Food advertising and broadcasting legislation—a case of system failure?

Viewpoint

Food advertising and broadcasting legislation—a case of system failure?

Heather Morton, Rosemary Stanton, Julie Zuppa and Kaye Mehta

Abstract (Nutr Diet 2005;62:26–32)

This study analysed a sample of food advertisements shown during 63 hours of children’s programming to investigate compliance and non-compliance with one of the Australian Children’s Television Standards (CTS): CTS 20.2a. This standard regulates the way premium offers may, and may not, be used to sell products to children. Of the 1721 advertisements contained in the sample, 544 (32%) were for food. A significantly higher number of food advertisements (41%) were shown during ‘C’ programs (which are specifically regu-lated and produced for children six to 13 years of age and suitable for viewing without adult supervision), compared with 30% during the less regulated ‘G’ programs (P = < 0.001) (suitable for children to view with-out adult supervision but not produced specifically for a child audience). Over one-third of food advertisements (36%) in ‘C’ time contained a premium offer compared with 17% in ‘G’ time (P = < 0.0001). Using a precisely defined interpretation of CTS 20.2a, this study found 30 (31%) of food advertisements breached the standard during ‘C’ programs. This was a significantly higher proportion than the 54 (12%) of breaches in ‘G’ time (P = < 0.0001). From this study, the current regulatory system has not resulted in more responsible food advertising during ‘C’ programs, and the widespread breaches of CTS 20.2a indicate this standard is ineffective as a means of regulating food advertising. The Australian Broadcasting Authority has recognised that children need protection from unfair marketing practices and the improper use of premium offers to promote a food product, therefore CTS 20.2a needs urgent review to make it more effective.Key words: food advertising, television, children, regulation

Department of Public Health, School of Medicine, University of AdelaideH. Morton, BA, DipT, MSc, MSocSc, LecturerSchool of Medical Sciences, Faculty of Medicine, University of New South Wales, SydneyR. Stanton, BSc, CNut/Diet, Dip Admin, PhD (Hon), APD, Visiting FellowBarossa Community Health Service and Modbury Public HospitalJ. Zuppa, BHSc, MNut/Diet, DietitianDepartment of Nutrition & Dietetics, School of Medicine, Flinders University of South Australia, AdelaideK. Mehta, BSc, GDipNut/Diet, CMge, LecturerCorrespondence: H. Morton, Department of Public Health, University of Adelaide, Mail Drop: 207, Level 9/ 10 Pulteney Street, SA 5005. Email: [email protected]. Mehta, H. Morton and J. Zuppa planned the details of the study. J. Zuppa and H. Morton collected and analysed the data. H. Morton wrote the first draft of the paper which was revised with substantial assistance from R. Stanton.

Introduction

The World Health Organization (WHO) and many gov-ernments emphasise the importance of healthy diets,especially for children, yet children have become anincreasingly important market for food advertisers, withtelevision the preferred medium for reaching them (1–3).Many studies have raised serious concerns about the typesof foods promoted to children in televisionadvertisements (4–9). With funding for public health edu-cation only a fraction of that available for making andbroadcasting food advertisements (10), most children havehad a greater exposure to advertising messages, over anumber of decades, than to any nutrition message (11–15).

Many governments have struggled to find ways ofprotecting children from unfair practices and exploitationengendered by high advertising of energy dense, micronu-trient poor (EDMP) foods and beverages (2). In 2002, theNew South Wales Childhood Obesity Summit (16) passeda resolution calling for an independent review of the cur-rent Australian regulations which exist within a complexsystem of ‘co-regulation’. The Australian BroadcastingAuthority’s (ABA) Children’s Television Standards (CTS)operate alongside a system of self-regulation described bythe voluntary Commercial Television Industry Code ofPractice, which applies to all commercial broadcastingand must conform to the general advertising codes author-

26 Nutrition & Dietetics (2005) 62:1

ised by the Australian Competition and ConsumerCommission (17).

The CTS form part of the regulatory framework thatapplies to the content of programs and advertisementsshown during designated children’s ‘C’ programs (thosespecifically produced for children six to 13 years of age).


Television licensees are required to broadcast at least 260hours of ‘C’ programs a year (or five hours per week).The programs must be entertaining and well producedwith appropriate Australian content which enhances chil-dren's understanding and experience (17).

The broadcasting license for each television station isconditional on all advertisements broadcast during ‘C’time complying with the relevant CTS. Advertisementsbroadcast during ‘G’ programs (those which are not pro-duced specifically for a child audience but which aresuitable for children to view without adult supervision) donot have to comply with the CTS. However, they areunder the jurisdiction of the self-regulatory Industry Codeof Practice. According to this code, advertisementsdirected to children must exercise special care and judg-ment, and comply with CTS 17–21 (18). Therefore,advertisements in ‘G’ time which do not comply with theCTS, while strictly not in breach of the CTS, are in breachof the Industry Code of Practice. This is an important dis-tinction because breaches of the CTS carry more seriouspenalties than breaches of the Code.

None of the standards regulate the types of food whichcan be advertised or the number of food advertisementswhich can be shown. However, one standard, CTS 20.2a,relates to the way premium offers can be promoted to chil-dren in advertisements, including those for food. Theregulation states: ‘if a premium is offered, any referenceto the premium must be incidental to the main product orservice advertised’ (18). Premium offers such as smallplastic figures and toys have been given away ‘free’ witha variety of foods marketed to children for many years andCTS 20.2a regulates rather than prohibits this practice.CTS 20.2a only refers to food advertisements with pre-mium offers and its aim is to protect children from oneaspect of food advertising practices. It prohibits advertis-ers placing undue emphasis on a collectable toy. CTS20.2a is an acknowledgement by the ABA that childrenneed legislative protection and any breaches of CTS 20.2amust be taken seriously.

An Australian advocacy group, the Coalition onAdvertising to Children (CFAC), had noted that manyfood advertisements with premium offers appeared tocontain potential breaches of CTS 20a. Previous studiesinto television food advertising directed towards childrenhave reported comprehensive nutritional content analysesof food advertising (7,9), but none has examined compli-ance with the CTS. This study sought to determine theamounts and types of premium offers used in food adver-tisements and whether these advertisements compliedwith CTS 20a during ‘C’ programs. It also investigatedwhether the current co-regulatory system led to differentfood advertising practices during ‘C’ and the less-regu-lated ‘G’ programs.

Methods

A total of 63 hours of children’s television programs,including those classified as ‘C’ and ‘G’ were videotapedfrom Adelaide’s three commercial channels (7, 9 and 10)during April 2001. The viewing times selected for theirrelevance to children were 7.00–10.30am and3.30–7.30pm Monday to Friday, and 7.00–11.30am Satur-day. News and current affairs programs were excluded onthe grounds they are directed more to an adult audience.

Community Service Announcements (CSA), station pro-motions and sponsorship announcements were alsoexcluded.

All food advertisements broadcast during the 12.5hours of recorded ‘C’ programs and 50.5 hours of ‘G’ pro-grams were analysed for compliance with CTS 20.2a(disclaimers and premium offers). There is a view thatCTS 20a is only relevant to food advertisements in ‘C’time since compliance with the CTS is not required during‘G’ programming. We included advertisements in ‘G’time for comparison, and because the Industry Code ofPractice requires all advertisements directed at children tocomply with the CTS 17–21 (18). To distinguish betweenthe two program zones, we designated any breaches in ‘G’time as breaches of the Code, although the only differencebetween breaches of the CTS and breaches of the Code isthat the former have legislative sanctions. Differencesbetween the compliance during ‘C’ and ‘G’ programswere compared using chi-square tests. A detailed nutri-tional content analysis of the food advertisements hasbeen published in a separate paper (9).

CTS 20a states ‘if a premium is offered, any referenceto the premium must be incidental to the main product orservice advertised’. The ABA defines a premium as: ‘any-thing offered with or without additional cost that isintended to induce the purchase of an advertised productor service’ (17). This definition was originally based on theCode for Advertising to Children used by the CanadianAssociation of Broadcasters (19).

The term ‘incidental’ creates some confusion. Before1989 the ABT regulations stated that ‘the amount of timedevoted to the premium must be in one continuous seg-ment not exceeding either one-third of the duration of theadvertisement or 20 seconds, whichever is theshorter’ (19). The advertising industry lobbied to have thisdefinition removed and their view prevailed (19). But sinceno new definition of the term ‘incidental’ has been intro-duced, this study used the former definition to definewhether the premium offer could be considered signifi-cant or incidental. All the food advertisements, whichused a premium offer as part of the sales pitch wereviewed by a single observer (JZ) and the total timedevoted to the offer was recorded. If the premium offertook up more than one-third of the total length of theadvertisement, it was labelled a breach of the CTS in ‘C’time and a breach of the Code in ‘G’ time. Following thecoding by the primary coder, coding instructions wereused by a second coder (HM) to re-code all the premiumoffer advertisements. Inter-coder reliability was 96%.

Results

Of the 1721 advertisements in the 63-hour sample of tele-vision, 544 (32%) were for food. The 12.5 hours of ‘C’programs had 97 food advertisements and the 50.5 hoursof ‘G’ programs in children’s timeslots had 447. Table 1shows 41% of advertisements in ‘C’ were for food, signif-icantly higher than the 30% of advertisements in ‘G’timeslots (P = < 0.001).

Table 2 shows that 35 (36%) of food advertisementsduring ‘C’ programs carried premium offers, significantlyhigher than the 76 (17%) in ‘G’ programs (P = < 0.0001).Premium offers were included for 14 different food adver-tisements, shown on 111 occasions. Of the food

Nutrition & Dietetics (2005) 62:1 27


Table 1. The total number of food advertisements in a 63-hour sample of children’s ‘C’ and ‘G’ programming expressed as a percentage of all advertisements broadcast in that timeslot(a)

(a) Chi-square for the difference between the percentage of food advertisements in ‘C’ and ‘G’ time = 11.4, P = 0.001.

Program ClassificationTotal program time in

hours

Total number of advertisements including

food advertisementsTotal number of food

advertisementsFood ads as a % of all

advertisements

‘C’ 12.5 236 97 41.1%(a)

‘G’ 50.5 1485 447 30.1%

Total 63 1721 544 31.6%

advertisements containing a premium offer, 84 of the 111were identified as not compliant with the CTS 20.2arequirement that the enticement should be incidental. Asignificantly greater proportion of these, 30 (31%)occurred in the ‘C’ time advertisements compared with 54(12%) in ‘G’ time (P = < 0.0001).

Table 3 lists the eight separate advertisements thatwere judged to breach CTS 20.2a. These were broadcaston a total of 84 occasions. Only four of the eight non-com-pliant advertisements were shown in ‘C’ time: forlollipops (16 occasions); two different fast food meals(eight and two occasions respectively); candy (four occa-sions); and fast food (twice). All eight advertisementsjudged non-compliant were shown during ‘G’ time.

Table 3 shows that six of the eight non-compliantadvertisements (shown on a total of 77 occasions) used95% or more of their advertising time describing the pre-mium. Of these advertisements, three were for fast foodrestaurants and three were for chocolate milk, lollipopsand breakfast cereals. Table 3 contains a brief descriptionof the type of premium offers used in the food advertise-ments. In two other advertisements with premium offers,(chocolate and candy), half of the 30-second advertise-ment was used to promote the premium offer. Table 4


Table 2. The total number of food advertisements with a premprogramming, including those which ‘breached’ CT

(a) Advertisements are judged to be in breach of CTS 20.2a if the total timtime.

(b) Chi-square for the difference between the proportion of food advertisem(c) Chi-square for the difference between the proportion of food advertisem

‘C’ & ‘G’ classified programs (with total hours in brackets)

Total number of food advertisements

Number andwith prem

‘C’ programs 97 3

(12.5 hrs)

‘G’ programs 447 7

(50.5 hrs)

Total 544

(63 hrs)

shows that each channel was judged to broadcast breachesof CTS 20.2a during 13 different ‘C’ programs shown onweekdays and Saturday mornings. During ‘C’ programs,2.4 non-compliant advertisements were screened per hourcompared with 1.1 per hour in ‘G’ time (P = < 0.0001).

Discussion

Like many countries, Australia has regulations to protectchildren against unfair marketing, but this study foundinfringements of one regulation. Using a precise interpre-tation of CTS 20.2a, many of these advertisements in thisstudy were judged to contravene one of the ABA regula-tions designed to protect children from unfair advertisingpractices.

A study of 13 countries reported that Australia had thehighest number of food advertisements during children’sviewing periods (2). Sweden and Norway, with virtualbans on advertising directed towards children, had thelowest number (2). Quebec stipulates no advertisementsare to be directed to children under 13 (20). In every coun-try, which allowed food advertising to children, a varietyof restrictions were placed on individual advertisements.In Australia concern has been consistently expressed overthe way foods are promoted to children and the apparent

ium offer in a 63-hour sample of children’s ‘C’ and ‘G’ S20.2a(a)

e given to a premium offer was greater than 33% of the total advertising

ents in ‘C’ and ‘G’ time with premium offers = 17.9 P = < 0.0001.ents in ‘C’ and ‘G’ time that breach CTS 20.2a = 21.7 P = < 0.0001.

% food advertisements iums [rate per hour]

Number and % food advertisements which ‘breached’ CTS 20.2a [rate per

hour]

5/97 (36%)(b) 30/97 (31%)(c)

[2.8 per hr] [2.4 per hr]

6/447 (17%) 54/447 (12%)


111 (20%) 84 (15%)



Table 3. The type and number of premium offer food advertisements which are in breach of CTS 20.2a in the 63-hour sample of children’s ‘C’ and ‘G’ programming(a)

(a) Advertisements are judged to be in breach of CTS 20.2a if the total time given to the premium offer was greater than 33% of the total advertising time.

Food advertisement Premium offer

Total number of food advertisements with premium

(number in ‘C’ time in brackets)

Percentage of time spent promoting the

premium offer

Mondo lollipops Three ‘Play with history’ collectable historical warriors including Knights, Zulus and Samurais

30

(‘C’ = 16) 100%

McDonald’s Pop-up Dogs Happy Meal

Four Lady & the Tramp pop-up dogs: collectables 21

(‘C’ = 8) > 95%

Hungry Jacks Kids Club Meal

Five Rugrat straw-hugger movie character toys: collectables

12

(‘C’ = 2) > 95%

Milo ‘Win a swim with Michael Klim’ and other prizes include 150 Nintendo games packs.

8

(‘C’ = 0) > 95%

Kellogg’s breakfast cereals

Prizes include 1000 portable CD players and 100 digital video cameras and the main prize is 20 family trips for 2 adults & 2 children to ‘California’s newest theme park next door to Disneyland’.

4

(‘C’ = 0) > 95%

KFC ‘Chicky Meal’

Six swap-monster collectable figurines 2

(‘C’ = 0) > 95%

Wonka Oompa candy Ten family trips to the Wonka factory in the US (‘and all the ‘scrummy’ lollies you can carry!’)

7

(‘C’ = 4) 50%

Mars Celebration Win $20000 or Polaroid joy camera 1

(‘C’ = 0) 50%

Total 84

(‘C’ = 30)

inadequacy of current legislation to protect children’sinterests (14,21–23). This study found that children watch-ing programs specifically classified as suitable for six- to13-year-olds were exposed to high numbers of foodadvertisements, with the proportion during ‘C’ time beingsignificantly higher than in the ‘G’ programs classified assuitable for a general audience (P = < 0.001). In the studysample time, premium offers were widely used, with 36%in ‘C’ time and 17% in ‘G’ time (P = < 0.0001). This wasmarkedly different from a 1982 study, which found nopremium offers in any food advertisement (4). Premiumoffers are attractive to children and are likely to stimulaterequests for the product. Children watching programswhich are specifically made for them (‘C’ programs) areexposed to proportionally more premium offers.

Using the classification system described, this analysisidentified a high proportion of breaches of CTS 20.2a,meaning the premium offers were not merely incidental tothe main product being advertised, as required in the regu-lations. Infringements were more frequent in ‘C’ time,with almost one third of advertisements in these programscontaining premium offers that breached the regulations.

This suggests the standards are widely ignored and/orinadequately monitored by the Australian BroadcastingAuthority under the current regulations.

Most of the food advertisements in this study con-tained premium offers that would be attractive to anaudience of younger children—four plastic animals, fivemovie character toys, six monster toys and three toy war-riors. Children were encouraged to collect these by eatingat the restaurant or buying the food product. Other adver-tisements offering premium competition vouchers to winsuch things as a ‘million dollars worth of prizes’ wouldalso appeal to older children. The prizes included 1000portable CD players, 100 digital video cameras, 150 com-puter games packs, 20 family trips to ‘California’s newesttheme park next door to Disneyland’, ‘swim with MichaelKlim’ and 10 trips to the (Willie) Wonka factory in theUSA with ‘all the ‘scrummy’ lollies you can carry’.

CTS 20.2a in the ABA regulations is an acknowledg-ment of potential problems in marketing a food product orservice to children by over-emphasising a premium offerrather than the attributes of the food. The ABA acceptedthat advertisements using such tactics to lure or entice



Table 4. Placement of food advertisements with premium offers which breach CTS 20.2a(a) in an analysis of 12.5 hours of ‘C’ programs

(a) Advertisements are judged to be in breach of CTS 20.2a if the total time given to the premium offer was greater than 33% of the total advertising time.

Channel Program

Timeslot (total program time shown

in brackets)Premium offer food

advertisement Number of advertisements

7 ‘Big Arvo’ 4.00–4.30pm Mondo 9

(2.5 hrs) McDonald’s 3

7 ‘Time Masters’ 10.30–11.00am Sat Mondo 1

(0.5hrs)

7 ‘Lil Horrors’ 9.00–9.30am Sat Mondo 1

(0.5hrs)

10 ‘Totally Wild’ 4.00–4.30pm Mondo 1

(2hrs)

10 ‘Wild Kat’ 4.00–4.30pm McDonald’s 1

(0.5hrs)

10 ‘Magic School Bus’ 7.00–7.30am Sat Mondo 1

(0.5hrs) McDonald’s 1

10 ‘Fast Tracks’ 7.30–8.00am Sat Mondo 1


10 ‘Totally Wild’ 8.00–8.30am Sat Mondo 1


10 ‘Where in the World is Carmen San Diego’

8.30–9.00am Sat Mondo 1


9 ‘Cushion Kids’ 4.00–4.30pm Hungry Jacks 2

(2.5hrs)

9 ‘Pick Your Face’ 7.00–7.30am Sat Oompa Candy 1

(0.5hrs)

9 ‘Good Sports’ 7.30–8.00am Sat Oompa Candy 1

(0.5hrs)

9 ‘Ship to Shore’ 9.00–9.30am Sat Oompa Candy 1

(0.5hrs)

9 ‘Download’ 9.30–10.00am Sat Oompa Candy 1

(0.5hrs)

Total 12.5 hours 30 advertisements

children into buying a food product would be unsuitableand exploitative. The Industry Code of Practice alsoaccepts that these regulations should apply to all adver-tisements directed to children.

Using a clear definition, breaches of the regulationswere found widely in this sample of advertisements withpremium offers such as small toys presumably to attractchildren’s attention. In this case the marketing ploy couldbe seen to encourage children to pester adults to buy cer-tain foods. A growing body of research has examined theeffects of ‘pester power’ or the ‘nag factor’ on familybuying patterns (3). According to Dalmeny et al. (24), ‘pes-ter power’, or the ability of children to influence theirparents’ purchasing choices, has become a well-used partof the marketing landscape (24). The careful targeting of


child consumers can also have the added advantage ofengaging and maintaining brand loyalty over decades (24).A national survey in the US reported that 10% of 12–13-year-olds admit to asking their parents more than 50 timesfor a product seen advertised on television (25). In the UK,a member of Parliament was recently reported as insistingthat an advertising agency publicly apologise for encour-aging children to pester their parents to buy a snack foodproduced by Walkers Crisps (26), where the advertisementshowed a child saying ‘I am going to pester mum for themwhen she next goes shopping’. The CEO was quoted asadmitting that ‘the wording was unfortunate and we won'tdo it again’ (26).

A former advertising copywriter concedes that televi-sion advertising is not a medium for information but for


emotion (27). Covert, as well as overt messages should beexamined and consideration given to the overall advertis-ing environment. In Australia, two national advocacybodies, the Coalition on Food Advertising to Children(CFAC) and Young Media Australia (YMA), haverecorded parental complaints about the number of pre-mium offers in food advertisements on Australiantelevision and the pressure this exerts upon them (28).

This study suggests that some food companies maynot be complying with CTS 20.2a. The time devoted tothe premium offers of collectable toys or free entry tocompetitions appeared to overwhelm the sales pitch forthe food, with 31% of the food advertisements in ‘C’ timecontaining a premium offer in breach of past regulations.Most devoted over 95% of the total advertising time to thepremium. Food packets were more likely to be shown inthe advertisement than the actual food product (data notshown). A further 15% of food advertisements in ‘G’ timewere similarly non-compliant.

Paradoxically, this study found that during ‘C’ time,where legislation applies with strong penalties in order toprotect children against unfair marketing practices, thereis significantly less compliance with CTS 20.2a than dur-ing ‘G’ time when only a voluntary Code of Practiceapplies (P = < 0.0001). This does not mean that the classi-fication itself is the cause of the poor compliance in ‘C’time. It may appear that advertisers have often savedaggressive advertising techniques for the timeslot whenchildren’s specially designated programs are shown andparents are more likely to feel their children are watching‘suitable’ content which does not require supervision (14).The higher proportion of breaches in ‘C’ time suggeststhat children are not being protected by existinglegislation.

With childhood obesity increasing and type 2 diabetesbeing diagnosed in obese children (29–35), healthy eatinghas become a public health priority for children and thereis a need to discourage high consumption of energy-dense,micronutrient-poor foods. This analysis found the foodadvertisements with premium offers were predominantlyfor snack foods and fast food restaurants and most of thebreaches of the premium offer regulations were by a fewmultinational companies. Reports indicate companiessuch as McDonalds, Hungry Jacks and KFC spend heav-ily on advertising directed to children (24,36,37).

It is reasonable to assume companies would not adver-tise food products during children’s television programs ifit was not effective in increasing sales (10). Food advertis-ing has the potential to encourage poor eating habitsamong children and unfair marketing practices exploittheir vulnerability (1,12,13,38). There is also potential forharm (39), with childhood eating habits being strong pre-dictors of adult diets (40) and poor nutrition contributing tofuture health care costs (41).

In Australia, concerns about the regulation of foodadvertising to children are strengthening. This analysisdemonstrates that if society permits food advertisingdirected towards children, regulations should be scruti-nised, strengthened and adequately regulated. Using ourprecisely defined interpretation of CTS 20.2a, there werefrequent breaches of one of the Australian Children’s Tel-evision Standards on each commercial television station.It would appear that regulations with legislative force did

not guarantee any more responsible advertising practicesin ‘C’ time than in ‘G’ time.

The CTS was designed to exert some control overadvertising, but we understand breaches are not routinelyinvestigated in Australia. The regulations themselves havenot been open to public debate for more than a decade. In2002, the Coalition on Advertising to Children forwardeda detailed complaint about breaches of CTS 20.2a to theABA regarding McDonald’s Happy Meal which com-prises an attractively packaged cheeseburger, small fries, asmall soft drink and a toy. Almost a year later, the ABArejected the complaint on the basis that a free offer such asthe toy given was not a premium offer but an integral partof the meal (L Atkinson-MacEwen, ABA, 2002, Pers,comm., 15 November) Free coupons for entry into compe-titions were also not considered to be premium offers.Such reasoning and the time taken to reach this decisionmay explain why few complaints are made or upheld.

It is difficult to reconcile the ABA response when apremium offer is defined in the legislation as: ‘anythingoffered with or without additional cost that is intended toinduce the purchase of an advertised product orservice’ (17). Additionally, there is evidence that, unlikethe ABA, the general public recognise items such asMcDonald’s Happy Meals’ toy collections as premiumoffers. These premiums are offered for sale on many inter-net sites around the world and they are colloquially calledHappy Meals premiums (42). With such confusion, theABA needs to clarify its definition of premium offers inthe regulations. In Finland, McDonald’s is specificallyforbidden to promote the toys in their advertisements forchildren’s meals (24).

Conclusion

Food advertising on television is an important issue thatwarrants consideration of ethical concerns and socialresponsibility towards children. Policy, advocacy and edu-cational issues and actions need to be established toensure food messages reaching children in all countriesare in their best interests (43). In North America, a recentreport calls for current food advertising practices to berevisited and for laws and regulations to be strengthenedto support parents’ attempts to feed their children healthydiets (44).

The current study found major problems with foodadvertising practices in Australia. A legally enforceablecode has not guaranteed compliance. Multiple breaches ofthe CTS concerned with premium offers in food advertise-ments were shown during the designated five hours perweek of ‘C’ time, showing that many advertisements useunsuitable tactics to entice children to buy foods, many ofwhich are energy dense and micronutrient poor.

Our experience demonstrates that reliance on self-reg-ulation by the industry is not working effectively, and thecomplaints process is prolonged and unsatisfactory. Com-munity values have also changed since the CTS wereintroduced and obesity and other diet-related diseaseshave increased dramatically. There is an urgent need tobetter protect children by creating a healthier televisionfood environment. The authors assert that this is an issuethat should be taken more seriously than currently appears



by stakeholders and policy makers in Australia andthroughout the world.

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Documents

Food advertising and broadcasting legislation—a case of system failure?