James Barge, Director of Public Policy, ISBA
Christie Dennehy-Neil, Head of Policy & Regulatory Affairs, IAB UK
Richard Lindsay, Director of Legal & Public Affairs, IPA
First published in The Telegraph on Tuesday 9 February.
Britain has an obesity problem. The advertising industry understands this as much as anyone. That’s why we’ve partnered with government and invested in helping people to get active and eat more healthily. We recognise that this is a challenge our nation has to solve.
Why, then, are we united in opposing the Prime Minister’s proposal for a total online ban on the advertising of food and drink products high in fat, sugar or salt (HFSS)?
Let’s start with what it means for you, your community, and high street. You will not be allowed to see adverts online from your local cake shop, Indian restaurant or burger joint. Social media posts from your pub, with their Sunday roasts and Christmas dinner, will be forbidden. Your supermarket will not be able to show you the items on offer that you have always bought to treat yourself and your family.
Then there’s the economics. Totally banning a substantial portion of advertising online will have a significant impact, and not just for the food and drink industry. Businesses large and small, new and established, will be hit. The ban will mean harsher regulation in the UK than anywhere else in the world, eroding revenue for our digital media industry (which supports the ad-funded internet) and disincentivising investment in healthier alternatives.
So why is a Conservative Government pushing ahead with a nanny-state policy which will hurt the economy, damage your high street, and restrict adults’ choices?
The public health campaigners driving this say that it’s because children pressure adults into buying the products they see; and that kids are abandoning TV, using their parents’ phones and tablets, and seeing huge volumes of adverts not intended for them.
Ministers have been captured by this argument. The problem is that the evidence they’ve presented simply doesn’t support it.
Firstly, it doesn’t support the idea that kids’ exposure to ads has “caused” increased rates of obesity. Instead, it suggests that ad exposure and caloric intake have both declined during the period that obesity has spiked. Caloric expenditure through physical activity was in even steeper decline at the same time, meaning that people were taking in more than they were burning – the driver of the obesity problem.
We already have some of the strictest restrictions on food and drink advertising in the world, with children’s exposure cut nearly in half since their imposition. Online advertising rules were brought in a few years ago to account for children spending more time online, lowering exposure further. No improvement in obesity rates has followed.
Secondly, Ministers assume that children are exposed to such a high level of HFSS marketing that they need to regulate it. But the truth is that there is very little exposure, because the strict rules are complied with. The Government’s own Evidence Note states that the average child is exposed to just 36 seconds of HFSS advertising per day – stunningly low, compared with 113 seconds in Canada and 139 seconds in the US. If we’re worried about the shift from TV to online, we should understand that over the next three years, TV ad exposure to children will drop by seven seconds. Only one second of that decline will be offset by kids seeing an ad online.
Even if you still think government should act, take a look at the results which the evidence says this intrusive action will achieve. By introducing their ban, Ministers project that they will cut calorie intake by the grand total of 2.84 calories per child, per day.
It’s worth letting that trade-off sink in. There will be a measurable hit at a time when our economy is reeling, all to possibly remove the equivalent of a third of a Smartie from children’s diets. (Even that calculation is based on an error in Ministers’ maths; once you’ve corrected for it, you arrive at 1.09 calories per child, per day. A Smartie doesn’t crumble small enough to give you the equivalent.)
The evidence doesn’t add up, and the policy won’t even do what it’s supposed to. But the most important reason we oppose this proposal isn’t just that it’s disproportionate, threatens businesses, and restricts your rights as an adult to choose. We oppose it because it’s bad policy. There are better, sophisticated, cost-effective ways to restrict the type of ads children see online, which would allow businesses to continue to reach their adult consumers.
Oxford University’s Professor Andrew Stephen, one of the UK’s leading marketing academics, argues that technological solutions could easily be deployed to reduce exposure to HFSS ads online even further, by “precision targeting” them away from children.
This would be more effective; the costs would be miniscule compared to a total online ban; and it wouldn’t wreak havoc on competition within industry by foreclosing online advertising to most food and drink companies. Businesses would remain fully able to reach adult audiences online, with few of the downstream impacts on the advertising and media value chain.
It also wouldn’t force consumers to bear the costs passed on by the food industry; and food – something we all need to live, and which can be a source of great joy and connection to tradition, culture, and family – would not be demonised.
Ultimately, this is about far more than advertising. This issue represents a choice for this Government. Do they really understand the modern world; and is the Conservative Party still the party of business?