Submission Number: 00089
Received: 5/27/2011 4:26:54 PM
Commenter: Vince Lombardo
Agency: Federal Trade Commission
Initiative: Preliminary Proposed Nutrition Principles to Guide Industry Self-Regulatory Efforts; Project No. P094513
Attachments: No Attachments
The advertising industry has stated that the guidelines are "sufficiently onerous that they would basically block a substantial amount of advertising." That is the whole point of the guidelines - to block advertising to children, but specifically for foods with high fat, sodium and sugar. The total amount of advertising could remain the same if that same advertising were redirected to fruit, vegetables and extra lean meat (and this type of advertising gives a company a more positive image).
Also, the food providers that advertise have been saying that it is up to parents to make sure that their children eat correctly. By that logic, advertisers should direct their advertisments to the parents if they are expecting that it would be the parents that would be making the decisions. By advertising to children, they are inherently showing that they are expecting children to be involved in the decision making - otherwise they would be completely wasting their advertising dollars. What that then sets up is a set of children trying to influence their parents in the decisions, and then the parents have to constantly try to undo the advertising messages that do not match with the decisions they want to make for their children. The parent has to fight sophisticated advertising in the forms of professional food imagery, tie-ins with well known movie/tv show characters, inclusions of toys, and constant repetition of the advertisement - and parents cannot possibly be aware of every single advertisement that their children receive. If advertisers practiced what they preached in that parents should make the decisions for their children, then they would advertise to the parents what there children should be fed and parents would not have to manage all influence that the direct to children advertisments have. If an advertiser were to advertise directly to parents what their children should eat, one would expect that they would appeal to parents desires to have them eat fruits, vegetables, extra lean meat and other healthful ingredients. This would have the benefit of automatically putting them in compliance with the guidelines. Of course one of their problems is that the food companies that the advertisers represent do not make nearly as much money in selling anything with a high fruit/vegetable content that also has low fat/sodium/sugar. But this should force food companies to come up with more of these healthy items - and the heavy advertisements for these should cause enough sells to help offset the cost. They will argue that they would make less money in total. As long as they still make money, that is fine. The primary goal of our country is not and should not be to maximize profits and increase shareholder value for these companies. Is keeping a set of higher profits more important than making sure that children eat as healthy as possible? They may say that this won't change eating habits and that people will still buy the unhealthier foods. Well, the food industry controls most of what we eat. If they decided to change the landscape of the food in this country and halved the sodium in our food that has high sodium, and made it so that they offered only a very limited number of products that had high sugar/saturated fat, people would have no choice but to eat healthier because 85% of the store would now be composed of healthier items. If all the soups had less sodium, if all the chips had less sodium, people would just have to buy it because that is all there is - and they would get used to less sodium (once you do, trying foods with that level of sodium tastes very salty). As long as every food maker of the same product type has the same guidelines, then they wouldn't have to worry about losing marketshare to anyone else. The food industry has an enormous impact on what everyone eats and it is time that they realize that with this great power comes great responsibility.