AFGC SUBMISSION PUBLIC CONSULTATION: PROMOTION AND MARKETING OF FOOD AND BEVERAGES IN LOCAL CANBERRA-SETTINGS - ACT Government
←
→
Page content transcription
If your browser does not render page correctly, please read the page content below
AFGC SUBMISSION PUBLIC CONSULTATION: PROMOTION AND MARKETING OF FOOD AND BEVERAGES IN LOCAL CANBERRA-SETTINGS
AFGC SUBMISSION: Public consultation: promotion NOV 2015
and marketing of food and beverages in local Canberra-settings
PREFACE
The Australian Food and Grocery Council (AFGC) is the leading national organisation
representing Australia’s food, drink and grocery manufacturing industry.
The membership of AFGC comprises more than 178 companies, subsidiaries and associates
which constitutes in the order of 80 per cent of the gross dollar value of the processed food,
beverage and grocery products sectors.
Composition of the defined industry’s turnover ($2013-14)
With an annual turnover in the 2013-14 financial year of $119 billion, Australia’s food and
grocery manufacturing industry makes a substantial contribution to the Australian economy
and is vital to the nation’s future prosperity.
Manufacturing of food, beverages and groceries in the fast moving consumer goods sector is
Australia’s largest manufacturing industry. Representing 30 per cent of total manufacturing
turnover, the sector accounts for over one quarter of the total manufacturing industry in
Australia.
The diverse and sustainable industry is made up of over 26, 551 businesses and accounts
for over $61.7 billion of the nation’s international trade in 2014-15. These businesses range
from some of the largest globally significant multinational companies to small and medium
enterprises. Industry spends $541.8 million in 2011-12 on research and development.
The food and grocery manufacturing sector employs more than 322,900 Australians,
representing about 3 per cent of all employed people in Australia, paying around $16.1 billion
a year in salaries and wages.
Many food manufacturing plants are located outside the metropolitan regions. The industry
makes a large contribution to rural and regional Australia economies, with almost half of the
total persons employed being in rural and regional Australia. It is essential for the economic
and social development of Australia, and particularly rural and regional Australia, that the
magnitude, significance and contribution of this industry is recognised and factored into the
Government’s economic, industrial and trade policies.
Australians and our political leaders overwhelmingly want a local, value-adding food and
grocery manufacturing sector.
2AFGC SUBMISSION: Public consultation: promotion NOV 2015
and marketing of food and beverages in local Canberra-settings
INTRODUCTION
The Australian Food and Grocery Council (AFGC) welcomes the opportunity to make this
submission to the Australian Capital Territory Government’s public consultation on the promotion
and marketing of food and beverages in local Canberra settings. The AFGC represents food and
beverage manufacturers in Australia, many of which provide products to Canberra’s consumers
through the retail sector including through supermarkets, restaurants, cafes, clubs, hotels, and
other outlets.
The AFGC also convenes a Quick Service Restaurant Forum comprising major quick service
restaurants McDonald’s Australia Ltd., Hungry Jack’s Australia, Yum! Restaurants Australia Pty.
Ltd. (KFC and Pizza Hut), QSR Holdings (Red Rooster, Chicken Treat, Oporto) and Subway
Australia.
HOW DOES THE FOOD INDUSTRY HELP PROMOTE
AND PROTECT GOOD HEALTH?
The links between diet and health have been recognised for hundreds of years and in the modern
era for over a century by the food industry. More recently, the food manufacturing industry has
established a strong track record of responding to advances in nutritional science by bringing
innovative new products to market designed to protect and promote good health.
Better products
In the 1970s concerns about links between saturated fat and heart disease led to the
development of polyunsaturated margarines. The 1980s saw the enrichment of breakfast cereals
and other foods with dietary fibre to lower the risk of bowel cancer. And the 1990’s witnessed the
development of lower fat milks (“lite white”) which now hold over 50% of the market. In almost
every food category product types with low fat, low sugar, low salt, added fibre or high protein
have been developed to provide choice to consumers. One area where Australia leads the world
has been the removal of trans-fats from the food supply so that the dietary intake is now 40%
lower than World Health Organization Recommendations (see Appendix, Case Study 1). The
food industry not only removes nutrients which are associated with disease risk, but it adds many
essential nutrients to foods (e.g. vitamins and minerals) under strict regulatory oversight which
ensures there is no risk to health from overconsumption.
Empowering consumers through information
Providing product choice in the market is an important step to helping consumers choose foods
as part of a healthy diet, but in addition it is important they have ready access to information.
Again, the Australian industry stepped up ten years ago in providing a world-first Front of Pack
(nutrition) Labelling (FoPL) scheme. This voluntary program called the Daily Intake Guide is run
by the AFGC and now appears on over 7200 products in all major food categories.
More recently the AFGC in conjunction with representatives of the public health sector, consumer
organisations and government developed and agreed to a new FoPL Health Star Rating (HSR)
System. The HSR, which is based on the levels of nutrients in the food product, assists
consumers compare products within food categories and thereby construct healthy diets.
Finalised barely a year ago the HSR already appears on over 1000 every day food products. This
3AFGC SUBMISSION: Public consultation: promotion NOV 2015
and marketing of food and beverages in local Canberra-settings
is an example of how the food industry working closely with public health organisations such as
the National Heart Foundation and with consumer organisations such as Choice can develop new
initiatives helping Australians to adopt healthy lifestyles.
Another example of the food industry working closely with Government and the public health
sector has been through the Food and Health Dialoguei. This initiative commenced in 2009
bringing together food industry and public health organisations in a coordinated category- by-
category food reformulation program aimed at reducing salt and saturated fat in food products.
The value of programs of this type for salt reduction is now widely recognisedii and encouraged
as part of the WHO’s Global Action Plan for the Prevention and Control of Non-communicable
diseases.2013-2020iii.
Responsible advertising
In addition to agreeing to collective action in the area of food formulation and food labelling, the
Australian food industry has also led the world in responding to concerns about childhood
obesity. Firstly, the AFGC provided $1 million to help fund the 2007 Australian Children’s Nutrition
and Physical Activity Surveyiv which provided up-to-date information on the levels of overweight
and obesity across Australia. The data indicated that levels were no longer rising (later confirmed
in further studiesv), but that they were too high putting the health of children at risk. This was a
call to action and in 2009 the Australian food industry voluntarily launched two initiatives to
provide guidance to food companies on responsible marketing of food to children.
The Responsible Children’s Marketing Initiative (RCMI) encompasses products in retail outlets,
while the Quick Service Restaurant Initiative for Responsible Advertising and Marketing to
Children (QSRI) covers food sold in in quick service restaurants. Together the initiatives capture
two thirds of all food and beverage advertising on television (see Appendix, Case Study 2).
These are voluntary commitments to restrict the advertising of non-core foods1 to children.
Advertisements for such foods will not be shown in children’s television viewing times, be
designed to appeal to children, or appear in programs with a considerable (35%+) audience.
The RCMI and QSRI are examples of very successful self-regulatory approaches. Extending
beyond television they include print media and the internet. The initiatives include a fully
independent complaints handling body through the Advertising Standards Bureauvi (ASB) and an
Arbiter at the University of South Australia. Compliance is monitored and reported annuallyvii. Any
complaint that is upheld by the ASB requires the signatory company to remove the
communication (i.e. the advertisement) and its associated investment. This can represent a
substantial commercial penalty for the company.
An ongoing commitment
The AFGC is highly committed to responsible advertising and marketing of food and non-
alcoholic beverages to children in all its forms. The RCMI and the QSRI have achieved significant
change in the advertising of food and non-alcoholic beverages to children, with discretionary food
advertising being virtually eliminated from children’s television programs and standards imposed
1Companies determine non-core foods by using criteria set by organisations such as National Heart Foundation
and the Healthy Kids School Canteen Guidelines.
4AFGC SUBMISSION: Public consultation: promotion NOV 2015
and marketing of food and beverages in local Canberra-settings
across radio, cinema, print, online and interactive games. This includes social media and
downloaded apps.
Notwithstanding this the purpose of the RCMI and QSRI is not to prevent children from ever
seeing an advertisement for a discretionary food product, rather it is to help the food industry
promote products responsibly to support community messages about healthy diet selection. In
doing so it supports parents to guide their children’s dietary and lifestyle habits, by reinforcing
healthy eating messages and ensuring the advertising of discretionary food products does not
target children directly. The Audience share requirement (35%) within the RCMI and QSRI is
intended to ensure that if a discretionary food communication is seen by child, it is likely to be in
the presence of an adult.
Thus the AFGC’s position, and that of its members, is one which recognises:
1) the rights of food companies to advertise their products within regulatory, co-regulatory and
self-regulatory constraints; and
2) the ongoing challenge of assisting both children and adults to select healthy diets through
responsible labelling and promotion of food products which reinforce messages about
healthy eating based on moderation, variety and balance, consistent with the Australian
Dietary Guidelines.
RESPONSIBLE ADVERTISING IN THE ACT
Whilst many forms of advertising are regulated at the national level (e.g. television,
internet, media) the ACT Government does have regulatory and/or management oversight
of some aspects of advertising and the sale of food products. Along with that comes a
responsibility to ensure that advertising:
1) reasonably reflects community values in its volume, positioning and content;
2) is protected as a legitimate business activity informing consumers of products and
services thereby driving both competition and a thriving business economy within the
ACT; and
3) is at all times within the current law.
The current consultation into the Promotion and Marketing of Food and Beverage
Products in Local Canberra Settings is focused on advertising of foods and beverages in
the ACT primarily on bill boards and signage within places where the public gather, and
the types of foods for sale within those venues. It is to support the ACT Government’s
Towards Zero Growth: Healthy Weight Action Plan (October 2013) which included
marketing of food and drinks aimed at children as a potential area for action.
The AFGC strongly supports measures which will assist consumers to healthy eating
which are:
1) evidence-based providing a high degree of confidence that they will be effective at
addressing a clearly defined issue; and if relevant;
5AFGC SUBMISSION: Public consultation: promotion NOV 2015
and marketing of food and beverages in local Canberra-settings
2) practical for industry to implement.
The AFGC supports healthy eating messages for both adults and children promoted by
Government and other agencies. Indeed, many of its member companies also promote on
pack and in food advertisements these messages and have invested significantly in
reformulation to improve the nutritional profile of their products.
With regard to assisting children, in addition to the RCMI and QSRI described above the
AFGC supports programs such as the National School Canteen guidelines which provide
guidance as to the types of products suitable for sale to children in school canteens.
The AFGC is unaware of any research that suggests that the level and nature of food and
beverage advertising within the ACT is having a detrimental effect on the nutritional status
and therefore the well-being of adult Canberrans, and/or their children. Indeed, the
evidence supporting the contention that advertising per se in any arena, or medium, is
detrimental to the health of children is sparse, and certainly not conclusive. Indeed, the
Australian Communication and Media Authorities most recent report into Children’s
Television Standards did not support the proposal that advertising of food and beverages
to children was contributing to obesity levels amongst children in Australia.
The Heart Foundation Audit Report.
The AFGC notes that the ACT Government’s website includes a link to a report prepared
by the Heart Foundation titled ‘Food and beverage marketing to children in the ACT:
Persistent, Pervasive, Persuasive’2.
The AFGC has carefully reviewed the Audit report and has provided a detailed response
to some aspects of that report (Appendix). The AFGC has some broader concerns with
the Audit report which are as follows:
1) The report goes beyond a simple audit report. The language use is pejorative and
judgemental. The title alone suggests a sinister element in food and beverage
marketing in the ACT.
2) The Background section seeks to build a case that there is strong evidence
suggesting that the market is having a detrimental effect on the health of ACT
children, but relies on studies and data which are out of date, or from studies
overseas, and ignores information readily available from Australia sources about
advertising in Australia. Against this backdrop, the less informed reader would
assume that any advertising viewed by children is likely to be harmful, while more
informed readers would conclude that the study does little, if anything, to inform and
assist health and wellbeing policy development.
2
http://www.heartfoundation.org.au/news-media/Media-Releases-
2015/Documents/HF%20Audit%20of%20Advertising%20to%20Children%20-
%20Final%20for%20March%202015%20launch.pdf
6AFGC SUBMISSION: Public consultation: promotion NOV 2015
and marketing of food and beverages in local Canberra-settings
3) The report fails to address the issues critical to the assessment of the impact of
advertising including:
a. population exposure levels – i.e. parsing the data against number of children
likely to see the advertisements and therefore the potential impact at the
population level;
b. individual exposure levels – i.e. what is the range of exposures to advertising
of any particular child in any particular neighbourhood;
c. the impact level – i.e. taking into account the content of the advertisements,
and particularly whether they are, or are not, targeted to children. This is a
serious shortcoming as all advertising regulatory and self-regulatory
considerations include the concept of advertising directed “primarily” at
children; and
d. the lack of any agreed ‘yardstick’ against which to judge the impact of the
advertising levels recorded.
The last point is of particular concern as it inevitably leads the reader to the
conclusion that any advertising of high fat, salt and sugar products is necessarily
bad for children.
4) Failure within the methodology to describe how some advertisements were deemed
“red” foods, when access to nutritional information was clearly limited, and failure to
explain satisfactorily how simple brand signage can reasonably be counted as an
example of advertising of “red” food to a child. The report methodology section states:
“….store signage for heavily branded chains, and those specifically
targeting children, were included in the marketing count, as such signage
tends to be readily associated by children with the product being
promoted.”
This is self-serving, likely to skew the results and potentially data confounding.
The AFGC’s overall view is that the study falls a well short of the quality research needed
to sensibly guide public health policy development. Worse, it stands to cloud the debate
by suggesting that rapid and strong action needs to be taken to protect children.
For the Record
Of great concern to the AFGC is that the authors of the Heart Foundation Report appear
to be completely unaware of the many changes to food products now on offer to
consumers, both in terms of manufactured food products, but also from quick service
restaurants. The authors’ views on the nutritional value of products are ill-informed and
outmoded and represent a tired paradigm of complaint from a bygone era. Many
companies, including the quick service restaurants have undertaken several rounds of
product and meal renovations resulting in a substantial realigning of their nutrient profile to
7AFGC SUBMISSION: Public consultation: promotion NOV 2015
and marketing of food and beverages in local Canberra-settings
Australia Dietary Guidelines. The AFGC stands ready to provide further information,
including commercial in-confidence information to the ACT Government demonstrating the
new, healthy product offerings which are now provided by many AFCG member
companies – both from the manufacturing sector and the quick service restaurants.
Facts on Outdoor Advertising
AFGC makes the following additional points which should be taken then taking into
account the Heart Foundation’s Audit report and its conclusions.
Outdoor advertising (also known as OOH – out of home) within this report includes
billboards, posters, ground displays (decals), bus shelters etc. These are all
legitimate advertising mechanisms and subject to advertising standards and codes.
Audience monitoring for outdoor advertising in Australia does not capture persons
under 14 years. This is due to many factors, including the difficulty in accurately,
appropriately and ethically tracking children and their responses to advertising in
outdoor settings.
Outdoor advertising is not a medium used by advertisers to target children, this is
reflected in there being no engagement measure to track the success of any
messaging (as opposed to some other media where audience tracking is used).
BROADER IMPLICATIONS
Outdoor advertising, in all its forms, remains an acceptable medium for businesses, large
and small to promote their goods and services and it is subject to regulations (standards
and codes).
Places where people congregate (e.g. shopping centres etc.) are attractive to advertisers
seeking to communicate with larger audiences. Many of those venues will have large
numbers of children passing through, but most often accompanied by their parents or
other adults. Responsible marketing in different venues, consistent with community
values, plays an important role in providing information to assist the informed choice of
consumers for different products, including close to their point of sale. Advertising
revenues often support those venues contributing to the value offered to consumers on
their visit. As such advertising, including advertising of food and beverage products, plays
an important commercial role within local communities, as well as at the national level.
Restricting advertising to a level greater than demonstrated necessary to protect
consumers risks:
1) undermining the financial viability of some of the venues hosting the advertising; and
2) disadvantaging some businesses which rely on local advertising to drive local sales.
This is most likely to be smaller businesses without a national marketing footprint in
mainstream media.
The AFGC considers these broader implications need to be carefully considered prior to
any action by Government to limit the advertising of food and beverages within the ACT.
8AFGC SUBMISSION: Public consultation: promotion NOV 2015
and marketing of food and beverages in local Canberra-settings
CONCLUSIONS
The AFGC and its members take the health of Australians very seriously and is keen to
consider ways in which its members can assist healthy diet selection by consumers,
including through responsible marketing approaches.
Companies are working with Governments at national, state and territory level to
determine how best to provide advice to consumers through product labels and other
initiatives, in addition to providing new products with new nutrient profiles and new product
formats aimed to assist consumers in their dietary choices.
The AFGC stands ready to provide further input into the ACT government’s policy
development in the area of the promotion of food and beverages in local Canberra
settings.
9AFGC SUBMISSION: Public consultation: promotion NOV 2015
and marketing of food and beverages in local Canberra-settings
APPENDIX
CASE STUDY 1. Trans-fats - an Australian success story
Background: The food industry introduced trans-fats into foods to replace saturated fats during
the 1960s and 1970s. Trans-fats are produced when vegetable oils are processed to make them
harder (less liquid) at room temperature. They found uses in margarines and products where
hard animal fats had previously been used (e.g. shortening in pastry).
The Problem: In the early 1990s nutritional science indicated that dietary trans-fats are a risk-
factor for heart disease.
The Solution: The major oil producers in Australia agreed to change their processes to phase
out trans-fats from all fats and oil products. This carried across into the food manufacturing
sector, significantly reducing the trans-fat levels in many processed foods where oil is an
ingredient.
The Benefit: Dietary levels of trans-fats in Australia are now at very low levels. The 2012
Australian Health Survey confirms that trans-fats represent only 0.6% of dietary energy which is
40% lower than the World Health Organization recommendations.
CASE STUDY 2. Marketing to Children
Background: Childhood overweight and obesity levels increased substantially during the 1970s,
80s and 90s although evidence is strong that they had plateaued by the early 2000s. The cause
of the rise was (and still is) unknown but it led to calls for regulatory bans on advertising to
children.
The Problem: Community concern regarding the possible impact of advertising on children’s
diets although the Australian Media and Communication Authority does not support regulatory
action as there is little evidence linking advertising to obesity levels in children.
The Solution: In 2009 the AFGC launched the Responsible Children’s Marketing Initiative and
the Quick Service Restaurant Initiative for Responsible Marketing to Children (QSRI). Under the
initiatives companies commit to restricting the advertising of non-core food products such that the
exposure of children to the adverts is limited.
The Benefit: Since the introduction of the initiatives, in 2013 less than 1% (0.6%) of all food and
beverage advertisements shown in children’s television programs across the three main
channels, were for non-core foods.
10AFGC SUBMISSION: Public consultation: promotion NOV 2015
and marketing of food and beverages in local Canberra-settings
RESPONSE TO HEART FOUNDATION ACT AUDIT OF ADVERTISING TO
CHILDREN IN THE ACT
Report AFGC Response/Position
Marketing is defined as any visual or audio message that publicises or This definition means that any marketing a child in the ACT may see is considered
promotes one or more unhealthy food or beverage products that could ‘marketing to children’. This is a significant departure from best practice, which
reasonably be expected to attract the attention of children (eg signage, acknowledges that for marketing to be considered marketing to children a number of
posters, billboards, prominent branding/labelling (including on vending elements should be present. This is reflected in the current Free TV Code of Practice,
machines), product placement, sponsorships, radio broadcasts and cinema AANA Codes and Practice Note (on directed primarily to children) and in the AFGC RCMI
advertisements). Page 5 and QSRI.
This approach has been endorsed in the complaint handling process administered by the
Australian Communications and Media Authority (ACMA).
The report is therefore of limited value in assessing the quantity and impact of the
documented food advertising in the context of marketing to children.
There is a growing body of evidence to show that this influences their dietary This evidence is limited and no causal relationship has been established.
preferences and contributes to unwanted weight gain. Page 6
While current there are some limited restrictions on food marketing to children Since the introduction of the RCMI and QSRI in 2009, food and beverage advertising to
in Australia, these restrictions are primarily self-regulatory codes and offer little children has been practically eliminate from children’s television programs and standards
protection to children from the commercial promotion of unhealthy foods and have been imposed across radio, cinema, print, online and interactive games. This includes
beverages. Page 6 social media and downloaded apps.
The report fails to acknowledge the effectiveness of these self-regulatory initiatives despite
the information being readily available from the AFGC.
11AFGC SUBMISSION: Public consultation: promotion NOV 2015
and marketing of food and beverages in local Canberra-settings
Report AFGC Response/Position
Analysis of Australia’s 1995 National Nutrition Survey found that energy- Analysis of the Australian Health Survey 2011-12 showed that this figure had decreased to
dense, nutrient-poor ‘extra foods’ contributed 41% of the total daily energy 37% of total daily energy intake of 2-18 year olds. Whilst many factors may have influenced
intake of 2-18 year olds. Page 9 this decrease, changes in advertising practices in Australia may have contributed.
In recent years, there has been increasing interest from marketers and food This is based on a 2004 US study using data pre dating the introduction of most self-
manufacturers in children and adolescents as consumers, accompanied by a regulatory and co-regulatory commitments regarding advertising to children, both in the
concomitant increase in the amount of marketing targeted at these age USA and particularly in Australia. It is inappropriate to use this old data to inform current
groups. Page 9 debate on this important issue as it will mislead.
Food and beverages are more frequently targeted at children than adults and This is based on US data from prior to 2004. This is not supported by Australian marketing
are the most common products featured in marketing targeted at children, with or advertising data.
the majority of foods promoted being energy dense and nutrient poor. Page 9
Results were skewed initially towards healthy foods by the classification of This commentary on the intent and effect of branding and stocking activities of beverage
water branded vending machines as marketing ‘healthy’ beverages. Data were vending machines is conjecture. No evidence is presented to support the statement.
adjusted to reflect the predominantly unhealthy nature of the contents of these
vending machines. It appeared that the water branding was being used to
provide a ‘halo effect’ – i.e. drawing in consumers by giving the impression
that the vending machines were selling ‘healthy’ beverages, when in fact
sugar-sweetened beverages featured heavily in all of the machines observed
as part of the audit. Page 15
12AFGC SUBMISSION: Public consultation: promotion NOV 2015
and marketing of food and beverages in local Canberra-settings
Report AFGC Response/Position
Apart from the examples of marketing identified in the audit tools, children are The rationale provided for the distinction between store signage is flawed. The report does
also exposed to a high volume of store signage for eating establishments such not describe how stores were identified as ‘targeting children’. Brand, or store awareness
as local cafes. These were not counted as marketing for the purpose of the per se, is not the same as ‘targeting’ sub-groups of consumers.
audit, as they did not contain branding or pictures that would be recognisable
to children as marketing a food or beverage; whereas store signage for heavily
branded chains, and those specifically targeting children, were included in the
marketing count, as such signage tends to be readily associated by children
with the product being promoted.
Unbranded vending machines were excluded from the audit. Page 15
Major shopping centres
Billboards, sandwich boards, vending machines and posters. Page 16
Billboards are generally located in the middle of walkways and at the top and
bottom of escalators. Page 17
The vending machines were classified as marketing by virtue of their presence
in the general concourse areas of the major shopping centres – i.e. where
children could be expected to see them and ‘pester’ their parents to purchase.
Page 18 (Beverages and confectionery)
Touch screens, skill testers
Unhealthy food and beverage marketing within close proximity of child-
designated areas. Page 21
Car parks and underfoot. Page 23
13AFGC SUBMISSION: Public consultation: promotion NOV 2015
and marketing of food and beverages in local Canberra-settings
Report AFGC Response/Position
Suburban shopping centres
Billboards, sandwich boards, vending machines, store signage (excluding
store branding) and posters. Page 28
Supermarkets
Floor displays, posters, product displays on the ends of aisles, checkout
displays and products handing in aisles. Page 30
Confectionery products designed to appeal to children are placed on the
lowest shelf. Page 32
The positioning of unhealthy foods and beverages, within easy reach and sight
of children, can encourage ‘pester power’. Page 32
Marketing within close proximity of ACT schools Marketing was observed in proximity to only 3 of the 12 primary schools in the audit.
Advertising and branding within a 200 metre radius of the school grounds.
Page 35
Food and beverage marketing was not observed within a 200m radius of nine
of the 16 schools. However, where supermarkets were within this radius,
promotional marketing and signage were observed. In addition, unhealthy
marketing was observed in close proximity to Primary School 1 (a sandwich
board) and Primary School 2 (visible signage for a fast food chain) despite
these schools not being located near a suburban supermarket. Page 35-36
14AFGC SUBMISSION: Public consultation: promotion NOV 2015
and marketing of food and beverages in local Canberra-settings
Report AFGC Response/Position
Case Study Store layout is highly complex with a number of factors coming into play aimed at facilitating
shoppers’ convenience. Product placement may vary with the predominant demographic of
the neighbourhood and how the store is used (i.e. daily shops versus weekly shops).
The Case Study reveals prejudice of the authors by using somewhat emotive language
regarding some of the product displays. The report states ‘Customers are confronted with
a large shelf displaying a variety of potato crisps of different types and brands’ and
‘customers are bombarded with displays and advertisements for energy dense, nutrient
poor foods and beverages. (AFGC emphasis). Rather florid language for a report presented
as a research paper.
Marketing on school bus routes ACT Government decreased school bus services in 2014 by 20 per cent. Further
investigation is needed to determine if this is because there has been a decrease in ACT
Data were collected on three school bus routes. The audit revealed only two
children catching the bus to school.
examples of food and beverage marketing visible from the bus routes; a
billboard advertisement on a bus shelter for popped potato snacks on one bus
route, and a fast food chain branding visible from another bus route. Store
branding for suburban shops and eating establishments were also visible from
each of the bus routes. Page 39
Bus Interchanges
Adshels, posters and signage, sandwich boards and ad sails, vending
machines, window decals. Page 39
15AFGC SUBMISSION: Public consultation: promotion NOV 2015
and marketing of food and beverages in local Canberra-settings
Report AFGC Response/Position
Sporting venues
Canteen/café area – branding fridge, branded games, ice cream freezer, pie
warmer, product displays, posters and signage, sandwich boards, straw
dispensers, vending machines. Page 42
Other areas (courtside, general concourse) – Ice cream freezer, posters and
signage, sandwich boards, vending machines. Page 42
Sports sponsorships Research shows that one of the key barriers to sports participation in children is cost of
participation. With only 20-23 per cent of ACT children meeting the physical activity
Nine sports organisations…reflect sports with high local participation rates
recommendations, there should be no interventions that limit a sporting organisations ability
among children. Page 44
to attract funding that supports and promotes physical activity to children.
4 of the 9 sporting organisations received ‘unhealthy’ sponsorship. Page 44
Sponsorships took the form of cash contributions; the provision of branded
uniforms, marquees, kit and equipment; free (or discounted) food at events;
and vouchers (including for free/discounted food items). Page 44
Hospitals ACT Healthy Food and Drink Choices Policies are already addressing the issue of food
choice and promotion in hospitals.
Cinema marketing Cinema marketing is captured by the RCMI and QSRI
Advertisements prior to two films, rated G or PG
2 of the 3 cinemas had no external food or beverage advertising (one had a
candy bar ad)
POS marketing at candy bars. Page 47
16AFGC SUBMISSION: Public consultation: promotion NOV 2015
and marketing of food and beverages in local Canberra-settings
Report AFGC Response/Position
Radio advertisements Radio advertising is captured by the RCMI and QSRI
Weekday mornings between 8.00am and 9.00am 666ABC Canberra most popular breakfast radio (no ads) – 21.1 per cent
Pre-recorded advertisements, pre-recorded ad with commentary from FM104.7 18.2 per cent
announcers, sponsorship, conversation / commentary. Page 48
MIX106.3 and Radio National – 11.9 per cent each
70 per cent of Canberra radio audience is not listening to the leading commercial radio
stations during the audited time period. This does not include people in cars that are
listening to personal music devices, those talking on the phone (hands free) or those driving
without any form of external audio input.
17AFGC SUBMISSION: Public consultation: promotion NOV 2015
and marketing of food and beverages in local Canberra-settings
i
http://www.foodhealthdialogue.gov.au/internet/foodandhealth/publishing.nsf
ii
Webster, J. et al. Nutrients 6. 3274-3287. 2014
iii
http://apps.who.int/iris/bitstream/10665/94384/1/9789241506236_eng.pdf?ua=1
iv
http://www.health.gov.au/internet/main/publishing.nsf/Content/phd-nutrition-childrens-
survey
v
Olds, T. et al. International Journal of Obesity, 34 (1), 57-66. 2010.
vi
http://adstandards.com.au/
vii
2014 Annual Compliance Report
18You can also read
