Alignment of Childrens Food Advertising

With Proposed Federal Guidelines

Melanie D. Hingle, PhD, MPH, RD, Jessica S. Castonguay, PhD, Danielle A. Ambuel, BS,
Rachel M. Smith, BS, Dale Kunkel, PhD
Introduction: It is well established that children are exposed to food marketing promoting
calorically dense, low-nutrient products. Reducing exposure to obesogenic marketing presents an
opportunity to improve childrens health. The purpose of this study was to determine the extent to
which televised food advertising practices targeting children (aged r12 years) were consistent with
guidelines proposed by a coalition of federal authorities known as the Interagency Working Group
on Foods Marketed to Children (IWG).
Methods: A sample of childrens TV programming aired on ve national broadcast networks and
two cable channels (N103 shows) was recorded February to April 2013. The sample contained 354
food ads. Advertised products were identied and categorized using industry classication codes and
nutrient data obtained from manufacturers. Product compliance with IWG saturated fat, trans fat,
added sugar, and sodium guidelines was evaluated.

Results: Analyses conducted in 2013 revealed that nearly all food ads (94%) met guidelines for
trans fats; 68% and 62% met guidelines for sodium and saturated fat, respectively; and 20% complied
with added sugar guidelines. Overall, 1.4% of all child-targeted food ads met all aspects of IWG
guidelines.

Conclusions: Nearly all food advertisements exceeded guidelines for at least one recommended
nutrient to limit. Individually, conformity was high for guidelines for trans fats, moderate for
sodium and saturated fats, and poor for added sugar. These ndings suggest that child-targeted
food advertising remains strongly biased toward less healthy options. Policymakers wishing
to regulate food marketing should understand the amount and types of advertisements that
children view.
(Am J Prev Med 2015;48(6):707713) & 2015 American Journal of Preventive Medicine

Introduction

hildhood obesity continues to pose a signicant

threat to public health1 and demands appropriate intervention efforts. Reducing childrens
exposure to obesogenic food advertising could mitigate
obesity risk, such that population-wide benets to child
health may be realized. Children and adolescents see
between 4,500 and 6,000 food ads on TV each year,24 the
majority of which are for products high in sugar and fat

From the Department of Nutritional Sciences (Hingle, Ambuel, Smith),

College of Agriculture and Life Sciences, Department of Communication
(Kunkel), College of Social and Behavioral Sciences, University of Arizona,
Tucson, Arizona; and Annenberg Public Policy Center (Castonguay),
University of Pennsylvania, Philadelphia, Pennsylvania
Address correspondence to: Melanie D. Hingle, PhD, MPH, RD,
University of Arizona, College of Agriculture and Life Sciences, Department of Nutritional Sciences, 1177 E. 4th Street, Shantz Bldg, Room 328,
Tucson AZ 85721. E-mail: hinglem@u.arizona.edu.
0749-3797/$36.00
http://dx.doi.org/10.1016/j.amepre.2015.01.004

& 2015 American Journal of Preventive Medicine

and low in essential nutrients,57 and whose intake has

been associated with increased obesity risk.5,710 In the
U.S., targeted food advertising and the burden of obesity
fall disproportionately on ethnic and racial minority
children compared to white children.6,11,12 Children are
uniquely vulnerable to commercial persuasion,13,14 so it
is not surprising that child-targeted food marketing
exerts signicant inuence on product preferences,
purchases, and food consumption.10,14,15 Given this
evidence, public health ofcials have voiced signicant
concern about the need to reduce childrens exposure to
advertising for unhealthy foods.16
Over the past decade, policymakers have worked to
identify appropriate tactics to address unhealthy food
marketing to children. Congress has conducted hearings,17 the Federal Trade Commission has initiated
investigations of industry practices,18 and the food
industry has implemented the Childrens Food and
Beverage Advertising Initiative (CFBAI), a program of

 Published by Elsevier Inc.

Am J Prev Med 2015;48(6):707713

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Hingle et al / Am J Prev Med 2015;48(6):707713

voluntary self-regulation intended to improve the nutritional quality of foods marketed to children.19,20 In 2006,
a landmark IOM report called for federal regulation to
limit unhealthy food marketing to children if improvements were not achieved quickly.10
One of the most noteworthy policy developments to
occur was the emergence of a proposal from a coalition of
four U.S. governmental agenciesCDC, Department of
Agriculture, Federal Trade Commission, and the Food
and Drug Administrationwhich suggested standards
for the nutritional quality of foods advertised to children.21 The coalition, referred to as the Interagency
Working Group on Foods Marketed to Children
(IWG), issued a proposal in April 2011 containing
criteria for identifying foods with sufcient nutritional
value so as to make them acceptable to advertise to youth.
The proposed IWG guidelines specied nutrient proles
for foods that provided a meaningful contribution to a
healthy diet, while setting limits for ingredients known to
have a negative effect on health when consumed in
abundance. Products that met the rst set of guidelines
(Principle A, Foods with a Meaningful Contribution to
Diet) would be encouraged, whereas products that
exceeded the limits specied in the second set of guidelines would be avoided (Principle B, Nutrients to
Limit).16 Of particular importance from a political
perspective, the IWG proposal would be entirely advisory
and hold no force of law if adopted. Instead, it would
serve as a guide for food industry efforts to adopt a
socially responsible stance in the marketing of products
to children.
Although compliance with IWG guidelines was completely voluntary, the food industry stridently opposed
their adoption. In congressional hearings, industry ofcials testied that the guidelines would prohibit marketing of healthy foods, cost jobs because of decreased sales,
and violate the First Amendment rights of advertisers.22
News accounts documented extensive industry lobbying
efforts against the initiative.23 Those efforts proved
successful when Congress created legal obstacles that
effectively stymied approval of the proposal.24
In the absence of alternative federal policy action in
this area, the marketing of unhealthy foods to children
has persisted over many decades.7,10,25 The CFBAI selfregulatory program asserts that all products advertised to
children by its participating companies now meet
industry-based nutritional standards enacted in June
2013. However, despite modest reductions in the number
of ads for unhealthy foods viewed by children between
2007 and 2013 (particularly those promoting sweet
snacks, juice, fruit drinks, and sport drinks),4 independent analyses4,5 continue to nd that a majority of
child-targeted food commercials promote nutritionally

decient food products. This discrepancy occurs in part

because standards employed by industry for dening
healthy foods are too lenient, allowing modest reductions
in undesirable ingredients (e.g., fat, salt, sugar) to qualify
products as acceptable to market to children. A secondary factor is that not all companies that market foods to
children participate in industry self-regulation; thus,
their products are not subject to any nutritional standards at all.
Even though IWG guidelines were not adopted as
proposed, they represent a uniquely credible and legitimate metric for specifying the nutritional quality of
foods appropriate to market to children. The guidelines
were devised by the governments leading nutrition and
public health ofcials, and were developed independent
of industry inuence. Although numerous such guidelines exist worldwide,26 the IWG guidelines are the most
relevant when evaluating the nutritional quality of U.S.based food advertising.27
Thus, the purpose of this study is to ascertain the
extent to which current advertising practices, purportedly improved by industry self-regulation, are consistent
with the proposed IWG guidelines. A secondary focus of
the analysis compares the degree of compliance with the
guidelines by companies that participate in industry selfregulation, as compared to those companies that do not.
Viewing current food advertising practices through this
lens will help illuminate the degree of progress achieved
in transforming the food marketing landscape as recommended by the IOM and other public health authorities.

Methods
The study monitored food advertising that aired during a broad
range of childrens programming on the most popular broadcast
(ABC, CBS, Fox, NBC, CW) and cable channels (Cartoon
Network, Nickelodeon) in 2013. Over 10 weeks (February 1April
15, 2013), one episode of every regularly scheduled childrens
program (airing between 7:00AM and 10:00PM on a weekday or
Saturday) was recorded on each targeted channel. The nal study
sample consisted of all food and beverage commercials (n354)
observed during 103 shows across 55 hours of program content.
For each advertised product, nutrient data, including manufacturer serving size, calories per serving, macronutrients and micronutrients per serving, and ingredients by weight, were obtained
from the Nutrition Facts Panel and the ingredients list on the food
package. When necessary, researchers placed phone calls to
manufacturers to obtain information not listed on the package.
Each advertised food or beverage product was categorized as an
individual product, a mixed dish, or a meal and then grouped by
product type according to the following standard industry product
classication codes: breakfast cereals, snack foods, candy, dairy
products, baked goods, carbonated beverages, fruit juice and noncarbonated beverages, prepared foods and meals, frozen/chilled
desserts, and restaurant food. The reference amounts customarily
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Hingle et al / Am J Prev Med 2015;48(6):707713

consumed (RACC; i.e., a portion size based on the amount that the
average person would eat at once) for each product were
conrmed using guidelines established by the Food and Drug
Administration.
The nutrition criteria established by the IWG include two
Principles, A and B. Principle A identies foods that make a
meaningful contribution to the diet (dened as containing at least
50% by weight of one of the following: fruit, vegetable, whole grain,
fat-free or low-fat milk products, sh, extra lean meat or poultry,
eggs, nuts and seeds, or beans). Principle B sets guidelines for the
four target nutrients identied as having a negative impact on
health and weight: saturated fat, trans fat, added sugars, and
sodium. It was not possible to identify whether all of the advertised
products met Principle A criteria, as current labeling laws do not
oblige manufacturers to provide gram weights for each ingredient
on the label. Thus, analysis of the advertised products was
restricted to evaluating compliance with guidelines for Principle
B, Nutrients to Limit (Table 1).
Using the RACC established for each of the advertised foods,
two research team members determined whether each of the
advertised products met or exceeded Principle B guidelines for
saturated fat, trans fat, sugar, and sodium. To allow for naturally
occurring sugars, an additional 12.5 grams of sugar per RACC
were allocated for milk products, whereas products made of
100% fruit or vegetables were exempt. Further adjustments were
made for products with a small RACC (dened as r30 grams),
which included all cold cereals and the majority of candy.
In these instances, nutrient limits were calculated based on the
amount of each nutrient per 50 grams of the food and not based on
the RACC. This change was specied in the IWG proposal21
and by federal food labeling regulations regarding the use of
RACC.28
Compliance data for each advertised product were independently generated by two research team members and sent to the lead
investigator on a weekly basis between May 15, 2013, and July 31,
2013 (approximately 35 ads per week). These data included
nutrient data provided by the manufacturer, product RACC,
adjusted nutrient data per RACC, and compliance determination
for each nutrient (i.e., meeting or exceeding each nutrient
criterion). The lead investigator independently determined compliance on a subset of ads each week (between ten and 15) for
quality control purposes. Inter-rater agreement between the two

709

team members was 40.95; discrepancies between team member

compliance determinations were resolved by the lead investigator
and brought to subsequent team meetings for discussion.

Results
The majority of child-targeted food ads met guidelines
for trans fats, at 94.1% of all sampled food ads (Table 2).
Roughly two thirds of advertised products also met the
guidelines for sodium (67.8%) and saturated fats (61.6%).
By contrast, only 20.1% of the food products promoted to
children complied with the IWG guidelines for added
sugar. Viewed individually, these levels of conformity
with IWG guidelines may not seem unusually decient,
with the sole exception of the sugar standard. But in
order to achieve full compliance with IWG nutrition
guidelines, advertised products must not exceed the
specied criteria for Nutrients to Limit across all four
areas, and only 1.4% of food products advertised to
children met that threshold. Simply put, 98.6% of all
foods marketed on TV to children in 2013 failed to
comply with one or more IWG nutrition guidelines.
From a product-specic perspective, breakfast cereals
were the food type most commonly advertised to
children, accounting for more than one of every three
(36.2%) televised food ads. Although approximately 90%
of all advertised cereals complied with IWG guidelines
for saturated fats, trans fats, and sodium, none of them
met the standard for added sugar. Commercials for fast
foods/restaurants were the second most common type of
child-targeted food advertising, accounting for roughly
one of every four (26.8%) ads observed in the study. In
this category, advertised food products met the IWG
guideline for sodium only about one third of the time
(35.8%), and the guideline for saturated fats less often
than that (13.7%). As with breakfast cereals, none of the
ads for fast foods/restaurants fullled all aspects of the

Table 1. Proposed Principle B (Nutrients to Limit) Criteria for Food and Beverage Advertisements Targeting Children
Nutrients
to limit

Individual product

Mixed dish (two 40-g portions

of food)

Meal (at least three 40-g

portions of food)

Saturated fat

1 g or less of sat fat per RACC; or,

15% or less of total calories from
sat fat

1 g or less of sat fat per 100 g

mixed dish; or 10% or less of total
calories from sat fat

1 g or less of sat fat per 100 g

meal; or 10% or less of total
calories from sat fat

Trans fat

o0.05 g of trans fat per RACC; or

o0.05 g trans fat per
manufacturer-stated serving size

o0.05 g of trans fat per RACC; or

o0.05 g trans fat per
manufacturer-stated serving size

o0.05 g of trans fat per RACC; or

o0.05 g trans fat per
manufacturer-stated serving size

Sodium

210 mg or less per RACC

450 mg or less per manufacturerstated serving size

450 mg or less per manufacturerstated serving size

Added sugar

13 g or less added sugar per

manufacturer-stated serving size

13 g or less added sugar per

manufacturer-stated serving size

13 g or less added sugar per

manufacturer-stated serving size

RACC, reference amount customarily consumed.

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Hingle et al / Am J Prev Med 2015;48(6):707713

Table 2. Food and Beverage Advertisements That Complied With the Federal Interagency Working Group Principle Ba
Nutrients to limit

n (%)

Saturated
fat
n (%)

Trans fat
n (%)

Added
sugar
n (%)

Sodium
n (%)

95 (26.8)

13 (13.7)

74 (77.9)

43 (45.3)

34 (35.8)

0 (0)

128 (36.2)

117 (91.4)

128 (100)

112 (87.5)

0 (0)

Snack foods

31 (8.8)

20 (64.5)

31 (100)

20 (64.5)

0 (0)

Candy

36 (10.2)

35 (97.2)

36 (100)

0 (0)

36 (100)

0 (0)

Fruit juice/non-carbonated
beverages

12 (3.4)

12 (100)

12 (100)

5 (41.7)

12 (100)

5 (41.7)

Prepared foods and meals

23 (6.5)

2 (8.7)

23 (100)

8 (34.8)

0 (0)

0 (0)

0 (0)

1 (100)

0 (0)
0 (0)

Product classication
categories
Fast foods/restaurant food
Breakfast cereals

Frozen/chilled desserts
Dairy products
Total ads and percent of total
a

1 (0.3)

0 (0)

1 (100)

0 (0)
12 (38.7)

28 (7.9)

19 (67.9)

28 (100)

3 (10.7)

1 (89.3)

354 (100)

218 (61.6)

333 (94.1)

71 (20.1)

240 (67.8)

Overall
standards
n (%)

5 (1.4)

Principle B proposed targets for limiting the amount of sodium, saturated fat, trans fat, and added sugars in products advertised to children.

IWG guidelines. Fast and restaurant foods were also the

most likely to not meet the trans fats guideline owing to
foods fried in vegetable oil (e.g., french fries, breaded and
deep-fried meats).
There was little variation between ads from companies
that did and did not participate in industry selfregulation in terms of overall compliance. Commercials
that originated from CFBAI participants met IWG
guidelines 2% of the time (n5 of 247 cases), whereas
no ads from non-participants (n107 cases) fullled all
IWG guidelines.

Discussion
This study evaluated the nutritional content of food and
beverage advertisements on childrens TV programming
using the IWG Nutrition Principle B guidelines. Results
indicated that nearly all food and beverage advertisements targeting children exceed recommended federal
guidelines for saturated fat, trans fat, sugar, or sodium.
This nding is disappointing, though hardly surprising.
When the IWG guidelines were proposed in April 2011,
Powell et al.29 analyzed advertising data previously
collected in 2009, nding that 97.8% of the products
exceeded one or more of the four IWG-recommended
nutrients to limit. Although their analysis examined
advertising practices that had occurred prior to the
release of the IWG proposal, the current studys evaluation of 2013 advertising underscores the food industrys
persistent lack of improvement in the foods marketed to
children as recommended by federal health ofcials.

A closer examination of the individual nutrient levels

for advertised foods revealed that conformity with the
recommended guidelines was actually quite strong for
trans fats, with 94.1% of all products in compliance. This
positive nding was no doubt in part related to increased
attention to trans fat content in food, which led to explicit
mention of this nutrient required on the Nutrition Facts
Panel beginning on January 1, 2006,30 and subsequent
product reformulations. Conformity with guidelines for
sodium and saturated fats was moderate, with roughly
two thirds of advertised products in compliance for each.
In contrast, the most problematic aspect of foods
advertised to children was added sugar, with four of
every ve food and beverage products advertised on TV
to children exceeding IWG criteria for acceptable levels
of added sugar. This nding highlights the disparity
between the recommendations of federal public health
ofcials and industry self-regulatory standards established by the CFBAI, which are more lenient in the
amount of added sugar.
This pattern of obesogenic advertising has been well
documented both before8 and after31 the advent of food
industry self-regulation, which claims to limit childtargeted commercials solely to healthier products. Overall, these ndings agree with a systematic review that
found that voluntary pledges by industry were not
effective at limiting childrens exposure to unhealthy
food advertising.32
Clearly, there is need for improvement in the childtargeted food marketing landscape. In its initial report on
the topic of food marketing to youth, IOM recommended
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Hingle et al / Am J Prev Med 2015;48(6):707713

that the food industry take broad, common, and urgent

action to make substantial improvements to its childtargeted marketing.10 Should improvements not be
effective within 2 years time, IOM stipulated that
Congress should act to restrict unhealthy food advertising on broadcast and cable TV programs directed to
children. This studys ndings suggest that such regulation may already be overdue.
Absent government involvement, industry might shift
the focus of food and beverage advertisements to reect
the full range of products offered by companies, placing
special emphasis on the options that meet objective
nutrition standards. Research has already demonstrated
the efcacy of child-targeted advertising techniques, such
as the use of brand characters, celebrity endorsements,
and premium offers, at inuencing childrens food
preferences, requests, and consumption.3335 These same
persuasive tactics could certainly be used to promote
nutritious foods such as fruits, vegetables, and whole
grains.36 Industry ofcials frequently object that adoption
of nutrition guidelines such as the IWG standards would
require signicant product reformulation, resulting in
nancial hardship for companies. Refocusing efforts on
the healthiest products would not require reformulation,
potentially even beneting companies as sales increase.
Finally, conveying to stakeholders the public health
impact of childrens exposure to unhealthy food advertising is critical to raise awareness of the issue and illuminate
the need for change. In the short term, multiple factors
(e.g., reduced federal spending, industry lobbying, a
highly contentious political environment, legal protection
for commercial speech) will most likely continue to
hinder implementation of bans on food advertising
targeting children. However, in the longer term, the
evidence base will continue to grow, providing policymakers with more ammunition from which to determine the best approach. In the interim, there are several
compelling simulation analyses modeling degrees of food
advertising restriction to children in relation to obesity.
Chou and colleagues37 estimated the effects of banning all
televised food and beverage advertisements on childhood
obesity prevalence as an 18% reduction in the number of
overweight children (aged 311 years). Analyses by
Veerman et al.38 suggested that an absence of TV food
advertising would lead to a 2.5% reduction in obesity
prevalence. Finally, a microsimulation analysis conducted
by Kristensen and colleagues,39 which estimated the
effects of a ban focused on limited fast food marketing
to children, suggested that a 1% reduction in obesity
prevalence would be achieved by children and adolescents. Collectively, these data suggest that even a modest
reduction in the volume of unhealthy food ads viewed by
children could yield signicant public health benets.
June 2015

711

This study was strengthened by the use of an objective,

evidence-based nutrient prole model developed by a
coalition of public health experts, to determine compliance of food advertisements targeting children with
public health nutrition guidelines. This study also had
several limitations. We were unable to determine compliance of advertised foods and beverages with Principle
A, which prevented acknowledgment of whether and the
extent to which products could meaningfully contribute
to childrens diets. Further, the study sample was
obtained from advertising typically aired during childrens programming. We did not include food and
beverage advertising during other programming,
although these networks have signicant numbers of
child viewers. Finally, our sample was limited to TVbased food and beverage advertising during the spring of
2013. Although TV remains the most popular form of
media, children are increasingly migrating to digital
media for much of their information and entertainment,
and notably, food and beverage advertising is also
increasingly found in this digital landscape.40

Conclusions
Application of the IWG guidelines to food and beverage
advertising aired during childrens TV programming
indicated that industry attempts at self-regulation have
been unsuccessful at minimizing childrens exposure to
advertising of unhealthy products. Child-targeted food
advertising remains dominated by products high in
nutrients believed to have negative impacts on childrens
weight and health. Policymakers who wish to enact
regulation or legislation to govern the food industrys
child-targeted marketing practices should have a clear
understanding of the amount and types of advertisements children view.
This research was supported by a grant from the Healthy
Eating Research program of the Robert Wood Johnson
Foundation. The Robert Wood Johnson Foundation did not
manage the study design; collection, analysis, and interpretation of data; writing of the report; or the decision to submit the
manuscript for publication. The authors report no conicts of
interest.
No nancial disclosures were reported by the authors of
this paper.

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