Thank you, and good afternoon.
I'm testifying today as an individual expert. I don't accept any industry funding and I don't represent any organization.
My expertise is in consumer health behaviour. I've studied tobacco marketing for almost 20 years and food marketing for the past decade. I've also served as an adviser to regulatory agencies for marketing regulations and as an expert witness in legal challenges to public health marketing laws.
You heard Dr. Potvin Kent describe the scope of the problem and the extent of marketing. I'm going to focus more on how to design effective regulations.
Let me begin by stressing the importance of this bill. It's a curious fact that almost none of us admit to being influenced by advertising, while at the same time companies spend billions of dollars shaping what we buy and what we consume. It's always been curious to me that when governments seek to restrict advertising, the same companies spending billions to advertise unhealthy foods suddenly question whether these ads actually make a difference in what we eat.
Over the course of your hearings you're likely to be told that the effect of food marketing is somehow different from other domains. You'll be told that's because obesity is complicated, because marketing is only one of the many causes of obesity. You'll be told that because marketing restrictions won't solve obesity on their own, they probably shouldn't be implemented. You'll probably even hear efforts to shift the focus entirely away from dietary intake and onto physical activity.
Putting aside the fact that physical activity levels in Canada have actually gone up over the last 30 years, I want to be clear about the evidence on food marketing. There is a very strong consensus in the scientific community that marketing promotes dietary intake of unhealthy foods. One of the most important lessons from that evidence is that marketing exerts its influence at a far earlier age than most of us realize.
There are all sorts of examples in research that's been conducted. I often think of the landmark study that was published more than 25 years ago in JAMA, which is one the world's leading medical journals. The study looked at brand logo recognition among three- to six-year-old children. Not surprisingly, right at the top of the list was Disney and the Mickey Mouse logo as the most recognized brand, but among these three- to six-year- olds, the next five brands were all food brands: McDonald's, Burger King, Domino's Pizza, Coca-Cola. and Pepsi. Research has consistently demonstrated that not only does this marketing reach children, but it actually has a greater influence among younger children.
I want to say a brief word about the timeline for thinking about the impact of marketing restrictions. Removing food marketing will not change obesity rates overnight, just as removing tobacco marketing didn't reduce smoking rates overnight. The impact is incremental. It's going to be strongest among the future generations who grow up in the absence of the promotional messages.
Indeed, in the case of tobacco marketing bans, it's often difficult to see any change at all in the year or two following the ban, but I can tell you that marketing restrictions are recognized as one of the most important factors in the reduction of smoking among young people over the last 40 years.
That's not to say that all marketing regulations are equal or have the same impact. I'd like to touch upon three important considerations that are likely to influence the effectiveness of the proposed measures.
The first consideration has to do with the number of marketing channels that will be covered. In short, marketing restrictions that only apply to a limited number of channels will have a limited impact. You can think of the marketing mix as a tube of toothpaste. If you squeeze at one point, it doesn't disappear, it just shifts to another spot. That's what we've seen with tobacco marketing: expenditures didn't decrease after traditional advertising was banned, but simply shifted into other areas.
In fact, the main area where expenditures increased was the point of sale in retail settings, which is a critically important channel for food marketing. That includes traditional advertising in stores, such as posters and signs, as well as paid product placement. It's not an accident that certain foods are right near the cash register.
It also includes packaging. You don't need to do research or be a researcher; you only need to walk down the cereal aisle of any grocery store to understand how food packaging targets young children through cartoons and product tie-ins.
To be effective, marketing restrictions should also include sponsorship activities. However benign they may seem, sponsorships are actually one of the most effective and pervasive ways to market unhealthy foods to kids.
I have three children. They play in hockey and soccer leagues where kids run around with fast-food logos on their shirts. I understand the importance of this type of funding to community groups and the political sensitivity of this issue, but from a marketing and public health perspective, these activities should be restricted. That doesn't have to be an outright ban. Certain jurisdictions allow sponsorships; they just restrict the use of logos and promotional messages about those sponsorships. In other words, community groups can continue to accept funding from the industry, but food companies can't promote their brands to children as part of that transaction.
The second key feature that I think will determine the impact of the restrictions is something that Dr. Potvin Kent referred to, and that's how child-directed marketing is defined.
To date, the industry standard, the Canadian children's food and beverage advertising initiative, defines child-directed marketing based on audience viewership, as you heard. To qualify, at least 35% of viewers must be under 12 years old. The problem is that most of the shows that children actually watch don't qualify as child-directed, because enough older kids and teenagers watch the same shows. Children under 12 account for only about 10% of our population, so you could have every Canadian under 12 watching a program, but if enough adults and youth were watching the same program, it would not be considered child-directed advertising.
Dr. Monique Potvin Kent has given you several examples of how the current industry standard has been applied, and frankly, I think most people are surprised to hear that companies like Coke, McDonald's, and Red Bull have policies that they don't advertise to children, even as they use Mickey Mouse, cartoons, skateboarding, and video games to promote their products.
In fact, in that brand logo study I mentioned earlier, it's interesting to note that more than half of the three- to six-year-olds recognized a logo for a cigarette brand and could identify it. That's not because the tobacco companies were running cigarette ads on kids' shows; it's because even three- to six-year-olds are exposed to the same media channels that the rest of us watch.
Therefore, I'd like to endorse the potential benefit of Health Canada's proposal to restrict unhealthy food marketing on all TV programs until 9 p.m. That's going to be a far more effective approach to eliminate what children are actually exposed to, and not just so-called child-directed marketing. If thresholds are needed for other channels and print media, then more robust thresholds should be used with higher age limits. For example, the U.K. uses 20% of viewers under 16 as a threshold for child marketing. As a safeguard, restrictions can also be applied to the content of food marketing to restrict the use of cartoon characters, games, and other methods to promote unhealthy foods.
The third and final consideration addresses how unhealthy foods are defined. As I understand the current framework, ads would be prohibited if they feature foods that exceed the nutritional threshold for sugar, sodium, or saturated fat. This assumes that the ad in question actually features a specific food product. In fact, many ads include only general brand imagery and don't actually show an individual product. Think about lifestyle ads that market the Coke brand without actually showing a particular bottle of Coke. With these ads, it's difficult to see how the nutritional criteria could be applied. While this might seem like a technical consideration, it actually has the potential to create a very big loophole that would allow companies to run advertisements on any channel at any time. Perhaps this will be addressed in the regulatory phase, but I'd encourage Health Canada to consider standards that would prevent generic brand advertising on restricted channels or at restricted times.
In summary, I would suggest that the proposal to restrict unhealthy food marketing to Canadian kids has the potential to be a highly effective public health measure. It's true that marketing restrictions are not a silver bullet, but fortunately we don't use silver bullets as a threshold for effective public health measures. If we did, tobacco advertising would still be ubiquitous and smoking rates would probably be closer to historic highs, similar to where our current levels of overweight and obesity are.
To be effective, the restrictions must reduce a meaningful amount of exposure, and that means they'll need to cover a comprehensive set of marketing channels, including retail settings, packaging, and sponsorships. The impact will be limited unless the restrictions capture the range of media content to which kids are actually exposed, and not just the thin wedge of so-called child-directed marketing.
Thank you very much.