RepoRt CaRd on Food-MaRketing poliCies - A- an analysis oF Food and enteRtainMent CoMpany poliCies RegaRding Food and BeveRage MaRketing to ChildRen doc

In 2008, the Federal Trade Commission FTC recommended that “all companies that market food or beverage products to children [should] adopt and adhere to meaningful nutrition-based standa

D+

F

A-B+

an analysis

oF Food and enteRtainMent CoMpany

poliCies RegaRding Food and BeveRage MaRketing

to ChildRen RepoRt CaRd

on Food-MaRketing poliCies

This study on corporate policies on the marketing of food to children was conducted,

and the report written, by Margo G Wootan, DSc, Ameena Batada, DrPH, and Ona

Balkus Additional help with data collection and analysis was provided by Arianne

Corbett, RD, Lauren McLarney, Seth Coburn, Lindsey Vickroy, and Annalisse Leekley.

CSPI and the Nutrition Policy Project

The Center for Science in the Public Interest (CSPI) is a nonprofit organization

based in Washington, D.C Since 1971, CSPI has been working to improve the

public’s health through its work on nutrition, food safety, and alcohol issues.

CSPI is supported primarily by the 850,000 subscribers to its Nutrition Action

Healthletter and philanthropic foundations.

CSPI’s Nutrition Policy Project works with concerned citizens, health professionals,

government officials and other nonprofit organizations to strengthen national,

state, and local policies and programs to promote healthy eating and reduce obesity.

Our goals are to help reduce the illnesses, disabilities, and deaths caused by

diet- and obesity-related diseases and conditions, such as heart disease, cancer,

high blood pressure, and diabetes.

For more information on CSPI’s projects and other policies to promote healthy eating

and reduce obesity, visit

www.cspinet.org/nutritionpolicy.

Report Card on Food-Marketing Policies: An Analysis of Food and Entertainment

Company Policies Regarding Food and Beverage Marketing to Children

is available on-line, free of charge at www.cspinet.org/marketingreportcard.

Acknowledgements

The Center for Science in the Public Interest deeply appreciates the financial

support provided for this report by the Robert Wood Johnson Foundation’s

Healthy Eating Research project and CSPI members.

We thank the members of the Food Marketing Report Card advisory committee

for their advice in determining which companies to include in the study,

evaluating our assessment/grading criteria, and reviewing the report:

Rudd Center for Food Policy

and Obesity, Yale University

Marvin goldberg, phd

Penn State University

Josh golin, Ma

Campaign for a Commercial-Free Childhood

MARGO G WOOTAN, DSc CENTER FOR SCIENCE

IN THE PUBLIC INTEREST (CSPI) PHONE:

gRade CoMpanies gRade CoMpanies

B+ Mars, Inc.

B QUBO Venture, LLC;

Procter & Gamble Company (Pringles)

B- Nestlé USA; Kraft Foods Global, Inc.; Cadbury Adams

USA, LLC; Hershey Company; Dunkin’ Brands;

General Mills, Inc.

C+ Post Foods, LLC; PepsiCo Inc.; Public Broadcasting

Service (PBS); Coca-Cola Company

C

Walt Disney Company (including ABC, Funschool, and

Pixar); Burger King Corporation; Campbell Soup

Company; Sesame Workshop; Hostess Brands, Inc.;

Kellogg Company; ConAgra Foods, Inc (Chef

Boyardee, Kid Cuisine, Peter Pan)

C- Unilever (Popsicle, Skippy); Highlights for Children,Inc.; Dannon Company; McDonald’s USA, LLC; H.J.

Heinz Company (Bagel Bites); Viacom International Inc (Nickelodeon)

D+ Sunny Delight Beverages Co.; Krispy Kreme

Doughnut Corporation; Cartoon Network;

Ruby Tuesday, Inc.

D Doctor’s Associates Inc (Subway);

Yum! Brands, Inc (KFC, Pizza Hut, Taco Bell); CEC Entertainment Concepts, L.P (Chuck E Cheese’s)

F

Bob Evans Farms, Inc.; CBS Corporation;

American Dairy Queen Corporation; Discovery Communications, LLP; Mattel, Inc.; NBC Universal, Inc.; Univision Communications Inc.; Warner Bros Entertainment Inc (New Line Cinemas)

Food-MaRketing poliCy

20th Century Fox

Activision (Sierra Studios, video games)

Alloy Media and Marketing (Channel One)

AMC Entertainment

American Girl Magazine

American Greetings Corporations

Arby’s Restaurant Group, Inc.

Blizzard Entertainment (video games)

Blue Sky Studios (Ice Age, Robots)

Boys’ Life Magazine

Brinker International (Chili’s Grill & Bar)

Buffalo Wild Wings Grill & Bar

Cajun Operating Company (Church’s Chicken)

Carmike Cinemas, Inc.

Cheesecake Factory Assets Co LLC

Chick-fil-A, Inc.

Cinemark USA, Inc.

Chipotle Mexican Grill, Inc.

CKE Restaurants, Inc (Carl’s Jr., Hardee’s)

Darden Concepts, Inc (Red Lobster,

Olive Garden, Longhorn Steakhouse)

Denny’s, Inc.

DineEquity, Inc (Applebee’s, IHOP)

Domino’s Pizza

E.W Scripps Company (Peanuts Comic)

Electronic Arts, Inc (video games)

Golden Corral

Girls’ Life Acquisition Co (magazine)

Hansen Beverage Company

Hasbro, Inc.

HIT Entertainment Limited (Barney, Bob

the Builder, Thomas the Train)

Hollywood Theaters, Inc.

HP Hood LLC

Jack in the Box Inc.

Kerasotes ShowPlace Theatre Kids Discover (magazine) Klutz (crafts and games) LFP Publishing, LLC (Tips & Tricks Magazine) Little Caesar Enterprises, Inc.

Lucasfilm Ltd.

Major League Soccer, L.L.C.

Marcus Corporation (movie theater) Marvel Characters, Inc.

McKee Foods Corporation (Little Debbie snack cakes) MGA Entertainment, Inc (Bratz) Microsoft Corporation (XBox) MLB Advanced Media, L.P.

(Major League Baseball) National Amusements Inc (movie theater) National Association for Stock Car Auto Racing, Inc (NASCAR)

National Geographic Society (National Geographic Kids) National Hockey League National Wildlife Federation (Wild Animal Baby Magazine,Your Big Backyard Magazine, Ranger Rick) NBA Properties, Inc.

NFL Enterprises LLC Nintendo of America, Inc.

OSI Restaurant Partners, LLC (Outback Steakhouse) Panda Restaurant Group, Inc.

(Panda Express) Panera Bread Papa John’s International, Inc.

Pearson Education, Inc (Fun Brain)

Perfetti Van Melle S.p.A (Airheads) Perkins & Marie Callender’s Inc.

Pilgrim’s Pride Corporation Pinnacle Foods Group LLC (Aunt Jemima, Lender’s, Duncan Hines) Pokémon Company

Popeyes Louisiana Kitchen (AFC Enterprises, Inc.) QIP Holder LLC (Quiznos) Rave Motion Pictures, LLC Red Robin International, Inc.

Regal Entertainment Group Romano’s Macaroni Grill Ryan’s Restaurant Group, Inc.

(Hometown Buffet/Old Country Buffet) Sara Lee Corporation

Scholastic Inc.

Schwan’s Home Service, Inc.

Sizzler Restaurants SONIC Corp.

Sony Corporation of America (Play Station, Sony Motion Pictures) Sunkist Growers, Inc.

T.G.I Friday’s Inc.

Texas Roadhouse, Inc.

Time Inc (Sports Illustrated for Kids, Time for Kids)

Topps Company, Inc (Bazooka, Ring Pop, Baby Bottle Pop) Waffle House, Inc.

Wendy’s International Inc.

Whataburger Restaurants LP World Wrestling Entertainment, Inc Zoobooks

no

policy

F

The National Academies’ Institute of Medicine (IOM) concluded that television food

advertising affects children’s food choices, food purchase requests, diets, and health

Yet, companies spend approximately $2 billion a year on marketing foods and beverages

to children, mostly for foods high in calories, fats, sugars, and sodium, and low in

fruits, vegetables, whole grains, and key nutrients

In 2008, the Federal Trade Commission (FTC) recommended that “all companies that

market food or beverage products to children [should] adopt and adhere to meaningful

nutrition-based standards for marketing their products” and that marketing include

all advertising and promotional techniques

In the past few years, a number of food and entertainment companies have

announced policies on food marketing to children independently or through the

Council of Better Business Bureaus’ (CBBB) Children’s Food and Beverage Advertising

Initiative (CFBAI) This report examines whether companies that market food to

children have adopted a policy on marketing to children, and if so, the adequacy

of that policy The report does not assess whether companies complied with

their policies in practice

During the summer of 2009, CSPI staff conducted telephone interviews and searched

company Web sites, articles in the Nexis news service, and used Google keyword

searches to collect company policies on marketing to children We evaluated food

and beverage manufacturers, chain restaurants, and entertainment companies that

market food to children We assessed policies for marketing to children under the age

of 12 years old and for marketing in elementary and secondary schools Although

some children in middle schools and all children in high

schools are not under 12, schools are a unique space that

should be free of the marketing of low-nutrition foods

We evaluated the strength of the companies’ nutrition

standards, scope of media covered by their policies,

and their definitions for “child-directed” media

Of the 128 companies analyzed, two-thirds (68%) did

not have a policy for food marketing to children A much

larger proportion of food and beverage manufacturers

(64%) had marketing policies than did restaurants (24%)

or entertainment companies (22%)

No company received an A for its policy The company

with the strongest policy was Mars, which received a B+ The Mars policy did not

allow for its products to be marketed to children under 12 years old and covered most

of the key media approaches used to reach children (with the exception of on-package

marketing and most marketing in high schools)

RepoRt CaRd

oF Food and enteRtainMent CoMpany

poliCies RegaRding Food and BeveRage MaRketing

to ChildRen

“All companies that market food

or beverage products to children [should]

adopt and adhere to meaningful nutrition-based standards for marketing their products” and that marketing should include all advertising and promotional techniques.

–Federal Trade Commission, 2008

The only entertainment company to get a B was Qubo Venture (which has a

television channel, Web site, and broadcasts its programming on NBC Saturday

mornings, ION Television, and Telemundo) Qubo had a comprehensive policy,

applying reasonably good nutrition standards to its full range of marketing

One food company received a B, six got a B-, 17 got a C, and 7 a D Ninety-five

companies received an F; of those, eight had very weak marketing policies and

87 did not have a policy

Food manufacturers and restaurants were more likely to have policies for television, radio,

print, the company’s own Web site, advertising on third-party Internet sites, product

placement, and use of licensed characters in advertising The companies were less

likely to have policies or policies were weaker for digital marketing, on-package

promotions, and marketing programs in schools

Eight in ten entertainment companies (45 companies) did not have

a food marketing policy When they did, those policies were generally

more limited in scope than were the policies of food and beverage

manufacturers If entertainment companies had a marketing policy,

it most likely addressed the use of licensed characters Policies generally

were weaker or did not exist for television, radio, print, company

Web sites, other digital media, and product placement For example,

the Cartoon Network applied nutrition standards to the licensing of

its characters, but not to its television advertising or Web site, which

are the primary means by which it markets to children

Of the companies with policies for marketing to children, almost all

(94%) of the food and beverage manufacturers surveyed had nutrition

standards or had policies not to market any of their products to children

under 12 years of age Fifty percent of restaurants and 46% of entertainment

companies with marketing policies had nutrition standards

Companies have not complied with the FTC’s recommendation to standardize

nutrition criteria for marketing to children Each company had a different set

of standards

Food and Beverage Manufacturers (n) Companies with

Entertainment Companies (n)

Pizza Hut’s “Book It” program provides pizza

as a reward for reading Food rewards can cultivate unhealthy relationships with food.

Perfetti Van Melle’s Web site for Airheads candy includes characters from the popular children’s movie, Alvin and the Chipmunks: the Squeakquel, as well as games and a kids’ club.

Nutrition standards were strongest for saturated fat and trans fat among all types

of companies

Food companies and restaurants also tended to have strong policies for total fat

It was more common for food manufacturers and restaurants to have weak policies

or no policy for sodium and added sugars

Among the entertainment companies that had policies, sodium and

total fat policies were generally weak or absent

Across all companies, a requirement for marketed food to provide positive

nutritional value — such as whole grains, fruits, vegetables, vitamins, or

minerals — was often weak or not included in the nutrition standards

Several previous reports found that company compliance with their policies

on food marketing to children was high However, the meaningfulness

of that compliance is questionable in light of this study finding that most

companies that market to children did not even have a policy (68%), and

the majority of existing policies were weak; three-quarters were graded

as C, D, or F

In order for self-regulation of food marketing to children to be effective:

All food and beverage manufacturers, restaurants, and entertainment companiesthat market to children should have a written food marketing policy that is readilyavailable to the public Companies that do any marketing to children, even if notduring children’s television programming, should have a marketing policy

• Although its program conditions are not ideal, all companies should belong tothe CBBB’s Children’s Food and Beverage Advertising Initiative, since its membercompanies’ policies are generally clearly spelled out, available in one place forpublic viewing, and compliance is monitored by the CBBB

• The CBBB and entertainment companies should work together to develop

a set of entertainment-company-specific criteria for the CFBAI, and

entertainment companies should join the Initiative

All companies should use a uniform set of strong nutrition standards

Company marketing policies should cover all approaches used to market

to children Many companies need to strengthen their policies for digital

marketing, on-package/in-store promotions, and practices in elementary,

middle, and high schools

• Companies should adopt a uniform set of definitions for marketing “directed

to children.” A set is expected to be recommended by the Interagency WorkingGroup on Food Marketed to Children

Without more significant progress in the next two years, the country will need torely on government regulation, rather than self-regulation, as the means to addressfood marketing to children

Food marketing affects children’s diets and health

In December 2005, the National Academies’ Institute

of Medicine (IOM) released a comprehensive review

of research on the influence of food marketing to

children (IOM, 2006) The IOM concluded that television

(which is by far the largest medium for advertising

to children) food advertising affects children’s food

choices, food purchase requests, diets, and health

In addition, the committee concluded that the

foods and beverages marketed to children are out

of balance with current dietary recommendations

Marketing to children is extensive

Companies spent approximately $2 billion in 2006 on marketing foods and beverages

to children (including toy give-aways with children’s meals at fast-food restaurants)

(FTC, 2008) Companies market food to children through traditional media, such as

television, radio, magazines, product packaging, and in-store

displays and promotions In addition, they use many other

approaches, such as the Internet and other new electronic

media, ads in movie theaters, school-based marketing, product

placement in movies and video games, marketing in amusement

parks, food-themed toys, clothing and other merchandise, and

almost anywhere a logo or product image can be shown Food

marketing techniques include the use of spokescharacters,

celebrities, cartoons, children’s meals and menus, premiums

(such as toys or other items distributed in product packaging,

with restaurant meals, through contests, or redeemable via

coupons, codes, or proof of purchase), games, contests, kids’

clubs, viral marketing, event sponsorship, and more

Low-income and racial-minority populations are disproportionately exposed to television

and other media (Rideout et al., 2010), which results in heightened exposure to the marketing

of unhealthy foods Some studies suggest that marketing of low-nutrition foods is

particularly prevalent on television channels targeting African Americans, such as BET

(Tirodkar & Jain, 2003), and Hispanic populations, such as Univision (Thompson et al., 2008)

Young people are uniquely vulnerable to food marketing

Children lack the skills and maturity to comprehend the complexities of good nutrition

or to appreciate the long-term consequences of their actions, such as that their dietary

patterns can result in cancer, diabetes, and heart or other diseases Children of different

ages face different vulnerabilities to food marketing and diverse challenges to

healthful eating

“Among many factors, food and beverage marketing influences the preferences and purchase requests of children, influences short-term consumption, may contribute to less healthful diets, and contributes to an environment that puts their health at risk.”

to be mixed with ketchup and “cheese”, which has maltodextrin as the first ingredient.

Young children do not understand the persuasive intent of advertising and are easilymisled Based on an extensive research review, the American Psychological Associationconcluded that until the age of about 8 years old children are unable to understandthe persuasive intent of advertisements (Kunkel et al., 2004) According to the IOM,children as old as 10 years may not understand the persuasive intent of advertising(IOM, 2006) Older children, who still do not have fully developed logical thinking,have considerable spending money and opportunities to make food choices andpurchases in the absence of parental guidance and the absence of understandingthe long-term consequences of poor nutrition.

Most of the foods and beverages marketed to children are unhealthy

The primary reason food marketing has a negative effect on children’s diets and health

is that the overwhelming majority of marketing aimed at children is for foods of poornutritional quality (IOM, 2006) A study of Saturday morning children’s televisionfound that 91% of the advertisements promoted foods that were high in saturatedfat, added sugars, or sodium, or low in fruits, vegetables, or key nutrients (Batada

et al., 2008) A 2000-calorie diet of advertised foods would exceed recommended dailyvalues for total fat, saturated fat, and sodium and provide nearly 1 cup of added sugar(Harrison and Marske, 2005) Carbonated beverages, fast food, and breakfast cerealsmake up 63% of the total amount spent on marketing to youth (FTC, 2008)

Foods Advertised on Saturday Morning Television

SNACK FOODS 18%

CANDY 14%

BEVERAGES 10%

YOGURT 4%

BREAKFAST PASTRIES 3%

FROZEN NOVELTIES 3%

PACKAGED MEALS

& ENTREES

3%

RESTAURANTS 19%

CEREAL &

CEREAL BARS

27%

Parental authority is undermined by the wide discrepancies between what parents

tell their children is healthful to eat and what marketing promotes as desirable to eat

In addition, while many parents have limited proficiency in nutrition, companies have

extensive expertise in persuasive techniques They hire psychologists and research firms

to conduct marketing and neuroscience research to determine

how to most effectively influence children’s food preferences

and choices Companies encourage children to choose foods

for fun and social acceptance, not for their nutritional or

health value (Page & Brewster, 2007) Companies also have

ready access to techniques to affect children’s food choices

that parents do not have, such as cartoon characters, contests,

celebrities, and toy give-aways

Parents, of course, bear the primary responsibility for feeding

their children Most parents try to get their children to eat

a balanced and healthful diet, but billions of dollars spent

on marketing low-nutrition foods to children makes it

exceedingly difficult

Children (8 to 12 years old) view an average of 21 food ads

on television each day (Gantz et al., 2007), along with many

additional marketing messages delivered through Web sites, schools, on food

packaging, etc Given how often companies communicate with children about food,

those who manufacture, sell, and promote food to children have an enormous, and

usually deleterious, effect on parents’ ability to feed their children a healthful diet

Self-regulation of food marketing to children

Based on the types of food marketed to children and the research that

shows that marketing has a negative impact on children’s diets and health,

the IOM (2006) concluded that, “current food and beverage marketing

practices put children’s long-term health at risk.” Among the IOM’s key

recommendations is that food and entertainment companies should

improve the balance of foods marketed to children within two years

of the report’s 2006 issuance; otherwise, the report recommended,

Congress should step in to regulate food marketing to children

Since the IOM report was released, a number of food and entertainment

companies have implemented policies on food marketing to children

The Council of Better Business Bureaus (CBBB) announced the Children’s

Food and Beverage Advertising Initiative (CFBAI) in November 2006

Thus far, sixteen food manufacturers and restaurants, representing

about 80% of television food advertising expenditures (Peeler et al.,

2009), have pledged not to market to children under 12 years old any

of their products or products that do not meet individual company

Children’s Food and Beverage Advertising Initiative Participants:

Burger King Cadbury Adams Campbell Soup Company Coca-Cola Company ConAgra Foods Dannon General Mills Hershey Kellogg Kraft Foods Mars McDonald’s USA Nestlé USA PepsiCo Post Foods Unilever United States

nutrition standards To participate in the CBBB Initiative, companies are asked to

address advertising through measured media (television, radio, print, and Internet),

product placement, and some types of advertising in elementary schools

A number of beverage and snack food companies have agreed to

limit the sale of low-nutrition beverages and snacks in elementary,

middle, and high schools through an agreement with the Alliance

for a Healthier Generation, a partnership of the William J Clinton

Foundation and the American Heart Association The School

Beverage Guidelines and the Competitive Food Guidelines were

adopted in 2006 (AHG, 2009)

Several entertainment companies also have announced efforts to

address food marketing to children, primarily by setting nutrition

standards for foods which can be associated with characters that

they license In addition, a few companies have announced that

they will apply their standards to other types of marketing, such as sponsorships and

the company’s own Web site No entertainment companies belong to the CBBB’s CFBAI

Food marketing to children report card

Studies have found that companies’ compliance with their own policies on food

marketing to children is high The CBBB has completed two assessments on the

compliance of companies that belong to the Children’s Food and Beverage Advertising

Initiative with their marketing policies (Peeler et al., 2009; Peeler & Kolish, 2008)

The CBBB evaluated compliance through company reports and monitoring of 54

hours of children’s television programming in 2009 (Peeler et al., 2009) The Center

for Science in the Public Interest (CSPI) also found high compliance by CFBAI companies

with their stated marketing policies by evaluating the nutritional quality of products

approved by companies for marketing to children and monitoring advertising in

28 hours of children’s television programming on Nickelodeon in 2009 (Batada

& Wootan, 2009)

If compliance is strong, the next key question is “compliance with what?” How strong

are company policies for food marketing to children? If the U.S Congress, Federal

Trade Commission, other policy makers, advocates, and parents are to assess the

effectiveness of self-regulatory efforts, they need a comprehensive analysis of company

marketing policies

The Federal Trade Commission has recommended that “all companies that market

food or beverage products to children should adopt and adhere to meaningful

nutrition-based standards for marketing their products” and that marketing should

include all advertising and promotional techniques (FTC, 2008) Previously, CSPI

summarized company marketing policies and the nutrition standards for marketing

to children for a number of food manufacturers, restaurants, and entertainment

companies (CSPI, 2009a; CSPI, 2009b) However, a need has been identified to analyze

in more detail the strength of those policies and the policies of additional companies

Imagination Farms uses popular Walt Disney characters to promote fresh produce to children.

In this study, we set out to meet that need by assessing many more companies’policies and evaluating the relative strength of each policy This assessment was achallenging undertaking given that each company has a different policy that applies

to different media and that has unique nutrition standards and different definitions

of media considered to be directed at children Unlike content analyses that havemeasured the balance of less nutritious versus more nutritious foods advertised

to children, the Report Card on Food-Marketing Policies assesses the strength of each

company’s marketing policy.

Methods

Our initial sample included 142 food and entertainment companies that market food tochildren: 42 food and beverage manufacturers, 42 chain restaurants, and 58 entertainmentcompanies.2To identify companies that market food to children, we consulted previousstudies and reports, including the FTC’s 2008 report on food marketing expenditures

to children (FTC, 2008) and studies on food marketing on the most popular children’sWeb sites (by number of visits) (Moore, 2006; Lingas et al., 2009)

We included companies identified as the top 100 food processors (Fusaro, 2008) andtop 100 restaurants (Hume, 2008) Of those 200 companies, we determined whichhad children’s sections on their Web sites, children’s meals/menus, corporate programsfor children or schools, or other marketing for children In addition, we includedcompanies that license the most popular children’s characters; that were one of thetop movie-theater chains, children’s television channels, or video-game producers;and that produced the top children’s movies or magazines (NATO, 2009; FTC, 2008;Jones, 2008; Nielsen, 2008; Ad Age, 2003) All 16 companies that have policies throughthe Council of Better Business Bureaus’ Children’s Food and Beverage AdvertisingInitiative were included in the study

Although they were included in the FTC expenditures study (FTC, 2008), we did notassess policies for three check-off programs (i.e., commodity promotion boards).3

We also excluded from the grading 11 produce companies.4While, ideally, all companiesthat market to children should have a marketing policy, those companies marketonly fruits and vegetables — healthful foods that are greatly under-consumed bychildren Thus, we evaluated a total of 128 companies (142 companies minus threecheck-off programs and 11 produce companies)

2 In most cases, we analyzed the marketing policy of the parent company Several of the parent companies

in the study operated more than one restaurant concept or media subsidiary that markets to children For example, Yum! Brands operates KFC, Pizza Hut, and Taco Bell.

3 California Milk Advisory Board, California Milk Processor Board, and National Fluid Milk Processor Promotion Board (MilkPEP).

4 Boskovich Farms, California Giant Berry Farms, Chiquita, Delmonte Fresh Produce, Dole Food Co., Grimmway Enterprises, Imagination Farms, Ready Pac Produce, Stemilt Growers, Summeripe Worldwide, and LGS Speciality Sales.

We evaluated company policies for marketing to children under 12 years old.

We included an assessment of not only primary schools, but also secondary schoolmarketing policies Middle schools include children under 12 (the average sixthgrader is 11 years old) Although, all high school students are over 12 years old,schools are a unique place, where children are required to be in attendance

and parents are not present to help guide their food choices

We called each company and administered a questionnaire that explored eachcompany’s policies and nutrition standards for food marketing to children Thequestionnaire was developed in consultation with the project’s advisory board,including experts in the areas of child health and welfare, marketing, media, policy,health, and nutrition In addition, we searched for publicly available informationabout the company’s marketing practices and policies through reviews of companyWeb sites and Nexis news service and Google keyword searches

During the summer of 2009, research assistants called each company andasked to speak with a staff person who would be able to answer questionspertaining to the company’s policy for food marketing to children Of 128

companies, 11 refused to participate and 27 contact people did not respond torepeated (more than five) calls, for a response rate of 70% If a contact persondid not respond to repeated calls and no marketing policy was identified throughthe company Web site and Nexis and Google searches, we categorized thecompany as not having a policy for food marketing to children (27 companies).Information from the completed questionnaires and Internet searches was analyzed

to determine how many companies had policies and the content of each company’spolicy The policies were rated in comparison to the model policy outlined in CSPI’s

Guidelines for Responsible Food Marketing to Children (CSPI, 2006), which are based

on key nutrition recommendations in the Dietary Guidelines for Americans (DHHS

& USDA, 2005), and in consultation with the project advisory board Criteria included:

strength of the nutrition standards:

• Beverage standards were evaluated by categories of beverages not permittedfor marketing (for example, soda, sports drinks, juice drinks, and high-fat milk)

• Food and meal standard were assessed for limits on total fat, saturated fat,trans fat, sodium, and added sugars, and a requirement for positive nutritionalcontent (whole grains, fruits, vegetables, or key vitamins or minerals)

• For companies that had different nutrition standards for different categories

of foods, we scored each set of nutrition standards and averaged them

• Companies that had policies not to market any food products to childrenreceived the maximum allotted points for nutrition standards

scope of media covered by the policy and the strength of definitions

of child-directed media.

• The points assigned to different types of media were weighted based on

the predominance of the media type in the FTC’s marketing expendituresstudy (FTC, 2008) For example, more weight was given to policies for

television than for radio and print marketing

• While the criteria for food companies and entertainment companies wereidentical for the nutrition standards, there were some differences for theassessment criteria for media approaches:

For food and beverage manufacturers and restaurants, we assessedpolices for television; radio; print; company-sponsored Web sites; third-party Internet advertising; other digital marketing, such as through cellphones, email, and portable electronic devices; use of licensed charactersand cross promotions with movies and television programs; productplacement; packaging and in-store displays; marketing in elementary,middle, and high schools; and marketing in out-of-school settings

for children

For entertainment companies, the same marketing approaches wereanalyzed, with the exception of third-party Internet sites and schools.Those two approaches were excluded, since entertainment companiesmarket their own products (movies, television shows, magazines, etc.),not food, through those outlets

Entertainment companies’ scores were based on the types of child-directedmedia outlets owned by the company For example, Highlights for Children(publisher of Highlights Magazine) was graded on their marketing policies forprint, company-sponsored Web site, cross promotions, and product placement.Its score was not affected by marketing outlets that the company did notown, such as television or radio

As we undertook the study, we realized that we could have included even

more categories of companies For example, one limitation of the study is that

it did not include grocery chains or book publishers (other than Scholastic, whichwas included along with the publishers of other top children’s magazines)

This analysis was cross-sectional at one point in time; some company policies

may have changed since we collected our data in the summer of 2009 In

addition, it is important to reiterate that we examined company policies onfood marketing to children, not practices For many companies, their policiesand practice align We did note a few companies where they did not For

example, Subway and Ruby Tuesday appear to have stronger practices thantheir policies reflect We suspect that some companies that have not used,and perhaps have no plans to use, certain marketing practices did not includethem in their policy We encourage companies to strengthen their policies

to reflect their practices and to cover all media available to them

Results and Discussion

Two-thirds of companies lack a marketing policy

Of the 128 companies that we analyzed that market foods

to children, one-third (32%) had a policy to govern their

marketing practices A much larger proportion of food

and beverage manufacturers (64%) had marketing policies

than did restaurants (24%) or entertainment companies

(22%) (Figure 1)

No company received an A for its policy The company

with the strongest policy for food marketing to children

was Mars, which received a B+ The Mars policy did not

allow for its products to be marketed to children under

12 years old and covered most of the key media approaches

used to reach children (with exception of on-package

marketing and most marketing in high schools)

The only entertainment company to get a B was Qubo

Venture (which has a television channel, Web site, and

broadcasts its programming on NBC Saturday mornings,

ION Television, and Telemundo) While most entertainment

companies’ policies covered only a small segment of their

marketing to children, Qubo applied reasonably good

nutrition standards to its full range of marketing Procter

& Gamble, which advertised Pringles, also received a B

FOOD AND BEVERAGE (64%)

RESTAURANTS (24%)

ENTERTAINMENT (22%)

Figure 1: Companies with Marketing Policies

NO POLICY POLICY

type of company (% of companies with marketing policies)

Examples of Vague Marketing Policies:

Warner Bros Entertainment, Inc.: “Balance

our portfolio of licensed/promotional food and beverage products featuring our entertainment characters to include an assortment of healthier

or better-for-you offerings” (no definition of healthier foods was given).

American Dairy Queen Corporation:

“ADQ does not intentionally target children with national or local TV, radio or print advertising, nor market food or treats to children in school settings.” (While this policy sounds promising, no definitions of child- directed advertising were specified Also, the company markets to children through its child-directed Web site, deeqs.com, and kids’ meals).

Discovery Communications, LLC: “Will only

license characters to use with better-for-you foods…based on internal nutrition standards” (the company would not share the nutrition standards).

Six companies earned a B-, 17 received a C, and 7 a D Those companies had key

weaknesses in their nutrition standards, the range of marketing covered, and/or

definitions of child-directed marketing Ninety-five companies received an F Eight of

those companies had marketing policies, but the policies were extremely weak or vague

The other 87 companies did not have policies and thus, received an F grade Some

companies responded to our questionnaire stating that they do not market food to

children However, while many of those companies did not advertise on children’s

television, they did market to children in other ways For example, many chain

restaurants that did not have marketing policies marketed to children through

children’s menu items and menus, fundraisers for schools, toy give-aways, movie

tie-ins, children’s sections on company Web sites, youth sports sponsorships, and

kids’ clubs No national movie theater chain had a marketing policy, though many

marketed to children through advertisements before movie showings, kids’ foods

or combo deals at concession stands, kids’ movie clubs, and contests

Marketing policies varied by type of media

Food manufacturers and restaurants

The strength of food manufacturers’ and restaurants’ policies for food marketing

to children varied by the type of media (Figure 2) Of the 28 food manufacturers

and restaurants with marketing policies, slightly over 50% had good5policies for

5 A company policy in the top half of the highest possible score for a particular medium was categorized as

good, and scores in the bottom half were classified as weak For example, the top score for a company’s

television policy was eight Television scores of 5 to 8 were categorized as good, and scores of 1 to 4 were

TV

RA D

IO

PR IN T

CK A

IN G /

IN -S

TO RE

Figure 2: Food Company and Restaurant Policies By Media Type

GOOD WEAK VAGUE/NO POLICY N/A

type of media

1

14

7 6 1

15

5 7 1

15

6 7 0

13 7 8 0

10 4 11 3

15

5 7 1

21

1 6 0

7 4 17 0

traditional measured media, such as television, radio, and print (mostly children’s

magazines), as well as for the company’s own Web site Slightly under half (46%)

had good policies for advertising on third-party Internet sites Nineteen percent to

30% of food manufacturers and restaurants had weak policies for the above media,

and 15-29% had no policy to address those media or the policy was so vague as

to be meaningless

definition of child audience:A company’s definition of what is considered to be

child-directed marketing is a key determinant of the scope of where a company ends up

marketing its products Yet, many companies had vague definitions and did not specify

the audience composition for what they considered to be child-directed marketing

Companies with clearer policies defined child-directed marketing as having an

audience that ranged from about 18% to 50% under 12 years old Eight companies

defined television advertising as targeting children if more than 50% of the audience

was under 12 (Figure 3) Six companies defined child-directed marketing as having

more than 35% of the audience under 12 Three (Burger King, Hershey, McDonald’s)

used a cutoff of 30%, and one (Mars) used a cutoff of 25% Campbell used the strongest

cutoff, of about 18% (twice the proportion of children in the U.S population) Higher

scores were given to companies with policies that coupled lower audience cutoffs

with additional criteria, such as if the medium was identified as targeted to children

or included child-directed themes, characters, or animation

Seven companies had policies that did not permit any of their products to be marketed

to children under six (even if the products met nutrition standards) (Table 1) Six

additional food manufacturers and two restaurants, as well as one entertainment

company, had policies to not market any of their products to children under 12

Such protections are commendable given that young children do not understand

the persuasive intent of advertising and are easily misled (Kunkel et al., 2004)

35% OR MORE 30% OR LESS NONE

Figure 3: Definition of “Child-Directed”:

Food and Restaurant Companies

product placement:Of all the different types of marketing other than television, food

processors and restaurants were most likely to have policies on product placement

(i.e., the integration of product marketing into movies, television programming, video

games, or other media) Of the food companies with marketing policies, 75% had policies

on product placement (Figure 2) In contrast, only a third (33%) of entertainment

companies had policies on product placement [that was of companies that 1) had a

marketing policy and 2) that had media into which product marketing could be integrated]

licensed characters and cross promotions:Use of licensed characters and tie-ins

with movies, television programs, or other media are common marketing techniques,

amounting to $208 million worth of marketing a year (FTC, 2008) About half (56%) of

the manufacturers and restaurants with marketing policies had good policies for the

use of licensed characters and tie-ins (Figure 2) A common weakness of the policies

was that they had vague definitions of when the use of licensed characters would be

considered to be directed to children In addition, many of the policies applied only

to the use of characters in advertising and not to on-package marketing Finally, the

policies did not apply to the company’s own equity characters (i.e., company-owned

characters such as, Keebler elves, the M&Ms characters, or the Trix rabbit) Many of

those characters are well-known to children and attract children to product packages

or advertisements

digital media:Policies were weakest for digital media and on-package/in-store

marketing to children (Figure 2) Only 40% of food manufacturers and restaurants that

had marketing policies had good ones regarding digital media (other than television

or Internet), such as social networks, text messaging, mobile phones, and other new

media Sixteen percent had weak policies and 44% had vague or no policies

The Kaiser Family Foundation’s study of children’s media use found that the increase

in children’s media use over the last five years was driven by mobile media (Rideout

et al., 2010) Ownership of cell phones by 8 to 18 year olds has increased from 39%

to 66% of children and MP3 ownership has increased from 18% to 76% of kids Given

the growth of the digital market place (in part due to lower costs for many of these

“NO ADVERTISING”

TO CHILDREN UNDER 6 POLICY

“NO ADVERTISING”

TO CHILDREN UNDER 12 POLICY

Campbell Soup Company

General Mills

Kellogg Company

Kraft Foods Nestlé USA Post Foods Unilever

Cadbury Adams Coca-Cola Company Dunkin’ Brands Hershey Company Highlights for Children H.J Heinz Company Krispy Kreme Doughnut Corporation

Mars, Inc.

Procter & Gamble Company

Table 1: Policies to Limit All Marketing to Children

Topps Company’s Facebook page for Ring Pop candy