Submission Number: 00495
Received: 7/11/2011 4:02:55 PM
Commenter: Jennifer Hill
Agency: Federal Trade Commission
Initiative: Preliminary Proposed Nutrition Principles to Guide Industry Self-Regulatory Efforts; Project No. P094513
Attachments: No Attachments
Dear Secretary Vilsack, Chairman Leibowitz, Director Frieden, and Commissioner Hamburg:
Thank you for your efforts through the Interagency Working Group (IWG) to reduce unhealthy food marketing to children. The proposed marketing guidelines are strong, based in nutrition science and comprehensive in scope. They will do much to encourage food and entertainment companies to limit junk-food marketing to children, support parents' efforts to feed their children a healthy diet, and ensure schools are healthy and supportive environments.
I support the IWG’s proposal to use a food-based approach in the nutrition standards to ensure that the foods marketed to children make a meaningful contribution to a healthful diet. I also support the IWG’s comprehensive view of marketing to children, covering the wide range of approaches companies use. I strongly support the overall proposed nutrition principles and marketing definition, but urge several changes to clarify and strengthen them.
Just a few changes in the nutrition standards would make them stronger:
• Clarify that the proposed nutrition principles apply to all foods marketed to children, not just those most heavily marketed to kids. It doesn't make sense to apply the standards to some marketed foods and not others.
• Revise the timeframe for implementation to two years (with a five-year timeline for the final sodium standards).
• Include calorie limits to better address childhood obesity.
• Combine fish, meat, poultry, eggs, nuts, and beans into one food group, as they are in MyPlate and the Dietary Guidelines, so that the standards do not overemphasize marketing meat.
It’s important that the marketing definitions accommodate the full range of approaches food companies use and that they:
• Provide a clear set of model marketing definitions that could be easily adopted by companies.
• Define brand marketing and require brand marketing to meet IWG nutrition principles. Many marketing efforts aimed at children do not promote individual products, but instead promote a line of products, one brand within a company, or a whole company.
I thank the IWG for its strong nutrition and marketing guidelines, and urge you to finalize them by the end of the year. I also hope that our nation’s food and entertainment companies will take children’s health seriously and adopt these voluntary principles.