WFA Avenue Louise, 120, Box 6 B-1050 Brussels Tel:

From: Karine Lesuisse [k.lesuisse@wfanet.org] Sent: Friday, 14 June 2002 14:56 To: dietandhealth@who.int Subject: Fwd: WFA Response to Draft Report on Diet, Nutrition Dear Sir, Could you please confirm, by return of email, that you have wellreceived the WFA Response to the Report (sent on June 13. Many thanks in advance for your cooperation. Karine +++++ Dear Sir, Re. WFA Response to the draft Report of the Joint WHO / FAO Expert Consultation on Diet, Nutrition and the Prevention of Chronic Diseases On behalf of Stephan Loerke, WFA Deputy Managing Director, please find attached the WFA response to the "Draft Report of the joint WHO/FAO Expert Consultation on Diet, Nutrition and the Prevention of Chronic Diseases". We are at your entire disposal if you need additional clarification to the points made in our response. Best regards, WFA Avenue Louise, 120, Box 6 B-1050 Brussels Tel: +32 2 502 57 40

Karine Lesuisse WFA --------------------------------------- World Federation of Advertisers Karine Lesuisse Avenue Louise 120-1050 Brussels Tel: +32 (0)2 502 57 40 Fax: +32 (0)2 502 56 66 Email: k.lesuisse@wfanet.org Website: www.wfanet.org WFA The Voice of Advertisers Worldwide. The World Federation of Advertisers is a unique, worldwide network, thanks to its dual membership: 46 national advertisers associations and nearly 30 corporate members. Through them, WFA represents more than 5,000 businesses operating in a broad spectrum of sectors at national, regional and global level. WORLD FEDERATION OF ADVERTISERS (WFA) 1

WFA RESPONSE TO DRAFT REPORT OF THE JOINT WHO/FAO EXPERT CONSULTATION ON DIET, NUTRITION AND THE PREVENTION OF CHRONIC DISEASES 1. Name of the Organisation World Federation of Advertisers (WFA) 2. Postal address 3. Telephone Avenue Louise, 120 B.6 1050 Brussels (Belgium) +32 2 502 57 40 4. The scope of activities of the organization The World Federation of Advertisers is a unique, worldwide network, thanks to its dual membership - over 46 National Advertisers Associations and 28 Corporate Members - comprising more than 5 000 businesses operating in a wide spectrum of sectors at national, regional and global level. 5. Mission of the organisation WFA defends the common interest of its national Associations of Advertisers, Corporate Members and Corresponding Members throughout the world, and, as such, promotes the free circulation of goods and services, including a company s intrinsic right to commercial communications. WFA s primary objective is to safeguard an advertiser s inherent right to unimpeded marketing and commercial communications throughout the world with particular emphasis on developments in free trade areas and common markets. 6. The organization s interest in diet, nutrition and the prevention of chronic diseases Many of our members are major companies in the food and drink industry. Their aims are to satisfy consumer needs and expectations by supplying a wide variety of safe, tasty and nutritious foods at affordable prices throughout the year. It is critical to the WHO s work and policy formulation that all views relevant be considered. The advertiser perspective will be an important component of any comprehensive consideration given to food advertising and the diet of children. 7. Source of funding Exclusively membership fees from National Advertiser Association and Corporate Members. 8. Email address : info@wfanet.org Fax Number : +32 (0)2 502 56 66 WORLD FEDERATION OF ADVERTISERS (WFA) 2

1 INTRODUCTION The World Federation of Advertisers (WFA) welcomes the opportunity to comment on the points made relating to advertising in the Draft report of the joint World Health Organisation (WHO)/Food and Agriculture Organisation (FAO) Expert Consultation on Diet, Nutrition and the Prevention of Chronic Diseases. The World Federation of Advertisers is a unique, world-wide network, thanks to its dual membership: 46 national advertisers associations and nearly 30 corporate members. Through them, WFA represents more than 5,000 businesses operating in a broad spectrum of sectors at national, regional and global level. Many of our members are major companies in the food and drink industry. Their aims are to satisfy consumer needs and expectations by supplying a wide variety of safe, tasty and nutritious foods at affordable prices throughout the year. Our web site detailing a wide range of activities in which we are involved can be visited at www.wfanet.org The WFA agrees with the report s assertion that diet, while critical to prevention of disease, is only one risk factor. We also support the report s acknowledgement of the growing body of evidence underscoring the role of physical activity in maintaining a healthy lifestyle. However, we have two broad areas of concern in the draft report: its misunderstanding of role and impact of advertising and its failure to acknowledge the proactive and positive role advertisers play in communicating the value of foods and nutrition to consumers. The following paper explains our concerns. We have drawn from existing scientific studies and other submissions on the subject. 2 ADVERTISING WHAT IT IS Advertising is one of the ways in which manufacturers sell a product or service to consumers. There are many routes to communicate the values or benefits of a brand to consumer. Consumers use and enjoy advertising as a means of communication. Advertising s important role in consumers lives has recently been acknowledged in a comprehensive survey undertaken by the European Commission. The Directorate General for Consumer Protection and Public Health, DG SANCO, commissioned a Consumers Survey of over 15,000 European consumers from all EU member states in January 2002. The results are representative of Europeans above the age of 15 years, including socio-economic factors. The objective of the survey was to understand the sources used by real European consumers to obtain information on purchasing information, consumer rights and consumer representation. One of the interesting findings supports the concept that consumers have a range of sources from which to get information: Europeans prefer to obtain information from the television, daily newspapers, advertising leaflets and their personal friends and relatives at least occasionally before making purchasing decisions: Friends and relatives 75% Advertising leaflets 74% TV 71% Daily newspapers 68% Brochures from manufacturers 64% Consumer publications 55% Regarding children s advertising, parents have acknowledged repeatedly that advertising is only one of many influences in their children s lives. Dr. Adrian Furnham of University College London states, Parents play a profound role in the consumer socialisation of their children the consumption behaviour of adolescents is mediated by communication with parents and is not necessarily triggered by exposure to advertising we found parents to be the strongest influence on the development of consumption norms in adolescence. 1 Main sources of information on nutrition/health reported by French children were parents (78%), school teachers (39%), television (14%) and their physician (10%). Mothers reported getting their own information re nutrition from magazines (29%), television (27%), their physician (27%) and food packaging 12%. 1 J. Sherry, B. Greenberg and H. Tokinoya, Orientation to TV advertising amongst adolescents and children in the US and Japan, International Journal of Advertising, 1999, 18, p. 235. WORLD FEDERATION OF ADVERTISERS (WFA) 3

This is a quantitative survey conducted among a representative sample of 1000 French children, aged 9-11 years, and their mothers 2. Advertising is among the most strictly regulated industries in the world. In addition to legal regulation, the advertising business implements self-regulatory systems that provide consumers with fast, effective and free recourse for issues arising from the advertising of products and services. 3 ADVERTISING: WHAT IT DOES There is an important distinction made between brand advertising and generic advertising. In a report by Ogilvy & Mather (one of the largest advertising agencies in the world), it is stated that: Normal brand advertising neither attempts to stimulate sales of the product type as a whole, nor aims itself at people who are not in the market for the product. For example, petrol advertising is aimed only at drivers, cosmetic advertising at women... 3 Companies advertise their own brands primarily to increase their market share and to protect that market share against brand switching. Advertising of branded foods is a tool of competition between brands. Advertising offers consumers choice. It communicates the range of brand choices to the consumer. The draft WHO/FAO Report s assertion that the influence of advertising (amongst other risk factors) has had a generally negative impact in terms of risk factors 1. Ignores the contribution that food advertisers make to raising awareness about the role of a range of foods in the diet and in their prevention of many chronic diseases. 2. Is not supported by any scientific evidence. Research commissioned by the UK government s former department Ministry of Agriculture, Fisheries and Food (MAFF) through the UK Universities of Exeter and Dundee (1996) is informative in analysing the various factors influencing consumption of food and food choices. The research was a world-wide literature review of the studies on how television commercials affect the food choice of children 4. Dr Brian Young of Exeter University, one of the report s authors recently stated: There are several issues that emerged from the MAFF Report. One was that many food choices and preferences were already in place well before children have any idea of what advertising is about or why it s there. There s a lot of evidence that these food-related habits originate in infancy and during the very early years. After a rigorous examination of the research literature, we concluded that there is no serious and methodologically sound evidence that shows that food advertising leads to an increase in the consumption by children of whole categories of foods Another conclusion was that the model of advertising influence that is often assumed in much of the research in this area is what is known as an effect model i.e. advertising has a direct effect on behaviour. This model does not do justice to the complex nature of advertising s influence to the extent that children consume advertising selectively and use it as a cultural resource for many social activities unrelated to purchase behaviour they laugh about it, parody it, and talk about it with friends. 4 ADVERTISING AND CHILDREN WFA supports the freedom to advertise products to children within a clear framework of law, backed by codes of practice and self regulatory processes that are continuously reviewed to ensure that they meet the proven expectations of parents, regulators and society. We believe that children are entitled, as adults, to receive information about products that are of interest to them. Without advertising, this information would not be available. Children s only information source will be advertising for brands particularly adult brands that are not relevant to their needs. These brands may in turn not only be irrelevant but positively harmful, even illegal. We believe that advertising is a part of a child s normal environment. It plays a part in their 2 F. Bellisle et al. Three consecutive years (1993, 1995, 1997) surveys of food intake, nutritional attitudes and knowledge, and lifestyle in 1000 French children aged 9-11 years. Blackwell Science Ltd, 2000, J. Hum. Nutr. Dietet., 13, pp. 101-111. 3 Quoted in Advertising & Markets, Ed. Luik & Waterson, Chapter 12. 4 B.M. Young, P. Webley, M. Hetherington and S. Zeedyk (1996). The Role of Television Advertising in Children s Food Choice. Report to the Ministry of Agriculture, Fisheries and Food (MAFF). WORLD FEDERATION OF ADVERTISERS (WFA) 4

development process by equipping children with the necessary knowledge and skills to act as responsible consumers later in life. It is everyone s responsibility, including advertisers, to help children familiarise themselves with the world in which as adults they will live. Children s advertising must be responsible and must not misuse children s relative inexperience. It must and does recognise that children do not mature at the same age and that they acquire consumer skills gradually. Children s advertising therefore is designed for them for their needs, with their very special circumstances in mind. It is ultimately parents responsibility to determine the level of family exposure to the media and to advertising that traditional media channels such as TV or new media channels, such as the Internet carry. Parents are in the best place to decide how, when and with what frequency their children should access media depending on that child s individual development. The draft Report quotes case studies to show children do not distinguish advertising from programmes, yet fails to consider the strong evidence to show that children can distinguish advertising as young as 4 years old. An excellent source of independent studies including the role of advertising, how children interact with advertising and the age at which children recognised advertising is the Advertising Education Forum on its web site www.aeforum.org 5 THE SELF REGULATORY SYSTEM Advertising is governed by self-regulatory systems and the International Chamber of Commerce codes 5 (suggest we do reference the ICC codes) are an integral part of these system. They apply to all WFA members and indeed to any advertiser operating in any part of the world. The draft WHO Report makes no mention of the substantial framework that industry upholds in order to promote responsible advertising and provide consumers with real protection. The ICC Codes provide an international common framework upon which all self-regulatory codes are based. The codes include provisions for advertising to children. National self-regulatory codes, based on the ICC are established policed and enforced by local selfregulatory organisations and industry in over 100 countries. The ICC code and its national codes are reviewed regularly, to ensure that they are appropriate response to local cultural and consumer concerns and that best practice is promoted. In EU law, advertising to children is regulated by the EU Television without Frontiers Directive as adopted in 1989 and revised in 1997. The TWF Directive based on Internal Market law, enshrines the basic freedom and legal right to advertise (including advertising to children), provided a set of minimum criteria are observed. These criteria reflect a standard agreed by EU Member States to be the necessary level of consumer protection, whilst allowing for the transmission of broadcasting and TV advertising across borders according to Internal Market Rules. EU Member States use the TWF Directive as framework legislation and complements its broad provisions with specific requirements laid down in national self regulatory codes, which include specific provision for the protection of minors/children from harmful or misleading advertising. In the USA, the Children s Advertising Review Unit (CARU) of the Council of Better Business Bureaux reviews advertising and promotional material directed at children in all media. CARU s basic activities are the review and evaluation of child directed advertising in all media and on line privacy practices as they affect children. When these are found to be misleading, inaccurate, or inconsistent with CARU ss Self Regulatory Guidelines for Children s Advertising, CARU seeks change through the voluntary cooperation of advertisers. CARU provides a general advisory service for advertisers and agencies and also is a source of information material for children, parents and educators. CARU encourages advertisers to develop and promote the dissemination of educational messages to children consistent with the Children s Televison Act of 1990. Assertions made in the draft WHO Report about the accuracy of advertising and current restrictions are not based on reality. In the context of the current wider debate on better regulation, the European Commission (DG Health and Consumer Protection) contracted Lex Fori, a research consultancy, to carry out a study on self-regulation 6. The study, published at the beginning of 2001, 5 http://www.iccwbo.org/home/statements_rules/menu_rules.asp 6 Available at: http://www.europa.eu.int/comm/consumers/policy/developments/enfo/enfo 02_fr.html WORLD FEDERATION OF ADVERTISERS (WFA) 5

analyses how soft law/self-regulation has been used in different EU countries, how effective it has been in specific sectors and how it could usefully be extended to other sectors. One conclusion of the study is that the advertising sector is a good model for how self-regulation works well in practice. It emphasises that self-regulatory systems are generally very transparent, independent and efficient. It adds that there is no evidence that public control would achieve better results. The study authors, however, suggest that the system could be improved by increasing consumer involvement. We believe that the system of industry self-regulation is the most appropriate way of ensuring that fair, decent, honest and legal advertising continues. This system is responsive to individual consumer concerns while ensuring high standards. It is open to all interested parties and responds quickly once a complaint against an advertisement has been filed. Finally, it guarantees effective control because it is supported by all parts of industry the advertisers, advertising agencies and the media. We believe these existing codes ensure children s advertising remains a responsible and beneficial way of communicating with children. 6 OBESITY The WFA supports the view of many health experts that foods cannot be categorised as healthy or unhealthy. There are no inherently good or bad foods, only unbalanced diets. Diets are a matter for individual and family choice and lifestyle. Advertising has a relatively small influence on diet numerous studies have shown that there are many more powerful factors influencing food choice than advertising itself. The WFA rejects suggestions that additional controls on advertising will have any effect on personal dietary choices. 7 ADVERTISING & NUTRITION Brand advertising has no discernible impact on total consumption or on dietary patterns. Specific research on the impact of advertising on food choice has the additional advantage of placing advertising in its proper context. Work conducted by the University of Leicester in the UK for the UK Government s then Ministry of Agriculture Fisheries and Food (MAFF) in 1996 looked at the role television (including advertising), fulfilled in the provision of information related to food choice, particularly amongst the young. Its summary stated, there is no evidence to suggest that advertising is the principal influence on children s eating behaviour. Indeed the opposite is likely to be true, in that advertising is just one influence amongst many factors 7. The importance of looking at advertising within its total context is important for understanding its relative influence. One of the most important aspects of this context is the family environment. Research in the UK conducted in 1994 8 examined the family s perception of the relative contribution of all potential influences on children s food preferences and their actual consumption and identified the values operating within the family to position food choices. The findings are: 1. Television advertising has a marginal influence on family food choices, on a scale similar to several other factors. 2. Influence from family members accounts for more than three-quarters of the important factors shaping children s diets. Television advertising accounts for only 5% of the influences on family food choice. Thus, the authors conclude that there is no evidence to support the idea that television is the major influence on children s diets. Indeed advertising was perceived as potentially positive in that it may encourage children to try out new foods. In other words, advertising as a relative influence is unlikely to compromise a healthy diet because it has less influence than other family processes. 8 ADVERTISING & CONSUMER FEEDBACK Advertising of food to children is not an area of major concern to consumers. This is supported by research by independent regulators and by opinion polls. Independent research shows that advertising as a whole is enjoying its highest ever levels of public approval. More than three quarters of the UK population now approve of advertising, only 5 per cent 7 B.M. Young, P. Webley, M. Hetherington and S. Zeedyk (1996). The Role of Television Advertising in Children s Food Choice. Report to the Ministry of Agriculture, Fisheries and Food (MAFF). 8 Influences on Children s Diet, Dr P Stratton (The Psychology Business Ltd) 1994 WORLD FEDERATION OF ADVERTISERS (WFA) 6

rank it as a principal concern and less than 1 per cent believe it is in need of major change. 'Public Attitudes to Advertising 2000', conducted by the British Market Research Bureau (BMRB), explores a range of factors to assess people's view of advertising, the extent to which it is a topic of importance and their opinions of it in different media. Approval of advertising 76 per cent of adults now approve of advertising and 21 per cent disapprove, in contrast to 1966 when 68 per cent approved and 25 per cent disapproved Approval is particularly high amongst those under 36, with 83 per cent of 15-24 year olds and 82 per cent of 25-34 year olds approving of advertising Approval is slightly lower at the opposite end of the age spectrum, with 68 per cent of those over 55 approving of advertising Concern about advertising On average, only 6 per cent of people rank advertising as something they talk about often, with the most talked about subjects being family (48 per cent), education and sport (33 per cent), the National Health Service (32 per cent) and bringing up children (31 per cent)less than 1% of the complaints received by the ITC in 1999 related to food advertising. In non-broadcast advertising, in which complaints are adjudicated by the Advertising Standards Authority (ASA), the figure for 1999 was 1.1%. These figures represent the total number of complaints received for all food categories not just those food advertisements aimed at children. Parents asked across 20 European countries expressed a very similar point of view 9. When asked about the most important influences in their children s lives, they say the top 5 influences include parents, school, friends, other family and TV programmes. Out of 4855 parents interviewed, 86% did not cite TV advertising as a top 5 influence in their children s lives. Of the total sample, 8% of European parents cite TV advertising as a top 5 influence in their children s lives and want to see its influence reduced. This clearly demonstrates that TV advertising is perceived as a relatively low concern by parents. 9 RAISING AWARENESS ABOUT PREVENTION OF CHRONIC DISEASES The food industry plays a key role in ensuring the supply of safe, nutritious, tasty, convenient and high quality foods that meet the diversity of consumer needs world-wide. Whilst the major responsibility of health promotion lies with national governments and health authorities, many of WFA members have been also been active in providing information about the importance of good nutrition. Health experts confirm that chronic diseases are caused by many different factors. While diet does play a vital role, we note that the WHO report indeed acknowledges the importance of other risk factors such as the influence of physical activity on chronic diseases. 10 CONCLUSION Advertisers take their responsibilities to consumers extremely seriously. The World Federation of Advertisers representing trade bodies nationally exists to promote, protect and explain the role of responsible advertising in society. We have specific programmes aimed at sharing our responsible actions around communications with children. Effective policies to combat childhood obesity and to propagate healthy eating messages must be based on understanding of the real causes of the problem. Advertising is a marginal influence on diet. Policies that restrict advertising further will: 1. Limit individual choice 2. Have no effect on child hood obesity WHO and FAO, we believe, should be seeking ways to use advertising and education to improve positive messages about healthy diets eating and physical activity. WFA would welcome the opportunity to start discussions with WHO and FAO to examine how best to pursue this goal. 9 Pan-European Study on Parental Perceptions of Influences in Children's Lives, Advertising Education Forum, May 2000. WORLD FEDERATION OF ADVERTISERS (WFA) 7