CCFC’s Comments to the Federal Trade Commission: Industry’s Experiment in Self-Regulation Has Failed

On July 14-15, the Federal Trade Commission will hold a workshop on Marketing, Self-Regulation, and Childhood Obesity. In preparation for the workshop, CCFC submitted comments that declared the current system of advertising industry self-regulation a failure. The comments were signed by fifteen of CCFC’s member organizations. A summary of the comments appears below; the complete text of the comments is available at http://www.ftc.gov/os/comments/FoodMarketingtoKids/516960-00053.pdf.

The advertising industry’s thirty-year experiment with self-regulation has failed. Children see more marketing in more venues than ever before and much of this marketing is for unhealthy food. Child-targeted marketing influences children’s food choices, contributes to the childhood obesity epidemic, and makes parents’ lives more difficult.

The industries responsible for this marketing cannot fix these problems without government restrictions; merely tweaking the existing system of self-regulation is not the answer. Far too often there is a conflict of interest between industry’s mandate to make a profit – a legal mandate in the instance of corporations – and public health and safety. Ultimately it is the government’s role, not the role of corporations, to safeguard the health of our children.

There is no doubt that food marketing is a factor in children’s consumption of unhealthy food and in the rise of childhood obesity. Studies of food marketing to children conducted by such august bodies as the World Health Organization, the Kaiser Family Foundation, the British Food Commission, and the Institute of Medicine all point to a link between child-targeted marketing and childhood obesity. While food marketers tend to minimize or deny the connection between children’s food choices and advertising, this stance is puzzling. Either advertising works or it doesn’t. If it works, then the marketing targeted to children will lead to a rise in consumption of the products being advertised to them. If it doesn’t work, then why are companies spending billions of dollars annually to target children?

Any legitimate conversation about marketing—including one about self-regulation—must include the point of view that government regulation, not self-regulation, is the best way to minimize the negative effect that advertising and marketing have on the health and well-being of children.

Read the complete text of CCFC's comments.

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