DHSC/DCMS proposals for introducing further advertising restrictions for TV and online for products high in fat, sugar and salt (HFSS) - Which? response

Summary:

• Which? welcomes these proposals from the Government to introduce further advertising restrictions on TV and online for products high in fat, sugar and salt (HFSS) to help support families and children in making healthier food choices. We agree that these are priority areas for stronger protections for children from unhealthy food marketing that current regulation and self-regulation do not address adequately.
• Our research into this issue over many years has found that HFSS foods are marketed to children through a variety of media and techniques, which are becoming increasingly integrated and, in some cases, difficult for parents and guardians who are potentially less media aware or not the target of the advertising to keep track of. Our wider work on consumer data controls1has highlighted the increased use of digital and people-based marketing that needs to be carefully considered.
• We support the overall approach to strengthening restrictions on TV by introducing a 9pm -5.30am watershed for HFSS advertising using the 2004/5 Nutrient Profile Model, but think that this needs to be supported by wider controls that recognise how children now access TV on-demand and through digital channels.
• We support a mixed approach to strengthening restrictions online recognising that a watershed would improve protections in TV-like content, but does not necessarily address the sophisticated techniques used to target children particularly via social media platforms.
• Issues concerning the use of children’s data by advertisers and the risks this may pose, as well as how they can be monitored, fully understood and mitigated need to be addressed alongside wider government initiatives focused on online harms.