AA submits response to Government HFSS advertising consultation

On June 10, the Advertising Association submitted our response to the Government’s consultation on further advertising restrictions on TV and online for HFSS products.

On the submission of the report, Stephen Woodford, Chief Executive, Advertising Association commented:

“The Government’s own Impact Assessment on the subject concedes that the proposed 9pm watershed restrictions would only remove around 1.7 calories per day from a child’s diet. UK advertising already has some of the toughest regulations in the world around high fat, salt & sugar food and drink products – enforced by the Advertising Standards Authority. We would urge the Government to come to a measured, appropriate and fact-based conclusion to avoid any decisions that would have a damaging impact on industry, while having little to no effect in lowering obesity levels.”

The consultation response highlighted that:

• HFSS advertising restrictions in place since 2008 have not impeded the rise of childhood obesity. In 2010, Ofcom described a pre-9pm watershed restriction as ‘disproportionate’ and ‘ineffective’.[1]
• The evidence regarding the Government’s proposal for a 9pm-5.30am watershed on HFSS advertising on TV and online fails to support the need for further regulatory intervention. Children see very little HFSS advertising today and that exposure is declining rapidly, both organically and through the self-and co-regulatory rules which are already in place.
• The 70% drop in children’s weekly exposure to HFSS advertising since 2005 and further 30% expected drop over the next 5 years means the rationale for further intervention is invalid.
• The Impact Assessment, which was issued by DCMS and DHSC alongside the consultation document, concedes that the proposed restrictions would only remove around 1.7 calories per day from children’s diets. This is even if the restrictions were even to succeed, which the evidence does not support.
• Were these restrictions to go ahead, consumers in the long run would stand to lose the benefits of the ad-supported media ecosystem that they currently enjoy. Evidence suggests that the impact of the restrictions would equate to over £1 billion in overall cost to UK GDP.
• Using the estimates of the Impact Assessment, that £1 billion would be spent in service of reducing 635 calories per year from the average child’s diet.
• The overwhelming impact (by a margin of over 50 to 1, in five years) will be on advertisers’ ability to communicate with adult audiences about foods that are primarily consumed by adults.  The proposed restrictions will miss the child target over 98% of the time.
• Given that the estimated costs would be between ten and seventeen times the benefits (depending on policy option), it would be disproportionate to introduce any of the proposed restrictions.
• Alternative measures focusing on calorie expenditure such as the Daily Mile project have the potential to increase calorific expenditure by over 40 times as much.

For further information, please contact David Henderson, Public Affairs Manager.

[1] https://www.ofcom.org.uk/__data/assets/pdf_file/0024/31857/hfss-review-final.pdf