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Regulatory axes on food advertising to children on television

Regulatory axes on food advertising to children on television This article describes and evaluates some of the criteria on the basis of which food advertising to children on television could be regulated, including controls that revolve around the type of television programme, the type of product, the target audience and the time of day. Each of these criteria potentially functions as a conceptual device or "axis" around which regulation rotates. The article considers examples from a variety of jurisdictions around the world, including Sweden and Quebec. The article argues that restrictions centring on the time of day when a substantial proportion of children are expected to be watching television are likely to be the easiest for consumers to understand, and the most effective in limiting children's exposure to advertising. Background cross-purposes. In particular, advocates of stricter regula- When it comes to television food advertising and child- tion do not claim that food advertising is the only cause hood obesity, it seems that everybody has an axe to grind. of childhood obesity, and yet they are frequently por- Health and consumer groups claim that food advertising trayed as espousing just such a view. contributes to an obesegenic environment for children, and should be curtailed, if not banned outright [1]. The Recent studies have found a direct correlation between broadcasting, advertising and food and beverage indus- children's exposure to food advertisements and their food tries dispute that regulation can help curb the rate of preferences [7,8]. Research also confirms that the majority childhood obesity, and (yet) insist they want to be part of of foods advertised on television during periods when the solution [2]. The television production industry is children are likely to be watching are high in sugar and fat concerned that additional restrictions on advertising to [9]. If preferences are a predictor of actual consumption, children could cause the market in children's programs to then it is reasonable to conclude that television advertis- dry up [3], and in Australia at least, the regulator appears ing leads children to consume more food of low nutri- to have accepted such arguments [4]. The previous Aus- tional value – which is often calorie dense and contains tralian government refused to take action on the ground high levels of sugar and fat – than they would otherwise that children's diets and lifestyles are a matter of personal do. On this view, children's daily energy intake is being choice and parental responsibility [5], and during the inflated without corresponding increases in opportunities 2007 election campaign Kevin Rudd, the new Prime Min- for physical activity. In public health parlance, food adver- ister, more or less agreed [6]. As with many complex tising to children contributes to an "obesegenic" environ- debates where the stakes are high, participants are often at ment. Page 1 of 10 (page number not for citation purposes) Australia and New Zealand Health Policy 2009, 6:1 http://www.anzhealthpolicy.com/content/6/1/1 At the time of writing there is debate in numerous coun- as this is the role that the research has identified for food tries as to whether food advertising should be more tightly advertising in contributing to childhood obesity. To bor- regulated. If that debate is resolved in favour of tighter reg- row a term that has been used frequently by the High ulation – if the axe falls – the next question will be how Court of Australia in determining the constitutionality of best to regulate food advertising in order to reduce chil- legislation, what is needed are criteria that are "appropri- dren's exposure to it. This article evaluates some of the ate and adapted" [10] to reducing children's exposure to core concepts through which regulators could differenti- food advertising, or to moderating the impact of food ate between advertising that is subjected to lighter, and advertising on children's food preferences. As will be seen, heavier, regulatory burdens. It is helpful to think of the not all criteria fit this description. conceptual device used in each case as an "axis" around which regulation rotates. This allows an appraisal of dif- Although this article is not (only) about the Australian ferent forms of regulatory options, each turning on a cer- regulatory system for advertising on commercial free-to- tain element of the advertising or context in which it is air television, it may be useful to provide a brief descrip- shown. tion of its key elements. Australia has a system of co-regu- lation, meaning that both government and industry have This article identifies a selection of regulatory axes cur- a role. The government contributes through the Australian rently in use and evaluates their relative likely effective- Communications and Media Authority (ACMA), which ness in achieving the goals of usability by average viewers exercises a range of functions under the Broadcasting Serv- and of limiting children's exposure to advertising that ices Act 1992 (Cth), including propounding and enforcing could influence their food preferences. In the interests of the Children's Television Standards (CTS). These impose brevity, this article deals only briefly with regulatory con- content quotas on commercial free-to-air broadcasters trols that focus on the content or effect of the advertise- relating to quality children's programming, and they also ment; for example, advertisements that have the effect of impose certain restrictions on the advertising that can be placing pressure on children to request the product from shown at the time when that programming is scheduled. their parents ("pester power"), or advertisements that The CTS rely on the public to notice breaches of the pro- contain inaccurate health or nutritional information. visions and to complain to ACMA. A range of civil sanc- Information and references in the article are current to tions is available for breaches of the CTS. At the time of February 2008 (but the authors note in particular that a writing the CTS are under review. revised version of the AANA code on advertising to chil- dren was introduced in April 2008). The industry body Free TV Australia contributes by devel- oping and maintaining the Commercial Television Indus- The first point to make is that regulatory axes need to pro- try Code of Practice (CTICP), which covers a range of vide criteria that are clear and easy to understand. This is matters listed in the Broadcasting Services Act and is regis- particularly the case if the regulatory system relies on con- tered by ACMA in accordance with that Act. Among other sumer complaints to activate its machinery, as is the case things the CTICP extends the CTS advertising restrictions in Australia. In order to maximise the likelihood that con- to advertisements "directed to children". It also contains sumers will recognise breaches and take the trouble to certain additional restrictions on advertising directed to complain, regulations should use criteria that are mean- children that are not found in the CTS. As with the CTS, ingful to the average person. Such a person is not likely to enforcement relies on consumer complaints, but in this bother complaining unless he or she can be reasonably case the complaints must go first to the broadcaster. A confident that a breach has occurred. consumer who is unsatisfied with the broadcaster's response to the complaint can then take the matter to Not all criteria being used around the world at the ACMA. moment are consumer-friendly in this sense. Many are vague and inherently open to interpretation, or such that The advertising industry has contributed to the regulatory reasonable minds may differ as to whether they have been environment by developing a number of codes (AANA met. In law we may be accustomed to such standards; Codes) that apply not just to television but to all media. arguing over them is the stock in trade of lawyers. It is dif- These do not have any legislative basis and the govern- ferent, however, in consumer-protection regulation. Con- ment has no role in their enforcement. Complaints are sumer complaints mechanisms do not support systematic determined by the Advertising Standards Board, an indus- input by professionals on both sides of the argument. try body. On the other hand, some of the AANA Codes Therefore the industry side tends to carry the day, even if have been incorporated into the CTICP. a consumer does take the trouble to mount the argument that a regulatory standard has been breached. This article now provides a selective review of those "reg- ulatory axes" that currently apply, or could apply, to food Second, regulation needs to limit the opportunities for advertising to children. food advertising to influence children's food preferences, Page 2 of 10 (page number not for citation purposes) Australia and New Zealand Health Policy 2009, 6:1 http://www.anzhealthpolicy.com/content/6/1/1 less than if the programme were of primary interest to The criteria 1. The type of program them, however that might be defined. Some regulations apply only to advertising shown during children's programs. There are a number of ways of defin- 2. The type of product ing this category. Food generally Food itself does not cause obesity; rather, obesity tends to Dedicated children's programming be the result of certain patterns of consumption of food, In Australia, the regulations that are directly enforced by and especially particular types of food. Indeed, food is the government, the Children's Television Standards, necessary for life. Therefore, it would be politically unpal- apply during periods that licensees have set aside for "C" atable to introduce a regulation to do away with all adver- programs, that is, dedicated children's programming that tising of any kind of food, as in principle, it would be has been classified as meeting certain regulatory criteria. taking matters too far. These programs are broadcast in fulfilment of a quota imposed on commercial free to air broadcasters. Audi- However, it is difficult to distinguish between foods that ences for these programs are relatively small, therefore the should and should not be caught by an anti-obesity regu- advertising restrictions have little impact on the amount lation, and it may lead to excessive hair-splitting and or kind of advertising to which children are exposed. interpretive debate. Moreover, it is arguable that if food is necessary for life, it should not be necessary to advertise it! There are broader approaches to the idea of "children's If a general ban on food advertising were applied, how programming" that do not involve a need for formal clas- much beneficial food advertising would be caught? sification. For example section 7b of the Swedish Radio According to the Australian lobby group, the Coalition on and Television Act 1996 requires the regulator to determine Food Advertising to Children, the answer is: not very to whom the programme is addressed: much. Therefore it advocates a ban on all commercial food advertising during times when a substantial propor- ... programmes primarily addressed to children under tion of children are in the audience [1]. twelve years of age may not be interrupted by advertis- ing. ... Commercial advertising may not occur imme- Since "food" as a category has meaning to the average con- diately before or after a programme or part of a sumer, it would normally be fairly easy to tell if a particu- programme that is primarily addressed to children lar advertisement was caught by any regulation using it as under twelve years of age [with certain exceptions]. an axis. The main reservation to this would relate to adver- tisements structured in such a way that they are for a com- Similarly, the new British regulations apply to programs pany that sells food, rather than for a particular food "specifically made for children" and programs "of partic- product. Sometimes such companies have campaigns that ular appeal to children" [11]. do not mention food at all, but only, for example, encour- age increased physical activity by children. However, such Such approaches, however, necessarily introduce a meas- advertisements are usually still heavily identified with the ure of vagueness. For example, what does it mean to say a company's logo and visual symbols. There may be room program is "of particular appeal to children"? Does it for debate and confusion as to whether they are advertise- mean that the program appeals more to children than to ments for food, strictly speaking, but there is no reason to adults? Or that it appeals to children more than other pro- doubt that they would have the effect of increasing chil- grams do? Clearly the reach and effectiveness of the regu- dren's favourable disposition towards the company's lation in limiting children's exposure to food advertising brand, and therefore also their preference for its food. will vary depending on how this question is answered. And even once the question is answered it will not always Arguably, then, an effective system for minimising the be easy to categorise any given program. impact of advertising on children's food preferences and nutrition behaviours should be addressed at brands as Another problem with a regulatory axis that focuses on well as at particular products. While on the surface this the type of program is that it tends to overlook the fact could look like victimisation of the companies in ques- that children watch many shows that are not "of particular tion, or some form of "guilt by association", it would have appeal" to them in either of the above senses. Young chil- the virtue of addressing the way that advertising works, by dren might not be terribly attracted by a prime-time sit- establishing brand loyalty. We are not aware of any regu- com such as How I Met Your Mother, for example, but if lation, anywhere in the world, using such an axis. their parents are watching it, the children probably will too. And even if they are not interested in the programme, Rather, there are numerous lesser restrictions, short of a chances are their attention will be drawn by the advertise- ban, that apply to all food advertising. For example, in Aus- ments. Therefore they are still exposed to advertising, no tralia Children's Television Standard (CTS) 19(6) states: Page 3 of 10 (page number not for citation purposes) Australia and New Zealand Health Policy 2009, 6:1 http://www.anzhealthpolicy.com/content/6/1/1 An advertisement for a food product may not contain a. Advertisements representing a mealtime should any misleading or incorrect information about the depict the food product within the framework of a nutritional value of that product. nutritionally balanced meal. Other provisions, such as Clause 6.23 of the Commercial b. Snack foods should be clearly depicted as such, and Television Industry Code of Practice, and clauses (b)7, not as substitutes for meals. (b)8 and (b)9 of the Children's Advertising Review Unit (CARU) Self-Regulatory Program for Children's Advertis- The AANA has propounded an entire code dedicated to ing in the United States, single out food advertisements food and beverage advertising, the Food and Beverage for special scrutiny. Clause 6.23 provides: Advertising and Marketing Communications Code. 6.23 Advertisements directed to children for food and/ The extent to which food advertisements might fall foul of or beverages: these provisions depends on the application of criteria that go beyond the mere fact of the advertisement being a 6.23.1 should not encourage or [expressly endorse] food advertisement. However, the regulations set out [not engaging in any or much physical activity as a way above provide illustrations of the kinds of restrictions that of life]; could turn on the "food" axis. The very variety of approaches available makes it difficult to comment on the 6.23.2 should not encourage or [expressly endorse] food axis in a general way, other than to say that the pres- [excessive or compulsive consumption of food and/or ence in numerous instruments of regulations revolving on beverages] .... this axis suggests a wide recognition of the sensitivity of food as a category. The Australian Association of National Advertisers (AANA) Advertiser Code for Advertising to Children con- "Junk" food tains a similar provision in Clause 2.10, except that to fall There is a compelling logic to the idea of limiting advertis- foul of it, an advertisement must encourage or promote ing restrictions to foods considered to be especially likely both inactive lifestyle and overconsumption. to contribute to obesity in children. Most people would instinctively include on any such list "fast" foods such as The US provisions state as follows: hamburgers, chips and fried chicken; confectionery including chocolate; ice cream; and salty snacks such as 7. The amount of product featured should not be potato chips. However, drawing the boundaries between excessive or more than would be reasonable to healthy and unhealthy foods is not a simple matter as it acquire, use or consume by a person in the situation must always involve balancing the nutritional value of the depicted. For example, if an advertisement depicts food with any excessive levels of fat or sugar. food being consumed by a person in the advertise- ment, or suggests that the food will be consumed, the For example, flavoured yoghurt contains the beneficial quantity of food shown should not exceed the labelled nutrients of protein, calcium and vitamins – but also a serving size on the Nutrition Facts panel; where no considerable amount of sugar. It is a healthier snack than, such serving size is applicable, the quantity of food say, chocolate, but overconsumption can still contribute shown should not exceed a single serving size that to obesity. Reasonable minds will disagree on whether it would be appropriate for consumption by a person of should be included or excluded from a list of foods to be the age depicted. subject to advertising restrictions in the name of prevent- ing childhood obesity. 8. Advertising of food products should encourage responsible use of the product with a view toward There are various ways of dividing food up into "good" healthy development of the child. For example, adver- and "bad" categories for the purposes of regulation. One tising of food products should not discourage or dis- is nutrient profiling, which is the approach that the UK parage healthy lifestyle choices or the consumption of has recently adopted in order to identify foods high in fat, fruits or vegetables, or other foods recommended for sugar and salt – referred to as HFSS foods. The Australian increased consumption by current USDA Dietary Communications and Media Authority Issues Paper for Guidelines for Americans and My Pyramid, as applica- the Children's Television Standards Review said that "this ble to children under 12. option [is] currently unviable in the Australian context" but did not explain why the British system could not be 9. Advertisements for food products should clearly adopted here. Nor did it appear to recognise the existence depict or describe the appropriate role of the product under Food Standards Australia and New Zealand of a within the framework of the eating occasion depicted. profiling system [12]. Page 4 of 10 (page number not for citation purposes) Australia and New Zealand Health Policy 2009, 6:1 http://www.anzhealthpolicy.com/content/6/1/1 Another possibility in Australia would be to use the dis- ing against an advertisement for some major categories of tinctions between basic food items and luxuries that have food. been drawn up for the purposes of the goods and services tax [13]. This would have the virtue of a degree of famili- 3. The (apparent) target audience arity within the Australian community; but on the other The majority of regulatory rules for the protection of chil- hand it would not necessarily distinguish neatly and accu- dren from advertising single out for added restrictions rately between healthy and non-healthy foods. advertising that has children as its target audience. For example, Quebec and Sweden are well-known for having Regulations revolving on the "junk food" axis share the strict rules to protect children from advertising; this is the problem adverted to earlier, of advertisements for brands kind of axis used in both places. In Quebec, s 248 of the rather than particular products. Indeed the problems are Consumer Protection Act 1980 provides in part: more deeply ingrained in the case of a "junk food" axis because restaurant chains that have traditionally special- no person may make use of commercial advertising ised in burgers and fried foods have recently started to directed at persons under thirteen years of age. introduce healthier alternatives. The same would be said (emphasis added) of a number of food and beverage companies that pro- duce a range of products, some of which are healthier than It is worth noting that this provision extends to all adver- others. A regulatory system that was serious about limit- tising, not just food and not just that on television. The ing the effect of advertising on children's food preferences Swedish ban appearing in Chapter 7, s 4 of the Radio and and nutrition behaviours would include restrictions on Television Act 1996, by contrast, applies only to television: the use of more general advertising that could attract chil- dren to a brand, or an outlet, where unhealthy food dom- Commercial advertising in a television broadcast may inates. not be designed to attract the attention of children under 12 years of age. (emphasis added) Children's food In some cultures, it is possible at some level to distinguish Australian regulations contain provisions that divide the between children's foods and other foods, and there is a world up in a similar way. For example, Clause 6.20 of the superficial logic to singling such foods out for special Commercial Television Industry Code of Practice applies attention when imposing restrictions on advertising for the advertising restrictions from the Children's Television the protection of children. Standards to advertising "directed to children" and Clause 1(c) of the Advertiser Code for Advertising to Children An example of such an approach is in the Australian Asso- applies to "Advertisements which ... are directed primarily ciation of National Advertisers Advertiser Code for Adver- to Children". (As mentioned above, this latter provision is tising to Children (ACAC). As we shall see in the next further restricted to advertisements for children's prod- section, the ACAC applies only to advertising that is ucts). aimed at children; its application is limited further in that the product being advertised must be one which is "tar- The first question about such an axis is whether the judg- geted toward" children and has "principle [sic] appeal" to ment is subjective or objective: does the regulation cover children (see Clause 1(c) in conjunction with (b)). There- advertisements whose authors intend to catch children's fore, in so far as the Code applies to food advertising, it attention, or advertisements that are expected to have that applies only to this subset of foods. effect irrespective of intent? The Swedish provision, in par- ticular, makes it sound as if it might be the former, which As with the notion of children's programming, children's is clearly the narrower of the two approaches. However, food is not an easy category to define. There is considera- the more usual approach is a broader one of providing cri- ble room for debate as to whether products like hamburg- teria for determining whether an advertisement meets the ers, fried foods, chocolate and potato chips would be seen definition. Section 249 of the Quebec legislation pro- as being in the category, or whether their appeal to adults vides: would rule them out. Yet these are clearly some of the foods for which children have been developing too great To determine whether or not an advertisement is a preference and effective anti-obesity regulation should directed at persons under thirteen years of age, include them. account must be taken of the context of its presenta- tion, and in particular of: Moreover, the very vagueness of the category would make it difficult to know whether it would be worth complain- (a) the nature and intended purpose of the goods advertised; Page 5 of 10 (page number not for citation purposes) Australia and New Zealand Health Policy 2009, 6:1 http://www.anzhealthpolicy.com/content/6/1/1 (b) the manner of presenting such advertisement; � the target audience for the commercial – is the target audience children? This is relevant where the other fac- (c) the time and place it is shown. tors set out above indicate that a commercial is intended to appeal to children. In Sweden, the three criteria used for assessing whether an advertisement is "designed to attract the attention of chil- It remains to be seen just how these factors will work in dren under 12 years of age" are roughly the same: the practice. For example, is it sufficient for one criterion to be design of the advertisement, the type of product and the met, or must they all be met before an advertisement will context of the broadcast [14]. In the USA, the Children's be thought of as "directed at children"? Advertising Review Unit Self-Regulatory Program document lists four factors, revolving around the adjacent program- It may be useful to consider the example of an advertise- ming and the apparent intent of the advertiser (see para- ment that the broadcaster did not consider to be "directed graph II(A)(1)(a)-(d)). to children", albeit under the previous version of the Code which did not contain the Advisory Note. This was one In Australia, the official publication containing the Com- where an adult addressed comments (ostensibly) to par- mercial Television Industry Code of Practice (CTICP) con- ents about the vitamins and minerals in a highly sugared tains a document entitled Advisory Note: Commercials or breakfast cereal. The advertisement was considered not to Community Service Announcements Directed to Children, be directed to children [15] even though (a) the product which is stated to be: is one that is of primary interest to children, and (b) the adult concerned is a well-known children's entertainer. intended to provide guidance on the factors licensees will consider in assessing who [sic] a commercial is Under the Advisory Note, the first factor would suggest directed to for the purpose of applying Clause 6.23 of that the advertisement was directed to children, but the the Code "Commercials or Community Service Announce- rest would suggest the opposite. Therefore, if a balancing ments Directed to Children". (emphasis in original) approach were taken, we might expect that the result would be the same: the advertisement would not be con- Clause 6.23, set out above, is a provision relating specifi- sidered to be "directed to children". It is interesting to cally to food advertisements. The factors for consideration note that the presenter's status as a children's entertainer under the Advisory Note are: is not "caught" by any of the factors. She is not a child actor depicted using the product, but neither is she unrec- � the nature of the product or service, and the persons ognisable to children. most likely to be interested in that product or service – is the product or service one for which children are the Another example of how this kind of axis works in prac- only users or form a substantial part of the market?; tice comes from Quebec: in an advertisement for a fast- food restaurant chain, a man is shown taking a young boy � the theme of the commercial – are adult or children's to the restaurant. The child is clearly enthusiastic about themes used? For example, characters such as mon- being there, and is shown at the table with a child's meal sters, animals and the like; in front of him. But the "story line" of the advertisement is the man's interest in the number of attractive women in � the 'story line' and the approach taken in selling the the restaurant eating salads. He is shown noticing them, product or service – is the story line aimed at children? then at the end of the advertisement the boy says, "There For example, does the commercial have a simple are lots of ladies here, aren't there?" and the man says, uncomplicated plot structure such as 'good' against "Really? I hadn't noticed." Therefore on the surface, the 'evil'?; advertisement is addressed to single heterosexual men. Also it places greater emphasis on the restaurant chain's � the visuals used in the commercial – are the visuals salad lines than on the unhealthy fast-food for which it is aimed at children? For example, the commercial uses traditionally known. Unless a single element is sufficient animation or imaginative visuals which appeal to chil- to satisfy the Advisory Note to Clause 6.23 of the CTICP dren; (which seems unlikely), this advertisement would pass muster under the CTICP as not being "directed to chil- � the language of the commercial – does the commer- dren". Although the little boy is seen 'actively using a cial use children's language?; product or service for which children constitute the mar- ket', every other element of the advertisement is contrary � the age of actors appearing in the commercial – are to what is described in the Advisory Note. The advertiser child actors depicted actively using a product or service would claim that the 'product or service' being advertised for which children constitute the market?; and is the salads, not one 'for which children are the only users Page 6 of 10 (page number not for citation purposes) Australia and New Zealand Health Policy 2009, 6:1 http://www.anzhealthpolicy.com/content/6/1/1 or form a substantial part of the market'. The theme of limited to the impact of children's advertising in this picking up attractive women is not a children's theme, and sense, so there is no reason to limit regulations in this way for the same reason the 'story line' is clearly not aimed at either. We argue that a regulation applying only to adver- children. The visuals are not child-oriented, in the sense tising aimed at children is inherently inappropriate and that there is no animation or similar, and the language is ill-adapted to addressing the contribution of food adver- not children's language but rather a life-like conversation tising to childhood obesity. between an adult and a child. The advertisement was pre- sumably permissible under Quebec's strict laws for much 4. The time of day the same reasons, under the "manner of presenting" con- The discussion above suggests that it is better, and easier sideration contained in s 249(b). Yet there is nothing to for consumers, if regulation uses different times of day, suggest that a child would not have noticed the advertise- rather than the type of program, the type of product or the ment, and received its selling message about the chain. target audience, for determining the level of advertising restriction that applies. Reliance on times of day has the A third example comes from Swedish television. An adver- important virtue of centring levels of regulation on an tisement for cheesy snacks shows a cartoon-style mouse objectively verifiable fact, and it is not left to consumers or superhero ("Mouseman") rescuing a cartoon-style old regulators to interpret more subjective criteria. Such cer- lady (conservative 50 s-style skirt suit and pillbox hat with tainty may also be beneficial for broadcasters. a veil) who has been mugged by some cartoon-style rob- bers (striped jumpsuits and eye masks), to deprive her of The current regulatory system in Australia does not draw a large piece of cartoon-style cheese she is carrying (a lines according to times of day, except in the general sense wedge, with holes). However the advertisement is not a that the Commercial Television Industry Code of Practice cartoon, rather it is live action with a cartoon-like design. (CTICP) lays down classification zones during which Also, it is in English. These, presumably, were the reasons material must meet certain criteria relating to matters such it was able to be shown on Swedish television. Yet once as coarse language, sexual references and adult themes. again there is no reason to think that a Swedish child's While these restrictions extend to advertisements, they do attention would not be drawn by the advertisement. Still not have any particular application to food advertising. less could one say that a child seeing the advertisement would not have been exposed to food advertising. When children are watching There are three possible ways of dividing up the day and In all of the above systems, consumers and regulators are the week according to when children are watching. One is provided only with a list of factors to take into considera- to make observations about how children spend their day tion, and not with a definition as such. The need to bal- and when they will therefore be available for television ance a number of different considerations means that it is watching. The presumption is then made that many chil- impossible to say with certainty what the conclusion will dren will be watching at those times. This happens to be, and this is telling in itself. In any system which, like some extent in the setting of classification zones on Aus- Australia, relies on complaints from consumers to alert tralian television: for example, children are presumed to authorities to possible breaches, the number of com- be in school until 3.30 pm on weekdays, so under Clause plaints is bound to be minimised by maximising uncer- 2.8 of the CTICP, the "G" classification zone does not start tainty as to whether a breach has occurred. until 4.00 pm. It is otherwise during school holidays: see Clause 2.9. This might be called the 'opportunity to watch' The foregoing discussion shows that regulatory axes of approach. this kind – that is, those that centre on some notion of a target audience for the advertisement – have a superficial The other two ways of setting time zones are based on appeal but are inherently vague and open to interpreta- consideration of data on actual viewing patterns, but use tion. This is especially so where multiple factors need to them in different ways. One looks at when children make be balanced against each other. It would be far easier for up a given proportion of the audience; the other looks at consumers to identify breaches under a "single factor" the proportion of children who would be expected to be test, where heightened scrutiny was activated by any one watching at a given time. Both of these are based not on factor indicating children are targeted. opportunity but on actual audience information. In addition, target audience tests have a limited capacity The first of these two approaches is more favourable to to restrict children's exposure to food advertising, because privileging the commercial interests of the TV station there is no reason to think that they do not notice any which would wish to have access to the greatest number other kind of advertisement. The research on the impact of adult viewers. If children are a large proportion of the of food advertising on children's choices has not been audience, that means there are relatively few adult viewers Page 7 of 10 (page number not for citation purposes) Australia and New Zealand Health Policy 2009, 6:1 http://www.anzhealthpolicy.com/content/6/1/1 to whom access is being restricted. The more adult view- tion, however, we provide a few indications of what such ers, the more the broadcaster has to lose as a result of axes consider to be relevant features, and the factors that advertising restrictions. However, such an approach has limit the effectiveness of some such axes. In addition to only limited capacity to restrict children's exposure to the matters discussed below, it is worth noting that some food advertising. The fact that a large number of adults of the elements used to determine whether an advertise- might be watching does not change the potential impact ment is aimed at children also refer to elements of content of the advertising on the child audience. (see eg Cl 6.23 of the CTICP, quoted above). A more effective approach is to consider what proportion Use of personalities of children are expected to be in the television audience at Many regimes have specific rules about the use of person- a given time. If restrictions are tighter at times when large alities in children's advertising, for example Children's numbers of children are watching, this means that more Television Standard 22 (Australia); Radio and Television Act children are having their exposure limited. 1996, Chapter 7, Section 4 (Sweden); Broadcast Code of Advertising Practice, section 7.2.4 (UK); Code for Advertis- Whichever approach is taken, it is important to nominate ing to Children, Guideline 2(l) (NZ). The recent popularity the times of day for different levels of restriction in of this advertising strategy suggests that it is seen by indus- advance, and for these zones to be reasonably stable. It try as having a significant impact on children, but on the would not assist the effectiveness of the scheme if the other hand the fact that such advertisements continue to zones shifted from one week to the next, or even one be broadcast suggests that the rules are not very effective month to the next. Consumers should be able to ascertain in curtailing it. This may be because they are not always with ease which zone they are in, so as to determine what sufficiently broad to catch the full range of personalities level of restriction applies. Therefore it would be necessary (for example, sporting heroes) that might appeal to chil- to make some generalised predictions about the make-up dren. of audiences, rather than trying to micro-manage the audiences for particular programmes in particular weeks. Premiums Another popular way of promoting products to children is to offer some kind of give-away, or premium. Many sys- This means that "when children are watching" criteria cannot be expected to tie regulation, all the time, to factu- tems contain rules limiting the presentation of premiums ally accurate information about audiences. There is always in the context of advertising. However, in Australia at scope for variations (up or down) when particular shows least, these have been interpreted so as to allow the mar- are screened. On the other hand, programming does tend rying of food and non-food items in a single "product" so to follow viewing patterns, so times of day would nor- that a toy given away with food is not considered to be a mally be a reasonable proxy for the size of the child audi- "premium" and is therefore not caught by the restrictions ence. [16]. A watershed Pester power Using a time of day as a watershed for regulating food "Pester power" is a term that refers to the ability of chil- advertising for the protection of children has the benefit dren in many families to gain access to the products they of simplicity. If the watershed were, say, 9 pm, the rule desire by wearing their parents down so that they give in would be: no food advertising before 9 pm. A watershed and purchase. Its documented efficacy [17] suggests it could also be applied in a more nuanced way; for exam- would be a powerful link in the chain of causation ple, no ads for foods high in fat, sugar or salt before the between food advertising and obesity. watershed, no use of premium offers before the water- shed, and so on. This would have the very substantial ben- Many regulatory provisions appear to address pester efits of simplicity and certainty, though of course at the power by making some reference to "undue pressure". For cost of sacrificing a degree of finesse and accuracy in tar- example, Children's Television Standard 18 provides that geting times and programs when children are actually, or "A licensee may not broadcast any advertisement even likely to be, watching. Therefore, a simple watershed designed to put undue pressure on children to ask their rule would risk overstepping the mark, by biting into parents or other people to purchase an advertised product broadcasters' profits without any necessary corresponding or service." However the "undue pressure" this provision benefit to children. addresses is pressure from the advertisement, on children. Pester power is at work when children place undue pres- 5. The content of the advertisement sure on parents. Therefore CTS 18 and provisions like it Space does not permit a detailed examination of regula- do not really limit the role of pester power in providing a tory axes centring on the advertisement itself. In this sec- link between food advertising and childhood obesity. Page 8 of 10 (page number not for citation purposes) Australia and New Zealand Health Policy 2009, 6:1 http://www.anzhealthpolicy.com/content/6/1/1 Moreover, so-called anti-pester power provisions tend to In addition, not all criteria in use have a capacity to mod- assume that the reason children pester their parents is that erate the impact of television food advertising on chil- an ad has instructed them to do so. This is not the case, dren's food preferences, or their diets. For example but rather children pester when they want a product badly regulations tend to assume that children are more influ- enough. Realistically, then, the only way to do away with enced by advertising that is in some sense aimed at them. pester power is to do away with effective advertising to Not only is this an inherently vague category, but the children. assumption is not supported by the research [6]. Misleading or deceptive The most effective means of moderating the impact of Consumer protection legislation against misleading and food advertising on children's food preferences is to limit deceptive conduct in the promotion of goods and services their exposure to it, and the regulatory criterion with the is both well-known and ubiquitous [18]. In the context of greatest capacity to do so is one based on the time of day food advertising, it is not sufficient to say that misleading when a certain number of children are (expected to be) in information is disallowed; it is necessary to address the the audience. overall picture being painted of an unhealthy product. For example, a sugary breakfast cereal might be rich in cal- Competing interests cium, and lollies are typically fat-free. Many provisions The authors declare that they have no competing interests. allow advertisers to focus on these positive aspects with- out making reference to others that make the product, Authors' contributions overall, an unhealthy one. To be effective, advertising reg- CN did the initial research on the content of the various ulation needs to disallow selective reference to minor regulatory regimes; all authors developed the ideas and nutritional attributes. analysis through discussion amongst them. All have been involved in the preparation of a major report on the out- Promoting unhealthy lifestyles comes of the study. EH drafted this article and all authors Recent reviews of industry codes have seen the emergence read and approved the final manuscript. JC revised the of provisions disallowing the encouragement of article following suggestions from the editors. unhealthy practices such as overeating or inactive life- styles [19,20]. There is a serious question as to whether Acknowledgements The authors acknowledge the generous support of the Australian Research such provisions prevent the broadcast of any advertise- Council and the South Australian Department of Health, under ARC Link- ment that any advertiser would otherwise want to have age Project LP0455068 in which Handsley, Coveney and Mehta are Chief shown. Advertisers over the years have shown themselves Investigators. Nehmy is a postgraduate student who has also been working much more interested in associating their unhealthy food on the project. products with health and physical vigour. References Therefore, it is difficult to escape the conclusion that such 1. Coalition on Food Advertising to Children: Policy Statement. provisions in advertising codes have little or no effect on [http://www.chdf.org.au/icms_wrapper?page=666&issur vey=&rand=0.7155561212149879&via_smartchoice=&return=no]. the exposure of children to food advertising. There is sim- 2. Chandler J: Will TV Ads Turn Us into the Biggest Losers? The ply no advertisement that they would otherwise see, that Age 2006 [http://www.theage.com.au/news/in-depth/an-expanding- problem/2006/04/28/1146198343089.html]. is made unavailable by these provisions. 3. Save Kids TV: Newsletter 6. 2006. 4. Australian Communications and Media Authority: Children's Tele- vision Standards Review: Issues Paper. 2007. Conclusion 5. Fullerton T: Generation "O." 2005 [http://www.abc.net.au/4corners/ This article has described a number of axes around which content/2005/s1484310.htm]. regulation revolves. Each axis represents a specific crite- 6. Anonymous: Rudd Says No to Junk Food Ad Ban. Sydney Morn- ing Herald 2007. rion that singles out for stricter regulation certain advertis- 7. Hastings G, Stead M, McDermott L, Forsyth A, MacKintosh AM, ing to children, including food advertising. We have seen Rayner M, Godfrey C, Caraher M, Angus K: Review of Research on that some of the criteria commonly used rely on vague or the Effects of Food Promotion to Children. 2003 [http:// www.foodstandards.gov.uk/multimedia/pdfs/ subjective notions that make it difficult to determine in foodpromotiontochildren1.pdf]. advance whether a breach has occurred. This has two 8. Livingstone S: A Commentary on the Research Evidence effects: it makes it less likely that a consumer will take the Regarding the Effects of Food Promotion on Children. 2004 [http://www.ofcom.org.uk/research/tv/reports/food_ads/ trouble to complain, and it makes it harder to obtain a appendix1.pdf]. breach finding. The more serious the misconduct that the 9. Neville L, Thomas M, Bauman A: Food advertising on Australian television: the extent of children's exposure. Health Promotion regulation seeks to capture, the more likely that regulators International 2005, 20(2):105. and decision-makers will be reluctant to adopt an inter- 10. Lange v Australian Broadcasting Commission 1997 [http:// pretation that makes an advertiser "guilty" of that miscon- www.austlii.edu.au/au/cases/cth/HCA/1997/25.html]. 11. Ofcom: Television Advertising of Food and Drink Products to duct. Children: Final Statement. 2007. Page 9 of 10 (page number not for citation purposes) Australia and New Zealand Health Policy 2009, 6:1 http://www.anzhealthpolicy.com/content/6/1/1 12. Food Standards Australia New Zealand (FSANZ): Health Claims Nutrient Profiling Calculator. [http://www.foodstand ards.gov.au/foodmatters/healthnutritionandrelatedclaims/ nutrientprofilingcal3499.cfm]. 13. A New Tax System (Goods and Services Tax Act) 1999. (Cth), ss 38.3, 38.4; Schedules 1 and 2 14. Swedish Consumer Ombudsman: Interpretative Advice on the Prohibition of Commercial Advertising to Children on Tele- vision. [http://www.konsumentverket.se/mallar/en/startsi dan.asp?lngCategoryId=662&lngArti- cleId=889#B.%20THE%20PROHIBITION]. 15. Justine Cawood, Legal Counsel, Regulatory and Business Affairs, Seven Network (Operations) Limited: Letter addressed to Kaye Mehta, Coalition on Food Advertising to Children, Re: Com- plaint regarding advertisement for Coco Pops. 2004. 16. Atkinson-MacEwen L: Letter to Kaye Mehta. 2002. 17. Australian Communications and Media Authority: Television Advertising to Children: A review of contemporary research on the influence of television advertising directed to chil- dren. 2007:29-30. 18. Trade Practices Act 1974 [http://www.austlii.edu.au/au/legis/cth/ consol_act/tpa1974149/]. (Cth) 19. Commercial Television Industry Code of Practice, Clause 6.23 . 20. Australian Association of National Advertisers Code on Advertising to Chil- dren, Clause 2.15 [http://www.aana.com.au/childrens_code.html]. Publish with Bio Med Central and every scientist can read your work free of charge "BioMed Central will be the most significant development for disseminating the results of biomedical researc h in our lifetime." Sir Paul Nurse, Cancer Research UK Your research papers will be: available free of charge to the entire biomedical community peer reviewed and published immediately upon acceptance cited in PubMed and archived on PubMed Central yours — you keep the copyright BioMedcentral Submit your manuscript here: http://www.biomedcentral.com/info/publishing_adv.asp Page 10 of 10 (page number not for citation purposes) http://www.deepdyve.com/assets/images/DeepDyve-Logo-lg.png Australia and New Zealand Health Policy Springer Journals

Regulatory axes on food advertising to children on television

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Springer Journals
Copyright
Copyright © 2009 by Handsley et al; licensee BioMed Central Ltd.
Subject
Medicine & Public Health; Public Health; Social Policy
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1743-8462
DOI
10.1186/1743-8462-6-1
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19159485
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Abstract

This article describes and evaluates some of the criteria on the basis of which food advertising to children on television could be regulated, including controls that revolve around the type of television programme, the type of product, the target audience and the time of day. Each of these criteria potentially functions as a conceptual device or "axis" around which regulation rotates. The article considers examples from a variety of jurisdictions around the world, including Sweden and Quebec. The article argues that restrictions centring on the time of day when a substantial proportion of children are expected to be watching television are likely to be the easiest for consumers to understand, and the most effective in limiting children's exposure to advertising. Background cross-purposes. In particular, advocates of stricter regula- When it comes to television food advertising and child- tion do not claim that food advertising is the only cause hood obesity, it seems that everybody has an axe to grind. of childhood obesity, and yet they are frequently por- Health and consumer groups claim that food advertising trayed as espousing just such a view. contributes to an obesegenic environment for children, and should be curtailed, if not banned outright [1]. The Recent studies have found a direct correlation between broadcasting, advertising and food and beverage indus- children's exposure to food advertisements and their food tries dispute that regulation can help curb the rate of preferences [7,8]. Research also confirms that the majority childhood obesity, and (yet) insist they want to be part of of foods advertised on television during periods when the solution [2]. The television production industry is children are likely to be watching are high in sugar and fat concerned that additional restrictions on advertising to [9]. If preferences are a predictor of actual consumption, children could cause the market in children's programs to then it is reasonable to conclude that television advertis- dry up [3], and in Australia at least, the regulator appears ing leads children to consume more food of low nutri- to have accepted such arguments [4]. The previous Aus- tional value – which is often calorie dense and contains tralian government refused to take action on the ground high levels of sugar and fat – than they would otherwise that children's diets and lifestyles are a matter of personal do. On this view, children's daily energy intake is being choice and parental responsibility [5], and during the inflated without corresponding increases in opportunities 2007 election campaign Kevin Rudd, the new Prime Min- for physical activity. In public health parlance, food adver- ister, more or less agreed [6]. As with many complex tising to children contributes to an "obesegenic" environ- debates where the stakes are high, participants are often at ment. Page 1 of 10 (page number not for citation purposes) Australia and New Zealand Health Policy 2009, 6:1 http://www.anzhealthpolicy.com/content/6/1/1 At the time of writing there is debate in numerous coun- as this is the role that the research has identified for food tries as to whether food advertising should be more tightly advertising in contributing to childhood obesity. To bor- regulated. If that debate is resolved in favour of tighter reg- row a term that has been used frequently by the High ulation – if the axe falls – the next question will be how Court of Australia in determining the constitutionality of best to regulate food advertising in order to reduce chil- legislation, what is needed are criteria that are "appropri- dren's exposure to it. This article evaluates some of the ate and adapted" [10] to reducing children's exposure to core concepts through which regulators could differenti- food advertising, or to moderating the impact of food ate between advertising that is subjected to lighter, and advertising on children's food preferences. As will be seen, heavier, regulatory burdens. It is helpful to think of the not all criteria fit this description. conceptual device used in each case as an "axis" around which regulation rotates. This allows an appraisal of dif- Although this article is not (only) about the Australian ferent forms of regulatory options, each turning on a cer- regulatory system for advertising on commercial free-to- tain element of the advertising or context in which it is air television, it may be useful to provide a brief descrip- shown. tion of its key elements. Australia has a system of co-regu- lation, meaning that both government and industry have This article identifies a selection of regulatory axes cur- a role. The government contributes through the Australian rently in use and evaluates their relative likely effective- Communications and Media Authority (ACMA), which ness in achieving the goals of usability by average viewers exercises a range of functions under the Broadcasting Serv- and of limiting children's exposure to advertising that ices Act 1992 (Cth), including propounding and enforcing could influence their food preferences. In the interests of the Children's Television Standards (CTS). These impose brevity, this article deals only briefly with regulatory con- content quotas on commercial free-to-air broadcasters trols that focus on the content or effect of the advertise- relating to quality children's programming, and they also ment; for example, advertisements that have the effect of impose certain restrictions on the advertising that can be placing pressure on children to request the product from shown at the time when that programming is scheduled. their parents ("pester power"), or advertisements that The CTS rely on the public to notice breaches of the pro- contain inaccurate health or nutritional information. visions and to complain to ACMA. A range of civil sanc- Information and references in the article are current to tions is available for breaches of the CTS. At the time of February 2008 (but the authors note in particular that a writing the CTS are under review. revised version of the AANA code on advertising to chil- dren was introduced in April 2008). The industry body Free TV Australia contributes by devel- oping and maintaining the Commercial Television Indus- The first point to make is that regulatory axes need to pro- try Code of Practice (CTICP), which covers a range of vide criteria that are clear and easy to understand. This is matters listed in the Broadcasting Services Act and is regis- particularly the case if the regulatory system relies on con- tered by ACMA in accordance with that Act. Among other sumer complaints to activate its machinery, as is the case things the CTICP extends the CTS advertising restrictions in Australia. In order to maximise the likelihood that con- to advertisements "directed to children". It also contains sumers will recognise breaches and take the trouble to certain additional restrictions on advertising directed to complain, regulations should use criteria that are mean- children that are not found in the CTS. As with the CTS, ingful to the average person. Such a person is not likely to enforcement relies on consumer complaints, but in this bother complaining unless he or she can be reasonably case the complaints must go first to the broadcaster. A confident that a breach has occurred. consumer who is unsatisfied with the broadcaster's response to the complaint can then take the matter to Not all criteria being used around the world at the ACMA. moment are consumer-friendly in this sense. Many are vague and inherently open to interpretation, or such that The advertising industry has contributed to the regulatory reasonable minds may differ as to whether they have been environment by developing a number of codes (AANA met. In law we may be accustomed to such standards; Codes) that apply not just to television but to all media. arguing over them is the stock in trade of lawyers. It is dif- These do not have any legislative basis and the govern- ferent, however, in consumer-protection regulation. Con- ment has no role in their enforcement. Complaints are sumer complaints mechanisms do not support systematic determined by the Advertising Standards Board, an indus- input by professionals on both sides of the argument. try body. On the other hand, some of the AANA Codes Therefore the industry side tends to carry the day, even if have been incorporated into the CTICP. a consumer does take the trouble to mount the argument that a regulatory standard has been breached. This article now provides a selective review of those "reg- ulatory axes" that currently apply, or could apply, to food Second, regulation needs to limit the opportunities for advertising to children. food advertising to influence children's food preferences, Page 2 of 10 (page number not for citation purposes) Australia and New Zealand Health Policy 2009, 6:1 http://www.anzhealthpolicy.com/content/6/1/1 less than if the programme were of primary interest to The criteria 1. The type of program them, however that might be defined. Some regulations apply only to advertising shown during children's programs. There are a number of ways of defin- 2. The type of product ing this category. Food generally Food itself does not cause obesity; rather, obesity tends to Dedicated children's programming be the result of certain patterns of consumption of food, In Australia, the regulations that are directly enforced by and especially particular types of food. Indeed, food is the government, the Children's Television Standards, necessary for life. Therefore, it would be politically unpal- apply during periods that licensees have set aside for "C" atable to introduce a regulation to do away with all adver- programs, that is, dedicated children's programming that tising of any kind of food, as in principle, it would be has been classified as meeting certain regulatory criteria. taking matters too far. These programs are broadcast in fulfilment of a quota imposed on commercial free to air broadcasters. Audi- However, it is difficult to distinguish between foods that ences for these programs are relatively small, therefore the should and should not be caught by an anti-obesity regu- advertising restrictions have little impact on the amount lation, and it may lead to excessive hair-splitting and or kind of advertising to which children are exposed. interpretive debate. Moreover, it is arguable that if food is necessary for life, it should not be necessary to advertise it! There are broader approaches to the idea of "children's If a general ban on food advertising were applied, how programming" that do not involve a need for formal clas- much beneficial food advertising would be caught? sification. For example section 7b of the Swedish Radio According to the Australian lobby group, the Coalition on and Television Act 1996 requires the regulator to determine Food Advertising to Children, the answer is: not very to whom the programme is addressed: much. Therefore it advocates a ban on all commercial food advertising during times when a substantial propor- ... programmes primarily addressed to children under tion of children are in the audience [1]. twelve years of age may not be interrupted by advertis- ing. ... Commercial advertising may not occur imme- Since "food" as a category has meaning to the average con- diately before or after a programme or part of a sumer, it would normally be fairly easy to tell if a particu- programme that is primarily addressed to children lar advertisement was caught by any regulation using it as under twelve years of age [with certain exceptions]. an axis. The main reservation to this would relate to adver- tisements structured in such a way that they are for a com- Similarly, the new British regulations apply to programs pany that sells food, rather than for a particular food "specifically made for children" and programs "of partic- product. Sometimes such companies have campaigns that ular appeal to children" [11]. do not mention food at all, but only, for example, encour- age increased physical activity by children. However, such Such approaches, however, necessarily introduce a meas- advertisements are usually still heavily identified with the ure of vagueness. For example, what does it mean to say a company's logo and visual symbols. There may be room program is "of particular appeal to children"? Does it for debate and confusion as to whether they are advertise- mean that the program appeals more to children than to ments for food, strictly speaking, but there is no reason to adults? Or that it appeals to children more than other pro- doubt that they would have the effect of increasing chil- grams do? Clearly the reach and effectiveness of the regu- dren's favourable disposition towards the company's lation in limiting children's exposure to food advertising brand, and therefore also their preference for its food. will vary depending on how this question is answered. And even once the question is answered it will not always Arguably, then, an effective system for minimising the be easy to categorise any given program. impact of advertising on children's food preferences and nutrition behaviours should be addressed at brands as Another problem with a regulatory axis that focuses on well as at particular products. While on the surface this the type of program is that it tends to overlook the fact could look like victimisation of the companies in ques- that children watch many shows that are not "of particular tion, or some form of "guilt by association", it would have appeal" to them in either of the above senses. Young chil- the virtue of addressing the way that advertising works, by dren might not be terribly attracted by a prime-time sit- establishing brand loyalty. We are not aware of any regu- com such as How I Met Your Mother, for example, but if lation, anywhere in the world, using such an axis. their parents are watching it, the children probably will too. And even if they are not interested in the programme, Rather, there are numerous lesser restrictions, short of a chances are their attention will be drawn by the advertise- ban, that apply to all food advertising. For example, in Aus- ments. Therefore they are still exposed to advertising, no tralia Children's Television Standard (CTS) 19(6) states: Page 3 of 10 (page number not for citation purposes) Australia and New Zealand Health Policy 2009, 6:1 http://www.anzhealthpolicy.com/content/6/1/1 An advertisement for a food product may not contain a. Advertisements representing a mealtime should any misleading or incorrect information about the depict the food product within the framework of a nutritional value of that product. nutritionally balanced meal. Other provisions, such as Clause 6.23 of the Commercial b. Snack foods should be clearly depicted as such, and Television Industry Code of Practice, and clauses (b)7, not as substitutes for meals. (b)8 and (b)9 of the Children's Advertising Review Unit (CARU) Self-Regulatory Program for Children's Advertis- The AANA has propounded an entire code dedicated to ing in the United States, single out food advertisements food and beverage advertising, the Food and Beverage for special scrutiny. Clause 6.23 provides: Advertising and Marketing Communications Code. 6.23 Advertisements directed to children for food and/ The extent to which food advertisements might fall foul of or beverages: these provisions depends on the application of criteria that go beyond the mere fact of the advertisement being a 6.23.1 should not encourage or [expressly endorse] food advertisement. However, the regulations set out [not engaging in any or much physical activity as a way above provide illustrations of the kinds of restrictions that of life]; could turn on the "food" axis. The very variety of approaches available makes it difficult to comment on the 6.23.2 should not encourage or [expressly endorse] food axis in a general way, other than to say that the pres- [excessive or compulsive consumption of food and/or ence in numerous instruments of regulations revolving on beverages] .... this axis suggests a wide recognition of the sensitivity of food as a category. The Australian Association of National Advertisers (AANA) Advertiser Code for Advertising to Children con- "Junk" food tains a similar provision in Clause 2.10, except that to fall There is a compelling logic to the idea of limiting advertis- foul of it, an advertisement must encourage or promote ing restrictions to foods considered to be especially likely both inactive lifestyle and overconsumption. to contribute to obesity in children. Most people would instinctively include on any such list "fast" foods such as The US provisions state as follows: hamburgers, chips and fried chicken; confectionery including chocolate; ice cream; and salty snacks such as 7. The amount of product featured should not be potato chips. However, drawing the boundaries between excessive or more than would be reasonable to healthy and unhealthy foods is not a simple matter as it acquire, use or consume by a person in the situation must always involve balancing the nutritional value of the depicted. For example, if an advertisement depicts food with any excessive levels of fat or sugar. food being consumed by a person in the advertise- ment, or suggests that the food will be consumed, the For example, flavoured yoghurt contains the beneficial quantity of food shown should not exceed the labelled nutrients of protein, calcium and vitamins – but also a serving size on the Nutrition Facts panel; where no considerable amount of sugar. It is a healthier snack than, such serving size is applicable, the quantity of food say, chocolate, but overconsumption can still contribute shown should not exceed a single serving size that to obesity. Reasonable minds will disagree on whether it would be appropriate for consumption by a person of should be included or excluded from a list of foods to be the age depicted. subject to advertising restrictions in the name of prevent- ing childhood obesity. 8. Advertising of food products should encourage responsible use of the product with a view toward There are various ways of dividing food up into "good" healthy development of the child. For example, adver- and "bad" categories for the purposes of regulation. One tising of food products should not discourage or dis- is nutrient profiling, which is the approach that the UK parage healthy lifestyle choices or the consumption of has recently adopted in order to identify foods high in fat, fruits or vegetables, or other foods recommended for sugar and salt – referred to as HFSS foods. The Australian increased consumption by current USDA Dietary Communications and Media Authority Issues Paper for Guidelines for Americans and My Pyramid, as applica- the Children's Television Standards Review said that "this ble to children under 12. option [is] currently unviable in the Australian context" but did not explain why the British system could not be 9. Advertisements for food products should clearly adopted here. Nor did it appear to recognise the existence depict or describe the appropriate role of the product under Food Standards Australia and New Zealand of a within the framework of the eating occasion depicted. profiling system [12]. Page 4 of 10 (page number not for citation purposes) Australia and New Zealand Health Policy 2009, 6:1 http://www.anzhealthpolicy.com/content/6/1/1 Another possibility in Australia would be to use the dis- ing against an advertisement for some major categories of tinctions between basic food items and luxuries that have food. been drawn up for the purposes of the goods and services tax [13]. This would have the virtue of a degree of famili- 3. The (apparent) target audience arity within the Australian community; but on the other The majority of regulatory rules for the protection of chil- hand it would not necessarily distinguish neatly and accu- dren from advertising single out for added restrictions rately between healthy and non-healthy foods. advertising that has children as its target audience. For example, Quebec and Sweden are well-known for having Regulations revolving on the "junk food" axis share the strict rules to protect children from advertising; this is the problem adverted to earlier, of advertisements for brands kind of axis used in both places. In Quebec, s 248 of the rather than particular products. Indeed the problems are Consumer Protection Act 1980 provides in part: more deeply ingrained in the case of a "junk food" axis because restaurant chains that have traditionally special- no person may make use of commercial advertising ised in burgers and fried foods have recently started to directed at persons under thirteen years of age. introduce healthier alternatives. The same would be said (emphasis added) of a number of food and beverage companies that pro- duce a range of products, some of which are healthier than It is worth noting that this provision extends to all adver- others. A regulatory system that was serious about limit- tising, not just food and not just that on television. The ing the effect of advertising on children's food preferences Swedish ban appearing in Chapter 7, s 4 of the Radio and and nutrition behaviours would include restrictions on Television Act 1996, by contrast, applies only to television: the use of more general advertising that could attract chil- dren to a brand, or an outlet, where unhealthy food dom- Commercial advertising in a television broadcast may inates. not be designed to attract the attention of children under 12 years of age. (emphasis added) Children's food In some cultures, it is possible at some level to distinguish Australian regulations contain provisions that divide the between children's foods and other foods, and there is a world up in a similar way. For example, Clause 6.20 of the superficial logic to singling such foods out for special Commercial Television Industry Code of Practice applies attention when imposing restrictions on advertising for the advertising restrictions from the Children's Television the protection of children. Standards to advertising "directed to children" and Clause 1(c) of the Advertiser Code for Advertising to Children An example of such an approach is in the Australian Asso- applies to "Advertisements which ... are directed primarily ciation of National Advertisers Advertiser Code for Adver- to Children". (As mentioned above, this latter provision is tising to Children (ACAC). As we shall see in the next further restricted to advertisements for children's prod- section, the ACAC applies only to advertising that is ucts). aimed at children; its application is limited further in that the product being advertised must be one which is "tar- The first question about such an axis is whether the judg- geted toward" children and has "principle [sic] appeal" to ment is subjective or objective: does the regulation cover children (see Clause 1(c) in conjunction with (b)). There- advertisements whose authors intend to catch children's fore, in so far as the Code applies to food advertising, it attention, or advertisements that are expected to have that applies only to this subset of foods. effect irrespective of intent? The Swedish provision, in par- ticular, makes it sound as if it might be the former, which As with the notion of children's programming, children's is clearly the narrower of the two approaches. However, food is not an easy category to define. There is considera- the more usual approach is a broader one of providing cri- ble room for debate as to whether products like hamburg- teria for determining whether an advertisement meets the ers, fried foods, chocolate and potato chips would be seen definition. Section 249 of the Quebec legislation pro- as being in the category, or whether their appeal to adults vides: would rule them out. Yet these are clearly some of the foods for which children have been developing too great To determine whether or not an advertisement is a preference and effective anti-obesity regulation should directed at persons under thirteen years of age, include them. account must be taken of the context of its presenta- tion, and in particular of: Moreover, the very vagueness of the category would make it difficult to know whether it would be worth complain- (a) the nature and intended purpose of the goods advertised; Page 5 of 10 (page number not for citation purposes) Australia and New Zealand Health Policy 2009, 6:1 http://www.anzhealthpolicy.com/content/6/1/1 (b) the manner of presenting such advertisement; � the target audience for the commercial – is the target audience children? This is relevant where the other fac- (c) the time and place it is shown. tors set out above indicate that a commercial is intended to appeal to children. In Sweden, the three criteria used for assessing whether an advertisement is "designed to attract the attention of chil- It remains to be seen just how these factors will work in dren under 12 years of age" are roughly the same: the practice. For example, is it sufficient for one criterion to be design of the advertisement, the type of product and the met, or must they all be met before an advertisement will context of the broadcast [14]. In the USA, the Children's be thought of as "directed at children"? Advertising Review Unit Self-Regulatory Program document lists four factors, revolving around the adjacent program- It may be useful to consider the example of an advertise- ming and the apparent intent of the advertiser (see para- ment that the broadcaster did not consider to be "directed graph II(A)(1)(a)-(d)). to children", albeit under the previous version of the Code which did not contain the Advisory Note. This was one In Australia, the official publication containing the Com- where an adult addressed comments (ostensibly) to par- mercial Television Industry Code of Practice (CTICP) con- ents about the vitamins and minerals in a highly sugared tains a document entitled Advisory Note: Commercials or breakfast cereal. The advertisement was considered not to Community Service Announcements Directed to Children, be directed to children [15] even though (a) the product which is stated to be: is one that is of primary interest to children, and (b) the adult concerned is a well-known children's entertainer. intended to provide guidance on the factors licensees will consider in assessing who [sic] a commercial is Under the Advisory Note, the first factor would suggest directed to for the purpose of applying Clause 6.23 of that the advertisement was directed to children, but the the Code "Commercials or Community Service Announce- rest would suggest the opposite. Therefore, if a balancing ments Directed to Children". (emphasis in original) approach were taken, we might expect that the result would be the same: the advertisement would not be con- Clause 6.23, set out above, is a provision relating specifi- sidered to be "directed to children". It is interesting to cally to food advertisements. The factors for consideration note that the presenter's status as a children's entertainer under the Advisory Note are: is not "caught" by any of the factors. She is not a child actor depicted using the product, but neither is she unrec- � the nature of the product or service, and the persons ognisable to children. most likely to be interested in that product or service – is the product or service one for which children are the Another example of how this kind of axis works in prac- only users or form a substantial part of the market?; tice comes from Quebec: in an advertisement for a fast- food restaurant chain, a man is shown taking a young boy � the theme of the commercial – are adult or children's to the restaurant. The child is clearly enthusiastic about themes used? For example, characters such as mon- being there, and is shown at the table with a child's meal sters, animals and the like; in front of him. But the "story line" of the advertisement is the man's interest in the number of attractive women in � the 'story line' and the approach taken in selling the the restaurant eating salads. He is shown noticing them, product or service – is the story line aimed at children? then at the end of the advertisement the boy says, "There For example, does the commercial have a simple are lots of ladies here, aren't there?" and the man says, uncomplicated plot structure such as 'good' against "Really? I hadn't noticed." Therefore on the surface, the 'evil'?; advertisement is addressed to single heterosexual men. Also it places greater emphasis on the restaurant chain's � the visuals used in the commercial – are the visuals salad lines than on the unhealthy fast-food for which it is aimed at children? For example, the commercial uses traditionally known. Unless a single element is sufficient animation or imaginative visuals which appeal to chil- to satisfy the Advisory Note to Clause 6.23 of the CTICP dren; (which seems unlikely), this advertisement would pass muster under the CTICP as not being "directed to chil- � the language of the commercial – does the commer- dren". Although the little boy is seen 'actively using a cial use children's language?; product or service for which children constitute the mar- ket', every other element of the advertisement is contrary � the age of actors appearing in the commercial – are to what is described in the Advisory Note. The advertiser child actors depicted actively using a product or service would claim that the 'product or service' being advertised for which children constitute the market?; and is the salads, not one 'for which children are the only users Page 6 of 10 (page number not for citation purposes) Australia and New Zealand Health Policy 2009, 6:1 http://www.anzhealthpolicy.com/content/6/1/1 or form a substantial part of the market'. The theme of limited to the impact of children's advertising in this picking up attractive women is not a children's theme, and sense, so there is no reason to limit regulations in this way for the same reason the 'story line' is clearly not aimed at either. We argue that a regulation applying only to adver- children. The visuals are not child-oriented, in the sense tising aimed at children is inherently inappropriate and that there is no animation or similar, and the language is ill-adapted to addressing the contribution of food adver- not children's language but rather a life-like conversation tising to childhood obesity. between an adult and a child. The advertisement was pre- sumably permissible under Quebec's strict laws for much 4. The time of day the same reasons, under the "manner of presenting" con- The discussion above suggests that it is better, and easier sideration contained in s 249(b). Yet there is nothing to for consumers, if regulation uses different times of day, suggest that a child would not have noticed the advertise- rather than the type of program, the type of product or the ment, and received its selling message about the chain. target audience, for determining the level of advertising restriction that applies. Reliance on times of day has the A third example comes from Swedish television. An adver- important virtue of centring levels of regulation on an tisement for cheesy snacks shows a cartoon-style mouse objectively verifiable fact, and it is not left to consumers or superhero ("Mouseman") rescuing a cartoon-style old regulators to interpret more subjective criteria. Such cer- lady (conservative 50 s-style skirt suit and pillbox hat with tainty may also be beneficial for broadcasters. a veil) who has been mugged by some cartoon-style rob- bers (striped jumpsuits and eye masks), to deprive her of The current regulatory system in Australia does not draw a large piece of cartoon-style cheese she is carrying (a lines according to times of day, except in the general sense wedge, with holes). However the advertisement is not a that the Commercial Television Industry Code of Practice cartoon, rather it is live action with a cartoon-like design. (CTICP) lays down classification zones during which Also, it is in English. These, presumably, were the reasons material must meet certain criteria relating to matters such it was able to be shown on Swedish television. Yet once as coarse language, sexual references and adult themes. again there is no reason to think that a Swedish child's While these restrictions extend to advertisements, they do attention would not be drawn by the advertisement. Still not have any particular application to food advertising. less could one say that a child seeing the advertisement would not have been exposed to food advertising. When children are watching There are three possible ways of dividing up the day and In all of the above systems, consumers and regulators are the week according to when children are watching. One is provided only with a list of factors to take into considera- to make observations about how children spend their day tion, and not with a definition as such. The need to bal- and when they will therefore be available for television ance a number of different considerations means that it is watching. The presumption is then made that many chil- impossible to say with certainty what the conclusion will dren will be watching at those times. This happens to be, and this is telling in itself. In any system which, like some extent in the setting of classification zones on Aus- Australia, relies on complaints from consumers to alert tralian television: for example, children are presumed to authorities to possible breaches, the number of com- be in school until 3.30 pm on weekdays, so under Clause plaints is bound to be minimised by maximising uncer- 2.8 of the CTICP, the "G" classification zone does not start tainty as to whether a breach has occurred. until 4.00 pm. It is otherwise during school holidays: see Clause 2.9. This might be called the 'opportunity to watch' The foregoing discussion shows that regulatory axes of approach. this kind – that is, those that centre on some notion of a target audience for the advertisement – have a superficial The other two ways of setting time zones are based on appeal but are inherently vague and open to interpreta- consideration of data on actual viewing patterns, but use tion. This is especially so where multiple factors need to them in different ways. One looks at when children make be balanced against each other. It would be far easier for up a given proportion of the audience; the other looks at consumers to identify breaches under a "single factor" the proportion of children who would be expected to be test, where heightened scrutiny was activated by any one watching at a given time. Both of these are based not on factor indicating children are targeted. opportunity but on actual audience information. In addition, target audience tests have a limited capacity The first of these two approaches is more favourable to to restrict children's exposure to food advertising, because privileging the commercial interests of the TV station there is no reason to think that they do not notice any which would wish to have access to the greatest number other kind of advertisement. The research on the impact of adult viewers. If children are a large proportion of the of food advertising on children's choices has not been audience, that means there are relatively few adult viewers Page 7 of 10 (page number not for citation purposes) Australia and New Zealand Health Policy 2009, 6:1 http://www.anzhealthpolicy.com/content/6/1/1 to whom access is being restricted. The more adult view- tion, however, we provide a few indications of what such ers, the more the broadcaster has to lose as a result of axes consider to be relevant features, and the factors that advertising restrictions. However, such an approach has limit the effectiveness of some such axes. In addition to only limited capacity to restrict children's exposure to the matters discussed below, it is worth noting that some food advertising. The fact that a large number of adults of the elements used to determine whether an advertise- might be watching does not change the potential impact ment is aimed at children also refer to elements of content of the advertising on the child audience. (see eg Cl 6.23 of the CTICP, quoted above). A more effective approach is to consider what proportion Use of personalities of children are expected to be in the television audience at Many regimes have specific rules about the use of person- a given time. If restrictions are tighter at times when large alities in children's advertising, for example Children's numbers of children are watching, this means that more Television Standard 22 (Australia); Radio and Television Act children are having their exposure limited. 1996, Chapter 7, Section 4 (Sweden); Broadcast Code of Advertising Practice, section 7.2.4 (UK); Code for Advertis- Whichever approach is taken, it is important to nominate ing to Children, Guideline 2(l) (NZ). The recent popularity the times of day for different levels of restriction in of this advertising strategy suggests that it is seen by indus- advance, and for these zones to be reasonably stable. It try as having a significant impact on children, but on the would not assist the effectiveness of the scheme if the other hand the fact that such advertisements continue to zones shifted from one week to the next, or even one be broadcast suggests that the rules are not very effective month to the next. Consumers should be able to ascertain in curtailing it. This may be because they are not always with ease which zone they are in, so as to determine what sufficiently broad to catch the full range of personalities level of restriction applies. Therefore it would be necessary (for example, sporting heroes) that might appeal to chil- to make some generalised predictions about the make-up dren. of audiences, rather than trying to micro-manage the audiences for particular programmes in particular weeks. Premiums Another popular way of promoting products to children is to offer some kind of give-away, or premium. Many sys- This means that "when children are watching" criteria cannot be expected to tie regulation, all the time, to factu- tems contain rules limiting the presentation of premiums ally accurate information about audiences. There is always in the context of advertising. However, in Australia at scope for variations (up or down) when particular shows least, these have been interpreted so as to allow the mar- are screened. On the other hand, programming does tend rying of food and non-food items in a single "product" so to follow viewing patterns, so times of day would nor- that a toy given away with food is not considered to be a mally be a reasonable proxy for the size of the child audi- "premium" and is therefore not caught by the restrictions ence. [16]. A watershed Pester power Using a time of day as a watershed for regulating food "Pester power" is a term that refers to the ability of chil- advertising for the protection of children has the benefit dren in many families to gain access to the products they of simplicity. If the watershed were, say, 9 pm, the rule desire by wearing their parents down so that they give in would be: no food advertising before 9 pm. A watershed and purchase. Its documented efficacy [17] suggests it could also be applied in a more nuanced way; for exam- would be a powerful link in the chain of causation ple, no ads for foods high in fat, sugar or salt before the between food advertising and obesity. watershed, no use of premium offers before the water- shed, and so on. This would have the very substantial ben- Many regulatory provisions appear to address pester efits of simplicity and certainty, though of course at the power by making some reference to "undue pressure". For cost of sacrificing a degree of finesse and accuracy in tar- example, Children's Television Standard 18 provides that geting times and programs when children are actually, or "A licensee may not broadcast any advertisement even likely to be, watching. Therefore, a simple watershed designed to put undue pressure on children to ask their rule would risk overstepping the mark, by biting into parents or other people to purchase an advertised product broadcasters' profits without any necessary corresponding or service." However the "undue pressure" this provision benefit to children. addresses is pressure from the advertisement, on children. Pester power is at work when children place undue pres- 5. The content of the advertisement sure on parents. Therefore CTS 18 and provisions like it Space does not permit a detailed examination of regula- do not really limit the role of pester power in providing a tory axes centring on the advertisement itself. In this sec- link between food advertising and childhood obesity. Page 8 of 10 (page number not for citation purposes) Australia and New Zealand Health Policy 2009, 6:1 http://www.anzhealthpolicy.com/content/6/1/1 Moreover, so-called anti-pester power provisions tend to In addition, not all criteria in use have a capacity to mod- assume that the reason children pester their parents is that erate the impact of television food advertising on chil- an ad has instructed them to do so. This is not the case, dren's food preferences, or their diets. For example but rather children pester when they want a product badly regulations tend to assume that children are more influ- enough. Realistically, then, the only way to do away with enced by advertising that is in some sense aimed at them. pester power is to do away with effective advertising to Not only is this an inherently vague category, but the children. assumption is not supported by the research [6]. Misleading or deceptive The most effective means of moderating the impact of Consumer protection legislation against misleading and food advertising on children's food preferences is to limit deceptive conduct in the promotion of goods and services their exposure to it, and the regulatory criterion with the is both well-known and ubiquitous [18]. In the context of greatest capacity to do so is one based on the time of day food advertising, it is not sufficient to say that misleading when a certain number of children are (expected to be) in information is disallowed; it is necessary to address the the audience. overall picture being painted of an unhealthy product. For example, a sugary breakfast cereal might be rich in cal- Competing interests cium, and lollies are typically fat-free. Many provisions The authors declare that they have no competing interests. allow advertisers to focus on these positive aspects with- out making reference to others that make the product, Authors' contributions overall, an unhealthy one. To be effective, advertising reg- CN did the initial research on the content of the various ulation needs to disallow selective reference to minor regulatory regimes; all authors developed the ideas and nutritional attributes. analysis through discussion amongst them. All have been involved in the preparation of a major report on the out- Promoting unhealthy lifestyles comes of the study. EH drafted this article and all authors Recent reviews of industry codes have seen the emergence read and approved the final manuscript. JC revised the of provisions disallowing the encouragement of article following suggestions from the editors. unhealthy practices such as overeating or inactive life- styles [19,20]. There is a serious question as to whether Acknowledgements The authors acknowledge the generous support of the Australian Research such provisions prevent the broadcast of any advertise- Council and the South Australian Department of Health, under ARC Link- ment that any advertiser would otherwise want to have age Project LP0455068 in which Handsley, Coveney and Mehta are Chief shown. Advertisers over the years have shown themselves Investigators. Nehmy is a postgraduate student who has also been working much more interested in associating their unhealthy food on the project. products with health and physical vigour. References Therefore, it is difficult to escape the conclusion that such 1. Coalition on Food Advertising to Children: Policy Statement. provisions in advertising codes have little or no effect on [http://www.chdf.org.au/icms_wrapper?page=666&issur vey=&rand=0.7155561212149879&via_smartchoice=&return=no]. the exposure of children to food advertising. There is sim- 2. Chandler J: Will TV Ads Turn Us into the Biggest Losers? The ply no advertisement that they would otherwise see, that Age 2006 [http://www.theage.com.au/news/in-depth/an-expanding- problem/2006/04/28/1146198343089.html]. is made unavailable by these provisions. 3. Save Kids TV: Newsletter 6. 2006. 4. Australian Communications and Media Authority: Children's Tele- vision Standards Review: Issues Paper. 2007. Conclusion 5. Fullerton T: Generation "O." 2005 [http://www.abc.net.au/4corners/ This article has described a number of axes around which content/2005/s1484310.htm]. regulation revolves. Each axis represents a specific crite- 6. Anonymous: Rudd Says No to Junk Food Ad Ban. Sydney Morn- ing Herald 2007. rion that singles out for stricter regulation certain advertis- 7. Hastings G, Stead M, McDermott L, Forsyth A, MacKintosh AM, ing to children, including food advertising. We have seen Rayner M, Godfrey C, Caraher M, Angus K: Review of Research on that some of the criteria commonly used rely on vague or the Effects of Food Promotion to Children. 2003 [http:// www.foodstandards.gov.uk/multimedia/pdfs/ subjective notions that make it difficult to determine in foodpromotiontochildren1.pdf]. advance whether a breach has occurred. This has two 8. Livingstone S: A Commentary on the Research Evidence effects: it makes it less likely that a consumer will take the Regarding the Effects of Food Promotion on Children. 2004 [http://www.ofcom.org.uk/research/tv/reports/food_ads/ trouble to complain, and it makes it harder to obtain a appendix1.pdf]. breach finding. The more serious the misconduct that the 9. Neville L, Thomas M, Bauman A: Food advertising on Australian television: the extent of children's exposure. Health Promotion regulation seeks to capture, the more likely that regulators International 2005, 20(2):105. and decision-makers will be reluctant to adopt an inter- 10. Lange v Australian Broadcasting Commission 1997 [http:// pretation that makes an advertiser "guilty" of that miscon- www.austlii.edu.au/au/cases/cth/HCA/1997/25.html]. 11. Ofcom: Television Advertising of Food and Drink Products to duct. Children: Final Statement. 2007. Page 9 of 10 (page number not for citation purposes) Australia and New Zealand Health Policy 2009, 6:1 http://www.anzhealthpolicy.com/content/6/1/1 12. Food Standards Australia New Zealand (FSANZ): Health Claims Nutrient Profiling Calculator. [http://www.foodstand ards.gov.au/foodmatters/healthnutritionandrelatedclaims/ nutrientprofilingcal3499.cfm]. 13. A New Tax System (Goods and Services Tax Act) 1999. (Cth), ss 38.3, 38.4; Schedules 1 and 2 14. Swedish Consumer Ombudsman: Interpretative Advice on the Prohibition of Commercial Advertising to Children on Tele- vision. [http://www.konsumentverket.se/mallar/en/startsi dan.asp?lngCategoryId=662&lngArti- cleId=889#B.%20THE%20PROHIBITION]. 15. Justine Cawood, Legal Counsel, Regulatory and Business Affairs, Seven Network (Operations) Limited: Letter addressed to Kaye Mehta, Coalition on Food Advertising to Children, Re: Com- plaint regarding advertisement for Coco Pops. 2004. 16. Atkinson-MacEwen L: Letter to Kaye Mehta. 2002. 17. Australian Communications and Media Authority: Television Advertising to Children: A review of contemporary research on the influence of television advertising directed to chil- dren. 2007:29-30. 18. Trade Practices Act 1974 [http://www.austlii.edu.au/au/legis/cth/ consol_act/tpa1974149/]. (Cth) 19. Commercial Television Industry Code of Practice, Clause 6.23 . 20. Australian Association of National Advertisers Code on Advertising to Chil- dren, Clause 2.15 [http://www.aana.com.au/childrens_code.html]. Publish with Bio Med Central and every scientist can read your work free of charge "BioMed Central will be the most significant development for disseminating the results of biomedical researc h in our lifetime." Sir Paul Nurse, Cancer Research UK Your research papers will be: available free of charge to the entire biomedical community peer reviewed and published immediately upon acceptance cited in PubMed and archived on PubMed Central yours — you keep the copyright BioMedcentral Submit your manuscript here: http://www.biomedcentral.com/info/publishing_adv.asp Page 10 of 10 (page number not for citation purposes)

Journal

Australia and New Zealand Health PolicySpringer Journals

Published: Jan 22, 2009

References