The proposed ‘junk food’ advertising ban is aimed at you, not your children

We are being sold a pig in a poke by obesity campaigners. When Action on Sugar started complaining about added sugar in pasta sauces in 2014, there was no reason to think that it would soon become government policy to remove sugar from chocolate, confectionery and puddings.

When Public Health England began its food reformulation scheme, the agency said that it would be focusing on the ‘food categories that contribute the most to children’s sugar intakes’. Adults could rest easy. It was, after all, a Childhood Obesity Strategy. But then came the bait-and-switch. Earlier this year, Public Health England suddenly noticed that ‘Our children don’t eat special children’s food. We buy the same food for our entire family.’ It is now open season on the whole food supply.

Next up is a ban on ‘junk food’ advertisements on television before 9pm. This, supposedly, is to give children more ‘protection’ than the existing ban which only covers broadcasting that is specifically aimed at children. According to a YouGov poll, 65 per cent of Britons are in favour of such a ban. I am not surprised. Advertising restrictions are an easy sell. Advertising is irritating and gets in the way of the programmes. Most people do not see advertising as an issue of free speech, though it is, and the main losers from such bans appear to be greedy corporations and fancy-pants advertising executives.

Add ‘junk food’ and ‘children’ into the mix and you have an unstoppable campaign. What kind of monster is going to stand up for the right of companies to advertise ‘junk’ to ‘children’?

Well, I will for a start. Because it’s another pig in a poke. The public are being misled.

Let’s start with the word ‘children’. If you tune into the main commercial channels between 7pm and 9pm this evening you will have a choice between the following programmes: Emmerdale, Coronation Street, Heathrow: Britain’s Busiest Airport, Channel 4 News, Great Rail Restorations, MotoGP Highlights, and ShopSmart: Save Money. This is hardly X-rated stuff, but if you are old enough to take an interest in any of it, you are old enough to see an advert for chips.

In any case, if you are watching live television you are almost certainly over the age of 30, let alone over the age of 18. Everybody else is watching Netflix, Youtube, the iPlayer or illegal downloads. The idea of banning TV commercials is very appealing to ‘public health’ campaigners who want to follow the anti-smoking playbook to the letter, but the world has moved on. Banning advertisements during programmes that are aimed at adults on a medium that is overwhelmingly used by adults cannot seriously be described as a policy aimed at children.

Now let’s take the term ‘junk food’. In the public’s mind, ‘junk food’ is synonymous with American fast food chains, an impression reinforced by the media’s tendency to illustrate every story about it with a picture of a burger. If McDonald’s has to wait until 9pm to tell us about their new limited edition bacon burger, it seems a relatively trivial encroachment on freedom.

But ‘junk food’ has no legal definition. The nearest equivalent is HFSS food – food that is deemed to be high in fat, sugar and/or salt. For the purposes of advertising regulations, Ofcom uses a definition of HFSS food that encompasses a much broader range of products than the colloquial term ‘junk food’ implies.

They use a fiddly and rather puritanical system known as the Nutrient Profile Model which condemns almost everything except raw food and health food. The model was devised by our old friend Mike Rayner who literally believes that God told him to bring about a sugar tax in Britain. All the obvious stuff gets a black mark under Rayner’s model: pizza, crisps, biscuits, confectionery, milkshakes and sugary drinks. It also rules out lots of products that are not typically considered to be ‘junk’ but which can be expected to get caught up in a system that focuses on sugar, salt and fat: ice cream, clotted cream, jam, marmalade, honey, bacon, pretzels, salted peanuts, sweetened fruit juice, smoothies and most sausages.

But then there are the foods that hardly anyone would consider ‘junk’ but which still fail the test: cheese (including half-fat cheese), raisins, sultanas, soy sauce, mustard, most tinned fruit, most yoghurts, most breakfast cereals (including high fibre varieties), peanut butter, Marmite, mayonnaise (light and regular), tomato soup, most cereal bars, many pasta sauces, all butter, fat spreads and olive oil.

All of this and more will be treated like soft porn if the campaigners get their way. If the government bans so-called ‘junk food’ advertising before the watershed, it will be easier to list the products that can be advertised than the products that cannot. And most of the products that could be advertised under this regime – milk, fresh fruit, fresh vegetables, raw meat, unprocessed nuts – will never be advertised to any great extent because they are not branded goods.

While one branch of government runs a ‘Food is Great’ campaign to promote British cuisine, another branch of government treats it as junk. This government website gives visitors a list of the ‘best British food to eat while you’re in Britain’. All of the products pictured – haggis, pork pies, cream tea and cheese – would be covered by the advertising ban, as would the products in the posters below.

You can see why those who campaign for such a ban prefer to use the sloppy and misleading term ‘junk food’ rather than explain what is at stake. The government hasn’t thought this through and that is just the way the campaigners like it.


  • Gavin Jacque-Floris

    Pointless article – seems Chris has only just figured out that parents are a part of a child’s life. Of course these measures are aimed at everyone because kids eat children and adult food (depending on their age) and parents buy a lot of their food for them.

    In the same way you accuse public health of saying this is just about children, you are exaggerating and saying it is aimed at parents and not children. Both ways of putting it are sloppy and incompetent.

    Don’t personally agree that a 9pm watershed is the right approach, but I can see a need to look at what types of food/drink advertising children are exposed to across all media.

    At least you are not using this article to spout the IEA rubbish that advertising is mainly about brand switching and brand retention. By that logic, if all retailers of a HFSS product are not allowed to advertise, there would be no substantive loss of consumers for each respective brand, and manufacturers/retailers would just be competing on the quality of their product.

    Gavin Jacque-Floris

    • Dick_Puddlecote

      “the IEA rubbish that advertising is mainly about brand switching and brand retention”

      Erm, that is the *entire* point of advertising. No advertising has ever concentrated on increasing consumption. Jeez.

      • Gavin Jacque-Floris

        Thanks for the input, Dick, and particularly the emphasis on *entire*.

        I can’t take your opinion seriously if you truly believe brand switching is the only thing advertising does. Clearly advertising is used to persuade consumers to use a brand in the face of competition, no one argues that isn’t the case. But a simple look at a marketing textbook shows it is also used to inform people of a new brand to build primary demand, and to remind people to keep buying it to sustain that demand irrespective of the competition. If you had any intelligence, you would know virtually all a company’s activities are focused on increases demand for their product or service, thus increasing consumer usage.

        By your logic, if no advertising was allowed by any company, there would be no impact on sales.

        You provide a pointless contribution to debate.

        Gavin