Elaine D. Kolish, VP and Director Children’s Food & Beverage Advertising Initiative Council of Better Business Bureaus

Grocery Manufacturers Association Public Policy Summit July 17, 2013 Washington, DC

The Children’s Food and

Beverage Advertising Initiative

“Responsible Marketing: A Report Card on Industry

Progress”

About the CFBAI

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CFBAI Goals

• Respond to IOM/FTC calls for more self regulation

• Be part of the solution

• Focus on what foods are advertised to children

– Use meaningful nutrition standards

• Bring transparency & accountability to company commitments

IOM: Shift the emphasis to foods substantially lower in calories, lower in fats, salt,

and added sugars, and higher in nutrient content

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CFBAI Requirements Have Evolved Since Nov. 2006 Launch

• Increased commitment to 100% (from 50%) healthier food ads or no child-directed ads (effective Jan. 2010) – Dropped “healthy lifestyle messaging” as compliance option

• Harmonized “child-directed” definitions substantially (announced Sept. 2010) – Now all use 35% (or smaller %) viewers

– Those at 50% moved to 35%

• Adopted CFBAI-developed uniform nutrition criteria to replace company-specific criteria (effective Dec. 31, 2013)

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Radio

Covered Venues Have Expanded

Internet

Video Games

Print

Mobile Media

Original

Added (as of 2010)

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CFBAI Participants & Commitments

~ 80% Food Ads on Kid’s TV

No child-directed ads

Use nutrition criteria for 100% of child-directed ads

or

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CFBAI Monitors and Reports on Company Compliance

• CFBAI scrutinizes company-submitted compliance reports

– Self assessment is opportunity to detect and correct problems

• CFBAI monitors independently TV, print, radio, mobile, Internet

– TV & websites primary venues

– Company-owned sites

• Those reported as child-directed

• Others to verify reporting

– Third-party child-directed sites

• Large list of where companies advertise, media lists of top kid sites, etc.

• CFBAI will conduct inquiries into complaints

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What’s Changed: Decline in Child-Directed Food Ads*

62%

38%

1977

24%

76%

2010

33%

67%

2004

Food Ads

Non Food Ads

*Results for 1977 & 2004 are from an analysis of shows with 50%+ kids in the audience. See Table 5.3 in FTC’s Bureau of Economics Staff Report, “Children’s Exposure to TV Advertising in 1977 and 2004” (2007). The FTC estimated there was a 9% decline in children’s exposure to food ads across all programming. 2010 & 2012 results are from two CFBAI analyses of over 30 hours of children’s TV.

23%

77%

2012

Ads for sedentary entertainment more prevalent.

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What’s Changed: Significant Improvements

From Meaningful Nutrition Criteria

• ≥ 100 foods changed or created to meet nutrition standards

– Other foods no longer advertised or discontinued

– Reformulation and new product development ongoing

• Calories

– Virtually every individual food under 200 calories

– No entrees/main dishes > 350 calories; No meals > 600 calories

• Sodium

– Pre-CFBAI some foods with > 900 mg sodium

– Now highest is 750 (most far less: FDA “healthy” levels used by many)

• Sugars

– Variety of meaningful limits, such as 35% sugars by weight (new USDA snack foods standards)

– Reductions in cereals, yogurts; lower-sugar items sourced

• Fats

– ≤ 2 grams or ≤ 10% calories sat fat general standards

– A number of foods reformulated to lower fats to meet limits

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Significant Changes From Use of Meaningful Nutrition Criteria

More nutrient dense than before:

– 89% of foods: contain a “good” source of a “nutrient of concern” and/or contain F/V/D/WG

• 25% increase from 2010 (71%)

– 72% of foods: contained F/V/D/WG

• 50% increase from 2010 (48%)

– 71% of ads: for foods with at least a half-serving of fruit or whole grains

• ~40% increase from 2010 (~51%)

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Recent Improvements: F/V/D/WG Increases

• All “small meals” & “meals” include fruit and/or veg as a side dish or in a beverage

– Apples, applesauce, peaches, berries, banana

• Separate items, toppings, in smoothies

– Corn, tomato sauce

• Small meals providing at least one F/V/D/WG serving

– Most (52%) contain 2 servings

• Meals provide at least 1.5 F/V/D/WG servings

– Over half (58%) provide at least 2 servings

• Many dairy products

– More yogurt/yogurt type drinks

– Low-fat milk, fat-free milk, fortified milk 11

Whole Grains: Use Increasing

• More whole grains usage overall (May 2012 analysis)

• Cereals (May 2013)

− 73% contain ≥ 8 grams whole grains (up from 60% in 2011)

• 2010 DGA: 8 grams significant amount

− 50% list whole grains as first ingredient

− 36% contain ≥ 12 grams whole grains

− 32% are at least a “good” source of fiber

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Recent Changes: Added Sugar Reductions

• 2012: Burger King Corp. & McDonald’s dropped caramel dipping sauces

• 2009-2013: Sugar content of cereals in child-directed ads steadily declined

– Before CFBAI: 14 or 15 grams sugar per serving

– Now: Most ≤ 10 grams sugar per serving

16%

41%

60%

36%

73%

27%

0%

10%

20%

30%

40%

50%

60%

70%

80%

≤ 9 grams ≤ 10 grams 11 or 12 grams

Table 1. Sugar Content of Cereals 2009 to May 2013

2009 May 201313

Sodium Reductions: In Many Product Lines & Products

• Individual foods – Cereals (e.g., Lucky Charms: 170 mg from 190 mg)

– Campbell’s kids soups: advertised soups meet FDA “healthy” 480 mg criterion (from pre-pledge of > 900 mg)

• Main dishes – Campbell’s canned pasta: now all meet FDA’s “healthy” criterion of

600 mg (pre-pledge: > 900 mg)

– ConAgra Foods canned pasta: large reductions, now none exceed 750 mg (> ½ at 600 mg)

• Small meals – ConAgra Foods reduced sodium in KC meals advertised to children

an average of 15% from 2011 to 2012

• Meals – Sodium reductions in Burger King and McDonald’s kids meals

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Fats Content: Overview

• Trans fat: All products labeled 0 grams

• Saturated fat: Most foods contain ≤ 1.5 grams

– Exceptions:

• Peanut butters contain ≤ 3 grams

• Foods made with cheese contain ≤ 3.5 grams

• Products with meat contain ≤ 4 grams

• Meals do not exceed 10% of kcal from sat fat

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Meal “Default” Changes

• Burger King Corp. changed POS practice in 2011 to stop “default”

– Now ask what side & beverage wanted (rather than just giving fries & soda)

• Choices include advertised milk, 100% fruit juice, apple slices (½ cup = one serving)

• McDonald’s adopted “default”

– All Happy Meals come with apple slices (½ serving) and small fries (~ 100 kcal)

• Apples can be substituted for fries (get 2 bags)

• Buyer selects entrée and beverage

– Choices include white or choc milk, or 100% apple juice

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Measuring Progress

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Assessing Progress: CFBAI

• CFBAI compares prior and current nutrition content

• Are advertised foods improving?

– Have calories, fats, sodium, or sugars been reduced?

• Look at gram and percentage changes of key nutrients

– Has fruit, veg, dairy or whole grains content increased?

– Has nutrient content, particularly nutrients of concern content, increased?

• Have foods been dropped or added?

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Assessing Progress: Others (Variety of Nutrition Standards Used)

• Non-U.S. (UK) criteria: even though not aligned with U.S. DGAs

– E.g., no credit for whole grains content

• Nutrition content of child-targeted cereals compared to adult-targeted ones: kids’ taste preferences and changes in children’s cereals ignored

• “Go, Slow, Whoa”: illogical, with categories and results contrary to DGAs

– All low-fat yogurts, no matter how sugary are “Go” foods, while all presweetened cereals, no matter how little sugar or how nutrient dense are “Whoa” foods

• Use of binary (meets/does not meet) metrics: does not identify the steady, incremental change that is our goal

– “35-10-35” metric: no credit for improvements such as 5-20% or greater reductions in sugar if cereal has > 35% sugar by weight

• Use of government standards scorned: meeting FDA’s definition for “healthy” not good enough

• Use of IWG’s criteria: even though only proposed standards, with a proposed 2016 implementation date

– FTC to Congress (Oct. 2011): The anticipated revisions [to IWG’s proposal] go a long way to address industry’s concern and share much in common with the new CFBAI uniform nutrition standards.” (emphasis added)

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Assessing Progress: Others (Ad Standard Analyses Vary)

• Studies of all TV ads kids may see – CFBAI focus on child-directed ads

– Not family/adult-focused ads in prime time dramas/reality shows

• While many kids in audience, the % of kids is small

• Studies of websites kids visit or with child-appealing foods – CFBAI focus on child-directed sites

– Percentage of kid visitors and/or multi-faceted

analysis (intent, content, net impression, etc.)

• Cookies, candy, colas per se ≠ child-directed site

• Games alone ≠ child-directed site

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What the Public

Wants *Image edited by CFBAI 21

Most People Don’t Favor an Ad Ban─ Other Policies Favored

(AP-NORC Survey 2012)

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*Nationwide Findings from the 2013 Kaiser Permanente Childhood Obesity Prevention Survey 23

Healthier Foods are Good for the Bottom Line

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What’s Next?

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CFBAI’s New Category-Specific Uniform Nutrition Criteria

• Historic agreement in 2011 to use new criteria

• CFBAI submitted criteria with comment to IWG

– Explained well within scope of what IWG was seeking as an alternative to its own proposal

• Comment explained IWG nutrition principles unrealistic & unworkable

– Sodium limits dramatic example

• To 210 mg per serving (“healthy” level 480 mg) in 5 years

• Further reduce to 140 mg by RACC by 2021

– Functional roles for nutrients not well understood

– Consumer acceptance issues misjudged

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CFBAI’s Category-Specific Uniform Nutrition Criteria Benefits

• Overall stronger than company-specific criteria

– New criteria fill gaps in current participant standards

– Eliminate foods qualifying solely on “reduced” claim

– Eliminate foods qualifying on 100-calorie packaging

– Include calorie limits for all categories

– Include NTL limits & NCTE requirements for all categories

• Limits on saturated fat, trans fat, sodium, total sugars

• Requirements for food groups and/or nutrients

• Even more transparent/easier to understand

• Rigorous implementation deadline – Dec. 31, 2013

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New Criteria Will Drive Further Improvements

• Many recipes need changes if foods to be advertised post Dec. 31, 2013 – ~ 1/3 of CFBAI-listed products (7/2011) fail new criteria

– Affects products in pipeline: many scraped already

• Provides a strong, but reasonable, roadmap for new product development – Incremental changes necessary for consumer acceptance

• Review planned when 2015 DGA issued – Experience and/or changes in guidance may lead to

strengthening criteria

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Positive Government Response to Self Regulation

FTC & USDA on CFBAI’s Uniform Nutrition Criteria

• FTC: The CFBAI’s criteria represent “substantial progress” & are “considerably stronger than the status quo.”*

• USDA: “The new uniform CFBAI nutrition criteria appear to be a step forward in changing the food advertising landscape, while also taking into consideration the feasibility of manufacturers making meaningful changes . . . .”

*Congressional Subcommittee Hearing on Food Marketing to Children (Oct. 12, 2011)

FTC on Self Regulation Generally (Dec. 2012 FTC Report)

• “The food and beverage industry, and in particular the CFBAI, has made major strides since the early days of self-regulation in 2006. The industry has expanded the scope of children’s marketing to which their efforts apply and has strengthened and standardized the nutritional criteria for foods marketing to children. New uniform criteria . . . will likely lead to further improvements in the nutritional quality of foods marketed to children . . . .”

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Good News: Self-Regulation is Improving Child-Directed Food Advertising

Good News: The Obesity Needle is Moving

• Food advertised are healthier as IOM recommended

• Dynamic program has been expanded/enhanced

• New uniform nutrition criteria = more improvements

– Commitment to review criteria going forward

• FTC (& others) reports children (age 2-11) eating fewer kcal

– 1860 kcal in 1999/2000 compared to 1732 in 2009/2010

• RWJF reports that childhood obesity rates are leveling off and declined in 11 areas

– No clear link tying specific efforts to declining rates

– Many areas have made broad changes (e.g., more access to healthier foods, healthier schools, supporting activity initiatives)

• Food industry & self regulation need to continue efforts & to be a part of the solution

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