The Children’s Food and Beverage Advertising Initiative:

Progress to Date and Future

Elaine D. Kolish, VP and DirectorChildren’s Food & Beverage Advertising InitiativeCouncil of Better Business Bureaus

“New Challenges and Opportunities in Food Marketing Children and Youth:” A WorkshopInstitute of MedicineNovember 5, 2012

Progress to Date and Future

The Children’s Food and Beverage Advertising Initiative:

Progress to Date and Future

, VP and DirectorChildren’s Food & Beverage Advertising Initiative

“New Challenges and Opportunities in Food Marketing

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Progress to Date and Future Directions

About the CFBAIAbout the CFBAI

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CFBAI Goals

• Respond to IOM/FTC calls for more self regulation

• Be part of the solution

• Focus on what foods are advertised to children– Use meaningful nutrition

standards

• Bring transparency & accountability to company commitments

CFBAI Goals

Respond to IOM/FTC calls for

foods are

Use meaningful nutrition

accountability to company

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IOM: Shift the emphasis to foods substantially lower in calories, lower in fats, salt,

and added sugars, and higher in nutrient content

CFBAI Requirements Have Evolved Since Nov. 2006 Launch

• Require 100% healthier food ads or no childdirected ads (effective Jan. 2010)– Increased from 50% to 100%– Dropped “healthy lifestyle messaging” as compliance option

• “Child-directed” definitions substantially • “Child-directed” definitions substantially harmonized (announced Sept. 2010)– Now all use 35% (or smaller %) viewers– Those at 50% moved to 35%

• Adopted CFBAI-developed uniform nutrition criteria to replace company– Effective Dec. 31, 2013– Five participants already have adopted in whole or in part

CFBAI Requirements Have Evolved Since Nov. 2006 Launch

Require 100% healthier food ads or no child-directed ads (effective Jan. 2010)

Increased from 50% to 100%Dropped “healthy lifestyle messaging” as compliance option

directed” definitions substantially

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directed” definitions substantially harmonized (announced Sept. 2010)

Now all use 35% (or smaller %) viewersThose at 50% moved to 35%

developed uniform nutrition criteria to replace company-specific criteria

Five participants already have adopted in whole or in part

Covered Venues Have Expanded

Internet

Original

RadioPrint

Covered Venues Have Expanded

Video Games

MobileMedia

Added(as of 2010)

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CFBAI Focus:“Child-Directed” Ads

• “Ads primarily directed to children under 12”– Ads designed to be

appealing/persuasive to kidskids

• Not all ads kids might see– On prime time dramas or

reality shows ─ primarily directed to families/adults

– On sites primarily directed to teens/adults/families

CFBAI Focus:Directed” Ads

“Ads primarily directed to

appealing/persuasive to

Not all ads kids might seeOn prime time dramas or

primarily directed to families/adultsOn sites primarily directed to teens/adults/families

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“Child-Directed” Means…

• Viewer/visitor standard generally used• TV ─ mature medium

– ≥ 35% viewers under 12 works well

• Online ─ more dynamic and evolving• Online ─ more dynamic and evolving– ≥ 35% visitors under 12 alone may not encompass all

child-directed sites– CFBAI/companies may view sites as child directed

even if < 35% or unknown % visitors– Multi-faceted analysis (intent, content, net impression,

where site advertised)• Cookies, candy, colas per se • Games alone ≠ child-directed site

Directed” Means…

Viewer/visitor standard generally used

≥ 35% viewers under 12 works well

more dynamic and evolvingmore dynamic and evolving≥ 35% visitors under 12 alone may not encompass all

CFBAI/companies may view sites as child directed even if < 35% or unknown % visitors

faceted analysis (intent, content, net impression,

Cookies, candy, colas per se ≠ child-directed sitedirected site

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CFBAI Participants & Commitments~ 80% Food Ads on Kid’s TV

Use nutrition criteria for 100% of child-directed ads

CFBAI Participants & Commitments~ 80% Food Ads on Kid’s TV

No child-directed ads

Use nutrition criteria for 100% of directed ads

or

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CFBAI Monitors and Reports on Company Compliance

• CFBAI scrutinizes company-submitted compliance reports – Self assessment is opportunity to detect

& correct problems

• CFBAI monitors independently TV, print, radio, mobile, sites print, radio, mobile, sites – TV & websites primary venues– Company-owned sites

• Those reported as child-directed• Others to verify reporting

– Third-party child-directed sites• Large list of where companies advertise,

media lists of top kid sites, etc.

• CFBAI will conduct inquiries into complaints

CFBAI Monitors and Reports on Company Compliance

submitted compliance reports Self assessment is opportunity to detect

CFBAI monitors independently TV,

directed

Large list of where companies advertise,

CFBAI will conduct inquiries into

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What’s Changed: Decline in ChildDirected Food Ads

38%

1977

33%

2004

62% 67%

Food Ads

Non Food Ads

*Results for 1977 & 2004 are from an analysis of shows with 50%+ kids in the audience. Bureau of Economics Staff Report, “Children’s Exposure to TV Advertising in 1977 and 2004” (2007). The FTC estimated there was a 9% decline in children’s exposure to food ads across all programming. 2010 & 2012 results are from two CFBAI analyses of over 30 hours of children’s TV.

Ads for sedentary entertainment more prevalent

What’s Changed: Decline in Child-Directed Food Ads*

24%

2010

23%

2012

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76%

Food Ads

Non Food Ads

*Results for 1977 & 2004 are from an analysis of shows with 50%+ kids in the audience. See Table 5.3 in FTC’s Bureau of Economics Staff Report, “Children’s Exposure to TV Advertising in 1977 and 2004” (2007). The FTC estimated there was a 9% decline in children’s exposure to food ads across all programming. 2010 & 2012 results are from two CFBAI analyses of over 30 hours of children’s TV.

77%

Ads for sedentary entertainment more prevalent.

What’s Changed: Significant Improvements From Meaningful Nutrition Criteria

• ≥ 100 foods changed or created to meet nutrition standards – Other foods no longer advertised or discontinued

– Reformulation and new product development ongoing

• Calories – Virtually every individual food under 200 calories

– No entrees/main dishes > 350 calories; No meals > 600 calories– No entrees/main dishes > 350 calories; No meals > 600 calories

• Sodium – Pre-CFBAI some foods with > 900 mg sodium

– Now highest is 750 (most far less: FDA “healthy” levels used by many)

• Sugars – Variety of meaningful limits

– Reductions in cereals, yogurts; lower

• Fats– ≤ 2 grams or ≤ 10% calories sat fat general standards

– A number of foods reformulated

What’s Changed: Significant Improvements From Meaningful Nutrition Criteria

created to meet nutrition standards no longer advertised or discontinued

Reformulation and new product development ongoing

under 200 calories

No entrees/main dishes > 350 calories; No meals > 600 calories

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No entrees/main dishes > 350 calories; No meals > 600 calories

with > 900 mg sodium

less: FDA “healthy” levels used by many)

Reductions in cereals, yogurts; lower-sugar items sourced

≤ 2 grams or ≤ 10% calories sat fat general standards

foods reformulated to lower fats to meet limits

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Significant Changes From Use of Meaningful Nutrition Criteria

More nutrient dense than before:

– 89% of products: for foods with a – 89% of products: for foods with a “good” source of a “nutrient of concern” and/or contain F/V/D/WG

• 25% increase from 2010 (71%)

– 72% of products: for foods with F/V/D/WG

• 50% increase from 2010 (48%)

– 71% of ads: for foods with at least a half-serving of fruit or whole grains

• ~40% increase from 2010 (~51%)

Significant Changes From Use of Meaningful Nutrition Criteria

for foods with a for foods with a “good” source of a “nutrient of concern”

for foods with at least a serving of fruit or whole grains

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Recent Changes:F/V/D/WG Increases

• All “small meals” & “meals” include fruit and/or veg as a side dish– Apples, applesauce, peaches, berries, banana

• Separate items, toppings, in smoothies

– Corn, tomato sauce – Corn, tomato sauce

• All small meals & meals contain at least one F/V/D/WG serving– Most contain at least 1.5 servings

• Many dairy products– More yogurt/yogurt type drinks– Low-fat milk, fat-free milk, fortified milk

Recent Changes:F/V/D/WG Increases

All “small meals” & “meals” include fruit and/or veg as

Apples, applesauce, peaches, berries, bananaSeparate items, toppings, in smoothies

All small meals & meals contain at least one

Most contain at least 1.5 servings

More yogurt/yogurt type drinksfree milk, fortified milk

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Whole Grains: Increasing

• 2010 DGA: 8 grams significant amount

• Cereals (Oct. 2012)− 71% contain ≥ 8 grams whole grains (up from

60% in 2011)

− 1/3 contain ≥ 12 grams whole grains

• More whole grains usage overall (May 2012 analysis)

− 1/3 contain ≥ 12 grams whole grains

− 1/3 list whole grains as first ingredient

Whole Grains: Increasing

8 grams significant amount

71% contain ≥ 8 grams whole grains (up from

1/3 contain ≥ 12 grams whole grains

More whole grains usage overall (May 2012 analysis)

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2012: Cereals Participants Advertise to Children

1/3 contain ≥ 12 grams whole grains

1/3 list whole grains as first ingredient

Recent Changes: Added Sugar

• 2012: Burger King Corp. & McDonald’s dropped caramel dipping sauces

• 2009-2012: Sugar content of cereals in childdirected ads steadily declined– Before CFBAI: 14 or 15 per serving– Before CFBAI: 14 or 15 per serving– Now: Most ≤ 10 grams sugar per serving

Recent Changes: Added Sugar Reductions

2012: Burger King Corp. & McDonald’s dropped

2012: Sugar content of cereals in child-directed ads steadily declined

Before CFBAI: 14 or 15 per servingBefore CFBAI: 14 or 15 per servingNow: Most ≤ 10 grams sugar per serving

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Sodium Reductions:In Many Product Lines & Products

• Individual foods– Cereals (e.g., Lucky Charms: 170 mg from 190 mg)

– Campbell’s advertised kids soups: meet FDA “healthy” 480 mg criterion (from pre-pledge of > 900 mg)

• Main dishes• Main dishes– Campbell’s advertised kids canned pasta: meet FDA’s “healthy”

criterion of 600 mg (pre-pledge: > 900 mg)

– ConAgra Foods kids canned pasta: large reductions, now none exceed 750 mg (> ½ at 600 mg)

• Small meals – ConAgra Foods reduced sodium in

an average of 15% less sodium from 2011 to 2012

• Meals – Sodium reductions in Burger King and McDonald’s kids meals

Sodium Reductions:In Many Product Lines & Products

Cereals (e.g., Lucky Charms: 170 mg from 190 mg)

Campbell’s advertised kids soups: meet FDA “healthy” 480 mg pledge of > 900 mg)

Campbell’s advertised kids canned pasta: meet FDA’s “healthy” pledge: > 900 mg)

ConAgra Foods kids canned pasta: large reductions, now none exceed 750 mg (> ½ at 600 mg)

ConAgra Foods reduced sodium in KC meals advertised to children an average of 15% less sodium from 2011 to 2012

Sodium reductions in Burger King and McDonald’s kids meals16

Fats Content: Overview

• Trans fat: All products labeled 0 grams

• Saturated fat: Most foods contain ≤ 1.5 grams grams – Exceptions:

• Peanut butters contain ≤ 3 grams• Foods made with cheese contain ≤ 3.5 grams• Products with meat contain ≤ 4 grams• Meals do not exceed 10% of kcal from sat fat

Fats Content: Overview

fat: All products labeled 0 grams

Saturated fat: Most foods contain ≤ 1.5

Peanut butters contain ≤ 3 gramsFoods made with cheese contain ≤ 3.5 gramsProducts with meat contain ≤ 4 gramsMeals do not exceed 10% of kcal from sat fat

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Meal “Default” Changes

• Burger King Corp. changed POS practice in 2011 to stop “default”– Now ask what side & beverage wanted (rather

than just giving fries & soda)• Choices include advertised milk, 100% fruit juice, apple • Choices include advertised milk, 100% fruit juice, apple

slices (½ cup = one serving)

• McDonald’s adopted “default” – All Happy Meals come with apple slices (½

serving) and small fries (~ 100 kcal)• Apples can be substituted for fries (get 2 bags)• Buyer selects entrée and beverage

– Choices include advertised white or choc milk, or 100% apple juice

Meal “Default” Changes

Burger King Corp. changed POS practice in 2011 to stop “default”

side & beverage wanted (rather than just giving fries & soda)

Choices include advertised milk, 100% fruit juice, apple Choices include advertised milk, 100% fruit juice, apple slices (½ cup = one serving)

McDonald’s adopted “default” All Happy Meals come with apple slices (½ serving) and small fries (~ 100 kcal)

Apples can be substituted for fries (get 2 bags)Buyer selects entrée and beverage

Choices include advertised white or choc milk, or 100%

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Measuring ProgressMeasuring Progress19

Assessing Progress: CFBAI

• CFBAI compares prior and current nutrition content

• Are advertised foods improving?– Have calories, fats, sodium, or sugars been reduced?– Have calories, fats, sodium, or sugars been reduced?

• Look at gram and percentage changes of key nutrients

– Has fruit, veg, dairy or whole grains content increased?

– Has nutrient content, particularly nutrients of concern content, increased?

• Have foods been dropped or added?

Assessing Progress: CFBAI

CFBAI compares prior and current nutrition

Are advertised foods improving?Have calories, fats, sodium, or sugars been reduced?Have calories, fats, sodium, or sugars been reduced?

Look at gram and percentage changes of key nutrients

Has fruit, veg, dairy or whole grains content increased?

Has nutrient content, particularly nutrients of concern

Have foods been dropped or added?

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Assessing Progress: Others

• Variety of standards used: no uniformity!– Non-U.S. (UK Food Profiling) and criteria that conflict with U.S. DGAs

– Compare nutrition content of child-targeted cereals with adult targeted rather than look at improvements in children’s cereals

• “Go, Slow, Whoa”: illogical, categories and results contrary to DGAs– All low-fat yogurts, no matter how sugary are “Go” foods, while all presweetened – All low-fat yogurts, no matter how sugary are “Go” foods, while all presweetened

cereals, no matter how little sugar or how nutrient dense are “Whoa” foods

• Use of binary (meets/does not meet) metrics: does not identify the steady, incremental change that is our goal– “35-10-35” metric: no credit for improvements such as 5

reductions in sugar if cereal has > 35% sugar by weight

• Use of government standards scorned: meeting FDA’s definition for “healthy” not good enough

• Studies of all ads kids may see: CFBAIfamily/adult-focused ads in prime time dramas/reality shows

Assessing Progress: Others

Variety of standards used: no uniformity!U.S. (UK Food Profiling) and criteria that conflict with U.S. DGAs

targeted cereals with adult targeted ones, rather than look at improvements in children’s cereals

Whoa”: illogical, categories and results contrary to DGAsfat yogurts, no matter how sugary are “Go” foods, while all presweetened fat yogurts, no matter how sugary are “Go” foods, while all presweetened

cereals, no matter how little sugar or how nutrient dense are “Whoa” foods

Use of binary (meets/does not meet) metrics: does not identify the steady, incremental change that is our goal

35” metric: no credit for improvements such as 5-20% or greater reductions in sugar if cereal has > 35% sugar by weight

Use of government standards scorned: meeting FDA’s definition for

ads kids may see: CFBAI focus on child-directed, not focused ads in prime time dramas/reality shows

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What’s Next?22

CFBAI’s New CategorySpecific Nutrition Criteria

• Groundbreaking agreement last July to use new criteria

• CFBAI criteria submitted with – Explained well within scope of what IWG was seeking as an

alternative to its own proposalalternative to its own proposal

• Comment explained IWG nutrition principles unrealistic & unworkable– Sodium limits dramatic example

• To 210 mg per serving (“healthy” level 480 mg) in 5 years

• Further reduce to 140 mg by RACC by 2021

– Functional roles for nutrients not well understood– Consumer acceptance issues misjudged

CFBAI’s New Category-Specific Nutrition Criteria

Groundbreaking agreement last July to use new

CFBAI criteria submitted with comment to IWGwell within scope of what IWG was seeking as an

alternative to its own proposal

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alternative to its own proposal

Comment explained IWG nutrition principles unrealistic & unworkable

Sodium limits dramatic exampleTo 210 mg per serving (“healthy” level 480 mg) in 5 years

Further reduce to 140 mg by RACC by 2021

Functional roles for nutrients not well understoodConsumer acceptance issues misjudged

CFBAI’s CategoryNutrition Criteria Benefits

• Overall stronger than company

– New criteria fill gaps in current participant standards

– Eliminate product qualifying solely on “reduced” claim

– Eliminate product qualifying on 100

– Include calorie limits for all categories

– Include NTL limits & NCTE requirements for all categories

• Limits on saturated fat, trans

• Requirements for food groups and/or nutrients

• Even more transparent/easier to understand

• Rigorous implementation deadline

CFBAI’s Category-Specific Nutrition Criteria Benefits

company-specific criteria

criteria fill gaps in current participant standards

Eliminate product qualifying solely on “reduced” claim

Eliminate product qualifying on 100-calorie packaging

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Include calorie limits for all categories

Include NTL limits & NCTE requirements for all categories

trans fat, sodium, total sugars

Requirements for food groups and/or nutrients

more transparent/easier to understand

Rigorous implementation deadline – Dec. 31, 2013

Developed Through CFBAI’s Nutrition Review

• Goal to develop uniform standards stronger company-specific criteria– 2009 & 2011 IWG proposals one but not only impetus

– Upcoming 2010 Dietary Guidelines a factor

• Participant committee of scientists & nutritionists• Participant committee of scientists & nutritionists– Started work in Spring/summer 2010

• Reviewed wide array of material– 2010 Dietary Guidelines, DGAC report

– Government standards for “healthy,” “low,” etc.

– IWG proposals

– IOM FOP, sodium and school food reports

– AHG, Disney (2006 standards) and QUBO standards

• CFBAI White Paper explains categories/criteria

Developed Through CFBAI’s Nutrition Review

Goal to develop uniform standards OR updated, specific criteria

2009 & 2011 IWG proposals one but not only impetus

Upcoming 2010 Dietary Guidelines a factor

Participant committee of scientists & nutritionistsParticipant committee of scientists & nutritionistsStarted work in Spring/summer 2010

Reviewed wide array of material2010 Dietary Guidelines, DGAC report

Government standards for “healthy,” “low,” etc.

IOM FOP, sodium and school food reports

AHG, Disney (2006 standards) and QUBO standards

CFBAI White Paper explains categories/criteria25

New Criteria Will Drive Further Improvements

• Many recipes need changes if foods to be advertised post Dec. 31, 2013 – ~ 1/3 of CFBAI-listed products (7/2011) fail new criteria

• NTL need to be reduced, OR NCTE need to be increased, OR both need adjustmentneed adjustment

– Affects products in pipeline: many scraped already

• Provides a strong, but reasonable, roadmap for new product development– Incremental changes necessary for consumer acceptance

• Review planned when 2015 DGA issued– Experience and/or changes in guidance may lead to

strengthening criteria

New Criteria Will Drive Further Improvements

Many recipes need changes if foods to be advertised post Dec. 31, 2013

products (7/2011) fail new criteriaNTL need to be reduced, OR NCTE need to be increased, OR both

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Affects products in pipeline: many scraped already

Provides a strong, but reasonable, roadmap for new product development

Incremental changes necessary for consumer acceptance

Review planned when 2015 DGA issuedExperience and/or changes in guidance may lead to

Positive Government Response to CFBAI’s Uniform Criteria

FTC: The CFBAI’s criteria represent “and are “considerably stronger

USDA: “The new uniform CFBAI nutrition criteria appear to USDA: “The new uniform CFBAI nutrition criteria appear to be a step forward in changing the food advertising landscape, while also taking into consideration the feasibility of manufacturers making meaningful changes to the nutrient content of food products

* Congressional Subcommittee Hearing on Food Marketing to Children (Oct. 12, 2011)

Positive Government Response to CFBAI’s Uniform Criteria

criteria represent “substantial progress” considerably stronger than the status quo.”*

The new uniform CFBAI nutrition criteria appear to The new uniform CFBAI nutrition criteria appear to step forward in changing the food advertising

, while also taking into consideration the feasibility of manufacturers making meaningful changes to the nutrient content of food products.”*

* Congressional Subcommittee Hearing on Food Marketing to Children (Oct. 12, 2011) 27

Conclusion: SelfChild-Directed Food Advertising

• Healthier foods advertised as IOM recommended– Well over 100 reformulated, new or enhanced foods

– Some foods no longer advertised or discontinued

– Reformulation and innovation continuing

• Dynamic program has been expanded/enhanced • Dynamic program has been expanded/enhanced – More ad venues covered as of Jan. 1, 2010

– Child-directed ad definitions substantially harmonized

• Uniform nutrition criteria adopted– Product reformulation aligned with DGA goals

– New CFBAI uniform criteria = even more improvements

– Commitment to review criteria going forward

Conclusion: Self-Regulation Improving Directed Food Advertising

Healthier foods advertised as IOM recommendedreformulated, new or enhanced foods

Some foods no longer advertised or discontinued

Reformulation and innovation continuing

Dynamic program has been expanded/enhanced Dynamic program has been expanded/enhanced More ad venues covered as of Jan. 1, 2010

directed ad definitions substantially harmonized

Uniform nutrition criteria adoptedProduct reformulation aligned with DGA goals

New CFBAI uniform criteria = even more improvements

Commitment to review criteria going forward

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