FTC Is Urged To Investigate Digital Food Marketing To Kids

As use of digital media becomes a pervasive way of life for young people, regulators investigating the link between junk food marketing practices and childhood obesity need to scrutinize this new "marketing ecosystem" carefully, maintain the authors of a 98-page report submitted yesterday to the Federal Trade Commission.

Food and beverage marketers are using digital marketing techniques to aggressively target children and adolescents in ways that often fly below the radar of parents and regulators, the authors maintain, calling for a governmental review of the practices.

"The public policy debate has focused on TV commercials," said American University professor Kathryn Montgomery, co-author of the report with Jeff Chester, executive director of the Center for Digital Democracy.

"Interactive Food & Beverage Marketing: Targeting Children and Youth in the Digital Age" reads like a how-to primer on industry practices and a who's who of brand marketers, suppliers and agencies involved.



Several marketers cited in the report for their marketing practices are part of a "voluntary self-regulation program" formed last year by the National Advertising Review Council "to shift the mix of advertising messaging to children to encourage dietary and healthy lifestyles."

"What we are trying to do is encourage some serious discussion and figure out a way to address the problem," added Montgomery, who has a full book on the subject coming out next month from MIT Press. "I don't think self-regulation works by itself."

But Dan Jaffe, EVP/government relations for the Association of National Advertisers, said the letter is an attempt to expand the scope of the current FTC analysis into advertising expenditures.

"We think that would be inappropriate," he said. "If these other issues need to be dealt with, they should be dealt with separately."

The Children's Advertising Review Unit, he maintained, has expanded its coverage to include all types of media, including the Internet. CARU keeps growing to incorporate new technologies and issues as they develop.

In addition, the FTC already has the authority to stop any false, deceptive or unfair practice. "If people are not satisfied, then they should go to the Federal Trade Commission," he said.

Each time a new media emerges, "there are critics who have said the sky is falling," Jaffe added, citing comic books as an example. "The fact is that with all these media, we've been able to develop regulatory systems that are appropriate. In fact, parents have much more control over media now than when I was a kid," he added.

Chester and Montgomery are no strangers to online marketing to children, and wrote the research 10 years ago that led to the eventual adoption of the Children's Online Privacy Protection Act. That law, which took effect in 2000, restricts the collection of personal information from children under the age of 13 by commercial Web site operators.

"As our research shows, major food and beverage brands are utilizing a variety of new venues--including cell phones, instant messaging, video games, user-generated video, and three-dimensional virtual worlds--in their efforts to target children and adolescents and to foster ongoing personal relationships with them, often under the radar of parents," wrote Chester and Montgomery in an accompanying letter to the FTC co-signed by Lori Dorfman, director of the report's co-issuer Berkeley Media Studies Group, Patti Miller of Children Now, and Jason A. Smith, associate executive director of the Public Health Advocacy Institute.

About eight months in the making, the report was timed to meet today's FTC deadline for comments on its upcoming review of food industry marketing practices. In it, the authors urge the FTC to pay special attention and to probe marketers about their spending and practices such as behavioral profiling, viral and social networking campaigns, broadband and more.

"When you look at all of these together," said Chester, "these are powerful technologies. We have to use them wisely."

The report cites a 23.2% increase in spending on Internet display advertising of food, beverages and candy--the 15th-ranked category for 2006. It offers dozens of examples--ranging from KFC's MosquitoTone ring tone campaign to Kraft Lunchables' sponsorship of Yahoo's IMvironment.

Domino's Pizza gets singled out for its viral video success, "MacKenzie Gets What MacKenzie Wants," in which a spoiled girl offers a car on eBay for $9.99 after she gets a new one in the color of her choice. It tied in with an "Anything Goes Deal Contest," but Domino's was never named.

The report "reveals that children are being targeted to eat poorly in even more insidious ways than most of us could possibly have imagined," said Marion Nestle, a noted professor of nutrition, food studies and public health at New York University.

The report also faults efforts by marketers to target African-American and Latino youth through specific multicultural marketing efforts using digital media.

The report calls on the FTC, the Federal Communications Commission and Congress to work together with the industry and public health and child advocacy groups to develop a new set of rules governing the marketing of food and beverage products to children.

In addition, it urges venture capitalists and other financial investors in the digital space to develop policies to ensure that companies they fund do not engage in deceptive or unfair marketing of food products to children and adolescents.

The full report is at www.digitalads.org.

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