The AANA, food ads and kids: unpacking the propaganda
Prof. Elizabeth Handsley, President of Children and Media Australia
On 19 June 2023, the House of Representatives Standing Committee on Health, Aged Care and Sport put out a media release about plans for a public hearing on diabetes the following day. Also on 19 June, the Australian Association of National Advertisers (AANA) released a statement opposing ‘blanket bans on advertising for some parts of the food and beverage industry’.
Such statements could be dismissed as more of the same industry propaganda we have been hearing for decades, but if the AANA, which presumably knows something about messaging, takes the trouble to put one out, we have to figure it’s going to hit home somewhere. So it’s worth unpacking.
First, the AANA release reminds us of the role of education, parental guidance, and so on in reducing childhood obesity. Nobody is saying these things have no role, and even if they were, the existence of other factors doesn’t diminish the reasons to address advertising.
Second, the release talks up the ‘rules’ contained in the AANA’s Food and Beverages Advertising Code – described as ‘some of the strongest in the world’ (not saying much). However, when it claims a nearly 100% compliance rate, this is not with the rules themselves but with the complaints body’s findings when it upholds a complaint. This begs the question of how ‘strong’ those complaints decisions are.
Then, the trifecta: job losses. These will flow from the fact that less advertising means less consumption. In other words AANA would like the government to reduce childhood obesity without any reduction in children’s intake of ‘occasional’ foods.
Coming back to the Code, its most important faultline is the application of some seemingly strong provisions only to ads that ‘target’ children. This framing leads the field wide open for ads that appeal to adults as well as children, so the necessary ‘targeting’ isn’t apparent and the child-friendly restrictions don’t kick in. In any case, it’s no simple matter to determine whether an ad ‘targets’ children, because there are three separate criteria which the AANA complaints body applies on a case-by-case basis. We just don’t know whether the body will require one, two or all three criteria to be satisfied before it will hold an ad in breach, so we can’t know how ‘strong’ the rules are in any given case, much less overall.
At least one of the criteria in the rules is very cleverly designed to ensure few ads will ever be caught: it says that an ad might ‘target’ children if the ‘Expected average audience at the time or place the advertisement appears includes a significant proportion of Children’, further explained as possibly including a situation where ‘25% or more of the predicted audience will be Children’. A regulation that was serious about children’s health would look at the raw numbers of children, with the understanding that anything under 25% is still a significant number of children and the protective provisions should apply.
Another major faultline in the AANA system is the fact that it relies on the public to notice breaches and take the trouble to complain. Yet, for a member of the public to know what audience an advertiser ‘expects’ and therefore gauge whether a breach has occurred, is highly unrealistic.
CMA hopes very much that when receiving submissions to their inquiry into diabetes, the Standing Committee will see through these arguments, and listen carefully to the message from public health and children’s rights advocates: it’s time we stopped letting the advertising industry mark its own homework.
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