This paper aims to outline the historic development of advertising regulation that governs food advertising to children in Australia. Through reviewing primary and secondary literature, such as government reports and research, this paper examines the influence of various regulatory policies that limit children’s exposure to food and beverage marketing on practices across television (TV), branded websites and Facebook pages.
This paper reviews studies performed by the food industry and public health researchers and reviews of the evidence by government and non-government agencies from the early 19th century until the present day. Also included are several other research studies that evaluate the effects of self-regulation on Australian TV food advertising.
The government, public health and the food industry have attempted to respond to the rapid changes within the advertising, marketing and media industries by developing and reviewing advertising codes. However, self-regulation is failing to protect Australian children from exposure to unhealthy food advertising.
The findings could aid the food and beverage industry, and the self-regulatory system, to promote comprehensive and achievable solutions to the growing obesity rates in Australia by introducing new standards that keep pace with expanded forms of marketing communication.
This study adds to the research on the history of regulation of food advertising to children in Australia by offering insights into the government, public health and food industry’s attempts to respond to the rapid changes within the advertising, marketing and media industries by developing and reviewing advertising codes.
Saha, N. (2020), "Advertising food to Australian children: has self-regulation worked?", Journal of Historical Research in Marketing, Vol. 12 No. 4, pp. 525-550. https://doi.org/10.1108/JHRM-07-2019-0023
Emerald Publishing Limited
Copyright © 2020, Emerald Publishing Limited
This paper sheds light on the historic development of the advertising regulation that governs food advertising to children in Australia and investigates how the current self-regulatory system can strengthen its enforcement capacity to restrict food marketers from using integrated marketing strategies to target child consumers, across traditional advertising platforms (including television [TV]), company-owned and third-party websites and social media. Because of the changing nature of media and technology, advertising regulation has been subject to continuous amendments. These amendments have been made in response to ongoing transformations in the media landscape. Food advertising remains intensively debated and is considered to be a potential cause for childhood obesity, which raises concerns for parents and policymakers. It is important to have a thorough understanding of the factors and circumstances that have contributed to past and current advertising regulatory developments in Australia. This research makes an important contribution to the literature by offering insights into how the current regulatory system is responding to a changing media landscape.
Birth of advertising regulation in Australia
During the 1860s, increased employment, followed by increased availability of a wider range of affordable commodities, heightened competition among manufacturers. Advertisers often benefited from increased competition among manufacturers differentiating their brand from their competitors (Blainey, 2003, pp. 52, 369; Butlin, 2013, p. 6; Linge, 1979, pp. 709-10). Increased deceptive and misleading advertising practices by patent medicine industry proprietors, during the late 19th and early 20th century, created concerns among the community. During this time, patent medicine industry proprietors were the largest advertisers for media outlets (Bentham and Bentham, 1998, p. 68; The Daily Examinar, 1938, p. 1; The Brown Independent, 1933, p. 2; The Examiner, 1939, p. 4; The Mudgee Guardian and North-Western Representative, 1939, p. 16). The lack of regulation enabled patent medicine proprietors to advertise extensively (The Daily Examinar, 1938, p. 1; The Armidale Express, 1938, p. 1); however, with questionable legitimacy (Crawford, 2008). Therefore, members of the advertising industry realised that they could improve consumers’ confidence in advertising by not making false claims about products or services (Crawford, 2008, p. 49). At that time, radio’s increasing popularity made it an important advertising medium (The Daily Examinar, 1938, p. 1; The Armidale Express, 1938, p. 1; The Daily Telegraph, 1938, p. 5; The Examiner, 1939, p. 4). The Australian Association of National Advertisers (AANA) was formed in 1928, as the result of a meeting held by 12 advertisers to uphold high advertising standards and safeguard consumer trust and protection for the best interests of community members. The AANA introduced new codes and amended existing codes whenever required so as to uphold the rights and responsibilities of companies and individuals involved in Australia’s advertising, marketing and media industries (Australian Association of National Advertisers, 2015a). Similarly, in the following decades, the advertising industry undertook a number of initiatives that contributed to the industry’s quest for societal legitimacy.
During the 1940s, post-Second World War, government interventions hindered the growth of the Australian advertising industry. The introduction of TV in 1956 increased the growth of TV advertising expenditure in the 1950s immensely (The Sydney Morning Herald, 1954, p. 2). After TV was introduced, advertising agencies feared that unnecessary government intervention would damage commercial TV and hinder the advertising industry’s growth. The flourishing advertising industry was eager to be recognised as a legitimate creative industry (Crawford, 2008, pp. 126-132). Hence, the Media Council of Australia (MCA) was established in 1967 to represent the interests of nearly all conventional media outlets by ensuring that they acted responsibly and ethically. It was responsible for administering a range of self-regulatory codes and accreditation for advertising agencies (Media Council of Australia, 1996).
Media outlets used to sell advertising space to advertisers through advertisement agencies and, in return, these agencies received commissions from the media outlets. However, investigations revealed that the MCA was serving its own interest by accrediting more financially affluent organisations, which could then trade on credit. Thus, while commercial publishers’ and broadcasters’ organisations created an arrangement to ensure that the industry met community standards in relation to the content of advertisements, the accreditation system was used by media outlets as a licence to practise advertising. Although this set-up was beneficial to the media outlets and big agencies for advertisers, it was ineffective as a regulatory body (The Canberra Times, 1975, p. 12; The Canberra Times, 1982a, p. 11).
The publication of The Hidden Persuaders by Vance Packard in 1957 alerted people to advertising’s negative side. Advertisers also started facing increased criticism from leaders, parliamentarians and educators (The Canberra Times, 1982b; Packard and Mercader, 1982). The increasing public debates between academics and admen made the industry realise that, to defend themselves from critics’ attacks, the advertising industry needed to engage with them directly. Therefore, the Australasian (later Australian) Consumers’ Association was established in 1959 (CHOICE magazine, 2020) to protect consumers from misleading advertising by informing consumers about their rights, and the value and safety of products (The Australian Women’s Weekly, 1960, p. 9). The changing media environment, emergence of various media platforms, implementation of new innovative strategies and rise of consumer movements (see e.g. Billboard Utilising Graffitists Against Unhealthy Promotions [BUGA-UP] movement), followed by the Americanisation and internationalisation of the Australian advertising industry during the 1960s and 1970s (Newspaper News, 1959, p. 1; Sinclair, 1991), increased regulatory pressure on commercial creativity (Crawford, 2008).
Increased government regulation of advertising content created the need for a self-regulatory body to protect itself from external intervention. The Australian Advertising Standards Advisory Authority (AASAA) was established in 1973, to safeguard the advertising industry’s interests by enforcing advertising standards. The increased regulation also created the need for a national body to represent agencies’ interests (The Canberra Times, 1973, p. 2). Therefore, the non-profit Advertising Federation of Australia (AFA) was established in 1975 to represent the business and professional interests of its member agencies (The Canberra Times, 1975, p. 12). The AFA offered marketing programmes for their agencies, and provided agencies with important advice on different issues, such as copyright and advertising codes, and with data about their operation and management performance (The Canberra Times, 1976d, p. 7; Jones, 2000, pp. 25-26). Through these activities, the AFA enabled advertising agencies to produce marketing messages that complied with relevant advertising laws and codes, and thus supported effective self-regulation (The Canberra Times, 1976c, p. 6; The Canberra Times, 1976d, p. 7; Advertising Federation of Australia, 2008).
The AASAA was renamed the Advertising Standards Council (ASC) in 1976 (Blakeney and Barnes, 1982). The ASC was funded by the MCA (Trade Practices Commission, 1988), with members drawn from industry associations such as the AFA, AANA (two members), radio, print and TV organisations. It also had non-industry members. The ASC was an independent complaint-handling body, free from any kind of influence from the advertising industry. The ASC was responsible for monitoring, evaluating and enforcing the MCA’s Advertising Code of Ethics (The Canberra Times, 1976a, p. 11; The Canberra Times, 1992, p. 17). If the ASC upheld a complaint, the advertisement was stopped from running on TV (Advertising Standards Bureau, 2015). Because the MCA funded the ASC, it represented the commercial interests of the MCA’s industry members (Blakeney and Barnes, 1982). It thus failed to remain independent from industry dominance and became less responsive of the codes and to changes in community needs – it did not serve consumer interests (The Canberra Times, 1991a, p. 24; Commonwealth of Australia, 1983). While during the late 18th and early 19th centuries, the fight was against deceptive advertising practices and laws restricted the industry’s freedom; from the later 19th century onwards, the advertising industry fought to retain unhealthy food advertising for children.
Growing public concern over food advertising to children
Over the past century, Australia has seen a dramatic shift in attitudes towards food advertising to children. In 1979, Bill Snow and Rick Bolzan set up the BUGA-UP movement to protest against outdoor cigarette and alcohol advertisements. As a part of the movement, members of the organisation damaged thousands of billboards across Australia. The movement grew (Moffat, 1980, p. 6; The Age, 1980) and, in 1989, the Australian Government passed the Tobacco Products Advertisements (Prohibition) Act 1989, which imposed a ban on advertising tobacco products in all newspapers and magazines, effective from December 1990 (Grace, 2016). The BUGA-UP movement taught consumers to raise their voices against a range of issues in advertising, including the stereotyping of women, promotion of foods directed at children and racial stereotyping (Tharunka, 1990, p. 18; The Canberra Times, 1985, p. 99).
Consumer movements during the 1960s and 1970s prompted the government to enact legislation to regulate content in commercial TV. The Australian Broadcasting Tribunal (ABT) set the standards for all programmes aired by Australian TV stations (The Canberra Times, 1976b, p. 13). One of the Transitional Provisions of the Broadcasting Services Act 1992 required the Tribunal to report on its operations (Australian Broadcasting Tribunal, 1977). Accordingly, in 1977, the ABT undertook a review into the Self-Regulation of Broadcasting (The Canberra Times, 1977, p. 2). The Tribunal received 539 written submissions and held country-wide public hearings (Edgar, 2006, pp. 51-52), which centred on the screening of poor and low-budget children’s programmes, and the lack of age-appropriate local content for children screening in children’s viewing times (Parliament of the Commonwealth of Australia, 1977). These submissions led to “C Program” children’s classifications being introduced in 1979 (Edgar, 2006, pp. 56–57; The Canberra Times, 1984) and the Tribunal adopted the Children’s Television Standards (CTS) in 1984 (The Canberra Times, 1984, p. 1; Westerway, 1992). The condition for CTS was set out in the Broadcasting Services Act 1992 (Marin, 1994). C-classified programmes are aimed at children who are 14 years or younger (Australian Communications and Media Authority, 2020).
Following public concern about children’s exposure to food and beverage advertisements with misleading or incorrect information about the product’s nutritional value (Australian Broadcasting Tribunal, 1989, p. 28), in 1987, the Tribunal reviewed the CTS (The Canberra Times, 1987). The review revealed increasing public concerns about nutrition and its impact on child health (Rutherford et al., 2011). The tribunal introduced a revised CTS in January 1990 (Filmnews, 1989, p. 3) to address these concerns, while balancing the needs of the government and food industry. The revised CTS simplified the classification criteria, introduced a pre-classification requirement for “P” programmes, required a minimum of 16 h of new Australian children’s drama be broadcast each year, replaced the fixed time for children’s programming with time bands, reduced limitations on advertising and clarified advertising regulation (Australian Communications and Media Authority, 2007a; The Canberra Times, 1991b, p. 4). P-classified programmes are aimed at preschool children who have not yet started school (Australian Communications and Media Authority, 2020).
Several food poisoning incidents took place in Australia during 1990s (The Canberra Times, 1991c, p. 10), including an outbreak in Adelaide of haemolytic uremic syndrome because of Escherichia coli 0111, caused by bacterially contaminated sausage (The Canberra Times, 1995b, p. 3); an outbreak of salmonella in Melbourne, caused by peanut butter contaminated with a salami-type sausage (AP News, 1997, p. 5; The Canberra Times, 1989); and another outbreak of salmonella in South Australia, caused by contaminated orange juice (Australian Government Department of Health, 1999; The Canberra Times, 1995c, p. 45). Incidences such as these led to the emergence of the Code of Hazard Analysis and Critical Control Point (HACCP), which required suppliers to install the latest pasteurisers and adopt HACCP procedures (The Canberra Times, 1995c, p. 45). These incidents increased consumers’ concerns about the nutritional value and safety of consumable products. Australian food manufacturers also understood that, to continue manufacturing these products, they had to win public acceptance and public trust. Hence, the industry responded by establishing the Australian Food Council in 1994 to educate consumers about their products’ ingredients and manufacturing process.
The conservative Howard Government (1996-2007), however, which favoured free markets and adopted significant economic reform merely to promote trade and reduce government intervention (Jones, 2002; Mendes, 2003), refused to act to regulate advertising to children. They claimed that parents were responsible for children’s food choices and exercise habits; a view propagated by the advertising and food industries, which opposed regulatory intervention (Metherall, 2004).
Both the advertising and food industries have made regulatory initiatives by adopting codes before fully developing mechanisms to implement and monitor them. As a result, they fail to convince external concerned organisations (e.g. non-government organisations [NGOs] and the government), as well as consumers, that their policies can address community concerns and be properly enforced. In the eyes of NGOs, government and consumers, this led to the MCA’s regulatory arrangement to failure.
The ASC was responsible for considering public complaints about advertisements. Although the number of complaints increased dramatically, from 691 in 1992 to 1,066 in 1994 (Kerr and Moran, 2002), the ASC was criticised for acting on too few complaints (Crawford, 2008, p. 188). Incapable of indicating the whole community’s viewpoint, not just those of advertising agencies (Advertising Standards Council, 1986, p. 4), the ASC therefore had a limited understanding of its role and duties (Bonney and Wilson, 1983, p. 147). Moreover, it was more cost-efficient for the government to run an independent and autonomous body (Drummond, 1971). From October 1996, the ASC stopped taking complaints and ceased operations that December (Advertising Standards Bureau, 2015).
The absence of any governing body, however, restricted the government from industry interference. After abandoning the MCA and ASC, several controversial advertisements triggered the need for a regulatory framework and further demonstrated that the advertising industry could not be trusted without the AANA’s control (Australian Association of National Advertisers, 2014d). Furthermore, growing consumer dissatisfaction indicated that advertisers were incapable of addressing the concerns of government and consumer movements. Their failure to protect consumer interests would attract negative publicity, which could damage their brand reputations. If they did not meet community standards, the government would impose strict federal regulation to ensure consumer protection. Therefore, at the end of 1996, the AANA developed a three-part system of self-regulation in advertising, including the AANA Advertiser Code of Ethics, Advertising Standards Board (ASB) and Advertising Claims Board (ACB) (Advertising Standards Bureau, 2008). The ASB and ACB were established to determine consumer and competitive complaints about advertising, offering a free and fast route to competitive complaint resolution for consumers, who could express their views about advertising to an independent body. They thus discourage deceptive or misleading advertising practices by ensuring that advertisers comply with all relevant legislation (Advertising Claims Board, 2020). Since 1998, the ASB has administered a voluntary self-regulation system that governs advertising in Australia.
The AANA amended the MCA’s Advertising Code of Ethics in 1996 to keep pace with the rapid changes within the advertising, marketing and media industries. Both the old and new codes covered areas relating to sexism, taste and decency, discrimination, safety and children. The new AANA Code of Ethics, however, addresses broader issues such as lawful behaviour, misleading and deceptive behaviour, discrimination and denigration of competitors as well as the specific areas of sex, violence, environment, Australian content, offensive language, health and safety and children (Australian Association of National Advertisers, 2014c; Pearson, 1999). The incidents during the late 19th century, discussed above, also prompted the government to monitor and verify media content and industry operations frequently, to maintain community standards.
A key provision of the Broadcasting Services Act 1992 requires that providers of broadcasting services ensure their broadcast materials maintain community standards. Under the Act, the Australian Broadcasting Authority (ABA) conducts regular surveys to ascertain robust and reliable assessments of community attitudes towards TV content (Jarred, 2001). In October 1997, the ABA commissioned its fourth annual survey to determine Australians’ views about TV content, to monitor the effectiveness of the sets of professional standards. The suitability of advertising for children, in terms of amount and content, were two areas of public concern (Australian Broadcasting Authority, 1998). Although the study included people from different age groups, it made little comparison between adults’ and children’s views. Demographically, child and adult audiences respond differently to TV, in terms of how credible they find it, the quality and accuracy of content targeted to them and their attitudes to contemporary social issues. By comparison, their views on TV content, this study could have shed light on crucial points of difference between child and adult audiences. A clearer picture about different audience groups’ attitudes to different TV materials could have helped regulatory bodies understand how much regulation is needed for different audience groups. In 1999, the AANA introduced the Principles and Advisory Notes for Advertising to Children as a response to public and political concerns about advertising to children (Australian Association of National Advertisers, 2014b).
In 2000, the Productivity Commission commenced a major review of broadcasting to improve competition, efficiency and consumers’ interests in broadcasting services. The review revealed digital convergence issues and an increasing overlap of functions between the Australian Communication Authority (ACA) and ABA. The ACA was responsible for regulating technical and consumer issues in telecommunications and radio communications (Parliament of Australia, 2020), while the ABA was responsible for regulating broadcasting, telecommunications and radio communications (Australian Broadcasting Authority, 1992). It proved difficult for two regulators to find the same solution while dealing with wider convergence issues, or to provide a constructive response to convergence (Parliament of Australia, 2020). Hence, the Productivity Commission recommended that merging the two organisations might result in a higher level of administrative productivity (Productivity Commission, 2000). In 2002, the Department of Communications, Information Technology and the Arts invited submissions on spectrum management. Following the merger between the ACA and ABA in 2005, the government established a statutory agency, the Australian Communications and Media Authority (ACMA) (Australian Broadcasting Authority, 2002). This merger was the government’s response to technological convergence within the communication industry (Australian Broadcasting Authority, 2002; Parliamentary Debates. House of Representatives Official Hansard, 2005).
The ACMA has been entrusted to promote self-regulation, preserve competition in the communications industry and represent consumers’ interests by regulating broadcasting, telecommunications and radio communications matters (Australian Communications and Media Authority, 2016b; Australian Law Reform Commission, 2012, p. 329). The ACMA aims to ensure that Australia’s media and communication sector works in the public interest (Australian Communications and Media Authority, 2008). The government intended for the ACMA to play an important and prominent role in ensuring that industry meets community standards relating to media content (Australian Communications and Media Authority, 2016a). The government’s increased media investigations over children’s media content, amid growing public concerns about food advertising to children, made both the advertising and food industries realise that they needed to impose stricter regulation regarding unhealthy food advertising to children.
Industry’s response: self-regulation of food advertising
From the late 1990s to 2000s, childhood overweight and obesity had become a major public health concern and led to a heated debate over junk food, advertising and obesity. During that time, studies confirmed that Australian children were exposed to vast amounts of TV advertisements for food with low nutritional value. A 2000 survey of New South Wales (NSW) primary school children found that, of the 7-11-year-olds surveyed, 26.2% of boys and 28.4% of girls were either overweight or obese and were developing conditions such as type 2 diabetes and high blood pressure (Biggs, 2006). In the 10-year period from 1985 to 1995, the prevalence of obesity alone among 7-15-year-olds almost doubled (Magarey et al., 2001), and it more than doubled by 2007 (Moodie et al., 2009). Reports of the accelerating obesity rate among Australian children attracted public attention and created a strong community desire and public interest to protect Australian children and adolescents from food advertising. The World Health Organization, in their 2003 Diet, Nutrition and the Prevention of Chronic Diseases Report, identified children’s exposure to advertising for energy-dense, micronutrient-poor foods as a “probable” casual factor in weight gain and obesity, requiring inhibitory action (World Health Organization, 2003). Because of the accelerating obesity rate, Australia’s childhood obesity forums requested a ban on junk-food advertisements (Cumming, 2002). The Advertising and Marketing Communications Code 2003 resulted from the industry’s rapid response to community concerns about food and beverage advertising.
During 2004-2006, advertisements promoting food and beverage products received the most complaints (Advertising Standards Bureau, 2004, 2005, 2006). This reveals the community’s concern about advertising discretionary foods to children. Responding to community concerns, in 2007, the AANA introduced its Food and Beverages: Advertising and Marketing Communications Code (Food Code). The Food Code aims to limit the proportion of food advertising directed to children aged 14 years or younger (Mackay, 2009). It also contains restrictions on food and beverage advertising such as using popular personalities or celebrities, premium offers and competitions (Australian Association of National Advertisers, 2009, 2010).
Following the election of the Rudd Labor Government, on 15 August 2007, the ACMA was invited to review media industry codes of practice. The inquiry was prompted by public concern about the sexualisation of children in contemporary media (Rush and La Nauze, 2006, p. 1). The 2008 report revealed narrow or stereotypical portrayals of women’s bodies in print and advertising, and on radio, TV and the internet (Australian Senate, 2008). Its recommendations included reviewing the CTS’ classification systems and the Children’s Code’s effectiveness; introducing changes to the board, billboards and outdoor advertising; conducting research studies; educating the community; and governance and regulatory updates. The report did not consider, however, that the sexualisation of children had been a failure of self-regulation, and it failed to show any draconian measure that advertisers might have feared. Its critics, therefore, described the report’s recommendations as the Senate Committee’s attempt to thrash the advertising industry with a feather (Cowan, 2008).
The report also confirmed that children’s exposure to sexualised imagery may, in extreme cases, lead to clinical problems or other issues (Australian Senate, 2008). In response, the Children’s Code was revised in 2008, which prohibited the sexualisation of children and banned sexual imagery in advertising targeted at children (Australian Association of National Advertisers, 2011). The revised Children’s Code 2008 included one specific food advertising clause; this ensured that food and beverage advertising or marketing to children does not encourage or promote an inactive lifestyle or unhealthy eating or drinking habits, and complies with the Food Code (Mackay et al., 2011).
While the pre-election promises of the Rudd Labor Government (2007–2010) indicated a willingness to enforce government regulation of food advertising and to adopt legislative measures against unhealthy food advertising, they failed to keep their promises once in power (Hoek and King, 2008). Instead, they proposed a broad range of recommendations outside of government regulation, including claiming the sources, liability and solutions as more individualistic, and shifting their policy position to limit regulatory restrictions on industry activities because they feared losing voters or faced heightened demand from lobby groups (Henderson et al., 2009; Nathanson, 1999).
During 2007-2009, the Australian broadcasting system transitioned from an analogue to digital environment, defined by multi-channelling and technological advancement. In March 2007, the ACMA reviewed the CTS 2005 to ensure that the existing standards were appropriate and applicable in the current broadcasting environment. Along with stakeholder submissions, the ACMA drew on five evidence-based research projects. These studies were based on literature reviews, surveys (Brand, 2007; Rutherford et al., 2010), analysis of industry data from A.C. Nielsen’s “Economic impact of restrictions on television food and beverage advertising directed at children”, OzTAM ratings data (Australian Communications and Media Authority, 2007b) and interviews with producers, funding body representatives and network executives (Aisbett, 2007).
In August 2009, the ACMA issued its final report (Australian Communications and Media Authority, 2009b, 2017), which acknowledged the considerable community concerns about regulating food and beverage advertising to children. The ACMA found only a “modest” association between advertising “unhealthy” foods and childhood obesity, and limited evidence of the benefits of restricting this advertising on commercial free-to-air TV (Australian Communications and Media Authority, 2009b). However, the reliability of the report’s findings on the health impacts of food marketing to children remains questionable. For an overview of children’s viewing patterns, the ACMA relied on monitoring that was limited to C (suitable for children under 14) and P (suitable for pre-schoolers) programming times, whereas many programmes broadcast outside of these time bands were most popular with children older than 12 years; therefore, they were not subject to the CTS (Australian Communications and Media Authority, 2018). Furthermore, by not addressing the current monitoring and enforcement system’s inadequacy for dealing with CTS breaches, the ACMA’s CTS 2005 review report ignored using regulations and codes to limit children’s exposure to unhealthy food advertising. Perhaps this is because restrictions on food advertising during C and P programme periods would reduce broadcasters’ profitability (Baur et al., 2008).
Based on the CTS 2005 review, the ACMA did not impose any further general industry restrictions relating to food and beverage advertising under the CTS. After the final report, and following extensive public discussion, the ACMA developed the new Children’s Television Standards 2009 (Australian Communications and Media Authority, 2009a) on 24 August 2009. In the CTS 2009, Section 32 deals with the clear and accurate presentation of advertised goods and services: an advertisement must not contain misleading or incorrect information about a product’s nutritional value (Australian Communications and Media Authority, 2009a). However, this is the only section that deals with food advertising. The CTS 2009 requires all commercial TV licensees to broadcast 260 h of C programmes. These programmes must be specifically for children, entertaining and well produced, and with appropriate Australian content that enhances children’s understanding and experience (Australian Communications and Media Authority, 2009a).
In April 2008, Nicola Roxon, the then-Minister for Health and Ageing, established the national Preventative Health Taskforce (PHT) to develop policies controlling the health concerns caused by tobacco, alcohol and obesity. In its final report, the PHT recommended tackling food advertising to children, including phasing out promoting energy-dense nutrient-poor food and beverages on free-to-air TV (Roxon, 2010). In 2011, Harrison and Robson undertook a principled cost–benefit analysis of policy recommendations regarding obesity, alcohol consumption and tobacco control. The study concluded that preventative efforts will save money in some cases but, in others, they could burden the Australian economy. The study concluded that systematic methods were not being followed to provide a balanced ledger of costs and benefits to evaluate the proposed policies’ effectiveness. While the PHT’s initial report (Roxon, 2010) contends that paternalistic public health may be effective in reducing obesity, it did so without considering their costs and alternatives (Harrison and Robson, 2011).
The PHT report suggested saving money and improving health through prevention. While encouraging people to make healthy choices with regard to nutrition and exercise is a good thing, government interventions cannot force Australians to change their lifestyle choices to save the government’s future expenditure on obesity-related diseases. The PHT report did not compare the expected benefits against the cost of the interventions (Harrison and Robson, 2011).
In response to the PHT’s recommendations, the AFA expressed an opposing viewpoint regarding food advertising bans, claiming that, because there was no evidence available that banning advertisements would reduce childhood obesity, banning TV advertising of foods was unjustified and would not stop childhood obesity (AdNews, 2009; Champion, 2008). Because of the rise of digital platforms and devices, they stated, advertisers now had various platforms to reach potential customers. Advertising agencies also use new technologies to develop innovative ways to connect companies with consumers. On 1 January 2010, the boards of the Australasian Writers and Art Directors Association, AFA and Account Planning Group formed a new organisation, the Communications Council, to “offer a more influential, unified and stronger voice on issues affecting our industry and our members’ interests” (Advertising Federation of Australia, 2009) and to deal with the increasingly restrictive regulatory system (Advertising Federation of Australia, 2009).
Industry groups in Australia also addressed community concerns about TV food advertising to children by introducing two voluntary self-regulation initiatives (Obesity Policy Coalition, 2015) to shift public attention away from the negative health effects of the signatories’ products and to avoid tighter government regulation (Hartmann, 2011; Richards and Phillipson, 2017). A brand’s positive public image has a positive impact on its reputation; it enhances consumers’ awareness and thus encourages them to consume their products (Lai et al., 2010; Lin, 2016). Therefore, while maximising profit is these companies’ primary motivation, these initiatives would allow the big food brands to appear socially responsible and create a positive public image (Martin, 2015).
On 1 January 2009, the Australian Food and Grocery Council (AFGC) responded to public concern around the advertising and marketing of unhealthy food products to children by introducing the Responsible Marketing to Children Initiative (RCMI); and on 1 August 2009, the Quick Service Restaurant Industry introduced a separate initiative, the Quick Service Restaurant Initiative (QSRI) (Australian Communications and Media Authority, 2011). These initiatives aim to reduce advertising and marketing of unhealthy food products to children, use advertising and marketing to promote healthy eating and lifestyles to children and provide parents with resources to raise awareness about advertising to children. Signatories to the RCMI and QSRI publicly commit to promote healthy lifestyles through advertising healthy food products (Australian Food and Grocery Council, 2014a, 2014b). The ASB administers the RCMI and QSRI complaints process (Australian Food and Grocery Council, 2014a, 2014b). The ASB assesses complaints about food and beverage advertisements, such as whether the products represent a healthy choice and whether the advertisement is directed to children (Australian Food and Grocery Council, 2014a, 2014b).
In 2010, The Rudd/Gillard Labor Government created a taskforce to monitor and evaluate the RCMI’s and QSRI’s effectiveness, but not to implement provisions that would limit food marketing to children (Roxon, 2010). In response to the taskforce’s recommendations, the government established the National Preventive Health Agency (“ANPHA”) in January 2011 to conduct these activities (Australian Government, 2020a). However, the subsequent Abbott Coalition Government stopped the agency’s operation on 30 June 2014 before it could conduct and impact assessment of food marketing regulation (Australian Government, 2020b). Tony Abbott disparaged government interventions. When he was Federal Health Minister previously, he had responded to calls to restrict food advertising to children, saying: “the only person responsible for what goes into my mouth is me and the only people who are responsible for what goes into kids’ mouths are parents” (Kontominas and Metherell, 2006). Abbott had claimed that fast-food advertising does not need government regulation because it has been “proven not to work” (Anderson, 2006). Thus, although there were some initial government initiatives to supervise food industry self-regulation, these failed to be fully implemented.
Up until 2015, numerous studies have been carried out to measure the impact of the AFGC’s self-regulatory initiatives on unhealthy food and beverage advertising to children on Sydney TV. Most have been undertaken by the University of Sydney, in collaboration with Cancer Council NSW (Hebden et al., 2011; King et al., 2011; Watson et al., 2017). The findings of such peer-reviewed studies (Brindal et al., 2011; Hebden et al., 2011; King et al., 2013; King et al., 2011; Watson et al., 2017) help policymakers make more informed decisions about the nature of the advertising industry’s regulatory systems. These independent studies were based on data collected from free-to-air commercial TV channels in Sydney and found that the regulations had not actually reduced advertising for non-core foods and drinks. Because these research studies failed to provide a comprehensive picture of TV advertising across all major Australian cities and across different times of year, the ACMA therefore concluded that, because of the lack of sufficient evidence, it was currently unable to determine whether the initiatives affected the rate of food and beverage advertising on commercial free-to-air TV in Australia (Australian Communications and Media Authority, 2011). However, the ACMA has acknowledged ongoing community concerns around food and beverage advertising to children on free-to-air TV (Australian Communications and Media Authority, 2011). Despite a decrease in food advertising overall, studies (Hebden et al., 2011; Watson et al., 2017) found that children’s exposure to unhealthy food advertising remained almost unchanged in 2015 from 2009 (3.2 advertisements/hour in 2009 vs 3.0 advertisements/hour in 2015) (Hebden et al., 2011; Watson et al., 2017).
The AFGC’s 2016 Annual Compliance Report states that compliance with the RCMI and QSRI core principles was high during 2016. According to the AFGC, the overall compliance rate had increased slightly to 99.25%; a different picture from the industry compliance report on self-regulatory codes. Whereas independent studies (Brindal et al., 2011; Hebden et al., 2011; King et al., 2013; King et al., 2011; Watson et al., 2017) showed high levels of advertising of less healthy foods, the industry-sponsored reports suggested high adherence to the voluntary codes (Australian Food and Grocery Council, 2010, 2016). These discrepancies are because of methodological differences between the studies. The AFGC evaluated children’s exposure to food marketing during programmes primarily directed at children, but not during shows such as sporting games, reality shows or light-entertainment programmes (watched by many children between 6 p.m. and 9 p.m.), when children are exposed to large amounts of food advertising. When the total audience is high, the ratio of children to total audience diminishes accordingly. According to a recent study, 40,000 children watched the National Rugby League and 30,000 watched MasterChef, i.e. about 10% of the total audience, so a junk-food advertisement during those shows would still technically comply (Watson et al., 2017). Hence, the AFGC’s Annual Compliance Report failed to evaluate the full extent of children’s exposure to non-core food advertising, particularly when compared to peer-reviewed research, which assessed children’s exposure to unhealthy food marketing during a much wider range of time periods.
Consistent with previous studies (Brindal et al., 2011; King et al., 2011), Saha (2019) found an overall decline in advertising. This study found that signatories accounted for a higher proportion of unhealthy food advertisements than non-signatories. Consistent with Brindal et al.’s (2011) study, the study also found that unhealthy products were responsible for a higher proportion of food advertising, specifically promotions from fast-food restaurants (31%), followed by advertising for sugar-sweetened beverages (18%) (Brindal et al., 2011). Against this backdrop, it can be argued that the current industry regulatory system is failing to protect children from unhealthy food advertising, and that greater regulation is needed (Australian Communications and Media Authority, 2011).
In 2013, the ACMA established the Contemporary Community Safeguards Inquiry to outline what should be mentioned in contemporary broadcasting codes of practice (Australian Communications and Media Authority, 2014a, 2014b). After engaging and consulting with industry and citizens, the inquiry identified children’s protection from content or communications that were age-inappropriate or harmful as a significant matter for broadcasters, to provide appropriate community safeguards in their codes. The AANA responded by amending the existing Children’s Code to keep pace with the rapid changes within the advertising, marketing and media industries (Skelton and Hall, 2014). This ensured that advertising and marketing communications are regulated in social networking and other online activities. The Code now also adopts a clearer definition of “excluded advertising and marketing communications”. In a Practice Note, the new code includes several factors to determine whether media or programmes are designed for children. These would engage children using different marketing techniques by the media or programmes, which provide children with additional protection. Regarding the Code of Ethics, the revisions ensure that all communications would be judged against “prevailing community standards” and would require the ASB (the complaints adjudicator) to abide by any relevant practice notes published by the AANA (Australian Association of National Advertisers, 2014a, 2014b). The Contemporary Community Safeguards Inquiry clearly indicated that a minimum level of regulatory intervention could safeguard broadcasting content more effectively and support rationalisation, simplification and adaptation to changes in media markets and practices (Australian Communications and Media Authority, 2014a; Australian Communications and Media Authority, 2014b, p. 2).
As a response to the ACMA’s Contemporary Community Safeguards Inquiry of 2013 and the Australian Law Reform Commission’s Classification Review, on 1 December 2015, ACMA registered a new Commercial Television Industry Code of Practice in a bid to adapt to the changing media landscape. A more detailed discussion on this code is excluded because it contains no clause that specifically relates to food advertising. However, both the previous and a recently updated version of the code contains one clause, Section 5.7, that imposes a condition on all TV advertisers, requiring them to comply with the AANA Code of Ethics, AANA Code for Marketing and Advertising Communications to Children and AANA Food and Beverages: Advertising and Marketing Communications Code (Free TV Australia, 2015, 2018).
Together with the AMA, a coalition of 34 organisations, led by the Obesity Policy Coalition, Deakin University and Cancer Council (Australian Medical Association, 2018; Obesity Policy Coalition, 2017), urged the government in 2017-2018 to introduce a 20% tax on sugary drinks and restrict TV junk food advertising to children. The Turnbull Coalition Government (2015-2018) dismissed this tax, claiming that the government had already taken action, such as introducing laws for labelling ingredients and nutritional information and implementing voluntary measures to restrict food marketing to children (Hutchens, 2017; Karp, 2018). As shown with the discussion of the previous Labor Government, political parties are less likely to support government intervention when in power (Patterson et al., 2017).
Criticism of self-regulation’s effectiveness
With the emergence of new technologies, advertisers can now reach children through a number of new communication channels and advertising techniques, for example, internet-based promotions and “advergames”. The OPC (2015) advised the ACMA and others to strengthen a co- or full-regulatory approach on unhealthy food advertising to reduce children’s exposure; it concluded that, despite sound evidence regarding the ACMA’s failure to reduce children’s exposure to this type of advertising, no action has been taken.
On 23 October 2015, the AANA announced a revised definition of “advertising and marketing communication” to include relevant direct-to-consumer public relations materials. The revised definition allows consumers to complain about more than TV advertisements or radio commercials. Material such as social media promotions, including tweeting and blogging on behalf of a brand, are now captured by the codes. However, brand owners are not responsible for the editorial content in traditional or social media that they did not produce or cannot control. This revised definition was implemented across all AANA codes from 2016 (Australian Association of National Advertisers, 2015b, 2016).
The current AANA self-regulatory system is technology-neutral; internet advertising is, therefore, generally governed by the same rules and regulations. Because of dramatic changes such as the increasing popularity and growth of new media, using social media as a marketing tool needs to be continuously closely monitored and regulated (Australian Association of National Advertisers, 2014a). The Facebook and Twitter pages of companies are now clearly held as advertising, so not only must their content comply with Australian Consumer Law, it must also comply with the AANA’s Code of Ethics (Justice Connect, 2016).
Despite the increasing public concern about children’s protection from advertising for unhealthy products, the current regulatory system remains ineffective to limit children’s exposure to unhealthy food and drink marketing, both online and through new media. A recent study (Saha, 2019) shows that 19% of food brands advertising to children during children’s TV programming also promoted their company websites. This suggests that TV still remains a key advertising platform.
Despite ongoing changes in advertising restrictions, unhealthy products are still a high proportion of food advertising on TV. The question remains: Why is the current regulatory system failing to reduce children’s exposure to unhealthy food advertising? Studies have identified factors that allegedly limit the effectiveness of industry self-regulation of food and beverage advertising to children.
The ASB determines whether an advertisement targets children directly, according to the overall impact of its visuals, language and themes, and its intended target audience. This is particularly concerning when there are programmes that children find appealing, but which are designed for a general audience, such as Home and Away and MasterChef. Research suggests that most children watch TV programmes that are not specifically directed to them but towards a more general viewing audience. The vast majority of unhealthy food advertising takes place in general audience programming (G and PG) (Chapman et al., 2006; Kelly et al., 2011; Kelly et al., 2007; Smithers et al., 2012), meaning that the RCMI captures only a small proportion of advertisements to which children are exposed. The RCMI exempts most complaints on the basis that the advertisement appeared in media directed to adults, according to its creative content or because the audience was largely adult viewers.
Unlike the RCMI, the QSRI determines whether an advertisement is directed primarily to children based on its creative content, rather than the rating or audience share of TV programmes, for example, C and P programmes or those with a largely child audience. However, there are limited restrictions on the timing, placement and volume of food advertising, and on the types of products advertised to children (with the exception of the RCMI and QSRI). For example, the Food Code does not limit the timing, volume or placement of food advertising to children (King et al., 2009). Thus, regulation does not prevent children’s daily exposure to unhealthy foods and beverages, because these can reach children via other media (Hawkes, 2005; Mackay et al., 2011).
The AFGC did not consult with the government, consumers, public health advocates or other affected stakeholders during the RCMI’s and QSRI’s development and administration. By not consulting with external stakeholders, the AFGC failed to address consumer concerns about unhealthy food advertising to children and its association with obesity (Australian Communications and Media Authority, 2009b, 2011; Gill et al., 2006). Therefore, the RCMI and QSRI largely satisfy the food industry’s interests, rather than addressing community concerns. In retrospect, it is not appropriate to argue that external stakeholder consultation would have created well-defined objectives or stronger regulatory standards in the food industry’s scheme.
Global approaches to regulating unhealthy food advertising to children
The above sections documented the effectiveness of current regulatory codes on food marketing and advertising to children in Australia. Apart from self-regulation, there is an array of different regulatory arrangements globally that address advertisements of unhealthy food products. Inter-country comparisons will allow governments and policymakers to understand the international statutory landscape regarding the advertising of unhealthy food products to children and to judge the efficacy of different forms of regulation governing food advertising and marketing to children. It is hoped that this section will be a resource for governments and policymakers to understand the debates around the benefits and problems of different forms of regulations governing advertising to children, which is essential in developing effective regulations to protect children from unhealthy food advertising.
The USA relies on voluntary food industry pledges to restrict promotion of unhealthy foods. Its food advertising regulations can be grouped into two categories: government regulation (statutory and non-statutory) and self-regulation. In 2006, the Council of Better Business Bureaus (CBBB) introduced a voluntary self-regulation programme – the Children’s Food and Beverage Advertising Initiative (CFBAI) – to improve the mix of foods advertised to children younger than 12 by encouraging healthier dietary choices and lifestyles (Better business Bureau, 2020). The CBBB administers both the CFBAI and Children’s Advertising Review Unit (CARU) (Better Business Bureau, 2014a).
Participating companies must help promote healthy dietary choices in advertising and marketing communications directed to children younger than 12, with products determined by the CFBAI’s category-specific uniform nutrition criteria. The CFBAI defines child-directed advertising as TV, radio, print and third-party websites where children comprise more than 35% of the audience. Participants also commit to using interactive games primarily directed to children, and third-party licensed characters, celebrities and movie tie-ins, only for healthy products with advertising messages promoting children’s healthy dietary choices and lifestyles. Participants must not pay for or seek product placement in TV programmes, editorial content or interactive games aimed at children, and they agree not to advertise branded foods and beverages in primary schools (Better Business Bureau, 2014b).
The CFBAI guidelines do not apply to half of the food and beverage ads viewed by children (Harris et al., 2013). Most food ads viewed by children during children’s programming do not meet current CFBAI nutrition standards (Powell et al., 2013). These findings suggest that, to date, self-regulation has failed to protect children from unhealthy food advertising.
CARU developed guidelines to ensure that any advertising or marketing is designed to not be deceptive, unfair or inappropriate for its intended audience (Children’s Advertising Review Unit, 2020). When a member company does not adequately address a complaint to CARU, CARU can assign the case to the Federal Trade Commission (FTC) (Federal Trade Commission, 2020). Currently, the FTC operates in association with government agencies, consumer advocates, academics and industry, initiating regulatory dialogues into effective self-regulatory measures to tackle the problem of childhood obesity (Federal Trade Commission, 2020).
Some countries – such as Chile, South Korea and Ireland – have introduced legislative restrictions on food marketing, while others – such as the UK – have adopted a co-regulatory approach.
Chile has implemented statutory regulation to reduce children’s exposure to unhealthy food marketing and reduce purchases. In 2016, the Chilean Government implemented the Law of Nutritional Composition of Food and Advertising (Ley 20.606) (Corvalán et al., 2013, 2019), which prohibits marketing directed at children. In addition, foods and beverages that exceed set nutrient or energy thresholds are banned for sale in schools. After the Chilean Food Advertising and Labelling Law was enacted in 2016, child-directed marketing strategies on unhealthy breakfast cereals decreased significantly (Mediano Stoltze et al., 2019). A recent study (Carpentier et al., 2020) assessed the impact of Chile’s marketing regulation of unhealthy foods and beverages. It found a substantial decrease in pre-schoolers’ and adolescents’ exposure to the advertising of unhealthy foods on popular broadcast and cable TV, after Chile implemented this regulation.
Since 2008, food companies in the UK are required to follow a specific code of practice. This co-regulation framework is implemented between the Advertising Standards Authority (ASA) and Office of Communications, which regulate food advertising to children through TV and other media. The ASA is a self-regulatory organisation established by the UK’s advertising industry (Ofcom, 2020), which handles complaints for the advertising industry (Advertising Standards Authority, 2020).
The UK Code of Non-Broadcast Advertising and Direct and Promotional Marketing prohibits advertising foods that are high in fat, sugar or salt (HFSS) directly to children or with an audience of greater than 25% children younger than 16 years (Advertising Standards Authority, 2018). The UK Code of Broadcast Advertising also restricts advertisements for HFSS products in, or adjacent to, programmes commissioned for, principally directed at or likely to appeal to children younger than 16 years (Advertising Standards Authority, 2019). Even after implementing regulations, children are still exposed to high volumes of unhealthy food advertising on TV (Whalen et al., 2019).
Studies (Hawkes and World Health Organization, 2007; Reeve and Magnusson, 2018) have identified three distinct schemes regulating food advertising to children: statutory regulation, self-regulation or co-regulation. In the above discussion, three countries use three different regulatory schemes to protect children from being exposed to unhealthy food advertising. Chile has introduced legislative restrictions on food marketing, while the UK has adopted a co-regulatory approach. Self-regulation remains the prevailing approach in countries such as the USA and Australia.
None of the above-mentioned countries have been entirely successful in protecting children from being exposed to unhealthy food marketing. This could be because public health experts and food industry actors have different approaches towards achieving food advertising regulation. The food industry aims to reduce unhealthy food advertisements targeted at children. In contrast, public health advocates aim to decrease the volume of food advertising children are exposed to – whether aimed at adults or children (Reeve and Magnusson, 2018). According to public health officials, self-regulation should be replaced by transparent and accountable government regulatory restrictions on food marketing to children, accompanied by effective monitoring and enforcement mechanisms (Reeve and Magnusson, 2018).
This paper identified loopholes that exist in Australia’s self-regulatory codes regarding advertising food and beverages to children. Australia’s current advertising regulatory arrangements are ineffective in restricting the marketing techniques most commonly used to target children on media platforms that are relatively under-regulated, such as social media and branded websites. The government, advertisers, advertising agents, media, food industry and NGOs have been responding to consumer dissatisfaction and the changing media landscape by developing a range of co- and self-regulatory organisations and codes, and an independent complaint-handling body.
This paper raises important questions about the effectiveness of the self-regulatory framework governing food advertising to children in Australia. The existing codes contain loopholes, of which advertisers are taking advantage. Platform- and technology-neutral codes have resulted in no overall decrease in children’s exposure to unhealthy food advertising. The absence of centralised control makes the internet difficult to regulate in practice (Roberts, 1996; Zwart, 2012). Therefore, there are strong arguments for statutory regulation of unhealthy food advertising to children. The Federal Government appears to be reluctant to regulate; however, instead, supporting voluntary industry initiatives (Reeve, 2015). Comprehensive legislation limiting unhealthy food advertising to children is required immediately. Children’s access to inappropriate online content can also be regulated, perhaps, by providing training on using parental locks and educating parents about online safety (Australian Law Reform Commission, 2011). This study makes an important contribution to the literature by providing a historical background of the origins of children’s food advertising regulation in Australia. This study concludes that Australia’s current advertising regulatory arrangements remain ineffective in restricting the marketing techniques most commonly used to target children on relatively under-regulated media platforms such as social media and branded websites. This research could benefit the food and beverage industry, and government policy, to promote comprehensive and achievable solutions to Australia’s growing obesity rates by introducing new standards that keep pace with changes in marketing communication.
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This work is supported by UTS international Research Scholarship and Australian Government Research Training Program.
About the author
Nipa Saha has completed her doctoral degree at University of Technology Sydney – School of Communication in 2019. Previously, she has held academic and research positions at University of Technology Sydney, Macquarie University and University of Tsukuba in Japan. Her research interests include advertising, communication, history, marketing and health.