The Devil Is in the Detail: Challenging the UK Government’s 2019 Impact Assessment of the Extent of Online Marketing of Unhealthy Foods to Children

Abstract

Background: How much unhealthy marketing do children see on digital devices? Marketing of unhealthy food and beverages has long been identified as a factor in children’s preferences, purchase requests and consumption. Rising global obesity mandates States to craft environments that protect children and young people’s health, as recommended by the World Health Organization, among others. However, assessing the impact of marketing restrictions is particularly challenging: the complexity of digital advertising markets means that measurement challenges are profound. In 2019, the UK Department of Health published an Impact Assessment that applied a novel method aiming to calculate costs and benefits of restricting unhealthy food and beverage advertising on digital devices (planned for implementation by 2022). It estimated UK digital unhealthy marketing to children at 0.73 billion advertising impressions annually, compared to television impacts of 3.6 billion. Aim and Method: We assessed this conclusion by reviewing the UK Department of Health/Kantar Consulting’s Online Baseline Methodology (the “Government Model”). We examined the model’s underlying premise and specified the seven analytic steps undertaken. For each step, we reviewed industry and academic evidence to test its assumptions and the validity of data applied. Results: We found that, in each step, the Government Model’s assumptions, and the data sources selected, result in underestimates of the scale of digital advertising of unhealthy foods—at least tenfold, if not substantially more. The model’s underlying premise is also problematic, as digital advertising spend data relate poorly to digital advertising exposure, leading to further underestimation of market scale. Conclusion: We conclude that the Government Model very substantially underestimates the impact of digital unhealthy food advertising restrictions on health. This analysis has relevance for global policy and for the impact of regulation on children’s health and well-being.

An Exploration of the Role of Sugar-Sweetened Beverage in Promoting Obesity and Health Disparities

“…Targeted marketing of SSB and other unhealthy foods to people of color and low socioeconomic status takes advantage of their more limited options for healthy food choices and their need for product affordability, while ignoring their greater risk for obesity and obesity-related diseases. Therefore, in response to question 4, we echo others [ 120 ••, 121 , 122 ••, 123 – 127 , 128 ••, 129 , 130 • 131 – 133 , 134 ••, 135 , 136 •, 137 – 149 , 150 •, 151 – 153 , 155 ••] in suggesting that proactive environmental measures to decrease exposure to palatable food cues, particularly in the form of targeted marketing to our vulnerable populations, is a necessary strategy for slowing the obesity epidemic.…”

“…In the USA, there are no statutory regulations that limit the marketing of unhealthy foods to children [ 123 ]. The obstacles to such regulations include the economic power of the industry [ 124 – 126 ], prioritizing individual rights over public health outcomes [ 127 ], and the challenges of regulating advertising through digital media, which was recently described as the most significant paid-for media channel for unhealthy advertising to children [ 128 ••]. In 2019, the California Dental Association and the California Medical Association launched a campaign to highlight the soda industry’s marketing strategies targeted at children and low-income and minority communities [ 129 ].…”

Australian Children's Exposure to, and Engagement With, Web-Based Marketing of Food and Drink Brands: Cross-sectional Observational Study

“…The number of advertising impressions (views by children) that were estimated using this approach was approximately five times greater for television advertising than for web-based marketing. Interrogations of the approach used by academics suggested that the impact assessment underestimated children’s actual web-based food marketing exposures by 10-fold [ 41 ]. This study supports this finding, whereby Australian children’s web-based food marketing exposures are approximately nine times higher than their exposure to food advertising on television.…”

Does Government Intervention Ensure Food Safety? Evidence from China

“…However, there are obstacles in the process of implementing government intervention. As a result of these obstacles, in many cases, government intervention does not achieve the expected goal [ 40 , 41 ]. This study finds that government intervention in China is negatively associated with food safety performance, which is contrary to the research conclusions of Lv et al, Wang et al, and Duan et al, all of which find that government intervention has a positive influence on other industries [ 42 , 43 , 44 ].…”