The publication of the UK’s Committee of Advertising Practice (CAP) literature review on the impact of online food and drink advertising on children yielded few surprises and leaves many important questions unanswered.
The review itself is not at fault. In his preface to the report, Professor David Buckingham, Professor of Media and Communications at Loughborough University, described it as a “careful and balanced analysis”. However, the review was examining an area where there is a pronounced lack of conclusive research.
Commissioned by the CAP from the market and social research agency, Family Kids & Youth, the review’s primary finding was that “the extent and quality of the evidence base around the impact of online food and soft drink marketing to children is limited”.
While studies had shown online marketing can influence children’s brand awareness and short-term food preferences, it said the literature also “urges caution” as most of the research is lab-based. It concluded there is an “over-arching need for more and better evidence, including more long-term ethnographic and longitudinal research on the actual impact of online advertising on children’s diets”.
In addition to looking at the highly contentious area of advergames, the review also examined research into areas such as targeted advertising, marketing to children via social media, peer-to-peer marketing and mobile marketing.
The CAP’s own conclusions and recommendations from the review appear to underline the need for greater understanding of this area of marketing. While it concludes the rules and guidance in place are providing “the right level of protection”, it significantly adds: “This does not mean that no further action is required.”
In particular, the CAP says children’s critical understanding of the persuasive intent of online advertising is an area “we believe requires attention”. In its statement, the CAP adds: “We need to understand better how immersive online environments affect children’s critical understanding of advertising, and ensure that the ads seen by children are obviously identifiable as such.”
Despite being met with some scepticism by campaigners, the action CAP plans to take in light of the review may provide some useful further insight into an issue which clearly requires more examination. The CAP says it will “explore children’s critical understanding of commercial intent and recognition of marketing” and will produce guidance for advertisers by the third quarter of the year. The guidance will be informed by separate research identifying the various types and prevalence of immersive online marketing approaches.
The Children’s Food Campaign pressure group said it “the only commitment” to result from the review and pointed out the existing guidance on the use of advergames and similar digital marketing tools already states marketing communications should be obviously identifiable as such by children.
Nevertheless, this process offers the opportunity for greater clarity in the advertising code, and has the advantage self-regulatory systems offer of being a relatively swift response.
Prior to the publication of the new guidance later in the year, the CAP states that “if there is any doubt” as to whether an online ad, such as an advergame, might not be recognisable to children as advertising, this should be made clear, for example, by labelling. The CAP will publish this interim advice to advertisers immediately.
After the new guidelines are published, the CAP will conduct industry training during the fourth quarter. The CAP has also promised to conduct a “monitoring sweep” of online food and drink marketing to check compliance with the rules. It will also provide further advice and training resources to industry on understanding and compliance with the current rules on online behavioural advertising (OBA). How data is being collected from children and their exposure to OBA was one of the key concerns raised in the ‘grey literature’ included in the scope of the report which comprises material such as press articles, opinion pieces and TV documentaries.
Campaigners are generally unhappy with the self-regulatory system that exists for governing advertising in the UK, where the Committee of Advertising Practice, comprised of representatives of advertisers, agencies, media owners and other industry groups, writes and maintains the codes which are then administered by the regulatory body, the Advertising Standards Authority (ASA).
The CAP’s response to the review was deemed insufficient by activists. In a somewhat withering statement, the Children’s Food Campaign said it was “disappointed but not surprised that the industry body which sets the marketing rules – the Committee on (sic) Advertising Practice – has concluded that the rules governing online marketing to children ‘currently in place are providing the right level of protection’.”
The Children’s Food Campaign has been calling for a legislative regulatory framework to be put in place aimed at protecting children under 16 from the marketing of less healthy foods and drinks.
In the context of the broader debate about how advertising should be regulated, remarks by Guy Parker, chief executive of the Advertising Standards Authority, at last week’s Westminster Food & Nutrition Forum Keynote Seminar on tackling obesity, are worthy of note.
Speaking just before the publication of the CAP review, Parker referred to the concerns over the immersive nature of advergames and the issue of whether children comprehend that they are watching advertising in online contexts. His conclusions on advertising regulation more generally are also extremely relevant to the current debate on online marketing to children.
He said advertising regulation had to “steer a sensible course and make proportionate judgments based on the evidence”. He also said the evidence-base was not “a machine with a button on it and you press the button on it and it churns out the answer”. Interpretation and judgement is required.
The less evidence that is available, or the less conclusive the evidence is, clearly the more difficult that judgment becomes. An inconclusive evidence base is also likely to lead to more contentious debates, Professor Buckingham, suggests.
In his preface to the report, Professor Buckingham summed up the challenge regulators and policymakers face on the issue. “We know a fair amount about what advertisers and marketers are doing in these new digital spaces. What we do not really know is what children and young people (and indeed adults) make of it – how far they understand it, how they respond to it, and, ultimately, the effects it might have on them. Research of this kind can hopefully contribute to a better informed, and ideally less polarised, debate about the role of digital marketing. Yet in such a rapidly changing environment, we clearly cannot wait until we have all the evidence.”
Advocates of self-regulatory systems would contend their greater flexibility and responsiveness offer advantages when change is occurring rapidly. Among its conclusions, the report states the regulation of advertising and marketing “self-evidently needs to adapt in line with changing technologies and techniques” and that “in the current changing environment of online advertising to children, the regulatory framework and research needs to keep evolving”.
The CAP response to the review may be deemed insufficient by campaigners but it is at least relatively immediate. Moreover, it demonstrates the system’s capacity to adapt quickly as further, and possibly more conclusive, research into the subject becomes available.