Abstract
On March 18, 2019, the UK Government's Department of Health and Social Care announced a public consultation on further restrictions to advertising of products high in fat, sugar, and salt on television and online. The consultation coincides with a WHO report that warns that, despite existing policies, children and adolescents are still exposed to digital marketing for unhealthy products on a regular basis. This situation is unlikely to improve as time spent online increases, and advertising is predominantly personalised and targeted in nature. Current estimates suggest that more than 20% of children in England are obese or overweight by the time they start primary school at 5 years of age, rising to more than a third by the time they leave aged 11. The prevalence of type 2 diabetes and non-alcoholic fatty liver disease in children is increasing; by 2022–23, the Department of Health expects a further 1000 children every year will need to be treated for severe complications of obesity. Further, children with obesity are five times more likely to be obese as adults, which is associated with an increased risk of many cancers, including oesophageal, gastric, colorectal, pancreatic, and liver cancers. The consultation represents the latest step towards achieving the UK Government's ambition to halve the rate of childhood obesity by 2030. The scheduling of advertising of foods high in fat, sugars, and salt around television programmes commissioned for or likely to appeal to children has been prohibited in the UK since 2007. When the impact of that ban was assessed in 2009, it was estimated to have reduced the amount of advertising for junk food seen by children by more than a third. Nonetheless, children's viewing time reaches a peak between the hours of 6 pm and 9 pm, during which time most television shows are not children's programmes, and thus not subject to current restrictions. In addition, how and what children watch is changing: children aged 12–15, for instance, now spend more time online than watching broadcast television; 49% of 12–15 year olds prefer to watch YouTube than programmes on the television. New rules, which aligned non-broadcast advertising with broadcast advertising, were introduced in 2017; these rules prohibited the advertising of junk food in media that are particularly appealing to children, or for which more than 25% of its audience is under 16 years of age. However, most online display advertising is delivered based on demographic and behavioural data or on the content of the website on which it appears, and in these cases, the 25% rule does not apply. The major proposal being put forward in the consultation is the introduction of a watershed period for both television and online, prohibiting the advertisement of food and drink high in fat, sugar, and salt between 5·30 am and 9 pm. Other ideas include a banded system for television advertising (in which products with healthier nutritional profiles face fewer advertising restrictions than would less healthy options, with a view to encouraging manufacturers to reformulate), strengthening of current online targeting restrictions, or adopting a mixed model with different criteria for streaming video and other platforms. Although strengthening existing online restrictions or adopting a mixed model may seem less draconian than a watershed, only blanket restrictions on advertising of junk food would circumvent issues such as devices or online profiles being shared by adults and children and the false reporting of user ages (for instance, nearly a quarter of 8–11 year olds have a social media account, despite a minimum age of 13 for many of these sites). And while cognisant that obesity is a multifactorial problem that will require a broad range of different measures to tackle, banning such practices represents an easy win in reducing the exposure of children to at least one aspect of an unhealthy, obesogenic environment. The implementation in the UK of a watershed for advertising of foods high in fat, sugar, and salt online would represent a world first and would show strong leadership in the fight to curb the obesity epidemic. We wholeheartedly support the adoption of such a watershed, both via traditional broadcast media and also online. For more on the UK Department of Health's public consultation see https://www.gov.uk/government/news/restrictions-on-adverts-for-food-high-in-fat-sugar-and-salt-public-asked-for-viewsFor the latest data on childhood obesity in England see https://files.digital.nhs.uk/9F/22AF4D/nati-chil-meas-prog-eng-2017-2018-rep.pdfFor data on media use and attitudes see https://www.ofcom.org.uk/__data/assets/pdf_file/0024/134907/Children-and-Parents-Media-Use-and-Attitudes-2018.pdf For more on the UK Department of Health's public consultation see https://www.gov.uk/government/news/restrictions-on-adverts-for-food-high-in-fat-sugar-and-salt-public-asked-for-views For the latest data on childhood obesity in England see https://files.digital.nhs.uk/9F/22AF4D/nati-chil-meas-prog-eng-2017-2018-rep.pdf For data on media use and attitudes see https://www.ofcom.org.uk/__data/assets/pdf_file/0024/134907/Children-and-Parents-Media-Use-and-Attitudes-2018.pdf
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