Submission Number: 07874
Received: 7/14/2011 4:16:46 PM
Commenter: Juliet Sims
Organization: Prevention Institute
Agency: Federal Trade Commission
Initiative: Preliminary Proposed Nutrition Principles to Guide Industry Self-Regulatory Efforts; Project No. P094513
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July 14, 2011
Federal Trade Commission
Office of the Secretary, Room H-113 (Annex W)
600 Pennsylvania Avenue, N.W.
Washington, D.C. 20580
Re: Interagency Working Group on Food Marketed to Children: Proposed Nutrition Principles: FTC Project No. P094513
Prevention Institute strongly supports the proposed nutrition principles for foods marketed to children as defined by the Interagency Working Group (IWG). The introduction of robust, uniform nutrition and marketing principles is an important first step towards limiting the marketing of foods to children only to those that contribute to a healthy diet. We are pleased to have the opportunity to respond to the request for comments surrounding these standards.
Prevention Institute was founded in 1997 to serve as a focal point for primary prevention practice—promoting policies, organizational practices, and collaborative efforts that improve health and quality of life. As a national non-profit organization, the Institute is committed to preventing illness and injury, to fostering health and social equity, and to building momentum for community prevention as an integral component of a quality health system.
To address the specific questions for comment as outlined in the IWG’s proposed standards, please refer to the enclosed letter from Strategic Alliance. As a steering committee member of Strategic Alliance, we are in full support of their comments. Our additional comments are provided below.
The food and beverage industry spends nearly $2 billion per year marketing their products to children, most of which are high in calories, fats, and added sugars. 1 And it’s working. Today nearly 40% of kids’ calories come from unhealthy fats and added sugars – the building blocks of junk food. 2
In their current form, the standards will help shift the preponderance of foods that are marketed directly to children from those that are high in fat, calories and sugar to those with a healthier nutritional profile. Ultimately, however, the goal of the uniform standards should be to move beyond foods that are slightly healthier, to instead only allow truly healthy foods to be marketed to children. The Dietary Guidelines are clear: whole and minimally processed fruits, vegetables, whole grains, low-fat dairy, and lean protein are the foods that contribute to healthy growth and development. These should be the only foods allowed in marketing aimed at kids. Highly processed foods that contain added fats, sugars, salt, artificial colors and flavors, or other additives should not be permitted. Doing so would put more decision making power into the hands of parents, since compliant companies would not directly target children.
The proposed guidelines, if adopted by food and beverage manufactures, would make a vital contribution to addressing the improvement of foods marketed to children. With the food-based approach that has been suggested by the IWG, these principles are a huge step in the right direction. Moving forward, as food marketing standards evolve and progress, we urge IWG to continue to move in the direction of truly healthful food.
We thank the IWG for the opportunity to share our comments, and look forward to your response.
Juliet Sims, RD, MPH
1 Federal Trade Commission (FTC). Marketing Food to Children and Adolescents: A Review of Industry Expenditures, Activities, and Self-regulation. Washington, D.C.: FTC, 2008.
2 Reedy, J. and S.M. Krebs-Smith, Dietary Sources of Energy, Solid Fats, and Added Sugars among Children and Adolescents in the United States. Journal of the American Dietetic Association, 2010. 110(10): p. 1477-1484.