Proposed Guidelines for Marketing Foods to Children

The Federal Trade Commission (FTC) recently proposed some guidelines for marketing foods to children. The deadline for comments on the guidelines is June 13, 2011.

In 2009, the FTC, CDC, and USDA formed the Interagency Working Group on Food Marketed to Children, which they shortened to the Working Group. They were assigned to develop recommendations for standards for the marketing of food to children β€œwhen such food represents a significant component of the diets of children.”

Industry marketing practices towards children have been receiving a lot of attention.Β  The Center for Science in the Public Interest has made curbing junk food marketing towards children one of their Food Day principles.

The proposed guidelines have been released in the form of two principles:

Encourage Good Habits Through Responsible Advertising

Principle A: Advertising and marketing should encourage children to choose foods that make a meaningful contribution to a healthful diet. The foods should contain a significant amount of at least one of the following food groups: fruit, vegetable, whole grain, fat-free or low-fat dairy, fish, extra lean meat or poultry, eggs, nuts and seeds, or beans.

The FTC has asked for comments on whether the foods should contain at least fifty percent by weight of one or more of those food groups or a specific minimum amount of the food groups. Starting on page 16 of the proposed guidelines document (pdf), the amounts under consideration for each food group are listed.

Discourage Bad Habits Through Responsible Advertising

Principle B: Advertising and marketing should encourage children to minimize consumption of food with significant amounts of nutrients that could have a negative impact on health or weight – specifically sodium, saturated fat, transfat, and added sugars.

The foods should contain:

  • less than 210 grams of sodium per serving
  • one gram or less per serving and no more than 15% of calories from saturated fat
  • no transfats
  • no more than thirteen grams of added sugars

The guidelines state that naturally occurring nutrients don’t count towards the limits. Saturated fats would only count if they were added during processing (deep fried avocadoes?) Added sugars are only sugars added during processing. So, if a company sliced up an apple with its 16 grams of sugar and coated it with 12 grams of sugar for a total of 28 grams of sugar, they would be within the guidelines.

How Will the Principles Be Used?

The principles are intended to be applied the foods most heavily marketed to children. The FTC listed ten categories they want the food industry to focus on: breakfast cereal, snack food, candy, dairy products, baked goods, carbonated beverages, fruit juice and non-carbonated beverages, prepared foods and meals, frozen and chilled desserts, and restaurant foods.

It’s important to note that consumer choice will not be limited by these guidelines.Β  We’ll still be free to buy sugary cereals for our kids and send them to school with a lunchbox full of snack cakes.

The proposed guidelines are voluntary, so they’re pretty much just mild suggestions of what the food industry might possibly want to consider when formulating ad campaigns. But they don’t have to act on them.

Nevertheless, consumer opinion has an effect on how the food industry markets to us. If enough citizens comment on the guidelines, the companies that advertise to our children will notice. Pages 21-24 in the proposed guidelines document have specific questions the FTC wants public opinion on, although we’re not limited to just those questions.

What Can You Do?

The FTC has a request for how to submit the comments:

Comments on issues relating to the proposed nutrition principles, including comments on the food categories identified in the principles, will be reviewed primarily by the CDC, FDA, and USDA. Comments on issues relating to the proposed definitions of marketing and all other general comments will be reviewed primarily by the FTC. The Working Group therefore requests that, to the extent possible, comments be submitted separately on these two aspects of its recommendations.

To comment, either use the FTC’s web form or mail your comments to

Federal Trade Commission, Office of the Secretary
Room H-113 (Annex W)
600 Pennsylvania Avenue, N.W.
Washington, D.C. 20580

Check page 27 of the proposed guidelines document for a few specific instructions on how to label your mail. Mailed comments will be posted on the same web site as comments submitted through their online form.

The deadline is June 13, 2011 – just about a month away. Rest assured the food industry will get their opinions heard.

Image by HeyDanielle, used with Creative Commons license.

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