Submission Number: 00342
Received: 7/6/2011 10:25:41 AM
Commenter: Brian Jordan
Organization: Illinois Food Retailers Association
Agency: Federal Trade Commission
Initiative: Preliminary Proposed Nutrition Principles to Guide Industry Self-Regulatory Efforts; Project No. P094513
Attachments: No Attachments
On behalf of the Illinois Food Retailers Association whose membership is comprised of over 1,000 independent food retailers and the wholesalers and suppliers that service them throughout the state of Illinois I am writing to voice my concern regarding proposed voluntary guidelines for advertising and marketing within the food industry. The proposed restrictions actually ban all forms of advertising and marketing of virtually all foods and beverages to anyone under the age of 18, including in-store displays, sponsorships and print advertising.
While I whole heartedly support ideas to improve the health and well-being of my customers, I do not believe these "voluntary guidelines" will have any meaningful impact on the health of the public. In fact, many of the foods most affected by these stringent guidelines are lower-calorie, nutrient-dense foods that the government elsewhere has encouraged people to eat. This proposal will have a negative impact on the economy and jobs in the retail, food, advertising and media industries. Retail sales are driven through advertising, marketing and promotions. These stringent rules would effectively destroy the way the grocery industry goes to market.
The entire regulatory effort is based on the false premise that food advertising causes childhood obesity. There is no evidence to support this claim. Food advertising to children has been on the decline while obesity has been on the rise.
Your willingness to further review the negative impact these broads guidelines would have on a critical sector of our economy; not only grocery retailers and wholesalers but industries that work to package, distribute and work to gain the attention of consumers would be greatly appreciated.