1. family and parenting
2. children

Food Fables
- the second sitting
The truth behind how food
companies target children
MAKING THE HEALTHY
CHOICE THE EASY CHOICE
Which? wants to see the healthy choice become the easy choice for UK consumers.
Consumers want clear, easy to understand information about what makes a healthy diet,
and to be able to distinguish between healthier and less healthy products. They do not
want to be conned into buying products that are misleadingly presented as healthy and
they don't want to see pressure put on children to choose less healthy foods, making it
so much harder for parents to encourage their children to eat well balanced diets.
Our research shows that, despite supporting social responsibility, many companies
are still putting their efforts into heavily promoting less healthy products whether its
through cartoon characters aimed directly at children or the health claims and confusing
labelling aimed at reassuring or bamboozling their parents. This isn't good enough.
Which? wants to see responsible food companies using their creativity to help their
customers to make healthy lifestyle choices. We're not against treats and we aren’t
against marketing, but we are against irresponsible company practices and hollow
company commitments.
We’d love to see the need for regulation erased because all food companies had
cleaned up their act. We want to see all food companies using their ingenuity and
expertise to develop and market healthier options, supported and prompted by a
government that acts on its committment to tackle obesity.
WHY MARKETING LESS HEALTHY FOODS TO CHILDREN MUST STOP
Diet and Obesity Crisis
If current trends continue, it’s predicted
that 70 per cent of girls and 55 per cent
of boys will be overweight or obese by
2050, and that obesity will cost the
economy over £45 billion.1
Poor Quality Choices
The Food Standards Agency’s
National Diet and Nutrition Survey2
has highlighted that children eat too
much fat, sugar and salt and not enough
fruit and vegetables. Obesity is the
consequence of energy imbalance – too
many children are consuming more
calories than they use up with exercise.
Limiting foods high in fat and sugar,
particularly those that are highly
processed and contribute little
nutritional value, is critical in helping to
redress this imbalance and to reduce the
incidence of other diet-related disease.
‘Less healthy’ Ads Dominate
Which? research3 has highlighted the
wide range of promotional techniques
that are used to target fatty, sugary and
salty foods at children and the scarcity of
healthier promotions in comparison.
2 Food Fables-the second sitting
Ads Influence Kids
Four key reviews4 have all concluded that
food advertising and promotion
influences children’s food preferences
and food choices.
Parents Want Change
Which? research5 has shown
frustration by parents, and public
support for more action from
government and food companies.
In February 2008, a Which? survey
found that 88 per cent of consumers
think food companies need to be
more responsible in the way they
market food to children and that
84 per cent of consumers think the
government needs to do more to
control the way less healthy foods are
marketed to children.6
SUMMARY
Leading food companies in the UK are still not doing enough to curb their marketing of
less healthy food to children. Since our Food Fables report in 2006, stricter TV advertising
regulations have come into force but these are failing to stop children being exposed to less
healthy food advertising. There have been improvements. Many companies have stopped
targeting young children, and Kentucky Fried Chicken (KFC) and Weetabix stand out for taking a
more responsible approach. But our review of food marketing practices in the first six months of
2008 found that while most of the leading food companies now have impressive sounding
policies on marketing to children, they still leave plenty of scope for less healthy promotions.
Many are still reliant on traditional marketing techniques such as competitions and cartoon
characters on packaging. Others have shifted their focus to the teen market, using increasingly
diverse and often underhand ways to promote less healthy products to children using new media
such as websites and mobiles, in a way that parents are unlikely to be aware of.
All of this is in spite of spiralling child obesity rates and diet-related health problems.
Over 30 per cent of 2 to 15 year old boys and over 28 per cent of 2 to 15 year old girls are
already obese or overweight and predictions suggest this will rise dramatically.7
Which? wants to see an end to the marketing of foods high in fat, sugar and/or salt to
children as part of a broader strategy to tackle poor diets. Promoting food to children
influences what they choose to eat and current promotions are dominated by sugary breakfast
cereals, soft drinks, confectionery and savoury snacks. If we’re to help young people to eat more
healthily, it’s vital that we reduce their exposure to the marketing of less healthy foods.
A new Which? survey shows that the public wants change. 88 per cent of people think that
food companies need to be more responsible in the way that they market food to children.8
OUR RESEARCH
his report revisits the Which? Food Fables report
of November 2006.9 We have reviewed the
marketing tactics some of the leading food companies
use to target children with foods high in fat, sugar
and/or salt and how this has changed since
our last report.
We have also looked at company marketing policies to see if they
go far enough. We have drawn conclusions on the performance of
the food companies overall and made recommendations for the
action that needs to be taken by industry and government. We
have also highlighted specific areas that we think individual
companies could be focusing on in the meantime in order to be
more responsible. From January to June 2008 we looked at
T
company websites, packaging, advertising and other promotions.
From 31 March to 13 April 2008 we analysed TV viewing data10
to assess which foods were being advertised in different regions by
which companies when most children were watching the main
commercial TV channels.
We used the Food Standards Agency’s nutrient profiling scheme11
to assess the healthiness of products promoted by the companies.
Only products that were assessed to be ‘less healthy’ (ie. high in
fat, sugar and/or salt) have been used as examples in this report.
Throughout the report, we define a child as someone under 16.
‘Younger children’ are aged up to 11 and ‘older children’ are
12 to 15. Company policies have been edited, but we have
included all key aspects relevant to marketing of food to children.
Food Fables-the second sitting 3
WHERE ARE WE NOW?
80%
think TV ads for
unhealthy foods
shouldn’t be allowed
when kids are
watching in the
greatest numbers
4 Food Fables-the second sitting
here has been a lot of debate
about food marketing controls
since our first Food Fables
report. But there is currently
very little regulation
regarding the advertising and promotion
of food to children. While Ofcom, the
government communications regulator,
has introduced rules for TV ads,12 these are
too limited and other forms of marketing
are largely controlled by patchy self
regulation and company policies.
T
TV TIMINGS
Since January 2008 advertising of ‘less
healthy’ foods13 to children during
programmes ‘of particular appeal to under
16s’ has been restricted on terrestrial TV
channels. Digital children’s channels will
have to implement the new rules by
1 January 2009. The new rules are a
positive first step, but they are ineffective in
limiting the advertising of less healthy
foods when most children are watching
TV.14 This is because the restrictions are
determined not by the total number of
children watching, but by the proportion.
So if a programme is watched by 20 per
cent more under 16s than the general
viewing population, restrictions apply. On
the other hand, even if a huge number of
children are watching a show, if there’s also
a large number of adults watching,
restrictions don’t apply.
A self-regulatory code (Broadcast
Committee of Advertising Practice – BCAP)
restricts the actual content of TV adverts
targeted at children. It was strengthened in
2007 but the effect has been limited, and it
needs to go further. The Code contains
some restrictions on promoting foods high
in fat, sugar and/or salt such as the use
of celebrities or licensed cartoon characters,
but only for pre or primary school children.
Companies’ own cartoon characters, such
as Kellogg’s Tony the Tiger and Nestlé’s
Quicky the Nesquik Bunny, are not
restricted at all. The more general
requirements relating to children are also
vague and open to interpretation.
PUSHY PROMOTIONS
The majority of non-broadcast promotions,
such as press and billboard ads, online
advertising and promotional offers, fall
under the self-regulatory control of the
Advertising Standards Authority. The
content of this marketing is judged against
the CAP (Committee of Advertising
Practice)15 code, which is in most parts the
same as the BCAP, except that it doesn’t
even recognise that there are foods high in
fat, sugar and salt, only differentiating fresh
fruit and vegetables. Again specific
restrictions only apply to pre and primary
school children and these are limited in
scope (as with the BCAP, company cartoon
characters are permitted for children of
all ages).
Company and branded websites are free
to run any content, such as games and
promotions appealing to children, because
they are classified as editorial content. The
UK advertisers’ body ISBA introduced a
voluntary content code in 2007 but it is
similar to the CAP code16, and therefore has
similar inadequacies. Other forms of
marketing to children, such as food and
drink packaging, in-store promotions and
sponsorship are not covered by these codes
at all.
INDUSTRY IMPROVEMENTS
Leading food companies are beginning to
acknowledge the adverse effect
irresponsible marketing can have on food
preferences, or at least the pressure to act
more responsibly. Many have started to
clean up their act and reduce blatant
promotions to young children. A signal of
this shift was a pledge from 11 leading food
companies at the end of 2007 to ‘change
food and beverage advertising on TV, print
and internet to children under the age of 12
in the European Union’.17 However, this
initiative doesn’t go far enough as it doesn’t
cover under 16s, and only covers younger
children where they make up at least
50 per cent of the audience. The criteria for
distinguishing healthier and less healthier
foods have yet to be published.
Our review of individual company policies
has shown some improvement in
self-imposed restrictions on advertising and
promotion to young children, but we found,
they fall short of what we think is needed to
help improve children’s diets.
GOVERNMENT GESTURES
●
The government has started to take
action but isn’t going far enough, fast
enough. The UK-wide communications
regulator, Ofcom, was instructed to look
at tightening TV advertising of food to
children. This led to restrictions
introduced in 2007 but they are limited
in scope. A Food and Drink Advertising
and Promotion Forum was set up
following the publication of the
Choosing Health White Paper in 200418
and the subsequent Food and Nutrition
Action Plan for England.19 It was
supposed to tackle other forms of
marketing to children but has made
little progress and there haven’t been
any other government initiatives
looking at these broader areas
anywhere else in the UK.
● In January 2008, an Obesity Strategy
for England20 was published, reiterating
the actions needed. It also announced
bringing forward a review of the new
Ofcom restrictions on TV advertising,
and the intention to review the
effectiveness of all the advertising
content codes, with respect to children.
The new strategy also announced that a
Healthy Code of Good Practice would be
developed with the food and drink
industry. The aim of the code would
be to challenge the whole industry to
reduce consumption of saturated fat,
sugar and salt. Companies are
encouraged to take a voluntary
approach, but the government will
‘continue to examine the case for a
mandatory approach where this
might produce greater benefits,
particularly for children’s health.’
Food Fables-the second sitting 5
WHAT WE’VE UNCOVERED
ur research has highlighted
that food companies are still
using tried and tested tactics
to promote less healthy foods
to children and has
uncovered new trends in the ways
companies, advertisers and marketing
managers do this.
O
88%
think that food companies
need to be more
responsible in the way
they market food
to children
6 Food Fables-the second sitting
TARGETING TEENS
In response to public concern and consumer
campaigning, marketing of less healthy
foods to very young and primary school age
children is starting to be viewed as
increasingly unacceptable in the food
industry. But we’ve noted a shift among
several of the big companies towards the
teen market and young adults, for example,
by using social networking sites.
ONLINE OFFERS
We found a reduction in some companysponsored website content, including games
and downloads, aimed at young children
(for example, Kellogg’s Frosties and Coco
Pops sites and Nestlé’s site Fantasy World of
Fun have all been closed down). But several
companies have developed more
sophisticated brand sites, often tying in with
promotions and linking up with popular
sites such as video site YouTube, and social
networking sites Bebo, MySpace and
Facebook. A recent Ofcom report21 found
that social networking sites are most
common among children and young people.
Nearly half (49 per cent) of children (aged
eight to 17) have a profile on a social
networking site. Young people are also
exposed to online advertising. The recent
Fanta ‘Want it, Win it’ promotion, and the
MAOAM Dance Mayhem promotion, were
advertised on the under-18s clubbing
site Clubdtv.
Age restrictions are being applied on some
websites. To enter or get involved with many
you have to enter a date of birth, but with
most of those we tested it was easy to go
back and change your date of birth if you
were denied access. Coke Zone and the
M&Ms website make this more difficult
(by using cookies, a technical way for a
website to remember what you’ve done).
GOING GLOBAL
While several brands are reducing their
unsuitable child-focused website content in
the UK, their US and international sites can
still feature games and downloads. Because
the web is worldwide, access to these
websites can’t be restricted unless
companies start applying strict global
policies, and in some cases international
brands, such as M&Ms promote the same
web address in many countries. Several of
the most popular children’s websites in the
UK 22 are American, and carry ads to other
US websites.
manufacturers. A code taken from a pack is
texted to collect points (which can then be
used for rewards – such as Coke Zone), or to
enter a competition, such as Fanta’s ‘Want it,
Win it’. In this example a Fanta-branded
mobile phone game was sent to all entrants,
via a WAP push (WAP enables access to the
internet from a mobile phone). Companies
are also encouraging texting of a number to
receive a free ring tone (such as Kellogg’s
zookeeper competition and Dr Pepper’s
‘What’s the worst that could happen?’
promotion). When entering a promotion via
mobile phone it’s harder to apply age
restrictions than on the web.
Age restrictions on the
Coke Zone website
VIRAL VILLAINS
Viral marketing and viral advertising refer to
marketing techniques that use social
networks to increase brand awareness. Viral
promotions may be a video clip, an
interactive game, images or even text
messages. The key to a successful campaign
is to produce something that people want to
pass on to their friends. Advertising agency
Mother recently won an industry award23
for a viral video campaign run in 2007 for
Coca-Cola to promote its ‘Buy a Player’
campaign. Viral marketing can also be used
in a positive way – ‘Snack Dash’24, a healthy
eating game developed for the government’s
School Food Trust was the fastest growing
and highest traffic-generating viral ever
tracked by the Viral Chart.25
MOBILE MARKETING
Mobile phones are being used for
promotions, especially by soft drink
Fanta branded
mobile phone
game
CATCHY CHARACTERS
Licensed characters (such as Kung Fu
Panda, SpongeBob SquarePants and
Scooby-Doo!) are still being used on food
packaging to promote predominantly less
healthy foods to children. Tie-ins linked to
cinema and DVD releases are continuing at
Burger King and McDonald’s with free toy
promotions in children’s meals. Toys based
on The Spiderwick Chronicles, SpongeBob
SquarePants – Pest of the West and Indiana
Jones and the Kingdom of the Crystal Skull
have already featured in 2008. McDonald’s
also recently developed its own ‘Fairies and
Dragons’ characters. This was supported by
a sophisticated website, promoted on the
main McDonald’s website which included
games and puzzles. Film tie-ins were also
found on several Nestlé products. However,
Food Fables-the second sitting 7
since our review of the use of cartoons in
food marketing in 200726 we’ve noted a
reduction in the use of licensed characters by
the leading food companies. Some
companies are concentrating on using their
own characters as a shortcut to brand
recognition for young children.
TV TACTICS
We now have some TV advertising
restrictions and they do aim to protect
children under 16 and distinguish healthier
and less healthy foods. However our analysis
has repeatedly shown that the rules don’t
protect children when most are watching it.
Family-viewing programmes with large
audiences, such as Dancing on Ice, and
Coronation Street are often watched by more
children than a programme like The
Simpsons, but aren’t covered by the rules
because many adults are watching as well as
many children. Manufacturers of foods high
in fat, sugar and/or salt may no longer be
advertising during children’s programmes,
but they are still advertising their products
on TV when most children are
watching.27 During the two week
period we examined we found that 16
of the top 20 programmes showing
84%
think the Government
needs to do more to
control how foods are
marketed to children
8 Food Fables-the second sitting
ads that were watched by the highest
numbers of children weren’t affected by
the restrictions.28 In previous analysis
periods we have found that as few as one
programme in the top 20 programmes
watched by children was covered by
the restrictions29.
SPORTY SCHEMES
Several food companies are keen to promote
physical activity in an attempt to highlight
the other side of the energy balance
equation so critical in obesity. We found
several on-pack offers and promotions that
focus on sport. This usually involves taking
sweet packets to get a free swim, dance
session or badminton game, for example.
Several companies associated with foods
high in fat, sugar and/or salt also sponsor
youth sport. McDonald’s sponsors children’s
community football across the UK. Together
with the Amateur Swimming Association
(ASA) Kellogg’s is a long-term sponsor of the
community ‘Swim Active’ scheme which aims
to increase access to swimming across the
UK and the ASA Awards scheme. The Awards
used to be sponsored by Tony the Tiger but
the branding has changed
to the more neutral
Kellogg’s. In a similar
move, Coca-Cola has
changed the branding
of the sponsorship of
the ‘Coca-Cola
English Schools Cup’
to the ‘Minute Maid
Schools Cup’.
However a similar
competition in Scotland is
still known as the ‘Coca-Cola 7s’. Coca-Cola
and Pepsi have both run high
profile marketing campaigns featuring
footballers such as Wayne Rooney and David
Beckham. Which? research has found that
three in four parents (77 per cent) think
‘celebrities should take more responsibility for
the food they promote to children’.30
LOUSY LABELLING
The packaging of many products marketed to
children emphasises positive aspects. Vitamin
and mineral contents are highlighted and
there are suggestions that a food is ‘natural’,
or ‘contains fruit juice’ when the majority of
the sugar will be added sugar. In some cases
products with these claims didn’t carry full
nutrition information, so parents wouldn’t be
able to check the level of sugars, saturates or
salt (such as Nestlé’s Milkybar and
Rowntree’s Fruit Pastilles). None of the
packaging used the easy-to-understand
traffic light system of labelling.31 Which? has
consistently called for this system which is
colour-coded and based on values per 100g.
Research by Which? and others have
found that it’s the easiest for consumers
to understand.32
The industry favours percentage Guideline
Daily Amounts (GDA) and several companies
have voluntarily displayed percentage GDAs
on the front of packs, but
there are major
inconsistencies with this.
Some listed
values as percentage of a
five to ten year old child’s
GDA (Rowntree’s Jelly
Tots and Fruit Pastilles),
while others gave the
percentage
of an adult’s GDA
(Bassetts Jelly Babies
Minis and Milky Way). Some of the serving
sizes companies used seemed misleading.
Jelly Babies Minis and Dairy Milk Buttons
were labelled with percentage GDA for just a
single sweet rather than the whole small bag
which is unlikely to reflect the amount
usually eaten. Some 500ml bottles of soft
drinks are also labelled as having 2x250ml
servings, so a 500ml bottle of Coke is
labelled as 29 per cent sugar of an adult
GDA, but if the whole bottle were drunk it
would be 58 per cent.
Nestlé Fruit pastilles only
show 4 nutrients
DODGY DISCLAIMERS
We found the packaging of snack foods, in
addition to TV ads for Kellogg’s, suggesting to
consumers that the product can ‘be enjoyed
as part of a healthy, balanced diet’, together
with an ‘active lifestyle’. It is unclear what this
disclaimer is expected to convey and it seems
meaningless when put on foods high in fat,
sugar and/or salt. In some cases there is a
contradiction between this statement and
how a product is marketed. For example
Kellogg’s has recently promoted Coco Pops as
an after-school snack – therefore suggesting
children eat this high sugar breakfast cereal
more regularly.
Food Fables-the second sitting 9
THE 12 COMPANIES
BURGER KING
WHAT’S IN THE PRODUCTS?
The Kids’ Menu at Burger King includes hamburgers, cheeseburgers, Angus
mini-burgers, chicken fillet strips and fries. If a child chooses the cheeseburger,
regular fries and a small chocolate milkshake, they’ll be consuming a significant
29g fat, 13g saturates and 27g sugars. Healthier options include chicken bites, a
grape and apple ‘grapple bag’, water and milk.
We liked: Burger King has removed child-focused content from its
website and doesn’t use the site to promote the free gift offer available
with the Kids’ Menu.
We didn’t like: The Kids’ Menu, which includes less healthy
options, is still promoted with free gift giveaways both in store and in
large store window posters (visible from the street).
!
They need to: Stop marketing less healthy options on its Kids’
Menu with free toys. Extend the policy to protect under 16s from less
healthy promotions, based on FSA criteria for what is ‘less healthy.’
Free toys
are still given away
with kids’ meals
10 Food Fables-the second sitting
WHAT THEY SAY
WHAT WE FOUND
l “In
Fun Freebies
Free toys are still given away with kids’
meals. Most recently, these have
included characters from SpongeBob
SquarePants – Pest of the West, Fantastic
4: Rise of the Silver Surfer and Indiana
Jones and the Kingdom of the Crystal
Skull of which there were eight different
toys in the set to collect.
November 2006, we were one of the
first amongst our competitors to take the
voluntary step to stop all TV advertising to
children in the UK and then chose to remove
all kids’ content from our Burger King UK
website in June 2007.
l In November 2007, we were also one of
ten companies to sign up to the EU Pledge
on Children’s Advertising, further committing
to restrict 100 per cent of print and online
advertising directed to children under 12
years old to Kids’ Meals that meet the
Burger King nutrition criteria.
lThese moves were not commercial
decisions. We are committed to responsible
marketing and felt that a change in our
marketing strategy to children was right for
both our company and our customers. As
such all advertising and marketing is
squarely aimed at our adult audience.
CADBURY PLC
WHAT’S IN THE PRODUCTS?
Cadbury produces chocolates that particularly appeal to children, such as Dairy
Milk Buttons, Curlywurly and Fudge, as well as products such as Crunchie and
Dairy Milk. These are high in sugar, fat and saturates. Other popular
Cadbury-owned brands include Bassetts Jelly Babies Minis (74.6g sugar per
100g) and Maynards Wine Gums (55.6g sugar per 100g).
We liked: They have now withdrawn their teaching packs aimed
at primary schools.
We didn’t like: There hasn’t been much change since 2006.
Cadbury still has content for children on its main website and is
marketing Creme Egg on Bebo.
!
They need to: Extend their global marketing code so that they
don’t promote foods high in fat, sugar and/or salt to under 16s.
WHAT THEY SAY
“We drafted our Global Marketing Code in
2004. Under this Code we are committed:
● Not to advertise to children under the age
of 8 where they constitute the majority of
the audience.
● Impose restrictions when advertising to
children under the age of 12 (e.g. use of
celebrities and characters, pester power,
encouragement of irresponsible
consumption, respect of the role of parents).
● Take into account locally applicable
standards and requirements.
● Our Global Code applies not only to
television and radio, but to outdoor,
in-store and the growing new media. In
2006 we strengthened the Code’s
application in this respect, to better address
the Internet, SMS and other electronic
marketing channels.”
Cadbury was advertising
WHAT WE FOUND
during programmes
Wayward Websites
Fudge bar packaging promotes
www.cadbury-land.co.uk which takes
you to the main Cadbury site
(www.cadbury.co.uk), which includes
links to games and competitions.
watched by the
highest
numbers of children
Cadbury’s ‘Chocolate Machine’
on line game
Food Fables-the second sitting 11
Web TV Tactics
Cadbury Creme Eggs were embedded
into the script of popular Bebo soap
KateModern to launch the second phase
of the ‘Here today, Goo tomorrow’
campaign in February 2008.
KateModern is an online drama which
received 1.5 million weekly views for its
first series.33
Classroom Choc-packs
Cadbury produced two branded teaching
packs for schools, including the ‘Mixing,
Melting and Making Pack’, which is
aimed at Key Stage 1 (primary schools).
These chocolate-focused packs were
obtained via the Cadbury website
(www.cadbury.co.uk) early in our
research period. Cadbury have since
informed us that they have
withdrawn the teaching packs
aimed at primary schools, and
links to them have been removed
from their website. They are now
focusing on www.skillsspace.co.uk,
an educational site for children at
Key Stages 3 and 4.
TV Timing
During our analysis of TV advertising,
Cadbury was found to be advertising
Cadbury Flake, Cadbury Dairy Milk and
Maynards Wine Gums among
programmes watched by the highest
numbers of children. The Wine Gums
ad, ‘Set the Joose Loose’, for example,
featured a comical dancing Scotsman.
COCA-COLA
WHAT THEY SAY
WHAT’S IN THE PRODUCTS?
Coca-Cola brands include high sugar fizzy drinks such as Coke,
Fanta, Sprite and Dr Pepper. There are 13.25 teaspoons of
sugar in a 500ml bottle of Coke. Regular Capri-Sun, a drink
sold in pouches and targeted at children, contains fruit juice
from concentrate (12 per cent) but contains 10.5g of sugar
per 100ml. Low and no added sugar varieties, as well as
100 per cent fruit juices, are also available from Coca-Cola.
We liked: Even where promotions ran across all
brands, sugar-free versions were the main focus for
marketing. The name of the sponsored community
football scheme was changed from Coca-Cola to the
‘Minute Maid Schools’ Cup’.
We didn’t like: Despite what their policy says about not using celebrities
with strong appeal to under 16s, we found promotions for high sugar
products featuring footballer Wayne Rooney. They are still using the CocaCola brand in the sponsorship of the school football tournament in Scotland
(Coca-Cola-7s). The Capri-Sun website has games targeted at children.
!
They need to: Extend marketing restrictions to under 16s,
distinguishing healthier from less healthy products.
12 Food Fables-the second sitting
“We welcome the clarification that
Ofcom and the Advertising
Standards Authority’s Committee
on Advertising Practice have
recently provided regarding
restrictions on advertising of food
and drink products to children on
TV and within the non-broadcast
environment.We ensure that we
adhere to these new restrictions at
all times. In practice this means that:
● We do not advertise any of our
drinks on children’s TV channels,
such as Nickelodeon or CITV.
● We do not advertise any of our
drinks during TV programmes whose
audience predominantly consists of under
16s, or that are likely to be of particular
appeal to children under 16.
● We do not use celebrity or personality
endorsements or licensed characters (e.g.
animated cartoon characters) within any of
our marketing which might have strong
appeal to children under 16.
● Our
media use is audited externally and
independently to ensure compliance with
these commitments.
● In addition we’ve been listening to
parents’ concerns about advances in online
marketing and have updated our marketing
to children commitment as a result.
● We work in partnership with specialist
agencies, internet marketing regulatory
bodies and the Internet Advertising Bureau
to ensure that our online marketing adheres
consistently with our commitments.
● We do not have a presence in primary
schools and we are only in secondary
schools where we are invited.”
WHAT WE FOUND
Crafty Competitions
‘Find the next Rooney for your club’ was
advertised on pack and online. To enter,
codes from Coke drinks were submitted
(age limit 12 and over). Coke Zero
(sugar free) was the main brand used,
but the offer was on all Coke packaging.
Fanta launched an on-pack and website
promotion ‘Want it, Win it’ in March
2008 with prizes of cameras, MP3
players, games, DVDs and CDs. Codes
There are
over13
teaspoons of sugar
in a 500ml bottle
of Coke
from bottles or cans were entered via the
website or by text and it was promoted
on Bebo. Capri-Sun ran ‘Win CapriStunts’, where children (12 and
over) could enter codes
online from pouches of
Capri-Sun for a chance to
win a stunt experience, such
as ‘Be a human bowling ball’.
Loyalty Launch
£5m was spent launching
the new Coke Zone loyalty
scheme in April 2008. Codes
on all Coke products could be
entered via text or the
website to gain you points for
every Coke you drink. These
points could be spent on
‘rewards’ such as free gifts
relating to sport, music, fashion etc. The
age limit was 12 and over and the site
applied an effective method of stopping
those denied access because they were
under age from going back to change
their date of birth. But it was still
accessible for older children.
Wayward Websites
The main Coca-Cola website www.cocacola.co.uk promoted on packs will appeal
to older children. It has competitions,
Coca-Cola graphics which can be created
and then downloaded or emailed to
friends, downloads (wallpaper,
screensavers and chat icons) and
Coca-Cola TV ads to watch again.
The ‘Want it, Win it’ competition saw the
launch of a slick teen website for Fanta
(www.fanta.co.uk), and includes games,
downloads, and video content linked to
YouTube. The competition and new
website were promoted in online
advertising. TV advertising of the site
focused on gaming content, and
encouraged you to ‘challenge a friend’.
Capri-Sun packaging promotes
www.capri-sun.co.uk ‘For tons of fun &
games’. The site included several games
and encourages users to add them to their
profile pages on other sites and blogs.
Mobile marketing
The Fanta ‘Want it, Win it’ promotion
encouraged entries via mobile phone. A
free Fanta-branded mobile game was
sent back to anyone who entered
the competition the first time (via
a WAP push to their mobile).
Sports Sponsorship
Coca-Cola sponsors the main
school football tournament in
Scotland, and it is branded as
‘Coca-Cola 7s’. It also has a
strong sponsorship presence at
many major sporting events
popular with children. The
English Football League is
known as the ‘Coca-Cola
Football League’. Coca-Cola was
a sponsor of the 2008 UEFA
European Championship, and will be a
sponsor of the 2008 Olympics in Beijing
and the 2012 Olympics in London.
Celebrity Sell
Top footballer Wayne Rooney who has
broad child-appeal has been used in
several Coca-Cola ads and promotions.
TV Timing
During our analysis of TV advertising,
Coca-Cola was found to be advertising
regular Coke among some of the top 20
programmes watched by the highest
numbers of children. The ad included
a promotion for the Coke Zone
reward scheme.
Treat Trips
Capri-Sun had 2 for 1 vouchers to
family attractions such as Alton Towers,
Thorpe Park and Legoland on
ten-pack boxes.
Catchy Characters
Four animated characters (Todd, Merv,
Winnie and Marco) feature on Fanta
packaging, the website and TV ads.
Gimmicky Giveaways
We found Dr Pepper was giving away
free ringtones (‘20 to collect’) if the
code from the pack was texted or
entered online (you need to be 12
or over).
Food Fables-the second sitting 13
HARIBO DUNHILLS
WHAT’S IN THE PRODUCTS?
Haribo gums and jellies such as Starmix and Tangfastics are high in sugar.
Haribo also produce and promote MAOAM chews.
We liked: There was some reduction in the child-focused
content of the Haribo website.
We didn’t like: Use of competitions, DVD promotions and
the use of Haribo cartoon characters Hariboy and Gold-Bear on
packs and the website.
!
They need to: Stop the heavy promotion of sugary snacks to
children, including younger children, through cartoons,
competitions and websites.
WHAT THEY SAY
● “HARIBO
products are not only enjoyed
by children, but by people of all ages.
HARIBO is a fun product and brand and of
course our marketing activities to all
age-groups reflect this, however always in
a responsible manner.
● We do not position our products as
anything other than an enjoyable
treat – they are not meal substitutes. They
should be consumed in moderation, as part
of an active and healthy balanced lifestyle.
● HARIBO UK has not advertised in or
around programmes aimed at children
under 16 since the beginning of 2007.
This measure was taken in advance of the
Ofcom regulations coming into force.”
WHAT WE FOUND
Wayward Websites
The Haribo website has reduced the
child-centred content (for example,
games and screensavers have been
removed). But in April 2008 we found
an Alvin and the Chipmunks DVD release
promoted with a competition
on the site.
Crafty Competitions
Haribo regularly runs competitions
aimed at children. In May 2008 the
Haribo website launched a competition
14 Food Fables-the second sitting
to ‘run the Haribo factory and become a
sweet taster’. Entrants needed to be 14
or under. Winners toured the sweet
factory together with ‘Same Difference,’
an act from the X Factor TV show.
MAOAM ran several activity-based
competitions, including Dance Mayhem,
the ‘UK’s biggest under 18 freestyle
dance competition’. It was promoted in
teen magazine Mizz (www.mizz.com),
and on under 18s clubbing site Clubdtv
(www.clubdtvshop.com). Young people
were encouraged to upload their video
onto the site and it gave the chance to
get two dance lessons for the price of
one. Together with Kerrang Radio, the
MAOAM Kerrang Skate Jam competition
to win a years supply of MAOAM sweets,
as well as a professional skateboarding
lesson and kit, encouraged people to
upload videos of their skateboarding
skills. It was restricted to under 25s.
Catchy Characters
Haribo cartoon character Hariboy was
promoted on packs and on the website.
Candy Club
Children can join the Haribo club to
receive free sweets and newsletters.
The club is promoted on packs and from
the website homepage, and boasts over
9,000 club members.
KELLOGG’S
Ricicles, Frosties and Coco
WHAT’S IN THE PRODUCTS?
Many Kellogg’s cereals, particularly those aimed at children, are high in sugar,
including Ricicles (37g sugar per 100g), Frosties (37g sugar per 100g), and
Coco Pops (34g sugar per 100g) – all at least a third sugar. Products intended
for kids’ lunchboxes and snacks such as Coco Pops Cereal & Milk Bars and Rice
Krispies Squares, are high in sugar as well as saturated fats.
We liked: They’ve removed several child-focused websites.
We didn’t like: The continued use of cartoon characters in the
marketing of less healthy cereals on packaging and in TV ads.
!
They need to: Restrict marketing promotions to healthier
products based on FSA criteria, and extend restrictions to under 16s.
Stop using characters such as Tony the Tiger and Coco the Monkey to
promote high sugar cereals.
Pops are all at least
one third sugar
lThere are no ‘tell a friend’ functions
on our website and children do not receive
correspondence from us.
lBy the end of this year we will have invested
£3million with the ASA to get people across the
UK swimming as part of a balanced lifestyle
lWe currently meet all the EU pledge
commitments but, in addition, we will no longer
advertise during children’s airtime by the end
of 2008.
lWe do not advertise on children’s websites.
lWe have been dedicating 1/3 of the back of
many packs to healthy lifestyles since 2004. Our
packs are widely read and this links well with the
new lifestyle promotions.”
WHAT WE FOUND
WHAT THEY SAY
● “In June 2007 we announced the Kellogg’s
global commitment to responsible marketing to
children was to be further strengthened. We
changed what and how we market to children
under 12 using science-based Kellogg Global
Nutrient Criteria. This commitment is in
addition to our existing global code of not
advertising to children under six.
● We do not target any advertising at children
under six years of age.
● We do not produce educational material
for schools.
● We do not advertise to children under 12
years if the product does not meet strict criteria
for calories, salt, saturated fat and sugar content.
● We have moved more advertising to times
when parents watch. Since 2003 we have
shifted 80 per cent of Coco Pops spend outside
children’s airtime and this will be 100 per
cent by the end of 2008.
● We have changed the nature of our
advertisements and designed them to appeal
to famlies and mums rather than just children.
● We do not run promotions designed to
appeal to children. In 2005 we had six
third-party licensed character promotions.
In 2008 there will be zero.
● We no longer use licensed characters on
our packaging.
● All promotions are now provided across a
range of products to enable mums to choose
the food they want for their children.
● We do not advertise in children’s magazines
or comics.
● All gaming has been removed from Kellogg
UK websites.
Catchy Characters
Tony the Tiger (Frosties) and Coco the
Monkey (Coco Pops) regularly appear in
TV ads and on packaging for sugary cereals.
Gimmicky Giveaways
Cereal packets promoted various offers,
some combined with competitions including
vouchers for free entry to a zoo.
Wayward Websites
Kellogg’s has reduced child-focused content
(such as games) online. But more
sophisticated campaign support sites have
been developed. ‘Win a Day as a Zookeeper’
is promoted with a ‘zoo academy’ quiz and
lots of animal-focused content.
Food Fables-the second sitting 15
Tiger making appearances at pools and on
certificates. Now the branding has changed
to the more neutral ‘Kellogg’s’, but Tony the
Tiger still features on several ASA products,
such as armbands.
Mixed Messages
Packets of high sugar cereals included
tokens for a free cyclometer and vouchers
for a free swim.
Sports Sponsorship
Kellogg’s has long sponsored the Amateur
Swimming Association Awards for young
children learning to swim. Until 2006 these
were sponsored by Frosties, with Tony the
Health Hype
In early 2008 the Kellogg’s ‘Wake up to
Breakfast’ campaign was supported by
celebrities Jo Frost (TV nanny), Ian Wright
(former footballer) and Phillipa Forrester (TV
presenter). A quote on the Kellogg’s website
states that “A healthy breakfast each
morning provides essential energy to
prepare you in mind and body for the day”.
But many of Kellogg’s breakfast cereals
aimed at children are less healthy and high
in sugar.
TV Timing
During our analysis of TV advertising,
Kellogg’s was found to be advertising
Frosties among the top 20 programmes
watched by the most children. The ad
featured the Tony the Tiger cartoon character.
KENTUCKY FRIED CHICKEN (KFC)
WHAT’S IN THE PRODUCTS?
The Kids Choice menu at KFC includes popcorn chicken, crispy strips or a mini fillet burger. KFC do
not provide nutritional information about their products per 100g so we were unable to profile them
to determine which products are healthier or less healthy.
We liked: They’ve restricted advertising to children and have also stopped giving out free collectible toys
with kids meals.
We didn’t like: They are still advertising less healthy foods on TV when most children watch.
!
They need to: Stop advertising less healthy options during the most popular programmes with children.
Ensure their policy on marketing extends to children up to 16 and is based on the FSA’s criteria.
WHAT THEY SAY
● “We do not market directly to
children – this includes TV advertising and
sponsorship. We also took the decision a
number of years ago to stop using toy
promotions in store. Similarly, we have a self
imposed restriction on outdoor advertising
within a one mile radius of schools.”
● We recognise the importance of a
balanced diet and believe all foods can be
eaten in moderation. We help customers
make informed choices by offering a wide
16 Food Fables-the second sitting
range of menu items, including some
healthier options as well as smaller
portion products.
● Over recent years, we have implemented
a number of initiatives to improve the
nutritional profile of our products.”
WHAT WE FOUND
Improved Image
KFC has cut-back on blatant child
marketing in the UK. Toys and
promotions are no longer given out free
with Kids Choice meals. The company
website has no child-centred content,
such as games and downloads.
TV Timing
During our analysis of TV advertising3, KFC
was found to be advertising their Variety
Boneless Box (which includes popular
children’s options) among some of the top
20 programmes watched by the highest
numbers of children. While the full 30
second ad was targeted at, and featured, a
family, the shorter ten second ad also shown
during this period only featured children.
KRAFT
WHAT’S IN THE PRODUCTS?
The top-selling Dairylea range from Kraft, including less healthy Rippers,
Dunkers and Lunchables, is aimed at the children’s lunchbox market. Lunchables
Ham ‘n’ Cheese Crackers contain 6.8g saturated fat and 1.8g salt per 100g.
We liked: Dairylea websites aimed at children have been removed and
web activity is focused on a central Kraft site.
We didn’t like: The use of the cartoon Dairylea cows on TV ads and
packaging for less healthy foods.
!
They need to: Extend restrictions on marketing of less healthy
foods to under 16s and base them on FSA criteria. Stop using the
Dairylea cows in TV adverts to promote products high in fat and/or salt.
WHAT THEY SAY
WHAT WE FOUND
● “For many years, Kraft has not advertised
to children under six. And only products that
meet our Sensible Solution nutrition
criteria are advertised in media directed to
children under 12. We’ve also eliminated
in-school advertising and set nutrition
standards for Kraft products sold in schools.
● To qualify as a Sensible Solution, the
product must provide beneficial nutrients,
while staying within certain limits for
calories, fat, sodium and sugar. Or, it has
to have reduced calories, fat, sugar or
sodium compared to similar products.
● During 2008 we will be making our
policies public on the EU pledge website
and putting in place an independent
monitoring mechanism.
● In September 2004, Kraft Cares, the
community partnership programme for
Kraft Foods, launched Health 4 Schools,
an initiative to promote healthy diet and
active play to school children and
communities in Gloucestershire. Over four
years it has reached 100 schools with a
total of 24,000 pupils.”
Catchy Characters
The cartoon Dairylea cows are used
extensively in TV advertising as well as
on packaging. Previous Which? research
has found them popular and appealing
to children.34
Health Hype
In August 2007 the Advertising
Standards Authority banned Kraft from
using the claim that Lunchables were
‘Packed with good stuff’ because the
product was high in salt and saturated
fat. However we found a similar claim
on packs: ‘Dairylea goodness kids love’,
as well as ‘Made with real cheese and
milk’. Dairylea packs make strong claims
about containing vitamin D and calcium
'which helps build strong bones & teeth'.
TV Timing
During our analysis of TV advertising,
we found Kraft advertising Dairylea
Dunkers among the top 20 programmes
watched by the highest numbers of
children. This advert uses cartoon cows,
making the product particularly
appealing to children.
Dairylea Dunkers advert
Dairylea Lunchables Ham
‘n’ Cheese Crackers are
high in saturated
fat and salt
Food Fables-the second sitting 17
MARS/MASTERFOODS
WHAT’S IN THE PRODUCTS?
Popular chocolate brands include Mars Bar, Milky Way, M&Ms and Maltesers. All
are high in sugar and saturates. Skittles are high in sugar.
We liked: There are age restrictions on competitions and offers.
We didn’t like: There weren’t many changes since our last report
and they had lots of teen-friendly web promotions.
!
They need to: Extend less healthy food marketing restrictions to
under 16s based on government criteria.
WHAT THEY SAY
● “We will not advertise our food and
snackfood products in media primarily directed
to children under 12. For the purposes of this
commitment, we will not purchase advertising
time or space where the composition of the
under 12 audience at the time of the media
buy is expected to exceed 25 per cent.
● We will not advertise, sponsor or undertake
product placement in films or media
programming where the intended audience is
primarily children under 12.
● We will not use a celebrity or third party
licensed character intended to appeal primarily
to children under 12 to promote our
snack food products.
● We will cease to use branded education
materials in schools by children under 12.
● We will not sponsor sports events in
primary schools.
● Text and internet promotions will be primarily
directed to participants over the age of 12. We
will not advertise or promote our websites in
venues primarily directed at children under 12.
● We will use age-screening techniques to
ensure that only young people above 12 can
18 Food Fables-the second sitting
download branded wallpaper, screensavers or
other leave-behind material from websites of
potential interest to younger audiences.”
WHAT WE FOUND
Show Sponsorship
Revels sponsors ITV’s You’ve Been Framed,
very popular with children. Because it’s a
family programme, it’s not covered by the
new advertising restrictions but Which?
has found that it was the second most
popular programme with children when we
analysed viewing data for the first two
weeks in January 2008.
Wayward Websites
In June 2008 the Skittles website
www.goskittleyourself.com was relaunched
with a competition to design the front of
Skittles packs. The interactive site
encourages video uploads and the creation
of dancing animations and the homepage
links to the Skittles Bebo page. The M&Ms
US website (www.mms.com) is promoted
on pack across various countries and
includes child-friendly e-cards, downloads
and a stationery template featuring the
M&M characters. In June 2008 the site
promoted Indiana Jones and the Kingdom of
the Crystal Skull, with M&Ms as characters
in the film. This site effectively restricted
entry by age – it wasn’t possible to go back
to change your date of birth if entry was
restricted because you were underage.
Social Network Sites
Mars is active on Facebook, Bebo and
MySpace. Online weekly radio show
MySpace Mars Planets Radio was launched
in June 2008. It encourages users to add
the Radio Player and Mars Planet branded
banners to their profile, and add the site as
a ‘friend’ so ‘you could win a month’s supply
of Mars Planets to share with your mates’
(age 14 and over). A Skittles Facebook
group (which includes games) has over
10,000 members.
Catchy Characters
M&Ms characters are used on pack, and
promoted online. The Planet M&Ms site,
accessed via the main website lets users
create a personalised M&Ms character
which can be used in
games, on e-cards, or be
printed on merchandise,
such as t-shirts.
Health Hype
Milky Way carries
reassuring claims that it
has no artificial colours or
flavours and ‘Contains
milk’, but sugars and
saturates aren’t listed.
Several of the Mars products we looked at
only gave basic four nutrition information,
even if percentage GDAs for energy and fat
were labelled.
TV Timing
During our analysis of TV advertising,
Masterfoods was found to be advertising
Mars Bars, Mars Planets, and a free cinema
ticket promotion on large packs of
Maltesers, M&Ms and Revels all among the
top 20 programmes watched by the
most children.
MC DONALD’S
WHAT’S IN THE PRODUCTS?
A McDonald’s cheeseburger has 12g fat, 6g saturates and 1.5g salt per portion, that’s
half of a four-six year old’s recommended daily salt intake. A small portion of fries adds
another 11g fat, and a small chocolate milkshake adds 28g sugar and 6g fat.
McDonald’s offers fish fingers, fruit bags, carrot sticks, milk and water among healthier
options in a Happy Meal. Other menu items will appeal to older children and include
less healthy options.
We liked: Promotions of healthier Happy Meals options, including in TV ads.
We didn’t like: The child-focused website, with a strong promotion of
Happy Meal offers, which include less healthy options.
!
They need to: Stop free-gift giveaways and remove children’s content from
the website. Ensure that their marketing policy applies to children up to 16 and is
based on the FSA’s criteria.
WHAT THEY SAY
WHAT WE FOUND
● “Three quarters of our Happy Meal menu is
not high in fat ,sugar and salt. We intend to
continue marketing responsibly talking to parents
and children about our food.
● We intend our future advertising to stimulate
young people’s imaginations and encourage
physical activity.
● Like all food companies, we’re also subject to
tight regulations about how and when we
advertise food and drink to children. Within these
regulations, we are able to continue to advertise
a large part of our main menu and our Happy
Meal menu to children but will ensure we do
so within both the spirit and the letter of
the regulations.
● We are also taking steps to get children more
active – McDonald’s UK is the official Community
Partner of the four home nation Football
Associations working to create more volunteer
community football coaches. In partnership with
The FA, Scottish FA, Irish FA and Welsh Football
Trust, we’ve already created over 11,500 new
community coaches.”
Fun Freebies
Happy Meal free gift promotions included
Kung Fu Panda, Euro 2008 football sticker
albums and stickers, The Spiderwick
Chronicles, and board games. In April 2008 a
‘Fairies and Dragons’ promotion had its own
website (www.fairiesanddragons.com)
promoted from the Kids Zone on the main
McDonald’s site. It featured a jigsaw
puzzle-style game, set within a fairy tale
about all the characters.
Film Freebies
Often the free toys offered with Happy Meals
are characters from big film releases, such
as The Spiderwick Chronicles and Kung
Fu Panda.
Sports Sponsorship
McDonald’s is the official community partner
of the four national football associations.
Children involved in community youth
football projects are exposed to extensive
McDonald’s marketing including heavily
branded vests and also hoardings around the
pitches. McDonald’s sponsored the 2008
UEFA European Championship, including
the player escort programme that saw
children aged six to ten walk out onto the
pitch with the footballers. McDonald’s will
sponsor the 2008 Olympic games in Beijing
and the 2012 Olympics in London.
Wayward Websites
The Kids’ Zone of the McDonald’s site
(www.mcdonalds.co.uk) is clearly targeted at
children with various fun activities, such as
games and colouring-in sheets to print out
(although wallpaper and screensaver
downloads and e-cards have been removed).
When trying to enter the Kids’ Zone, a
message flashes up that requires children
under 16 to click to say they have
permission to access the site, but no
registration is required and it’s easy to
click through.
A McDonald’s cheeseburger has 1.5g
salt – that’s
half of a 4-6 year old’s recommended daily intake
Food Fables-the second sitting 19
NESTLÉ
WHAT’S IN THE PRODUCTS?
Many Nestlé breakfast cereals aimed at children are high in sugar, including
Golden Nuggets, Frosted Shreddies and Cookie Crisp. Nesquik
milkshake products are high in sugar, as are Rowntree’s Fruit
Pastilles and Jelly Tots. Chocolate products from Nestlé
include Smarties, KitKat and Milkybar.
We liked: The main child-friendly
gaming site for Nestlé cereals has
been removed.
We didn’t like: Child-focused
websites and on-pack promotions
for less healthy products.
!
They need to: Restrict
child-focused cereal promotions,
including cartoon characters, to
healthy products in the range. Remove
the remaining child-focused web content
and extend all marketing restrictions to under
16s based on Government nutrition criteria.
WHAT THEY SAY
● “Nestlé is a signatory to the EU pledge,
which will be in place for 1st January 2009:
● EU Pledge 1: Not to advertise food and
beverage products to children under the age
of 12 on TV, print and internet, except for
products which fulfil specific nutrition criteria
based on accepted scientific evidence
and/or applicable national and international
dietary guidelines.
● EU Pledge 2: Not to engage in any
commercial communications related to food
and beverage products in primary schools, except
where specifically requested by or agreed with the
school administration for educational purposes.
● Nestlé advertising fully complies with all new
rules (CAP and BCAP) and will continue to
20 Food Fables-the second sitting
operate to the “spirit of the law” not just
the “letter”.
● Nestlé adopted the new ISBA on-line
guidelines and has removed a number of
websites, for example removing the “Fantasy
World of Fun”.
WHAT WE FOUND
Catchy Characters
Nestlé breakfast cereal cartoon characters
include Chip the Wolf (Cookie Crisp) and
Pete & Pardner (Golden Nuggets). Quicky
the Nesquik Bunny features on all Nesquik
products and the website.
Gimmicky Giveaways
Free books and football stickers to collect for
a Euro 2008 football sticker album have
been included in Cheerios cereal packets.
Coupon Collecting
Nestlé’s ‘Go Free’ offer
(www.nestle-gofree.co.uk) involves collecting
wrappers from a range of products for
free sport or dance sessions and has no
age restrictions.
Crafty Competitions
Fab ice lolly launched a new website
www.myfabland.com with a ‘Design a Fab
Den 2008’ competition in May 2008.
The site appears to be aimed at parents,
but the activities and competition are
targeted at children (from five to 15 years).
This was supported by a Fab Tour visiting
tourist attractions and retailers in the
Summer of 2008.
Film Freebies
Story books from films such as The
Spiderwick Chronicles and The Golden
Compass were given away free with boxes of
cereal. Nestlé Yogurt & Milk Snack cake bars
aimed at children are promoted with
characters from the film Finding Nemo.
The first ingredient in the product is sugar,
but only the basic four nutrients are labelled.
Wayward Websites
The children’s game site Fantasy World of
Fun, built to support various breakfast cereals
was closed down in February 2008.
However Nestlé still has some websites
aimed at young children, including the
Nesquik website (www.nesquik.co.uk), that
we found promoted on Nesquik Magic
Straws. It describes itself as an online
adventure park, with detailed animated
games and stickers to collect, and the
Milkybar website (www.milkybar.co.uk)
which includes colouring-in sheets.
Frosted Shreddies packs promote
www.knittedbynanas.com – a teen-targeted
site which includes games. The Smarties
website (www.smarties.co.uk) has a young
focus, with an easy general knowledge quiz
and ideas for a Smarties party. Nestlé
launched a Facebook page for Smarties in
March 2008 to mark the return of the
blue Smartie.
Health Hype
All Nestlé cereals are labelled as containing
‘Wholegrain’ with the details of the health
benefits of this. But several of the cereals are
also high in sugar, particularly those targeted
at children. Nestlé claim ‘Now with 25%
fruit juice’ on Rowntree’s Fruit Pastilles, but
no sugars are labelled. Milkybar claims to
contain ‘All natural ingredients’, but no
sugars are labelled. Tubs of Nesquik
milkshake mix claim to ‘Contain vitamin D
for strong bones’, and be ‘Fortified with
vitamins,’ but again sugars aren’t labelled.
TV Timing
During our analysis of TV advertising, Nestlé
was found to be advertising KitKat Senses
and Cheerios cereal among the top 20
programmes watched by the highest
numbers of children. The KitKat Senses ad,
featuring popular group Girls Aloud, would
particularly appeal to girls .
PEPSICO
WHAT’S IN THE PRODUCTS?
PepsiCo brands include fizzy drinks Pepsi and 7Up, Walkers crisps and
Quaker. Pepsi and 7Up both have over 13 teaspoons of sugar per 500ml
bottle, but sugar-free versions are available. Walkers, the UK’s topselling crisps and snacks brand, has 15 different flavours of standard
crisps – all high in fat (about a third fat).
We liked: None of the offers of competitions we found were
open to under-16s.
We didn’t like: The use of football celebrities to promote high sugar
Pepsi products and websites with content appealing to older children.
!
They need to: Extend restrictions to under 16s and only run
promotions for ’healthier’ products based on government nutrition criteria.
WHAT THEY SAY
● “PepsiCo in the UK does not target its marketing at
children, and has not done so for several years. The
UK business complies fully with the new Ofcom
requirements, governing television advertising of food
and beverage products to children aged under 16.
● We believe that advertising and marketing
messages can be powerful tools to promote positive
behaviour change, including the consumption of a
healthy, varied and balanced diet and a more active
lifestyle to help improve health.
● PepsiCo has signed the ‘EU pledge’ on advertising
to children and will be making a set of commitments
about advertising and marketing to children. These
will be published during 2008 and will enter into
force by 1 January 2009 at the latest.
Pepsi and 7Up
both have over
13 teaspoons
of sugar per 500 ml bottle
● This includes no advertising of products to children
under 12 years, except for products which fulfil
specific nutrition criteria based on accepted scientific
evidence and/or applicable national and international
dietary guidelines. Companies will publish specific
criteria later this year. A third party will monitor
companies’ advertising output.
● In line with commitments already made within
UNESDA, the EU soft drinks association, PepsiCo
does not advertise any of its carbonated soft drinks
to children under 12 in ``the EU.”
WHAT WE FOUND
Wayward Websites
PepsiCo has made significant investment in
a range of sophisticated websites likely to
appeal to older children. www.pepsi.co.uk
(which focuses on Pepsi Max) is a major
site aiming to create an online community
with user-generated content, offers and
competitions, with the focus on music and
football. It links to football-focused social
networking site www.pepsiyouniverse.com.
Launched in 2008, this site enables you to
assess your football ‘type’ and see how you
match with top name footballers. Age is
checked, but there are no restrictions. Youth
site www.7up.co.uk, which includes
downloads, games and fun content, is
promoted strongly on all 7Up packs. The
site focuses on the 7Up character Fido
Dido, which also has it own website
(www.fidodido.com) and links to channels
on MySpace and YouTube.
Food Fables-the second sitting 21
Catchy Characters
7Up’s Fido Dido is used on packaging,
and on the website.
Celebrity Sell
The six ‘Pepsi Football Stars’ (Beckham,
Lampard, Henry, Ronaldinho, Messi,
Fabregas), wearing Pepsi-branded football
shirts, have featured on regular Pepsi
bottles and cans, Pepsi’s website
www.howyoufootball.com, as well as
on www.pepsiyouniverse.com.
WEETABIX
WHAT’S IN THE PRODUCTS?
Brand leaders Weetabix and Ready Brek are low in sugar. Products aimed at children such
as Weetos chocolate flavour and Disney Princess Multigrain Stars are higher in sugar but
still come out as a ‘healthier’ option overall based on the FSA nutrient profiling scheme.
We liked: The promotions of healthier cereals to children.
We didn’t like: There was nothing we didn’t like, as we didn’t find
any promotions for less healthy foods targeted at children.
!
They need to: Continue to avoid marketing any less healthy foods
to children and ensure this applies to up to 16s based on government
nutrition criteria.
WHAT THEY SAY
● “At Weetabix, although all our family
breakfast cereals are suitable for children we
only actually advertise Weetos directly to
children and this is because, although it is a
chocolatey cereal, it scores -1 against the
FSA/Ofcom Nutritional Profiling Model,
making it suitable for such advertising. All our
other breakfast cereals are aimed at families
so are not marketed to children at all.
22 Food Fables-the second sitting
● We have recently been promoting the
“Weetabix Week” which encourages the
addition of toppings onto Weetabix some of
which are fruit. So in addition to a nutritious
start to the day, this also helps busy mums get
their kids on their way to one of their
“five-a-day” at breakfast time.”
WHAT WE FOUND
Success Story
Weetabix has made efforts to ensure that
the products it markets to children meet
the ‘healthier’ criteria of FSA nutrient
profiling. We didn’t find any promotions
for less healthy foods targeted at children
during our research period.
OTHER COMPANIES
ur research threw the
spotlight on other companies
which are marketing foods
irresponsibly to children.
These companies also need
to curb their less healthy promotions.
O
Puffs (Honey Monster Foods Ltd),
which contain 35g sugar per 100g,
promote an extensive, child-friendly website
on packs, ‘visit www.honeymonster.co.uk
for loads of honeytastic fun and games’.
Packs promoted a competition to win an
Xbox and a film tie-in with Bee Movie.
● Bratz Fruity Splitz, Disney Princess
Dreamy Strawberry Iced Finger
Biscuits and The Simpsons Mini Golden
Cookies were just a few of the less healthy
foods promoted by BonBon Buddies Ltd,
which specialises in products branded with
licensed cartoon characters.
83%
● Disney Pixar 6 Chocolate Mini Rolls
feature Toy Story, The Incredibles and
Finding Nemo (McCambridge (North) Ltd).
food makes it harder to
● Sugar
Chocolate Bars featured Winnie
the Pooh and Piglet (Kinnerton
(Confectionary) Australia) Pty Ltd).
marketing of unhealthy
get children to eat healthily
● Disney
● Pom-Bear
snacks (Intersnack Ltd) are
promoted with the company’s ‘Pom Bear’
cartoon character. We found packs
promoting a competition to win a Raleigh
bike and safety kit, you just text a number
to enter. The product is promoted with a
child-focused website with a club to join,
downloads and games at
www.pom-bear.co.uk
think that irresponsible
● Pink
Panther Wafers are wafer biscuits
made by Rivington Foods Ltd.
● Bob
the Builder Turkey & Pork
Sausage is a high salt formed-meat
product in the shape of Bob’s head
(Feldhues GmbH).
● Transform-A-Snack
(Red Mill Snack
Foods Ltd) are aimed at young children and
have a promotion on pack for
www.transformas.co.uk which includes a
comic and wallpaper to download.
We also found several more foods
high in fat, sugar and/or salt
targeted at children using licensed
cartoon characters:
Food Fables-the second sitting 23
VERDICT
ome companies are starting to
take a more responsible
approach to advertising foods
to children, with those under
12 increasingly seen as an
inappropriate target. But frustratingly,
many are now simply channelling their
marketing in a different direction, towards
the teen market. We found many
examples of marketing via new media
such as websites and mobiles. These
techniques are popular with young people
and the nature of them makes them less
visible to parents. In addition we still
found too many on-pack promotions
carrying licensed and company cartoon
characters that would appeal to young
children. So overall, in spite of many
companies revising their policies and the
introduction of various new controls,
whether regulatory or industry selfregulation, children of all ages are still
being exposed to a significant amount of
marketing for less healthy foods. Below
are some of the problems we found and
our recommendations for action:
S
CATCHY CHARACTERS
overweight or obese
Young children are attracted to bright,
shiny, colourful packaging, particularly if
it features characters they are familiar
with. Many of the top food companies are
reducing the amount of licensed
characters they use on foods but we still
found several – on the whole being used
to target less healthy food to children.
Several of the top companies are still
using their own cartoon characters to
promote less healthy foods. These
characters should be used to promote
healthier foods instead.
by 2050
FUN FREEBIES
55%
of boys will be
We found too many free gift giveaways
designed for children to promote less
healthy foods, as well as incentive
schemes and competitions that indirectly
encourage consumption of less healthy
products (to get more points or entries to
a competition). These promotions should
be limited to healthier options.
24 Food Fables-the second sitting
WEB-WISE
Our research highlighted the shift towards
teen marketing in new media. This is
evident in both the use of social networking
sites and in the style and content of some
company websites. Where age-restrictions
were applied on websites, we found varying
levels of effectiveness, exposing the need
for industry standards on this. Competitions
and offers entered via mobile phones
couldn’t apply age restrictions.
Teen-friendly Fanta website
different company nutrition criteria – rather
than the FSA’s nutrient profiling model.
COMPANIES TO CHEER
Weetabix fares best among the large
breakfast cereal manufacturers. Its brand
leader – Weetabix – is a healthier product,
and while its child-targeted cereals are high
in sugar, they come out as a healthier
option overall. Among the fast food chains,
it was encouraging that KFC have removed
free toys from kids meals. However, both
companies could still do more to help
consumers make healthy choices. KFC
should provide complete nutritional
information and Weetabix should further
reduce the sugar in cereals aimed at
children, such as Weetos and chocolate
flavour and Disney Princess
Multigrain Stars.
GET ACTIVE
TV TIMINGS
The new Ofcom rules ban advertising of
any foods high in fat, sugar and/or salt
during programmes with a predominantly
child audience. However Which? has found
that significant numbers of children are
exposed to less healthy ads when watching
programmes such as Coronation Street,
Emmerdale, The Bill and Britain’s Got Talent.
These programmes are not affected by the
restrictions because high numbers of adults
watch them as well as children. The
advertising restrictions need to be extended
to include programmes watched by the
largest numbers of children, regardless of
how many adults are also watching.
AGE ADJUSTMENTS
Our review of leading food company
policies found an awareness of the need to
be seen to be tackling irresponsible
marketing behaviour. Many are taking steps
to stop direct advertising to children, but we
found a variety of cut-off ages. Most
company commitments to limit advertising
to children define them as under 12s,
rather than under 16s. However, these
restrictions are generally based on a
Our review of company promotions found a
trend towards activity-based offers (such as
swimming, sport and dance), in addition to
several company-sponsored sports and
community initiatives that encourage
exercise. Which? welcomes this, but using
less healthy products or a brand that
mainly sells less healthy food, to promote
exercise, can create a confusing message.
LOUSY LABELLING
We found much of the nutrition labelling
of the less healthy foods covered in this
report to be inconsistent and inadequate.
The labels should be helping consumers
recognise when foods are high in calories,
fat, saturates, sugar and salt, especially
when ‘health’ and ‘quality’ aspects of the
product are promoted.
Food Fables-the second sitting 25
fat, sugar and salt and protect
all children up to the age
of 16.
● The
£45
billion
is how much obesity
will cost the UK
economy by 2050
WHICH? IS
CALLING FOR:
Government to provide
leadership, working with
industry to develop a
stronger and broader code of
practice so restrictions are in
place for all forms of
promotion targeting children
with high fat, sugar and salt
foods. This includes ones
we’ve identified, such as
website, mobile phone, viral
marketing, company and
licensed cartoon characters
on packaging, use of
celebrities and sponsorship.
A clear deadline should be
set for voluntary action to
achieve these changes. If this
fails, the Government should
regulate, so that companies
have to be more responsible.
● The
Government’s TV
advertising restrictions for
foods high in fat, sugar and
salt to be extended to cover
advertising during the times
that most children are
watching, not just during
programmes mainly watched
by children.
● The
● Food
companies to go
further in their marketing
policies so that they limit all
promotions for foods high in
26 Food Fables-the second sitting
effectiveness of any
restrictions to be continually
monitored and reviewed, in
light of the evolving nature
of marketing.
1 Foresight Tackling Obesities: Future Choices –
Project Report, Government Office for Science,
October 2007
2 National Diet and Nutrition Survey: young
people aged 4-18 years, 2000
3 Childcatchers, Which? Campaign Report,
January 2006
10 BARB data for children aged four to 15 and
Nielsen data were analysed for the period:
31 March – 13 April 2008
11 http://www.food.gov.uk/
healthiereating/advertisingtochildren/nutlab/
12 Television Advertising of Food and Drink
Products to Children, Ofcom, February 2007
behaviours and use, Ofcom, April 2008
22 Top 20 children’s websites according to
Hitwise, February 2008
23 British Television Advertising Awards 2008,
Bronze Award for Best Viral
24 http://www.schoolfoodtrust.org.uk/
content.asp?ContentId=593
4 Review of Research on the Effects of Food
Promotion to Children, Hasting el al, September
13 ‘Less healthy’ foods are those high in fat,
sugar and/or salt – defined using the Food
25 http://www.brandrepublic.com/
News /793691/First-impressions/
2003 (Commissioned by the Food Standards
Agency); The Extent, Nature and Effects of Food
Promotion to Children: A Review of the Evidence,
World Health Organization, July 2006; Food
Marketing to Children and Youth: Threat or
Opportunity?, US Institute of Medicine,
December 2005. (Commissioned by the US
Congress);
New Research on Advertising Foods to Children:
Standards Agency nutrient profiling scheme
14 BARB data for children aged four to 15, and
Nielsen data were analysed for the periods: 1 –
14 January 2008; 31 March – 13 April 2008
15 British Code of Advertising, Sales Promotion
and Direct Marketing. Advertising Standards
Authority
16 Online Promotion of Food to Children. Best
practice principles for communications on
26 Cartoon Heroes and Villains, Which?
Campaign Report, August 2007
27 BARB and Nielsen data : 1 – 14 September
2007; 1 – 14 January 2008; 31 March –
13 April 2008
28 BARB and Nielsen data: 31 March –
13 April 2008
29 BARB and Nielsen data: 1 – 14
January 2008
An Updated review of the Literature, Sonia
Livingstone, January 2006 (commissioned
by Ofcom)
advertiser-owned websites, ISBA, July 2007
17 www.eu-pledge.eu Food and drink companies pledge to change advertising to children.
30 Which? survey of 815 parents of children
aged 16 in GB in February to March 2006.
31 http://www.food.gov.uk/foodlabelling/
5 Which? survey of 2,027 adults in GB (aged
16+) from 8 – 12 February 2008
6 A weighted sample of 2,027 adults (aged
16+) was surveyed 8 – 12 February 2008
7 Health Survey for England 2006 Latest Trends,
National Centre for Social Research,
January 2008
8 A weighted sample of 2,027 adults (aged
16+) was surveyed 8 – 12 February 2008
9 Food Fables, Which? Campaign Report,
Nov 2006
Published December 2007
18 Choosing Health: Making Healthy Choices
Easier, Department of Health white paper,
November 2004
19 Choosing a Better Diet: a Food and Health
Action Plan, Department of Health, March 2005
20 Healthy Weight, Healthy Lives:
A Cross-Government strategy for England,
Department of Health, January 2008
21 Social Networking: a qualitative and
quantitative research report into attitudes,
signposting/ (accessed 30 June 2008)
32 Healthy Signs?, Which? Campaign Report,
July 2006
33 http://www.talkingretail.com/
products/8407/KateModern-online-soap-tiein-.ehtml
34 Food Fables, op cit.
Food Fables-the second sitting 27
For further information please contact:
public_affairs@which.co.uk Tel: 020 7770 7353
More information can also be found on our website (www.which.co.uk/campaigns)
Published by: Which?, 2 Marylebone Road, London NW1 4DF. July 2008
Which? campaigns actively for all consumers. With around 675,000 members in the UK, we
are the largest consumer organisation in Europe. Entirely independent of government and
industry, we are funded through sales of our consumer magazines, online products and books.
Which? is the operational name of Consumers’ Association – a registered charity No 296072.