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Submission from Television New Zealand Limited to the Health Select Committee on the Public Health Bill

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Submission from Television New Zealand Limited to the Health Select Committee on the Public Health Bill Submission from Television New Zealand Limited to the Health Select Committee on The Public Health Bill 7 March 2008 1 Introduction: Television New Zealand Ltd is a Crown Owned Company established by the Television New Zealand Act (2003) with a remit that includes both maintaining commercial performance and giving effect to its public broadcasting Charter. The TVNZ Charter is the declaration of principles underpinning TVNZ, which emphasises TVNZ's public broadcasting responsibilities and is particularly designed to foster a sense of national culture and identity. The Charter assigns to TVNZ a crucial role in developing and celebrating a shared sense of what it means to be a New Zealander. As the country's nationally-owned public television broadcaster and largest New Zealand-owned media company, TVNZ has been given a mandate to feature New Zealanders and New Zealand events on free-to-air television, supporting locally-made programmes to an extent that is not possible in a purely commercial environment. Although TVNZ is a Crown Owned Company operating under the Charter, it still screens advertisements. TVNZ needs a significant stream of commercial revenue to help fund increasing local content and to purchase the best programmes from around the world. TVNZ earns more than 90% of its revenue from its commercial operations. The public funds it receives go directly into programmes and other specific initiatives such as the digital channels and maintaining transmission sites in remote parts of the country. TVNZ reinvests more than $100 million a year of its commercially earned revenues back into local content (4832.7 hours in FY07). In FY07 18 of the top 20 programmes were on TVNZ channels. 2 Executive Summary 1. TVNZ is passionate about the well-being of New Zealanders and, as such, is supportive of the purpose of the Public Health Bill to reduce the incidence of communicable and non-communicable diseases in New Zealand. 2. The problem of obesity in children in New Zealand, as in other similar countries, is complex and multi-factorial and requires a multi-faceted response. It is not appropriate for one industry or sector to bear the brunt of a multi-factorial ongoing social issue. 3. Less than one percent of all airtime on free to air television consists of advertising for inappropriate foods (those classified by the Ministry of Health as occasional or not at all foods appropriate for younger children). And the opportunity for children to be exposed to this advertising is very limited. On a daily basis in the 3:00pm to 8:30pm zone, all children in the 5-14 age group spend an average of 44 minutes viewing free to air television. That, in turn, means all children in the 5-14 age group are potentially exposed to 67 seconds of advertising for inappropriate foods. This equates to a potential exposure level of 2.2 30-second equivalent advertisements out of a total 946 advertisements that screen on free to air television during that zone in a day. 4. TVNZ is committed to the success of the joint industry self regulation framework agreed with Government to provide responsible programming and advertising. 5. TVNZ believes that the Public Health Bill, in its current form, imposes a needless additional layer of costs, controls and regulations that will result in significant harm to the company ($20 million per annum) and the free to air broadcasting industry without any tangible health benefits to the community. 6. TVNZ submits that clauses 81-88 and clauses 374 (r) and (x) of the Public Health Bill are unnecessary and should be deleted. Background: TVNZ is a supporter of the partnership approach outlined in the Health Select Committee Report on Obesity and Type 2 Diabetes. It was in that spirit that TVNZ and the other free to air broadcasters demonstrated a commitment to making significant advancements in advertising, funding and programming to help fight obesity through the May 2007 voluntary agreement between the Government and the New Zealand Television Broadcasters’ Council. 3 In that agreement, a five point plan to improve food advertising to children was set out. The five point plan is to: 1. Provide free commercial airtime to the Health Sponsorship Council social marketing campaign aimed at improving children’s healthy nutrition – to the value of $0.5 million per annum for the remaining two years of the programme; 2. Introduce a new 'Getting It Right' guide to children’s television advertising which includes a new Children’s Food (CF) rating. Only food products that receive this rating will be able to advertise in programmes directed at children; 3. Work closely with Sports and Recreation New Zealand (SPARC) in the production of television programming aimed at improving diet and exercise practice of children; 4. Provide training for advertisers and agencies in the new Getting It Right guide which is related to the Ministry of Health’s food classification system and the Codes for Food and Children approved by the Advertising Standards Authority (ASA); and 5. Participate in the Government consultative group on food advertising which will include monitoring of food promotion. TVNZ supports the Ministry of Health’s introduction of a food classification system for use in schools which will provide guidelines on food and nutrition. The new edition of the ‘Getting It Right for Children’ Code for advertising to children on television introduces a special advertising classification – CF (Children’s Food). Only food, drink, fast food outlets and confectionary products that receive this rating will be able to be advertised in programmes directed at children aged 5-14. All other advertisements for these products will be rated as General Excluding Children (GXC), which means they cannot be played in the children’s programme zones and all commercials will still have to meet the relevant ASA Code of Advertising Practice. Advertisements require a CF rating from the television industry’s pre-vetting agency, the Television Commercials Approvals Bureau (TVCAB) to resolve the eligibility of the advertisement for a CF classification, based on the Ministry of Health food classification system along with other information supplied by advertisers and agencies. TVNZ recognises that ‘moderation’ programming makes a positive contribution to help fight obesity. The free to air broadcasters screened more than 120 hours of ‘moderation’ programming in the 2007 year, almost two thirds of which (79 hours in total) screened in the 3:00pm-8:30pm zone. 4 According to AGB Nielsen Media Research moderation programming across free to air channels was seen by 91% of children aged 5-14 during 2007. Moderation programming that appeared in the key 3:00pm-8:30pm zone was seen by 87% of children aged 5-14. Below is a list of programmes which have screened on free to air television during the past year which act in a moderation capacity. • The Biggest Loser • Turn Back Your Body Clock • Downsize Me • Downsize my Pet • Fighting Fat • Ian Wright’s Unfit Kids • Diet Doctors • X Weighted • Health Hazard • Is It Safe to Eat? • The Truth About Food Children’s exposure to advertising It is important to understand that the opportunity for children to be exposed to advertising for inappropriate foods is very limited. Free to air television specifically aimed at pre-school children does not carry any advertising content. TVNZ submits that less than one percent of all airtime on free to air television consists of advertising for inappropriate foods (those classified by the Ministry of Health as occasional or not at all foods appropriate for younger children). Using the Ministry of Health’s current definitions for classifying food, “Classifying foods and drinks in early childhood education services”, TVNZ has gathered data that looks at the level of children’s exposure to advertising for those foods and beverages classified as ‘Occasional’ or ‘Not At All’ (O/N foods). Parameters used here are considered to be robust and are as listed below: • Children are defined as 5-14 years of age1 • The period of consideration was calendar 2007 year • The time period under consideration is 3:00pm to 8:30pm • Using main free to air channels only (TV ONE, TV2, TV3, C4, Prime)2 1 AGB Nielsen Media Research is responsible for the measurement of television viewing in New Zealand and measures the viewing of people aged 5+. 2 While Sky Network Television Ltd accepts commercial advertising on 20 of its channels, advertising content is only monitored across five channels (Sport 1, Sport 2, Movies 1, Movies Great and Box). The commercial channels Cartoon Network and Nickelodeon, which are aimed specifically at children, are not currently included in the advertising monitoring. Consequently we are unable to include Sky Television in this analysis. 5 On average, 20 percent of all airtime during a day on free to air channels is made up of advertising content. This equates to an average of 12 minutes an hour across a 24 hour schedule. In TVNZ’s case, the children’s programming slot (on TV2 this is 3:30pm-5:00pm Monday to Friday) has a 10 minute per hour limit. It is also important to note that on TV2 the 3:00pm-3:30pm period is advertising free, as is all Saturday and Sunday morning children’s programming. Using the above parameters less than one percent of total airtime on average in a whole day is made up of advertising for O/N products. It is slightly higher in the 3:00pm-8:30pm zone but still only makes up less than two percent of the total airtime during that time zone. In order to determine the exposure levels of children to these O/N advertisements, it is necessary to consider the quantity of viewing children do of free to air television.
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