings Corporations Little Caesar Enterprises, Inc. Pokémon Company policy Arby’s Restaurant Group, Inc. Lucasfilm Ltd. Popeyes Louisiana Kitchen Blizzard Entertainment (video games) Major League Soccer, L.L.C. (AFC Enterprises, Inc.) Blue Sky Studios (Ice Age, Robots) Marcus Corporation (movie theater) QIP Holder LLC (Quiznos) Boys’ Life Magazine Marvel Characters, Inc. Rave Motion Pictures, LLC Brinker International (Chili’s Grill & Bar) McKee Foods Corporation Red Robin International, Inc. Buffalo Wild Wings Grill & Bar (Little Debbie snack cakes) Regal Entertainment Group Cajun Operating Company (Church’s Chicken) MGA Entertainment, Inc. (Bratz) Romano’s Macaroni Grill Carmike Cinemas, Inc. Microsoft Corporation (XBox) Ryan’s Restaurant Group, Inc. Cheesecake Factory Assets Co. LLC MLB Advanced Media, L.P. (Hometown Buffet/Old Country Buffet) Chick-fil-A, Inc. (Major League Baseball) Sara Lee Corporation Cinemark USA, Inc. National Amusements Inc. (movie theater) Scholastic Inc. Chipotle Mexican Grill, Inc. National Association for Stock Car Auto Schwan’s Home Service, Inc. CKE Restaurants, Inc. (Carl’s Jr., Hardee’s) Racing, Inc. (NASCAR) Sizzler Restaurants Darden Concepts, Inc. (Red Lobster, National Geographic Society SONIC Corp. Olive Garden, Longhorn Steakhouse) (National Geographic Kids) Sony Corporation of America Denny’s, Inc. National Hockey League (Play Station, Sony Motion Pictures) DineEquity, Inc. (Applebee’s, IHOP) National Wildlife Federation Sunkist Growers, Inc. Domino’s Pizza (Wild Animal Baby Magazine,Your T.G.I. Friday’s Inc. E.W. Scripps Company (Peanuts Comic) Big Backyard Magazine, Ranger Rick) Texas Roadhouse, Inc. Electronic Arts, Inc. (video games) NBA Properties, Inc. Time Inc. (Sports Illustrated for Kids, Golden Corral NFL Enterprises LLC Time for Kids) Girls’ Life Acquisition Co. (magazine) Nintendo of America, Inc. Topps Company, Inc. (Bazooka, Hansen Beverage Company OSI Restaurant Partners, LLC Ring Pop, Baby Bottle Pop) Hasbro, Inc. (Outback Steakhouse) Waffle House, Inc. HIT Entertainment Limited (Barney, Bob Panda Restaurant Group, Inc. Wendy’s International Inc. the Builder, Thomas the Train) (Panda Express) Whataburger Restaurants LP Hollywood Theaters, Inc. Panera Bread World Wrestling Entertainment, Inc. HP Hood LLC Papa John’s International, Inc. Zoobooks Jack in the Box Inc. Pearson Education, Inc. (Fun Brain)
1 Within each grade, companies are listed from highest to lower scores. RepoRt CaRd on Food-MaRketing poliCies an analysis
oF Food and Summary
The National Academies’ Institute of Medicine (IOM) concluded that television food enteRtainMent advertising affects children’s food choices, food purchase requests, diets, and health. Yet, companies spend approximately $2 billion a year on marketing foods and beverages CoMpany to children, mostly for foods high in calories, fats, sugars, and sodium, and low in fruits, vegetables, whole grains, and key nutrients. poliCies In 2008, the Federal Trade Commission (FTC) recommended that “all companies that market food or beverage products to children [should] adopt and adhere to meaningful nutrition-based standards for marketing their products” and that marketing include RegaRding all advertising and promotional techniques.
In the past few years, a number of food and entertainment companies have Food and announced policies on food marketing to children independently or through the Council of Better Business Bureaus’ (CBBB) Children’s Food and Beverage Advertising BeveRage Initiative (CFBAI). This report examines whether companies that market food to children have adopted a policy on marketing to children, and if so, the adequacy of that policy. The report does not assess whether companies complied with MaRketing their policies in practice. During the summer of 2009, CSPI staff conducted telephone interviews and searched to ChildRen company Web sites, articles in the Nexis news service, and used Google keyword searches to collect company policies on marketing to children. We evaluated food and beverage manufacturers, chain restaurants, and entertainment companies that market food to children. We assessed policies for marketing to children under the age of 12 years old and for marketing in elementary and secondary schools. Although some children in middle schools and all children in high schools are not under 12, schools are a unique space that should be free of the marketing of low-nutrition foods. “All companies that market food We evaluated the strength of the companies’ nutrition or beverage products to children [should] standards, scope of media covered by their policies, adopt and adhere to meaningful nutrition-based and their definitions for “child-directed” media. standards for marketing their products” and that Of the 128 companies analyzed, two-thirds (68%) did marketing should include all advertising and not have a policy for food marketing to children. A much larger proportion of food and beverage manufacturers promotional techniques. (64%) had marketing policies than did restaurants (24%) –Federal Trade Commission, 2008 or entertainment companies (22%).
No company received an A for its policy. The company with the strongest policy was Mars, which received a B+. The Mars policy did not allow for its products to be marketed to children under 12 years old and covered most of the key media approaches used to reach children (with the exception of on-package marketing and most marketing in high schools). Food and Beverage Chain Entertainment Manufacturers (n) Restaurants (n) Companies (n)
Companies with 64% (18) 24% (10) 22% (13) marketing policies Of companies with policies, % with nutrition 94% (17) 50% (5) 46% (6) standards or did not allow marketing of any foods
The only entertainment company to get a B was Qubo Venture (which has a television channel, Web site, and broadcasts its programming on NBC Saturday mornings, ION Television, and Telemundo). Qubo had a comprehensive policy, applying reasonably good nutrition standards to its full range of marketing. One food company received a B, six got a B-, 17 got a C, and 7 a D. Ninety-five companies received an F; of those, eight had very weak marketing policies and 87 did not have a policy.
Food manufacturers and restaurants were more likely to have policies for television, radio, print, the company’s own Web site, advertising on third-party Internet sites, product placement, and use of licensed characters in advertising. The companies were less Pizza Hut’s “Book It” likely to have policies or policies were weaker for digital marketing, on-package program provides pizza as a reward for reading. promotions, and marketing programs in schools. Food rewards can cultivate unhealthy relationships Eight in ten entertainment companies (45 companies) did not have with food. a food marketing policy. When they did, those policies were generally more limited in scope than were the policies of food and beverage manufacturers. If entertainment companies had a marketing policy, it most likely addressed the use of licensed characters. Policies generally were weaker or did not exist for television, radio, print, company Web sites, other digital media, and product placement. For example, the Cartoon Network applied nutrition standards to the licensing of its characters, but not to its television advertising or Web site, which are the primary means by which it markets to children.
Of the companies with policies for marketing to children, almost all (94%) of the food and beverage manufacturers surveyed had nutrition standards or had policies not to market any of their products to children under 12 years of age. Fifty percent of restaurants and 46% of entertainment companies with marketing policies had nutrition standards. Perfetti Van Melle’s Web site Companies have not complied with the FTC’s recommendation to standardize for Airheads candy includes characters from the popular nutrition criteria for marketing to children. Each company had a different set children’s movie, Alvin of standards. and the Chipmunks: the Squeakquel, as well as games and a kids’ club.
ii Center for Science in the Public Interest | www.cspinet.org Nutrition standards were strongest for saturated fat and trans fat among all types of companies. Food companies and restaurants also tended to have strong policies for total fat. It was more common for food manufacturers and restaurants to have weak policies or no policy for sodium and added sugars. Among the entertainment companies that had policies, sodium and total fat policies were generally weak or absent. Across all companies, a requirement for marketed food to provide positive nutritional value — such as whole grains, fruits, vegetables, vitamins, or minerals — was often weak or not included in the nutrition standards.
Several previous reports found that company compliance with their policies on food marketing to children was high. However, the meaningfulness of that compliance is questionable in light of this study finding that most companies that market to children did not even have a policy (68%), and the majority of existing policies were weak; three-quarters were graded as C, D, or F.
In order for self -regulation of food marketing to children to be effective:
All food and beverage manufacturers, restaurants, and entertainment companies that market to children should have a written food marketing policy that is readily available to the public. Companies that do any marketing to children, even if not during children’s television programming, should have a marketing policy. • Although its program conditions are not ideal, all companies should belong to the CBBB’s Children’s Food and Beverage Advertising Initiative, since its member companies’ policies are generally clearly spelled out, available in one place for public viewing, and compliance is monitored by the CBBB. • The CBBB and entertainment companies should work together to develop a set of entertainment-company-specific criteria for the CFBAI, and entertainment companies should join the Initiative. All companies should use a uniform set of strong nutrition standards. Company marketing policies should cover all approaches used to market to children. Many companies need to strengthen their policies for digital marketing, on-package/in-store promotions, and practices in elementary, middle, and high schools. • Companies should adopt a uniform set of definitions for marketing “directed to children.” A set is expected to be recommended by the Interagency Working Group on Food Marketed to Children.
Without more significant progress in the next two years, the country will need to rely on government regulation, rather than self -regulation, as the means to address food marketing to children.
iii Center for Science in the Public Interest | www.cspinet.org RepoRt CaRd on Food-MaRketing poliCies
Introduction
Food marketing affects children’s diets and health In December 2005, the National Academies’ Institute “Among many factors, food and beverage of Medicine (IOM) released a comprehensive review marketing influences the preferences and purchase of research on the influence of food marketing to requests of children, influences short-term children (IOM, 2006). The IOM concluded that television consumption, may contribute to less healthful (which is by far the largest medium for advertising to children) food advertising affects children’s food diets, and contributes to an environment that choices, food purchase requests, diets, and health. puts their health at risk.” In addition, the committee concluded that the foods and beverages marketed to children are out –Institute of Medicine, 2006 of balance with current dietary recommendations.
Marketing to children is extensive Companies spent approximately $2 billion in 2006 on marketing foods and beverages to children (including toy give-aways with children’s meals at fast-food restaurants) (FTC, 2008). Companies market food to children through traditional media, such as television, radio, magazines, product packaging, and in-store displays and promotions. In addition, they use many other approaches, such as the Internet and other new electronic media, ads in movie theaters, school-based marketing, product placement in movies and video games, marketing in amusement parks, food-themed toys, clothing and other merchandise, and almost anywhere a logo or product image can be shown. Food marketing techniques include the use of spokescharacters, celebrities, cartoons, children’s meals and menus, premiums (such as toys or other items distributed in product packaging, with restaurant meals, through contests, or redeemable via coupons, codes, or proof of purchase), games, contests, kids’ clubs, viral marketing, event sponsorship, and more. Chuck E. Cheese “Pizza Low-income and racial-minority populations are disproportionately exposed to television Maker Play Set” includes and other media (Rideout et al., 2010), which results in heightened exposure to the marketing sauce powder that has of unhealthy foods. Some studies suggest that marketing of low-nutrition foods is to be mixed with ketchup and “cheese”, which has particularly prevalent on television channels targeting African Americans, such as BET maltodextrin as the (Tirodkar & Jain, 2003), and Hispanic populations, such as Univision (Thompson et al., 2008). first ingredient.
Young people are uniquely vulnerable to food marketing Children lack the skills and maturity to comprehend the complexities of good nutrition or to appreciate the long-term consequences of their actions, such as that their dietary patterns can result in cancer, diabetes, and heart or other diseases. Children of different ages face different vulnerabilities to food marketing and diverse challenges to healthful eating.
1 Center for Science in the Public Interest | www.cspinet.org Young children do not understand the persuasive intent of advertising and are easily misled. Based on an extensive research review, the American Psychological Association concluded that until the age of about 8 years old children are unable to understand the persuasive intent of advertisements (Kunkel et al., 2004). According to the IOM, children as old as 10 years may not understand the persuasive intent of advertising (IOM, 2006). Older children, who still do not have fully developed logical thinking, have considerable spending money and opportunities to make food choices and purchases in the absence of parental guidance and the absence of understanding the long-term consequences of poor nutrition.
Most of the foods and beverages marketed to children are unhealthy The primary reason food marketing has a negative effect on children’s diets and health is that the overwhelming majority of marketing aimed at children is for foods of poor nutritional quality (IOM, 2006). A study of Saturday morning children’s television found that 91% of the advertisements promoted foods that were high in saturated fat, added sugars, or sodium, or low in fruits, vegetables, or key nutrients (Batada et al., 2008). A 2000-calorie diet of advertised foods would exceed recommended daily values for total fat, saturated fat, and sodium and provide nearly 1 cup of added sugar (Harrison and Marske, 2005). Carbonated beverages, fast food, and breakfast cereals make up 63% of the total amount spent on marketing to youth (FTC, 2008).
Foods Advertised on Saturday Morning Television
RESTAURANTS 19%
SNACK FOODS 18%
CEREAL & CEREAL BARS 27%
CANDY 14% PACKAGED MEALS & ENTREES 3% FROZEN NOVELTIES BEVERAGES 3% YOGURT 10% BREAKFAST 4% PASTRIES 3%
2 Center for Science in the Public Interest | www.cspinet.org Parental authority is undermined by the wide discrepancies between what parents tell their children is healthful to eat and what marketing promotes as desirable to eat. In addition, while many parents have limited proficiency in nutrition, companies have extensive expertise in persuasive techniques. They hire psychologists and research firms to conduct marketing and neuroscience research to determine how to most effectively influence children’s food preferences and choices. Companies encourage children to choose foods for fun and social acceptance, not for their nutritional or health value (Page & Brewster, 2007). Companies also have ready access to techniques to affect children’s food choices that parents do not have, such as cartoon characters, contests, celebrities, and toy give-aways.
Parents, of course, bear the primary responsibility for feeding their children. Most parents try to get their children to eat a balanced and healthful diet, but billions of dollars spent on marketing low-nutrition foods to children makes it exceedingly difficult.
Children (8 to 12 years old) view an average of 21 food ads on television each day (Gantz et al., 2007), along with many additional marketing messages delivered through Web sites, schools, on food packaging, etc. Given how often companies communicate with children about food, those who manufacture, sell, and promote food to children have an enormous, and usually deleterious, effect on parents’ ability to feed their children a healthful diet.
Self-regulation of food marketing to children Based on the types of food marketed to children and the research that Children’s Food and Beverage shows that marketing has a negative impact on children’s diets and health, Advertising Initiative Participants: the IOM (2006) concluded that, “current food and beverage marketing Burger King practices put children’s long-term health at risk.” Among the IOM’s key Cadbury Adams recommendations is that food and entertainment companies should Campbell Soup Company Coca-Cola Company improve the balance of foods marketed to children within two years ConAgra Foods of the report’s 2006 issuance; otherwise, the report recommended, Dannon Congress should step in to regulate food marketing to children. General Mills Hershey Since the IOM report was released, a number of food and entertainment Kellogg companies have implemented policies on food marketing to children. Kraft Foods The Council of Better Business Bureaus (CBBB) announced the Children’s Mars McDonald’s USA Food and Beverage Advertising Initiative (CFBAI) in November 2006. Nestlé USA Thus far, sixteen food manufacturers and restaurants, representing PepsiCo about 80% of television food advertising expenditures (Peeler et al., Post Foods 2009), have pledged not to market to children under 12 years old any Unilever United States of their products or products that do not meet individual company
3 Center for Science in the Public Interest | www.cspinet.org nutrition standards. To participate in the CBBB Initiative, companies are asked to address advertising through measured media (television, radio, print, and Internet), product placement, and some types of advertising in elementary schools.
A number of beverage and snack food companies have agreed to limit the sale of low-nutrition beverages and snacks in elementary, middle, and high schools through an agreement with the Alliance for a Healthier Generation, a partnership of the William J. Clinton Foundation and the American Heart Association. The School Beverage Guidelines and the Competitive Food Guidelines were adopted in 2006 (AHG, 2009).
Several entertainment companies also have announced efforts to address food marketing to children, primarily by setting nutrition standards for foods which can be associated with characters that they license. In addition, a few companies have announced that Imagination Farms they will apply their standards to other types of marketing, such as sponsorships and uses popular Walt Disney characters to promote the company’s own Web site. No entertainment companies belong to the CBBB’s CFBAI. fresh produce to children.
Food marketing to children report card Studies have found that companies’ compliance with their own policies on food marketing to children is high. The CBBB has completed two assessments on the compliance of companies that belong to the Children’s Food and Beverage Advertising Initiative with their marketing policies (Peeler et al., 2009; Peeler & Kolish, 2008). The CBBB evaluated compliance through company reports and monitoring of 54 hours of children’s television programming in 2009 (Peeler et al., 2009). The Center for Science in the Public Interest (CSPI) also found high compliance by CFBAI companies with their stated marketing policies by evaluating the nutritional quality of products approved by companies for marketing to children and monitoring advertising in 28 hours of children’s television programming on Nickelodeon in 2009 (Batada & Wootan, 2009).
If compliance is strong, the next key question is “compliance with what?” How strong are company policies for food marketing to children? If the U.S. Congress, Federal Trade Commission, other policy makers, advocates, and parents are to assess the effectiveness of self-regulatory efforts, they need a comprehensive analysis of company marketing policies.
The Federal Trade Commission has recommended that “all companies that market food or beverage products to children should adopt and adhere to meaningful nutrition-based standards for marketing their products” and that marketing should include all advertising and promotional techniques (FTC, 2008). Previously, CSPI summarized company marketing policies and the nutrition standards for marketing to children for a number of food manufacturers, restaurants, and entertainment companies (CSPI, 2009a; CSPI, 2009b). However, a need has been identified to analyze in more detail the strength of those policies and the policies of additional companies.
4 Center for Science in the Public Interest | www.cspinet.org In this study, we set out to meet that need by assessing many more companies’ policies and evaluating the relative strength of each policy. This assessment was a challenging undertaking given that each company has a different policy that applies to different media and that has unique nutrition standards and different definitions of media considered to be directed at children. Unlike content analyses that have measured the balance of less nutritious versus more nutritious foods advertised to children, the Report Card on Food-Marketing Policies assesses the strength of each company’s marketing policy .
Methods
Our initial sample included 142 food and entertainment companies that market food to children: 42 food and beverage manufacturers, 42 chain restaurants, and 58 entertainment companies. 2 To identify companies that market food to children, we consulted previous studies and reports, including the FTC’s 2008 report on food marketing expenditures to children (FTC, 2008) and studies on food marketing on the most popular children’s Web sites (by number of visits) (Moore, 2006; Lingas et al., 2009).
We included companies identified as the top 100 food processors (Fusaro, 2008) and top 100 restaurants (Hume, 2008). Of those 200 companies, we determined which had children’s sections on their Web sites, children’s meals/menus, corporate programs for children or schools, or other marketing for children. In addition, we included companies that license the most popular children’s characters; that were one of the top movie-theater chains, children’s television channels, or video-game producers; and that produced the top children’s movies or magazines (NATO, 2009; FTC, 2008; Jones, 2008; Nielsen, 2008; Ad Age, 2003). All 16 companies that have policies through the Council of Better Business Bureaus’ Children’s Food and Beverage Advertising Initiative were included in the study.
Although they were included in the FTC expenditures study (FTC, 2008), we did not assess policies for three check-off programs (i.e., commodity promotion boards). 3 We also excluded from the grading 11 produce companies. 4 While, ideally, all companies that market to children should have a marketing policy, those companies market only fruits and vegetables — healthful foods that are greatly under-consumed by children. Thus, we evaluated a total of 128 companies (142 companies minus three check-off programs and 11 produce companies).
2 In most cases, we analyzed the marketing policy of the parent company. Several of the parent companies in the study operated more than one restaurant concept or media subsidiary that markets to children. For example, Yum! Brands operates KFC, Pizza Hut, and Taco Bell. 3 California Milk Advisory Board, California Milk Processor Board, and National Fluid Milk Processor Promotion Board (MilkPEP). 4 Boskovich Farms, California Giant Berry Farms, Chiquita, Delmonte Fresh Produce, Dole Food Co., Grimmway Enterprises, Imagination Farms, Ready Pac Produce, Stemilt Growers, Summeripe Worldwide, and LGS Speciality Sales.
5 Center for Science in the Public Interest | www.cspinet.org We evaluated company policies for marketing to children under 12 years old. We included an assessment of not only primary schools, but also secondary school marketing policies. Middle schools include children under 12 (the average sixth grader is 11 years old). Although, all high school students are over 12 years old, schools are a unique place, where children are required to be in attendance and parents are not present to help guide their food choices.
We called each company and administered a questionnaire that explored each company’s policies and nutrition standards for food marketing to children. The questionnaire was developed in consultation with the project’s advisory board, including experts in the areas of child health and welfare, marketing, media, policy, health, and nutrition. In addition, we searched for publicly available information about the company’s marketing practices and policies through reviews of company Web sites and Nexis news service and Google keyword searches.
During the summer of 2009, research assistants called each company and asked to speak with a staff person who would be able to answer questions pertaining to the company’s policy for food marketing to children. Of 128 companies, 11 refused to participate and 27 contact people did not respond to repeated (more than five) calls, for a response rate of 70%. If a contact person did not respond to repeated calls and no marketing policy was identified through the company Web site and Nexis and Google searches, we categorized the company as not having a policy for food marketing to children (27 companies).
Information from the completed questionnaires and Internet searches was analyzed to determine how many companies had policies and the content of each company’s policy. The policies were rated in comparison to the model policy outlined in CSPI’s Guidelines for Responsible Food Marketing to Children (CSPI, 2006), which are based on key nutrition recommendations in the Dietary Guidelines for Americans (DHHS & USDA, 2005), and in consultation with the project advisory board. Criteria included:
strength of the nutrition standards: • Beverage standards were evaluated by categories of beverages not permitted for marketing (for example, soda, sports drinks, juice drinks, and high-fat milk). • Food and meal standard were assessed for limits on total fat, saturated fat, trans fat, sodium, and added sugars, and a requirement for positive nutritional content (whole grains, fruits, vegetables, or key vitamins or minerals). • For companies that had different nutrition standards for different categories of foods, we scored each set of nutrition standards and averaged them. • Companies that had policies not to market any food products to children received the maximum allotted points for nutrition standards.
scope of media covered by the policy and the strength of definitions of child-directed media.
6 Center for Science in the Public Interest | www.cspinet.org • The points assigned to different types of media were weighted based on the predominance of the media type in the FTC’s marketing expenditures study (FTC, 2008). For example, more weight was given to policies for television than for radio and print marketing. • While the criteria for food companies and entertainment companies were identical for the nutrition standards, there were some differences for the assessment criteria for media approaches: For food and beverage manufacturers and restaurants, we assessed polices for television; radio; print; company-sponsored Web sites; third- party Internet advertising; other digital marketing, such as through cell phones, email, and portable electronic devices; use of licensed characters and cross promotions with movies and television programs; product placement; packaging and in-store displays; marketing in elementary, middle, and high schools; and marketing in out-of-school settings for children. For entertainment companies, the same marketing approaches were analyzed, with the exception of third-party Internet sites and schools. Those two approaches were excluded, since entertainment companies market their own products (movies, television shows, magazines, etc.), not food, through those outlets. Entertainment companies’ scores were based on the types of child-directed media outlets owned by the company. For example, Highlights for Children (publisher of Highlights Magazine) was graded on their marketing policies for print, company-sponsored Web site, cross promotions, and product placement. Its score was not affected by marketing outlets that the company did not own, such as television or radio.
As we undertook the study, we realized that we could have included even more categories of companies. For example, one limitation of the study is that it did not include grocery chains or book publishers (other than Scholastic, which was included along with the publishers of other top children’s magazines).
This analysis was cross-sectional at one p oint in time; some company policies may have changed since we collected our data in the summer of 2009. In addition, it is important to reiterate that we examined company policies on food marketing to children, not practices. For many companies, their policies and practice align. We did note a few companies where they did not. For example, Subway and Ruby Tuesday appear to have stronger practices than their policies reflect. We suspect that some companies that have not used, and perhaps have no plans to use, certain marketing practices did not include them in their policy. We encourage companies to strengthen their policies to reflect their practices and to cover all media available to them.
7 Center for Science in the Public Interest | www.cspinet.org Figure 1: Companies with Marketing Policies
NO POLICY POLICY
70 s e i 60 n a
p 50 m o
c 40 f 45 o
r 30 e 32 b 10
m 20 u
n 10 18 10 13 FOOD AND RESTAURANTS ENTERTAINMENT BEVERAGE (24%) (22%) (64%) type of company (% of companies with marketing policies)
Results and Discussion Examples of Vague Marketing Policies:
Two-thirds of companies lack a marketing policy Warner Bros. Entertainment, Inc.: “Balance Of the 128 companies that we analyzed that market foods our portfolio of licensed/promotional food and to children, one-third (32%) had a policy to govern their beverage products featuring our entertainment characters to include an assortment of healthier marketing practices. A much larger proportion of food or better-for-you offerings” (no definition of and beverage manufacturers (64%) had marketing policies healthier foods was given). than did restaurants (24%) or entertainment companies (22%) (Figure 1). American Dairy Queen Corporation: No company received an A for its policy. The company “ADQ does not intentionally target children with the strongest policy for food marketing to children with national or local TV, radio or print was Mars, which received a B+. The Mars policy did not advertising, nor market food or treats to allow for its products to be marketed to children under children in school settings.” (While this policy 12 years old and covered most of the key media approaches sounds promising, no definitions of child- used to reach children (with exception of on-package directed advertising were specified. Also, the company markets to children through marketing and most marketing in high schools). its child-directed Web site, deeqs.com, and The only entertainment company to get a B was Qubo kids’ meals). Venture (which has a television channel, Web site, and broadcasts its programming on NBC Saturday mornings, Discovery Communications, LLC: “Will only ION Television, and Telemundo). While most entertainment license characters to use with better-for-you companies’ policies covered only a small segment of their foods…based on internal nutrition standards” marketing to children, Qubo applied reasonably good (the company would not share the nutrition nutrition standards to its full range of marketing. Procter standards). & Gamble, which advertised Pringles, also received a B.
8 Center for Science in the Public Interest | www.cspinet.org Six companies earned a B-, 17 received a C, and 7 a D. Those companies had key weaknesses in their nutrition standards, the range of marketing covered, and/or definitions of child-directed marketing. Ninety-five companies received an F. Eight of those companies had marketing policies, but the policies were extremely weak or vague.
The other 87 companies did not have policies and thus, received an F grade. Some companies responded to our questionnaire stating that they do not market food to children. However, while many of those companies did not advertise on children’s television, they did market to children in other ways. For example, many chain restaurants that did not have marketing policies marketed to children through children’s menu items and menus, fundraisers for schools, toy give-aways, movie tie-ins, children’s sections on company Web sites, youth sports sponsorships, and kids’ clubs. No national movie theater chain had a marketing policy, though many marketed to children through advertisements before movie showings, kids’ foods or combo deals at concession stands, kids’ movie clubs, and contests.
Marketing policies varied by type of media Food manufacturers and restaurants
The strength of food manufacturers’ and restaurants’ policies for food marketing to children varied by the type of media (Figure 2). Of the 28 food manufacturers Many food companies and restaurants, including Panda Express, have children’s and restaurants with marketing policies, slightly over 50% had good 5 policies for sections on their Web sites.
Figure 2: Food Company and Restaurant Policies By Media Type
GOOD WEAK VAGUE/NO POLICY N/A 1 1 1 0 0 1 0 0 100% 3
s 90% 4 6
e 7 i 6 7 8 7 n
a 80%
p 1
m 70% 11 17
o 8 c 7 6 5 f 60% 5
o 7 e
g 50% a t
n 4
e 40%
c 21 r
e 4
p 30% 15 15 15 15 14 13 20% 10 10% 7
V O T Y T L / T / T I N N E E G A S C T G E D I T N T R N U N R A I N I E I N I R A P R I T - D E O R P S E S G E O G T M T I I C I M B D A T R E A S O E N T P K - C I R R C C N W E A A A I V H L P D C P - A N O type of media
5 A company policy in the top half of the highest possible score for a particular medium was categorized as good, and scores in the bottom half were classified as weak. For example, the top score for a company’s television policy was eight. Television scores of 5 to 8 were categorized as good, and scores of 1 to 4 were categorized as weak.
9 Center for Science in the Public Interest | www.cspinet.org traditional measured media, such as television, radio, and print (mostly children’s magazines), as well as for the company’s own Web site. Slightly under half (46%) had good policies for advertising on third-party Internet sites. Nineteen percent to 30% of food manufacturers and restaurants had weak policies for the above media, and 15-29% had no policy to address those media or the policy was so vague as to be meaningless. definition of child audience: A company’s definition of what is considered to be child-directed marketing is a key determinant of the scope of where a company ends up marketing its products. Yet, many companies had vague definitions and did not specify the audience composition for what they considered to be child-directed marketing. A coloring sheet available from Red Robin’s Web site Companies with clearer policies defined child-directed marketing as having an audience that ranged from about 18% to 50% under 12 years old. Eight companies defined television advertising as targeting children if more than 50% of the audience was under 12 (Figure 3). Six companies defined child-directed marketing as having more than 35% of the audience under 12. Three (Burger King, Hershey, McDonald’s) used a cutoff of 30%, and one (Mars) used a cutoff of 25%. Campbell used the strongest cutoff, of about 18% (twice the proportion of children in the U.S. population). Higher scores were given to companies with policies that coupled lower audience cutoffs with additional criteria, such as if the medium was identified as targeted to children or included child-directed themes, characters, or animation.
Seven companies had policies that did not permit any of their products to be marketed to children under six (even if the products met nutrition standards) (Table 1). Six additional food manufacturers and two restaurants, as well as one entertainment company, had policies to not market any of their products to children under 12. Such protections are commendable given that young children do not understand the persuasive intent of advertising and are easily misled (Kunkel et al., 2004).
Figure 3: Definition of “Child-Directed”: Food and Restaurant Companies
50% OR MORE 9 8 35% OR MORE
30% OR LESS
NONE
5 6
10 Center for Science in the Public Interest | www.cspinet.org Table 1: Policies to Limit All Marketing to Children
“NO ADVERTISING” “NO ADVERTISING” TO CHILDREN UNDER 6 POLICY TO CHILDREN UNDER 12 POLICY
Campbell Soup Company Cadbury Adams General Mills Coca-Cola Company Kellogg Company Dunkin’ Brands Kraft Foods Hershey Company Nestlé USA Highlights for Children Post Foods H.J. Heinz Company Unilever Krispy Kreme Doughnut Corporation Mars, Inc. Procter & Gamble Company
product placement: Of all the different types of marketing other than television, food processors and restaurants were most likely to have policies on product placement (i.e., the integration of product marketing into movies, television programming, video games, or other media). Of the food companies with marketing policies, 75% had policies on product placement (Figure 2). In contrast, only a third (33%) of entertainment companies had policies on product placement [that was of companies that 1) had a marketing policy and 2) that had media into which product marketing could be integrated]. licensed characters and cross promotions: Use of licensed characters and tie-ins with movies, television programs, or other media are common marketing techniques, amounting to $208 million worth of marketing a year (FTC, 2008). About half (56%) of the manufacturers and restaurants with marketing policies had good policies for the use of licensed characters and tie-ins (Figure 2). A common weakness of the policies was that they had vague definitions of when the use of licensed characters would be considered to be directed to children. In addition, many of the policies applied only to the use of characters in advertising and not to on-package marketing. Finally, the policies did not apply to the company’s own equity characters (i.e., company-owned characters such as, Keebler elves, the M&Ms characters, or the Trix rabbit). Many of those characters are well-known to children and attract children to product packages or advertisements. digital media: Policies were weakest for digital media and on-package/in-store marketing to children (Figure 2). Only 40% of food manufacturers and restaurants that had marketing policies had good ones regarding digital media (other than television or Internet), such as social networks, text messaging, mobile phones, and other new media. Sixteen percent had weak policies and 44% had vague or no policies. Topps Company’s Facebook page for Ring Pop candy The Kaiser Family Foundation’s study of children’s media use found that the increase in children’s media use over the last five years was driven by mobile media (Rideout et al., 2010). Ownership of cell phones by 8 to 18 year olds has increased from 39% to 66% of children and MP3 ownership has increased from 18% to 76% of kids. Given the growth of the digital market place (in part due to lower costs for many of these
11 Center for Science in the Public Interest | www.cspinet.org marketing approaches relative to traditional media, and children’s ready adoption of new media) and the ability of companies to precisely target such marketing, it is essential for companies to have strong policies on digital marketing to children. on-package and in-store marketing: Sixty-one percent of food manufacturers and restaurants with marketing policies did not have a policy, or had only a vague policy, regarding on-package and in-store marketing (Figure 2). On-package marketing includes licensed characters, cross-promotions with television shows and movies, company-owned equity characters, games, promotion of company Web sites, images of premium give-aways, contests, and the general design of packaging to make the product stand out and appeal to children.
In-store promotions include product samples, events, signs, and displays. Companies also pay slotting fees to acquire strategically positioned shelf space so that children can see and reach their products without assistance from their parents.
Only 25% of food companies and restaurants had a good policy for on-package/ in-store marketing (including General Mills, Hostess Brands, Kellogg, Nestlé, and Procter & Gamble). The FTC marketing expenditures study found that companies spent $195 million a year on such marketing, the second highest category of marketing expenditures after television (FTC, 2008).
Entertainment companies
Entertainment companies market foods to children through ads on their television channels, radio stations, Web sites, and in magazines; licensing their movie or television characters to appear on product packaging or in ads; allowing products to be integrated into the content of their movies, television programs, books, or video games; showing ads in their movie theaters or DVDs; and other means.
Compared to food manufacturers and restaurants, entertainment companies’ policies covered fewer types of marketing approaches. The type of marketing most often addressed by entertainment Unilever’s Web site for Popsicles companies was licensed characters (Figure 4); 50% of the entertainment companies, features characters from the Twentieth Century Fox film which had policies and characters that could be licensed, had good policies that Ice Age: Dawn of the Dinosaurs. limited the use of their characters to foods that meet nutrition standards.
One-third (33%) of entertainment companies had good policies for restricting food product placement through its programs or other media outlets (Nickelodeon, PBS, Qubo, and Sesame Workshop). A quarter had good policies for television advertising (27%) or marketing on their own Web sites (25%; Disney, Highlights Magazine, and Qubo).
12 Center for Science in the Public Interest | www.cspinet.org Figure 4: Entertainment Company Policies by Type of Media
GOOD WEAK VAGUE/NO POLICY N/A
100% 1 1 1 2 90% 3 4
s 80% e
i 6 n
a 70% 6 p 9 7 m 60% 6 8 o c 6 f
o 50%
e 6 0 g
a 40% t n
e 30% 2 2 6 0 c
r 1
e 6
p 20% 3 2 4 3 3 3 10% 0 1 1 1
V O T Y L / T I S C H T N N E A N T T S D I T T R I U U R A I I E - N G A P G T D E O N R P S I E O Y I M C I M T O B D A T R E T C E R P C E W A A S H L C P type of media
Qubo was the only entertainment company to receive the maximum allotted points for television advertising. Disney, PBS, and NBC 6 had policies that included some steps to address television advertising. For example, the main Disney Channel’s policy was to not accept any outside advertising (including for food) and to set nutrition standards for sponsorship spots. Other Disney-owned channels, however, such as Disney XD and ABC, did not have nutrition standards for children’s television advertising. PBS’s policy limited advertising to “sponsorship spots,” which could not include depictions of specific products including food. However, spots for brands, such as McDonald’s and Chuck E. Cheese’s, which include predominantly low-nutrition foods, were not limited by PBS.
Finally, one entertainment company (Disney) had a good policy for digital marketing, one had a good policy for print advertising (Highlights Magazine), but none had a good policy for radio advertising.
School-based marketing In schools, children are a captive audience. Unhealthy foods are available in many schools, but parents are not present to guide their children’s food choices or mitigate the influence of marketing. Schools are a major channel for food marketing to children. According to the FTC’s 2008 food marketing expenditures report, marketing in schools was the third-largest category of marketing to children, with $186 million spent in a year.
6 Though NBC had a policy to address television, it lacked nutrition standards to make the implementation of that policy meaningful.
13 Center for Science in the Public Interest | www.cspinet.org Figure 5: In-School Marketing Policies by Food Manufacturers and Restaurants
GOOD WEAK VAGUE/NO POLICY N/A
100% 1 1 1 90% 5
s 80% e i
n 14 14 a 70% p
m 60% o c 14 f
o 50% e g
a 40% t 6
n 7
e 30% c r e
p 20% 8 10% 7 6
ELEMENTARY MIDDLE HIGH SCHOOL SCHOOL SCHOOL
Other than on-package marketing, school marketing policies were the weakest component of food manufacturers’ and restaurants’ marketing policies (Figure 5). We did not assess school marketing policies for entertainment companies, as they market their own company or its products (movies, channels, shows, magazines, etc.), not food, in schools.
More food manufacturers and restaurants had policies for marketing in elementary schools (79%) than in middle (46%) or high schools (46%). However, the percentage of companies with good policies was only slightly higher for elementary schools (29%) than for middle (25%) or high schools (21%). Krispy Kreme markets their Many companies’ policies fell short because they applied only the minimal standards doughnuts to children through for school-based marketing called for in the Children’s Food and Beverage Advertising school-based fundraisers. Initiative (CFBAI, 2009). Those standards are insufficient to address food marketing on school campuses for several reasons.
One is that the CFBAI guidelines only cover elementary schools. While we understand that the CFBAI is limited to children under 12 years of age, the program should, at the very least, cover any school in which there are children under 12 years attending, including most middle schools, where the average 6th grader is 11 years old.
As many companies acknowledge, schools are a unique environment. Just as children under 12 years are vulnerable to the persuasive intent of television and other commercial media messages, older students have other unique vulnerabilities. Older children have more money and opportunities to make food purchases without their parents’ guidance. Parents should be assured that all schools are healthy places that do not undermine efforts to feed their children (of all ages) healthfully. The CFBAI should expand its guidance to include high schools, where a great deal of in-school food marketing takes place.
14 Center for Science in the Public Interest | www.cspinet.org Another major problem with the CFBAI school advertising guidelines is that they only cover a part of food marketing in schools – direct advertising, which the CFBAI describes as “commercial sales messages,” such as those on posters, signs (when not part of a display), coupons, and cafeteria tray liners (when not related to a specific product that a school is selling) (CFBAI, 2009) (Table 2). Other types of marketing for low-nutrition foods are allowed, including food sales, display devices (e.g., racks, coolers, and vending machines), branded fundraisers, public service announcements including brands (if the brand is not a prominent part of the PSA), and other approaches.
The CFBAI program omits product sales themselves as a form of in-school marketing, despite the fact that product sales are a major — and perhaps the most influential — type of marketing in schools. Nationally, 83% of elementary schools, 97% of middle/junior high schools, and 99% of senior high schools sell foods and beverages through vending machines, school stores, or a la carte in the cafeteria (O’Toole et al., 2007). Although healthier foods and beverages are becoming increasingly available, common items sold outside of school meals include candy, sugary drinks, chips, cookies, and snack cakes (CSPI, 2004; Kann et al., 2005; O’Toole et al., 2007; USDA, 2007). The sale of low-nutrition foods outside of school meals is associated with increases in children’s body mass index (BMI) (Kubik et al., 2005).
A number of companies (including, Coca-Cola, PepsiCo, Campbell, Dannon, Kraft, and Mars) have agreed to the Alliance for a Healthier Generation’s nutrition standards for food and beverage sales in elementary, middle, and high schools (AHG, 2009). However, many Marketing via vending machine exteriors is not covered by the CFBAI. other companies did not have nutrition standards for the foods they sell in schools.
Other school fundraising activities also are omitted from the CFBAI school marketing standards. Children are marketed to through a variety of branded fundraising programs and activities in schools, such as enlisting students to sell Hershey candy bars or Little Caesars pizza kits, promoting Subway cards through the schoolPAX program, holding fundraising nights at McDonald’s, Pizza Hut, or Chik-fil-A restaurants, and participating in Campbell or General Mills label redemption programs. The majority of foods sold through school fundraisers are of poor nutritional value. For instance, about half of elementary schools and two-thirds of high schools sell chocolate candy through fundraisers (O’Toole et al., 2007). Given the high rates of childhood obesity and children’s poor diets, companies should not enlist students in selling low-nutrition foods to help schools raise money. Regardless of the CFBAI guidelines, all food manufacturers and restaurants should apply their companies’ nutrition standards to any foods or brands that are part of school fundraising activities.
Through the CFBAI, companies may provide “personal appearances of spokescharacters or third-party celebrities, taped announcements featuring celebrities, posters or functional items such as book covers” (CFBAI, 2009). Whether a company actually shows a picture of a Happy Meal (which is not allowed) or has Ronald McDonald visit the classroom (which is allowed), both are marketing for McDonald’s — marketing all its meals, including those that do not meet its nutrition standards. Similarly, educational curricula and incentive programs often still contain marketing even if the brand logo is small compared with the other text on materials. For example, getting pizza in return for reading books is central to the Pizza Hut’s Book It! Program.
15 Center for Science in the Public Interest | www.cspinet.org Table 2: School Food Marketing Approaches Covered by the CFBAI Elementary Food Advertising Principles
Type of Marketing Not Allowed Allowed
Product Sales — All food sales
Advertising Direct advertising —
Displays & other — • Vending machine exteriors marketing promoting • Menus & menu boards food sales • Branded display racks • Branded coolers & refrigerator cases
Posters directed Posters or tray liners that Posters, signage, and tray at students feature specific products liners that feature specific or brands not tied to or products or brands tied to related to items being or related to items being offered for sale offered for sale
Teaching materials Branded curricula and • Branded curricula and and incentive programs other materials with sales other materials that identify messages or embedded sponsor or provider of branded products materials • Branded food reward programs (e.g., for reading, good grades, or good conduct) and adult-directed marketing materials about reward program
Materials for students Coupons, food samples, • Branded materials for staff and staff pencils, book covers, etc. (e.g., caps, calendars, aprons, etc.)
Fundraising and donations — • Fundraising programs (e.g., label redemption programs) • Formal gift-giving programs • In-kind donations of branded food (e.g., ready-to- eat or packaged) • In-kind donations of branded supplies (e.g., plates or cups) • Events off school campus (e.g., fundraising nights at restaurants and the in-school promotions for those events)
Other Public service • Events after the extended announcements with school day (e.g., family nights) prominent brand or product • Spokescharacters, depictions celebrities, and other public service announcements, as long as company name or brand is “not central”
16 Center for Science in the Public Interest | www.cspinet.org The CFBAI and its member companies unpersuasively argue that some types of school marketing do not target students, but are simply a way to inform school staff and parents. For example, a large collection bin for General Mill’s Box Tops for Education placed in the front hallway of a school is not considered marketing to students. Also, students usually are the ones to bring the box tops into school. In addition, branded mementos and promotional items, such as branded caps, aprons, cups, and calendars, may be given to school staff and faculty, and often are seen by children. We see no difference between such items and a poster, and disagree that such marketing is only incidentally viewed by children (CFBAI, 2009).
Finally, the CFBAI covers the entire school campus, grounds, and buses for the regular school day, but omits school-sponsored activities that take place through the extended school day. Children should not be exposed to marketing for low-nutrition foods at any school events, at any time.
Nutrition standards Of the food and beverage manufacturers with policies for marketing to children, almost all (94%) had nutrition standards or had policies not to market any of their products to children (Figure 6). In addition, 50% of restaurants and 46% of entertainment companies with marketing policies had nutrition standards. Sixty-one percent of food processors, 50% of restaurants, and only 15% of entertainment companies had good 7 nutrition standards or had policies not to market any food to children. 8
Figure 6: Nutrition Standards by Company Type
GOOD OR NO MARKETING WEAK VAGUE/NO POLICY
100% 1 90% s e i 80% n 6 a 5
p 7 70% m o
c 60% f o
e 50% 0 g a t
n 40% e c r 30% 11 4 e
p 5 20%
10% 2
FOOD AND RESTAURANT ENTERTAINMENT BEVERAGE type of company
7 Overall nutrition standards in the top 30 percent of the highest possible score were categorized as good. For individual nutrient standards (i.e., fats, sodium, added sugars, etc.), a standard in the top half of the highest possible score was categorized as good, and scores in the bottom half were classified as weak. For example, the top score for sodium standards was eight. Sodium standard scores of 5 to 8 were categorized as good, and scores below 5 were categorized as weak. 8 Companies that had policies not to market any food products to children under 12 (see Table 1) received the maximum allotted points for nutrition standards. 17 Center for Science in the Public Interest | www.cspinet.org Food companies and restaurants
Most food manufacturers and restaurants that had nutrition standards had strong standards for total fat (93% of companies), saturated fat (86%), and trans fat (100%) (Figure 7). A smaller proportion of companies had good standards for sodium (64%), added sugars (57%), or portion sizes/calories (71%). Several companies that make foods high in sodium had weak or no sodium standards, including Subway, McDonald’s, and Campbell’s (which had reasonable standards for soups, but not for Pepperidge Farm-brand snacks). 9 The major cereal manufacturers had weak added-sugars standards. 10
While almost three-quarters (71%) of companies had a policy for ensuring that marketed products have some positive nutritional value, only 14% of those policies were good. A common weakness was that the policies allowed for the positive nutritional value to be provided through fortification. For children to get the most benefit from foods, the positive nutritional value provided by a marketed product should be naturally occurring in the product, rather than through added vitamins or minerals.
Figure 7: Food Company and Restaurant Nutrition Standards
GOOD WEAK NO POLICY
100% 1 1 2 s 90% 1 3 e
i 4 n
a 80% 6 p 3 1 m 70% o c
f 60% o e
g 50% 14 a
t 13
n 12 8
e 40% c
r 10
e 9
p 30% 8 20%
10% 2
T T T M D E N A A A E S V N O E F F F U D I I Z I R T O T T I L D S D D A I I N S A E N O A G S T R T T O I E O A S U R T O A R S P N P T R T T U U O T N C A S
9 Since our data was collected, Campbell announced it would reduce the sodium in SpaghettiOs canned pastas. 10 Since our study was conducted, General Mills announced a strengthening of its sugars standard for cereals advertised to children.
18 Center for Science in the Public Interest | www.cspinet.org Only a small number of companies had nutrition standards for marketing beverages to children. Nestlé had excellent and PepsiCo had okay beverage standards. Nestlé’s policy limited marketing of high-fat milk and juice drinks. PepsiCo’s policy did not allow soda or juice drinks to be advertised to children. However, the company lost points for allowing the marketing of sports drinks (Gatorade) to kids. While sports drinks are lower in calories than regular soda, they are empty-calorie beverages that get all of their calories from sugars.
Entertainment companies
Few entertainment companies had nutrition standards (Figure 8); only Cartoon Network, Disney, Qubo, and Sesame Workshop did. In addition, Highlights Magazine had a policy that did not allow any food advertising (thus, it did not have nutrition standards and is not included in Figure 8).
Entertainment companies with nutrition standards were most likely to have good standards for portion sizes/calories, saturated fat, trans fat, and added sugars. Standards for sodium and total fat were evenly split between good and weak standards. All company standards for ensuring that marketed foods provide positive nutritional value were weak.
Figure 8: Entertainment Company Nutrition Standards
GOOD WEAK NO POLICY
100%
s 90% e i n
a 80% p
m 70% 6 6 6 6 6 o
c 7 7 f 60% o e
g 50% a t n
e 40% c
r 1 e 2 2
p 30% 20% 4 4 3 3 3 10% 2 2
T T T M D E N A A A E S V N O E F F F U D I I Z I R T O T T I L D S D D A I I N S A E N O A G S T R T T O I E O A S U R T O A R S P N P T R T T U U O T N C A S
19 Center for Science in the Public Interest | www.cspinet.org Recommendations and Conclusion
All companies that market food to children should have a written food marketing policy that is readily available to the public. All companies should belong to the CBBB’s Children’s Food and Beverage Advertising Initiative. Our analysis revealed that the majority of companies that market food to children did not have a marketing policy. Given the high rates of childhood obesity, the negative impact of obesity on health and health care costs, and the effect of marketing on children’s food choices and preferences, diets, and health, it is essential that all companies that market food to children have a written policy that is readily available to the public. Without such policies, the FTC, Congress, other policy makers, advocates, and parents cannot assess how companies are addressing food marketing to children and how well they are complying with their policies. Although Yum! Brands claims their restaurants do not market Our analysis was made difficult by the fact that many companies did not make their to children, Taco Bell promotes a policies publicly available. Although its program conditions are not ideal, all companies kids’ menu that includes Cinnamon Twists, a soft drink, and a toy. should belong to the CBBB’s Children’s Food and Beverage Advertising Initiative, since its member companies’ policies are generally clearly spelled out, available in one place for public viewing, and compliance is monitored by the CBBB.
Companies should have a marketing policy even if they do not advertise on television. No company had an ideal policy. However, nine (7%) companies received a B. The most common grade was an F, because many companies did not have marketing policies. Many of those companies claimed that they did not market to children, because they did not advertise on children’s television. However, those companies market to children in other ways, including through brand or character licensing, branded fundraisers for schools, children’s menu items or menus, toy give-aways, movie tie-ins, children’s sections on company Many chain restaurants, including Web sites, contests, youth sports or youth group sponsorships, kids’ clubs, and/or Whataburger, market to children advertisements before movie showings. via kids’ clubs.
20 Center for Science in the Public Interest | www.cspinet.org Company marketing policies should cover their full range of marketing. Virtually all companies have yet to comply with the FTC’s recommendation to expand the scope of their marketing policies to include all advertising and promotional techniques (FTC, 2008).
Most food manufacturers and restaurants need to strengthen their policies for digital marketing, on-package/in-store promotions, and schools. Food manufacturers and restaurants were more likely to have policies for television, radio, print, the company’s own Web site, advertising on third-party Internet sites, product placement, and use of licensed Ben & Jerry’s, owned by Unilever, characters in advertising. Policies were weaker or absent for other promotes their products through digital marketing, on-package promotions, and in schools. Web-based advergames, such as “Phishfood Flipout.”
Given the considerable weaknesses of the self-regulatory program for marketing in schools, schools should implement wellness policies, and states should pass legislation or adopt regulations to limit junk-food marketing in elementary, middle, and high schools. Local and state governments and school boards should adopt policies to prohibit junk-food marketing in schools, given that the majority of companies had weak or no policies for in-school food marketing and that the CBBB has rejected our suggestions for strengthening the CFBAI school marketing principles (Kolish, 2009).
Many companies patterned their policies on the weak CFBAI school marketing principles. Although the principles disallow some junk-food advertising in schools, many other forms of school food marketing are allowed. We again urge the Council of Better Business Bureaus to revise its Elementary School Advertising Principles and extend them to middle and high schools, and recommend companies strengthen their marketing policies to cover the full range of in-school marketing at all school levels for all times of the extended school day.
Entertainment companies should work with the CBBB to set up a track in the CFBAI for them. Not only did almost 80% of entertainment companies not have a marketing policy, but those policies were generally more limited in scope than were the policies of food and beverage manufacturers. If an entertainment company had a marketing policy, it most likely addressed the use of its licensed characters. Policies were weaker for television, radio, print, company Web sites, other digital media, and product placement.
Since a third of food and beverage manufacturers and three-quarters of restaurants that market to Viacom’s Nickelodeon includes food advertisements on nick.com, such as these Kellogg’s Froot Loops advertisements on the “Fanboy & Chum Chum” page.
21 Center for Science in the Public Interest | www.cspinet.org children did not have policies for food marketing to children, entertainment companies need to ensure that all companies that market through their television programming, Web sites, magazines, radio stations, video games, or other media are covered by nutrition standards and general principles of responsible food marketing to children. Entertainment companies need comprehensive marketing policies to ensure that all marketing placed with them meets strong standards.
Companies should adopt a strong, uniform set of definitions for marketing “direct to children.” Many companies have failed to develop and adopt meaningful, standardized definitions for what constitutes marketing that is directed to children under 12, as recommended by the FTC (FTC, 2008). We strongly support the FTC’s recommendation that such definitions be relevant to the marketing medium and consider the percentage and number of children reached, the time of day, and whether the marketing includes characters, themes, or other features that appeal to children.
We urge the Interagency Working Group on Food Marketed to Children, which includes representatives of the FTC, the Centers for Disease Control and Prevention (CDC), the Food and Drug Administration (FDA), and the U.S. Department of Agriculture (USDA), to recommend a strong set of definitions for companies to adopt.
Companies should adopt a uniform set of nutrition standards for marketing to children. Companies have not complied with the FTC’s Nutritional Quality of Products Approved recommendation to standardize nutrition criteria by Companies for Marketing to Children for marketing to children (FTC, 2008). The diversity of standards makes it harder for advocates and policy makers to assess company compliance with marketing policies. It also results in strategic loopholes in company marketing policies. For example, several companies that make foods high in sodium had weak or no sodium standards. While the major cereal manufacturers had strong 59% of products sodium standards, they had weak sugars standards. approved by companies for marketing to In a recent study, we found that products that children are of companies identified as appropriate to market to poor nutritional quality children met each company’s own standards (Batada & Wootan, 2009). However, the majority (59%) of company-approved products did not meet a third party (CSPI’s) nutrition standard. The percentage of foods that met CSPI’s nutrition standards varied across companies, from 0% to 100%. The majority of company-approved products from Burger King, Nestlé, Dannon, and ConAgra met CSPI’s standards, while the majority of products approved for marketing to kids by PepsiCo, Kraft, McDonald’s, General Mills, Kellogg, Unilever, and Campbell’s failed to meet those nutrition standards.
22 Center for Science in the Public Interest | www.cspinet.org The Interagency Working Group on Food Marketed to Children is expected to propose voluntary nutrition standards for food marketing to children. Its final report and recommendations are due out in July 2010 and should provide a model for companies to adopt.
Conclusion: In order for self regulation to result in meaningful change, all food and beverage manufacturers, restaurants, and entertainment companies that market to children should adopt a uniform set of strong nutrition standards and apply them to the full range of their marketing to children. If substantial progress in corporate marketing practices does not occur by January 1, 2012, the federal government should adopt legislation or regulations to protect children from the marketing of unhealthy foods.
“The food industry overall could do substantially more to limit [children’s] exposure to foods with minimal nutritional value… guidelines for advertising and marketing of foods and beverages must be finalized, and the industry should be encouraged to implement these guidelines on a voluntary basis. If voluntary adoption is not effective…these guidelines should be made mandatory." –President Barack Obama, as a presidential candidate in 2008
23 Center for Science in the Public Interest | www.cspinet.org Appendix: Companies that Market to Children
ENTERTAINMENT COMPANIES 20th Century Fox F Mattel, Inc. F Activision F MGA Entertainment, Inc. (Bratz) F Alloy Media and Marketing F Microsoft Corporation (XBox) F (Channel One) MLB Advanced Media, L.P. F AMC Entertainment F (Major League Baseball) American Girl Magazine F National Amusements Inc. F American Greetings Corporations F National Association for Stock Car Auto F (Strawberry Shortcake, Care Bears) Racing, Inc. (NASCAR) Blizzard Entertainment (video games) F National Geographic Society Blue Sky Studios F (magazine) F (Ice Age, Robots) National Hockey League F Boys’ Life Magazine F National Wildlife Federation F Carmike Cinemas, Inc. F (magazines) Cartoon Network D+ NBA Properties, Inc. F CBS Corporation F NBC Universal, Inc. F Cinemark USA, Inc. F NFL Enterprises LLC F Discovery Communications, LLP F Nintendo of America Inc. F E.W. Scripps Company (Peanuts) F Pearson Education, Inc. (Fun Brain) F Electronic Arts, Inc. (video games) F Pokémon Company F Girls’ Life Acquisition Co. (magazine) F Public Broadcasting Service (PBS) C+ Hasbro, Inc. F QUBO Venture, LLC B Highlights for Children, Inc. C- Rave Motion Pictures, LLC F HIT Entertainment Limited F Regal Entertainment Group F (Barney, Bob the Builder, Scholastic Inc. F Thomas the Train) Sesame Workshop C Hollywood Theaters, Inc. F Sony Corporation of America F Kerasotes ShowPlace Theatre F (Play Station, Sony Motion Pictures) Kids Discover (magazine) F Time Inc. F Klutz (crafts and (Sports Illustrated for Kids, board games) F Time for Kids) LFP Publishing Group, LLC F Univision Communications Inc. F (Tips & Tricks Magazine) Viacom International Inc. C- Lucasfilm Ltd. F Walt Disney Company C Major League Soccer, L.L.C. F Warner Bros. Entertainment Inc. F Marcus Corporation (movie theater) F World Wrestling Entertainment, Inc. F Marvel Characters, Inc. F Zoobooks F
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24 Center for Science in the Public Interest | www.cspinet.org Appendix: Companies that Market to Children (continued)
FOOD AND BEVERAGE MANUFACTURERS Cadbury Adams USA, LLC B- Nestlé USA B- Campbell Soup Company C PepsiCo Inc. C+ Coca-Cola Company C+ Perfetti Van Melle S.p.A. ConAgra Foods, Inc. (Chef Boyardee, (Airheads) F Kid Cuisine) C Perkins & Marie Callender’s Inc. F Dannon Company C- Pilgrim’s Pride Corporation F General Mills, Inc. B- Pinnacle Foods Group LLC F H.J. Heinz Company (Bagel Bites) C- (Aunt Jemima, Lender’s) Hansen Beverage Company F Post Foods, LLC C+ Hershey Company B- Procter & Gamble Company (Pringles) B Hostess Brands, Inc. C Sara Lee Corporation F HP Hood LLC F Schwan’s Home Service, Inc. F Kellogg Company C Sunkist Growers, Inc. F Kraft Foods Global, Inc. B- Sunny Delight Beverages Co. D+ Mars, Inc. B+ Topps Company, Inc. F McKee Foods Corporation (Bazooka, Ring Pop, (Little Debbie) F Baby Bottle Pop) Unilever (Popsicle, Skippy) C-
RESTAURANTS American Dairy Queen Corporation F Little Caesar Enterprises, Inc. F Applebee’s (as part of DineEquity, Inc.) F Longhorn Steakhouse F Arby’s Restaurant Group, Inc. F (as part of Darden Concepts, Inc.) Bob Evans Farms, Inc. F McDonald’s USA, LLC C- Buffalo Wild Wings Grill & Bar F Outback Steakhouse F Burger King Corporation C (OSI Restaurant Partners, LLC) Carl’s Jr. (as part of CKE Panda Restaurant Group, Inc. F Restaurants, Inc.) F Panera Bread F Chick-fil-A, Inc. F Papa John’s International, Inc. F Chili’s Grill and Bar F Pizza Hut (as part of Yum! (as part of Brinker International LLC) Brands, Inc.) D Chipotle Mexican Grill, Inc. F Popeyes Louisiana Kitchen F Chuck E. Cheese’s D Quiznos (QIP Holder LLC) F (CEC Entertainment Concepts, L.P.) Red Lobster F Church’s Chicken F (as part of Darden Concepts, Inc.) (Cajun Operating Company) Red Robin International, Inc. F Denny’s, Inc. F Romano’s Macaroni Grill F Domino’s Pizza F Ruby Tuesday, Inc. D+ Dunkin’ Brands B- Sizzler Restaurants F Golden Corral F SONIC Corp. F Hardee’s (as part of CKE Subway (Doctor’s Associates Inc.) D Restaurants, Inc.) F T.G.I. Friday’s Inc. F Hometown Buffet/Old Country Buffet F Taco Bell (as part of Yum! (Ryan’s Restaurant Group, Inc.) Brands, Inc.) D IHOP (as part of DineEquity, Inc.) F Texas Roadhouse, Inc. F Jack in the Box Inc. F Waffle House, Inc. F KFC (as part of Yum! Brands, Inc.) D Wendy’s International Inc. F Krispy Kreme Doughnut Corporation D+ Whataburger Restaurants LP F
25 Center for Science in the Public Interest | www.cspinet.org References
Advertising Age. “Magazines by Circulation.” Accessed at
26 Center for Science in the Public Interest | www.cspinet.org Kubik M, Lytle L, Story M. “Schoolwide Food Practices Are Associated with Body Mass Index in Middle School Students.” Archive of Pediatric and Adolescent Medicine 2005, vol. 159, pp. 1111-1114. Kunkel D, et al. Psychological Issues in the Increasing Commercialization of Childhood: Report of the APA Task Force on Advertising and Children. Washington: American Psychological Association, 2004. Lingas E, Dorfman L, Bukofzer E. “Nutrition Content of Food and Beverage Products on Web Sites Popular With Children.” American Journal of Public Health 2009, vol. 99, pp. S587-S592. Moore ES. A Kaiser Family Foundation Report. It’s Child’s Play: Advergaming and the Online Marketing of Food to Children. Menlo Park, California: Kaiser Family Foundation, July 2006. Available at
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