Prepared Foods July 25, 2005 enewsletter

An analysis released by the Public Health Advocacy Institute [PHAI] has sharply criticized industry self-regulation of food marketing messages to children. "Industry Controls Over Food Marketing to Young Children: Are They Effective?" finds the system is "ineffective when measured against available criteria for gauging the adequacy of self-regulation, and also ineffective in the context of the worsening obesity epidemic and its damaging impact on children."

The analysis was submitted to the Federal Trade Commission, which held a public meeting in Washington to consider the adequacy of the industry's self-regulatory system.

PHAI's analysis tests the Children's Advertising Review Unit's (CARU) operation and performance against a wide array of benchmarks, including criteria suggested by "Corporate Codes of Conduct: Self-Regulation in a Global Economy," a study published by the United Nations Research Institute for Social Development, and "Review of Research on the Effects of Food Promotion to Children," published by the U.K. Food Standards Agency.

Against these benchmarks, the PHAI analysis finds the CARU scheme and its potential for effectiveness are seriously flawed and not salvageable. It notes CARU fails to "provide an adequate public interest response" to public health needs; lacks "strong independent input, well-resourced monitoring and tough sanctions for breaches of the rules"; "applies subjective criteria in assessing advertisements; does not review advertising prior to dissemination; lacks third-party review of its decision, and cannot enforce its decisions, which can be ignored by advertisers."

According to PHAI, the proposals of the Grocery Manufacturers Association (GMA) to improve self-regulation do not address some of the most serious failings of CARU and self-regulation outlined in the PHAI analysis. The GMA proposal does not provide any mechanism for effective sanction or enforcement, does not provide for true transparency and suggests no clear objective criteria for monitoring advertising and marketing.

"It is unrealistic to expect that the U.S. advertising and food industries can or will make a positive contribution to obesity control by becoming effective self-regulators of marketing that targets children with messages urging purchase and consumption of high-calorie, low-nutrition foods," the PHAI analysis concludes. Unlike CARU, an effective regulatory system must place "the highest priority on the public health needs of children," PHAI asserts

A complete copy of "Industry Controls Over Food Marketing to Young Children: Are They Effective?" can be downloaded at