How Processed Food is Marketed to Kids

As I explained then, the feds’ solu­tion to the prob­lem of indus­try spend­ing more than $2 bil­lion annu­ally mar­ket­ing mostly junk food to chil­dren isn’t gov­ern­ment action, but rather improved vol­un­tary self-regulation, despite this non-system being a proven fail­ure, over and over again.

Ignoring the futil­ity of this approach, the feds set out to exam­ine how the food indus­try has cleaned up its act over the last few years. The report’s press release spin—commending indus­try for “progress”—defies the agency’s own data. Even the first page of the report’s exec­u­tive sum­mary admits: “The over­all pic­ture of how mar­keters reach chil­dren, how­ever, did not sig­nif­i­cantly change.”

Kids Targeted Online, and Everywhere Else

For starters, while total ad spend­ing directed at chil­dren dropped by 19.5%, the report notes a 50% increase in dig­i­tal ads and other forms of “new media,” an indi­ca­tion that cor­po­ra­tions are just get­ting smarter and more effi­cient in how they spend their mar­ket­ing dol­lars. Indeed, as the FTC explains:

Internet pro­mo­tional activ­i­ties have become an anchor for food mar­ket­ing, with more than 90% of the report­ing com­pa­nies engag­ing in online mar­ket­ing in 2009. Online mar­ket­ing is far less costly than TV and other media, and more inter­ac­tive and engaging.

Moreover, cross-promotions, such as when food com­pa­nies team up with movie stu­dios, video games, theme parks, etc., which FTC calls “a hall­mark of mar­ket­ing food to young peo­ple” increased from 80 reported exam­ples in 2006 to more than 120 in 2009. In a sign that it’s becom­ing increas­ingly impos­si­ble to sep­a­rate TV from online enter­tain­ment, FTC offers: “SpongeBob episodes, for exam­ple, could be viewed on food com­pany web­sites with cross-links between Nickelodeon’s SpongeBob web­site and the food com­pany site.”

Also, it’s not just that spend­ing is shift­ing from TV to online that’s sig­nif­i­cant, but that dig­i­tal mar­ket­ing tech­niques are more inter­ac­tive and at times down­right creepy, espe­cially when it comes to teens. (See my post about PepsiCo’s online video game designed—according to the ad agency—to “scare the crap out of teenagers.”) The FTC report describes the social intent of “advergaming:”

One game directed the child to hold a cereal box up to a web­cam in order to inter­act with the game. Other pop­u­lar online mar­ket­ing activ­i­ties included allow­ing chil­dren to cre­ate their own avatar and per­son­al­ize their vir­tual world, cre­at­ing art work to share with a friend online, join­ing online “clubs” that offer free or dis­counted meals on a child’s birth­day, and down­load­ing screen savers, “emoti­cons,” ring tones, videos, and other items.

The agency also exam­ined indus­try mar­ket research con­firm­ing the effec­tive­ness of online techniques:

… online mar­ket­ing activ­i­ties are a wor­thy invest­ment because they keep chil­dren engaged with the com­pany and pro­mote brand loy­alty. Other research under­scored the impor­tance of fre­quently updat­ing online con­tent to keep it fresh, and using stream­ing video and inter­ac­tive icons to appeal to teens.

Other exam­ples of non-traditional forms of mar­ket­ing included:

• An energy drink com­pany sent sam­pling teams in branded vans and buses to dis­trib­ute prod­ucts at places where teens congregate—beaches, ski venues, sports events, music fes­ti­vals and con­certs, sum­mer camps, col­lege fairs and SAT prep courses;
• The Jonas Brothers Band—which was fea­tured in both a con­cert tour and a movie—appeared in tele­vi­sion, radio and Internet ads for cheese slices; a free down­load of their music was avail­able by pur­chas­ing the product;
• A candy com­pany spon­sored a safe dri­ving pro­gram for high school students.

Also miss­ing from the mostly pos­i­tive FTC press release was eth­nic tar­get­ing, while the report con­tained these exam­ples of mar­ket­ing to Hispanics:

• Ads for bev­er­ages, energy drinks, snack foods, yogurt, cere­als, canned pasta and candy, as well as QSRs, aired ads on Spanish-language radio or tele­vi­sion sta­tions or net­works. Most were aimed at a gen­eral Spanish-speaking audi­ence, while some ads were teen-directed and a few were child-targeted;
• Workshops on healthy eat­ing for Hispanic par­ents and chil­dren were spon­sored by a non-carbonated bev­er­age com­pany, while town-hall meet­ings on col­lege appli­ca­tions and schol­ar­ship oppor­tu­ni­ties for Hispanic teens were spon­sored by a QSR;
• One mar­keter looked at pur­chas­ing pat­terns among Hispanic con­sumers and iden­ti­fied fam­i­lies with chil­dren as account­ing for the biggest growth in sales for that com­pany. This research also observed that Hispanic chil­dren are the pri­mary dri­vers of accul­tur­a­tion within their fam­i­lies and are reached effec­tively through a typ­i­cal kid’s media buy.

Translation: Marketers think the best way to get Hispanic adults to buy stuff is through their chil­dren. (Presumably this find­ing applies beyond just food.)

Of course, it’s not just Hispanic par­ents who want to please their kids. Market research from the com­pa­nies showed how effec­tive “pester power” is in get­ting par­ents to cave in to their child’s requests. Again, from FTC:

For exam­ple, one company’s study found that a child see­ing an ad for a food prod­uct or see­ing the prod­uct on the shelf was a key fac­tor in pur­chase and that 75% of the pur­chasers sur­veyed bought the prod­uct for the first time because their child requested it. Another study showed that in-store adver­tis­ing cam­paigns using child-targeted character-based themes out­per­formed those using mom-targeted themes.

Keep Industry in Charge, Why Fix What’s Broken?

So then, what does the agency charged with pro­tect­ing chil­dren from this sort of preda­tory mar­ket­ing offer up as a solu­tion? Just more of the sta­tus quo, based on the food industry’s alleged “improve­ments” in the nutri­tional qual­ity of the foods they are mar­ket­ing to chil­dren. According to FTC: “… many food com­pa­nies have con­tin­ued to improve the nutri­tional pro­file of their foods by refor­mu­lat­ing exist­ing prod­ucts and intro­duc­ing new ones… the Commission believes that the food indus­try can—and should—make fur­ther progress in using its mar­ket­ing inge­nu­ity and prod­uct port­fo­lio to address child­hood obesity.”

That the FTC has deter­mined its role is to nudge the food indus­try along in mak­ing minute refor­mu­la­tions to its prod­ucts is trou­bling to say the least. Even FTC had to admit to less than a one gram decrease in sugar-packed cere­als along with “slightly more whole grain”  (an increase of 1.6 grams, or one-tenth of one serv­ing). Of course, the food indus­try is jump­ing for joy over the feds’ mostly pos­i­tive spin.

And it’s ironic because in the report the FTC admits, while attempt­ing to assess industry’s self-regulatory sys­tem, that nutri­tion analy­sis is not its strength: “Although the Commission does not have the exper­tise to assess spe­cific nutri­tion criteria…”

Despite this admis­sion, a good por­tion of the report is devoted to a nutri­tion analy­sis of the foods being mar­ket­ing to chil­dren, along with a review of sur­vey data on dietary pat­terns, pre­sum­ably to con­nect any alleged “progress” of the food indus­try with how kids are eat­ing, despite the lack of sci­en­tific merit of con­nect­ing those two dots. (Kids’ eat­ing habits may get worse or bet­ter over time for any num­ber of rea­sons unre­lated to indus­try mar­ket­ing practices.)

Moreover, as I have argued before, it’s sim­ply uneth­i­cal to mar­ket to chil­dren, whether the prod­uct is fruit or Froot Loops, so I remain unim­pressed with any approach that gives over so much ground to industry.

It also defies logic that the FTC believes vol­un­tary self-regulation could ever work. The report admits that indus­try con­ve­niently exempts key forms of mar­ket­ing from its own guide­lines: “Product pack­ag­ing and in-store pro­mo­tion, includ­ing the use of licensed char­ac­ters from pop­u­lar children’s movies and TV shows, are exempt and con­tinue to be used exten­sively to mar­ket to chil­dren.” Probably not so coin­ci­den­tally, industry’s own reported mar­ket research iden­ti­fied these very strate­gies as the most effective.

Anyway, indus­try showed its true col­ors when four fed­eral agen­cies led by the FTC (this could explain why the agency is so fatigued over this issue) tried to make rec­om­men­da­tions to improve the food industry’s self-serving sys­tem of nutri­tion stan­dards and sug­gested science-based, uni­form, industry-wide guide­lines instead. Two years later, Congress brought the effort to a screech­ing halt, thanks to a huge out­cry from the food, adver­tis­ing and media industries.

It now appears the fed­eral gov­ern­ment is out of ideas, and is just going through the motions. That we can­not count on the Obama admin­is­tra­tion to pro­tect chil­dren from preda­tory mar­ket­ing when the first lady had made child­hood obe­sity her main cause demon­strates the polit­i­cal power of the food, media and mar­ket­ing indus­tries. So that’s it par­ents, you’re on your own.

For addi­tional per­spec­tives on the report, see my two interviews:

Is Big Food Playing Games with Data Reported to Feds on Marketing to Children? A Q&A with ex-industry insider Bruce Bradley

Feds’ Nutritionism Approach to Food Industry “Progress” on Marketing to Children—Q&A with reg­is­tered dietit­ian Andy Bellatti

Michele Simon

Michele is a pub­lic health lawyer who has been research­ing and writ­ing about the food indus­try and food pol­i­tics since 1996. Visit her site at www.EatDrinkPolitics.com/