One of the sectors garnering the most media attention at the moment is junk food advertising, particularly in relation to children. As the Committee of Advertising Practice considers whether to strengthen the rules around non-broadcast food advertising, it’s worth revisiting the more stringent rules that broadcast ads are already subject to.
What is junk food?
There’s no such a thing as junk food under the BCAP code. Food is split into two categories, High in Fat, Salt or Sugar (HFSS) and Not High in Fat, Salt or Sugar (Non-HFSS). The guidelines for how to work out which category a particular product fits into can be found here. It’s the HFSS category that have the most strict rules.
Can HFSS products advertise at any time?
The BCAP code is very specific on this. Under rule 32.5.1 HFSS products may not be advertised in or adjacent to programmes commissioned for, directed at, or likely to appeal particularly to under 16s. The broadcasters monitor the audience breakdown of every programme they broadcast, and will know which programmes fall under that banner. So while there isn’t a particular time that HFSS ads can’t be shown before, there are very clear rules in place to keep them away from children’s programmes.
Health claims – can HFSS products make them?
The key here is who the ad is targeting. If an ad is targeted at pre/primary school children then no nutrition of health claims may be made. How an ad is perceived to be targeted can depend on many factors, from visual style to the language used. If a voiceover specifically addresses adults or parents then a health claim is more likely to be acceptable in ambiguous cases. Health claims do of course come with a whole host of requirements and must be on the list approved by the EU.
Can celebrities and cartoon characters feature in HFSS ads?
A distinction is made here between licensed characters (for example, Spongebob) and a brand’s own characters (for example, Coco the Monkey). Rule 13.10 states that licensed characters and celebrities popular with children may not feature in HFSS ads directly targeted at pre/primary school children. A brand’s own characters may be used by advertisers as they see fit.
Promotional offers in HFSS ads
The same distinction is made here as in the previous points. Promotional offers are not allowed in ads directly targeted at pre/primary school children. In addition, any promotion must not encourage excessive consumption or purchase of a product solely to take advantage of the offer.
For the full rules that apply to food ads, take a look at section 13 of the BCAP code.