European Journal of Clinical Nutrition (2015) 69, 896–901 © 2015 Macmillan Publishers Limited All rights reserved 0954-3007/15 www.nature.com/ejcn
ORIGINAL ARTICLE
The EU pledge for responsible marketing of food and beverages to children: implementation in food companies JD Jensen1 and K Ronit2 BACKGROUND/OBJECTIVES: Increasing political pressure on the food industry’s marketing activities stimulated the formation of the collective EU Pledge for responsible marketing of foods and beverages to children. The objective of the study is to evaluate the commitments made by companies in joining the pledge for the purpose of assessing its effectiveness in regulating signatory companies’ marketing activities. SUBJECTS/METHODS: Data on company commitments in relation to the EU Pledge were collected, analyzed and recalculated in order to enable comparison across companies and with general nutritional recommendations. Data on companies’ product portfolio and market orientation were collected from their most recent available annual reports. Data on the companies’ product profiles were generated via review of the companies’ main websites. Similar data were generated for a reference group of companies outside the EU Pledge. RESULTS: Compared with a reference group of large food and beverage companies, EU Pledge signatory companies have a public image strongly based on products with appeal to children. The EU Pledge sets common standards for regulating signatory companies' marketing behaviour towards children. Further scrutiny of the companies' stated commitments revealed considerable variation in their actual content and in their de facto bindingness on the companies' marketing behaviour—for example, in the definition of target audience for advertising or in nutritional characteristics making products eligible for advertising to children. CONCLUSIONS: In order for voluntary self-regulation schemes such as the EU Pledge to be a credible alternative to public regulation of marketing behaviour, more transparency and stringency are needed. European Journal of Clinical Nutrition (2015) 69, 896–901; doi:10.1038/ejcn.2015.52; published online 1 April 2015
INTRODUCTION Childhood obesity has become a huge challenge for European societies over the last decades, and effective prevention strategies are called for.1,2 Increasing attention has been directed towards marketing and promotion activities of the food industry.3,4 The European food industry has responded to these challenges and especially to the perceived threat of public top downregulation in different ways, including participation in the EU Platform on Diet, Physical Activity and Health established in 2005 as a multistakeholder forum and formation of various self-regulation schemes.5,6 There is a rich literature outlining challenges of industry selfregulation.7–9 Many forms of self-regulation are based on voluntary participation, where companies can join a scheme but are not excluded from the market or otherwise ‘punished’ should they refrain from joining or complying with the code.10,11 Still, companies have incentives to join, because they solidify a scheme and thus avoid public regulation, they become accepted among peer companies and they enjoy reputational benefits of being associated with the scheme. An emerging field of research in food industry self-regulation with regard to obesity prevention12,13 is showing somewhat mixed results regarding the effectiveness of such self-regulation schemes in reducing children’s exposure to marketing of unhealthy foods and beverages.14–17 A number of major international companies have signed the so-called EU Pledge, as a collective self-regulation initiative
establishing a code of conduct for marketing activities directed towards children (Figure 1). The initiative came from companies in the international food industry, with the umbrella organisation Food and Drink Europe playing a leading role (http://www. fooddrinkeurope.eu/priorities/detail/nutrition-and-health/). As participation in the EU Pledge is voluntary, the initiative is not run by Food and Drink Europe as such.18 The pledge has also been officially encouraged and welcomed by the EU (http://www. wfanet.org).5,19 The EU Pledge is unique by being one of the most encompassing of its kind in the world (although many of the signatory companies have also signed up to the International Food and Beverage Alliance, which has the stated goal to help consumers achieve balanced diets and healthy, active lifestyles20). Whereas many business initiatives to combat obesity are paraded by individual companies or managed by industry associations with a capacity to administer such schemes, the EU Pledge is a relatively heterogeneous alliance of companies with diverse product portfolios from different branches of the food and beverage industry. Evaluations of companies' compliance with the commitments have been conducted annually by independent evaluators on the request of the EU Pledge secretariat. These evaluations generally indicate high compliance with the companies' stated commitments. A couple of studies have examined some aspects of the EU Pledge and its performance.17,21 They did not find strong support
1 Department of Food and Resource Economics, University of Copenhagen, Rolighedsvej, Frederiksberg C, Denmark and 2Department of Political Science, University of Copenhagen, Øster Farimagsgade, København K, Denmark. Correspondence: J Jensen, Department of Food and Resource Economics, University of Copenhagen, Rolighedsvej 25, Frederiksberg C DK-1958, Denmark. E-mail: [email protected] Received 21 October 2014; revised 28 January 2015; accepted 21 February 2015; published online 1 April 2015
The EU pledge for responsible food marketing JD Jensen and K Ronit
897 The EU Pledge is a voluntary initiative by leading food and beverage companies to regulate food and beverage advertising to children in the European Union. The EU Pledge was launched in December 2007 as part of signatories’ commitment to the European Union Platform for Action on Diet, Physical Activity and Health, and has been revised on a few occasions, most recently in 2012 and 2014. It consists of two main minimum commitments: •
No advertising for food and beverage products to children under the age of twelve on TV, print and internet, except for products, which fulfil specific nutritional criteria based on accepted scientific evidence and/or applicable national and international dietary guidelines.
•
No communication related to products in primary schools, except where specifically requested by, or agreed with, the school administration for educational purposes.
Individual companies can apply corporate standards that go above and beyond these common rules and the initiative is open to any food and beverage company active in Europe and willing to subscribe to the EU Pledge commitments. All participating companies have made their individual corporate commitments within the framework of the EU Pledge programme. EU Pledge member companies represent over three quarters of food and beverage advertising expenditure in the EU. For a list of signatory companies in the EU Pledge, see table 1.
Figure 1.
The EU pledge. Data source: http://www.eu-pledge.eu/.
for the effectiveness of the pledge but point to various shortcomings in the design and raise some scepticism as to whether it can deliver results that are comparable with public regulation. Still, a number of aspects of the pledge have not been examined, for example, the incentives driving companies' participation or non-participation in the EU Pledge and the companies’ follow-up commitments. Against this backdrop, the objective of the present study is to characterize participating companies and to examine the actual commitments made by these companies, for the purpose of assessing the effectiveness of the EU Pledge in regulating signatory companies’ marketing activities. First, we investigate the selection of companies joining the pledge, and second we analyze the companies' stated commitments within the pledge and the extent to which these commitments de facto restrict the companies' marketing opportunities. MATERIALS AND METHODS Although the food and beverage industry may have a key incentive to engage in self-regulation to avoid public regulation, the incentives to join and remain members of the EU pledge vary between companies. In this study, the decision to join and stay in the pledge is considered as the outcome of a trade-off between direct losses associated with restricting marketing activities on the one hand and indirect gains of improved image and increased probability of avoiding public regulations on the other hand. These gains and losses vary among companies, depending on their product portfolio and their market orientation. Companies with product profiles and market orientations closely associated with products appealing to children and with low nutritional value may see larger potential gains in the participation in voluntary self-regulation schemes, such as the EU Pledge, than companies with other profiles or market orientations. In self-regulation schemes, companies have the opportunity—and an incentive—to influence the design of the regulation in such a way that the reputational and political benefits relative to the sales hampering effect are maximized. Companies may therefore formulate self-regulations that seem stringent and far-reaching in scope, and are easy to communicate, but which at closer inspection appear to be less transparent and less binding for the company than what is perceived at first glance. Data regarding EU Pledge signatory companies for the current study were collected from the EU Pledge website18 and from the respective company websites (http://www.burgerking.com; http://www.coca-cola.com; http://www.ferrero.com; http://www.danone.com; http://www.generalmills.com; http://www.kraftfoodsgroup.com/home/index.aspx; http://www.mars.com; http://www.kelloggs.com; http://www.unilever.com; http://www.maarud.no; http://www.pepsico.com; http://www.mcdonalds.com; http://www.nestle.com; http://www.frieslandcampina.com/english/; http://www.intersnack.com; http:// © 2015 Macmillan Publishers Limited
www.orklacs.fi/en/frontpage.html; http://www.lorenz-snackworld.com/; http:// www.zweifel.ch/de/produkte/chips-snacks/original-chips/; http://www.sancarlo.it/ it/default.asp). Data for a reference group consisting of all Food and Drink Europe company members that had not joined the EU Pledge were collected from the respective websites of these companies (http://www.agrokor.hr/en-GB/ Brands.html; http://www.barilla.de/; http://www.cargill.com/; http://www. heineken.com/AgeGateway.aspx;http://www.heinz.com/our-food/key-brands. aspx; http://www.suedzucker.de/de/Homepage/; http://www.tateandlyle. com/Pages/default.aspx; http://www.ulker.com.tr/en). All website data were collected in August 2013, except data on the role of childappealing products in companies’ public image, which were collected in May 2014. Data about EU Pledge signatory companies' commitments were obtained from the EU Pledge website, and with links to the underlying information (for example, detailed nutritional criteria), when relevant: ●
● ●
Detailed description of the individual companies’ commitments in terms of target audience for television (TV) advertising and nutritional requirements for being eligible for advertisement to children Detailed description of the individual companies' commitments in terms of promotion activities in schools Description of the companies' commitments regarding other promotion activities towards children
On the basis of the most recent financial statement (annual report 2012) of the EU Pledge companies and the reference group, estimates of foods and beverages sales revenues in Europe were obtained for all companies by combining information on their total global sales with information on its distribution on product categories and geographical areas. As the companies in the study are quite heterogeneous in terms of product portfolio, geographical coverage, jurisdiction and legal structure, there was some variation in the accessible information regarding economic variables (Supplementary A1). Content analysis of company websites was conducted in order to obtain data on the role of low-nutritious child-appealing products in the companies' product profiles. Appearance of child-appealing brands (such as, for example, Ferrero’s Kinder brand or Danone’s Danonino brand) or products (for example, within sugared drinks, chocolate, sweets, biscuits/cookies, ice cream, savoury snacks, sweet breakfast cereals, fast food products) on the websites was evaluated on a 4-point scale (0: none, 1: less than one-third of the brands/products, 2: between one-third and two-thirds of the brands/products and 3: more than two-thirds of the brands/products). Furthermore, it was assessed, whether children (not clearly older than 12 years, that is, within or close to the age range targeted by the EU Pledge) or child-appealing characters (for example, spokes-characters or licensed cartoon characters) were used in the presentation of the companies' products. Because of the potential subjectivity of this method, the websites were evaluated by both authors European Journal of Clinical Nutrition (2015) 896 – 901
The EU pledge for responsible food marketing JD Jensen and K Ronit
898 independently, and their evaluations were subsequently consolidated by consensus. Companies' stated commitments in the EU Pledge and the companies' specific definitions were carefully recorded. For example, that a company declares ‘not (to) place any advertising for any of our products on any media that is primarily directed to, and has an audience of 50% or more, children under the age of 12’ (http://www.coca-cola.com). To enable comparison of companies’ stated commitments (which were elaborated in many different formats), these commitments were reinterpreted into one common format across all participating companies. For example, the bindingness of Kellogg’s commitment not to market products with more than 12 g added sugar per serving (http://www.kelloggs.com) was assessed by calculating the maximum energy percentage (E%) from added sugar among all Kellogg’s products complying with this commitment. According to this, a serving of Kellogg’s Frosted Flakes (30 g, as defined by Kellogg’s (http://www.kelloggs.com)) contains 110 calories and 11 g added sugar per serving, corresponding to 41 E% added sugar. For the present analysis, data on three parameters regarding TV advertising to children were procured for all signatory companies: one parameter characterizing companies' precise definition of target audience in terms of share of below 12-year-old children, and two parameters representing the companies' nutritional criteria (maximum E% saturated fat and E% added sugar) for products eligible for marketing.
RESULTS EU signatory companies’ product image Figure 2 compares the distribution of EU Pledge members on different levels of child-appeal image with the corresponding distribution for the reference group. EU Pledge signatory companies have a product profile strongly based on products with appeal to children, whereas only few of the reference group companies are identified with such products. Thus, Figure 2 indicates that companies producing goods with appeal to children are aware of their social responsibility and see participation in the EU Pledge as an image-improving activity, even though participation may limit their marketing activities. EU Pledge member companies’ commitments Almost all EU Pledge member companies have stated companyspecific commitments on these two above-mentioned items (not to advertise for food and beverage products to children under the age of 12 years on TV and so on, and not to undertake communication related to products in primary schools, cf.
percent of companies
70% 60% 50% 40%
Figure 1), but several of the companies have also stated commitments with regard to other marketing tools aiming at children (Table 1). Nine companies stated commitments regarding their use of licensed characters in promotion of products to children, the use of product placement and interactive games were subject to commitments by four and two companies, respectively, and commitments regarding portrayal of children in marketing were stated by one company. Four of the signatory companies committed themselves to efforts in the fields of public education and health promotion. The EU Pledge sets common standards for regulating signatory companies' marketing behaviour towards children, but further scrutiny of the companies' stated commitments reveals considerable variation in the actual content of these commitments. Definition of child audience in companies’ commitments It is generally accepted6 that the definition of child audience in a specific media, TV show and so on, hinges on these children's share of the target audience for this TV show and so on, but there is some variation in companies' operationalization of this definition. Some companies consider a TV show to be targeted towards children under 12 years, if this group of children comprises at least 30% of the target audience, whereas other companies set this threshold at 50%—making more TV shows eligible for advertisement. Figure 3 shows this variation and indicates companies with different thresholds’ share of total EU pledger companies’ sales in Europe. Companies considering 30% or less children in the target audience as the threshold represent about 15% of the EU-pledging companies’ total sales revenue, whereas companies considering 35% children as the threshold represent about 50% of the pledgers’ aggregate sales. It should be noted that during the revision of the EU Pledge in 2012, 35% has become the general standard in this respect. According to Figure 3, this revision may have some consequences for companies representing about 30% of EU Pledge member companies' total sales revenue in Europe. Nutritional criteria in companies’ commitments There is considerable variation among companies, as regards specification of nutritional criteria making their products eligible for marketing to children. Some companies base the assessment of nutritional value (for example, content of saturated fat or added sugar) by benchmarking the products against recommended average daily intake (that is, in terms of saturated fat or sugar's share of total energy intake, in E%; for example, McDonald's (http://www.mcdonalds.com)), others base their assessment on average actual intake per day (Danone (http://www.danone.com), Campina (http://www.frieslandcampina.com/english/)), and yet others evaluate the products against figures that could be
30% 20%
Table 1. Overview of EU Pledge member companies' stated commitments on marketing to children
10% 0% None
Low
Medium
High
Commitments on…
No. of EU pledge companies
Appearance of child-appealing products on company website EU pledge members
Reference
Figure 2. Distribution of EU Pledge members and reference group according to product image. Note: Hatched part of bars represent share of companies associating children with consumption of their products on their website. ‘Appearance of child-appealing products on company website’: None (no appearance), Low (o 33% of brands/products with appeal to children), Medium (33–67% of brands/products), High (467% of brands/products). Reference group: Food and Drink Europe members not participating in the EU Pledge (see Supplement A.1). Data source: Own data compiled from content analysis of company websites. European Journal of Clinical Nutrition (2015) 896 – 901
TV-, print-, Internet advertisement to children Marketing in schools Licensed characters Portrayal of children in marketing Product placement Interactive games Public education, health promotion Other initiatives Total number of companies in EU pledge
19 18 9 1 4 2 4 2 19
Data source: EU Pledge website (http://www.eu-pledge.eu/).
© 2015 Macmillan Publishers Limited
The EU pledge for responsible food marketing JD Jensen and K Ronit
899 interpreted as average nutritional composition of the market portfolio of products within the same product category (for example, the group of breakfast cereals; Kraft (http://www. kraftfoodsgroup.com/home/index.aspx), Kellogg's (http://www. kelloggs.com), Unilever (http://www.unilever.com), Nestle (http:// www.nestle.com)). This variation in the formulation of nutritional criteria reduces the transparency and consistency of these criteria. To compare criteria across companies, the individual companies’ criteria were converted to criteria regarding E% added sugar or saturated fat in the products. Figure 4 illustrates the betweencompany variation in these criteria, with maximum acceptable added sugar content and maximum acceptable saturated fat contents as examples. Some of the companies state that they will totally abstain from advertising their products to children, cf. discussion above (CocaCola (http://www.coca-cola.com), Ferrero (http://www.ferrero. com), Mars (http://www.mars.com), PepsiCo (http://www.pepsico. com)). They represent about 30% of the total sales in Europe from the EU Pledge member companies. Other companies (representing about 25% of the pledgers' total sales in Europe) have nutritional standards, which imply an upper limit of 10 E% sugar, corresponding to the recommended maximum daily intake (although there are currently considerations to lower this recommendation22). Companies representing about 45% of the EU pledgers' total sales in Europe have nutritional standards that allow more than 10 E% sugar in products advertised to children, most pronounced among producers of breakfast cereals, where the energy share of sugar may exceed 40 E% and still be eligible for advertisement to children younger than 12 years.
Share of EU pledgers' European sales 2% 15% 28%
ORIGINAL ARTICLE
The EU pledge for responsible marketing of food and beverages to children: implementation in food companies JD Jensen1 and K Ronit2 BACKGROUND/OBJECTIVES: Increasing political pressure on the food industry’s marketing activities stimulated the formation of the collective EU Pledge for responsible marketing of foods and beverages to children. The objective of the study is to evaluate the commitments made by companies in joining the pledge for the purpose of assessing its effectiveness in regulating signatory companies’ marketing activities. SUBJECTS/METHODS: Data on company commitments in relation to the EU Pledge were collected, analyzed and recalculated in order to enable comparison across companies and with general nutritional recommendations. Data on companies’ product portfolio and market orientation were collected from their most recent available annual reports. Data on the companies’ product profiles were generated via review of the companies’ main websites. Similar data were generated for a reference group of companies outside the EU Pledge. RESULTS: Compared with a reference group of large food and beverage companies, EU Pledge signatory companies have a public image strongly based on products with appeal to children. The EU Pledge sets common standards for regulating signatory companies' marketing behaviour towards children. Further scrutiny of the companies' stated commitments revealed considerable variation in their actual content and in their de facto bindingness on the companies' marketing behaviour—for example, in the definition of target audience for advertising or in nutritional characteristics making products eligible for advertising to children. CONCLUSIONS: In order for voluntary self-regulation schemes such as the EU Pledge to be a credible alternative to public regulation of marketing behaviour, more transparency and stringency are needed. European Journal of Clinical Nutrition (2015) 69, 896–901; doi:10.1038/ejcn.2015.52; published online 1 April 2015
INTRODUCTION Childhood obesity has become a huge challenge for European societies over the last decades, and effective prevention strategies are called for.1,2 Increasing attention has been directed towards marketing and promotion activities of the food industry.3,4 The European food industry has responded to these challenges and especially to the perceived threat of public top downregulation in different ways, including participation in the EU Platform on Diet, Physical Activity and Health established in 2005 as a multistakeholder forum and formation of various self-regulation schemes.5,6 There is a rich literature outlining challenges of industry selfregulation.7–9 Many forms of self-regulation are based on voluntary participation, where companies can join a scheme but are not excluded from the market or otherwise ‘punished’ should they refrain from joining or complying with the code.10,11 Still, companies have incentives to join, because they solidify a scheme and thus avoid public regulation, they become accepted among peer companies and they enjoy reputational benefits of being associated with the scheme. An emerging field of research in food industry self-regulation with regard to obesity prevention12,13 is showing somewhat mixed results regarding the effectiveness of such self-regulation schemes in reducing children’s exposure to marketing of unhealthy foods and beverages.14–17 A number of major international companies have signed the so-called EU Pledge, as a collective self-regulation initiative
establishing a code of conduct for marketing activities directed towards children (Figure 1). The initiative came from companies in the international food industry, with the umbrella organisation Food and Drink Europe playing a leading role (http://www. fooddrinkeurope.eu/priorities/detail/nutrition-and-health/). As participation in the EU Pledge is voluntary, the initiative is not run by Food and Drink Europe as such.18 The pledge has also been officially encouraged and welcomed by the EU (http://www. wfanet.org).5,19 The EU Pledge is unique by being one of the most encompassing of its kind in the world (although many of the signatory companies have also signed up to the International Food and Beverage Alliance, which has the stated goal to help consumers achieve balanced diets and healthy, active lifestyles20). Whereas many business initiatives to combat obesity are paraded by individual companies or managed by industry associations with a capacity to administer such schemes, the EU Pledge is a relatively heterogeneous alliance of companies with diverse product portfolios from different branches of the food and beverage industry. Evaluations of companies' compliance with the commitments have been conducted annually by independent evaluators on the request of the EU Pledge secretariat. These evaluations generally indicate high compliance with the companies' stated commitments. A couple of studies have examined some aspects of the EU Pledge and its performance.17,21 They did not find strong support
1 Department of Food and Resource Economics, University of Copenhagen, Rolighedsvej, Frederiksberg C, Denmark and 2Department of Political Science, University of Copenhagen, Øster Farimagsgade, København K, Denmark. Correspondence: J Jensen, Department of Food and Resource Economics, University of Copenhagen, Rolighedsvej 25, Frederiksberg C DK-1958, Denmark. E-mail: [email protected] Received 21 October 2014; revised 28 January 2015; accepted 21 February 2015; published online 1 April 2015
The EU pledge for responsible food marketing JD Jensen and K Ronit
897 The EU Pledge is a voluntary initiative by leading food and beverage companies to regulate food and beverage advertising to children in the European Union. The EU Pledge was launched in December 2007 as part of signatories’ commitment to the European Union Platform for Action on Diet, Physical Activity and Health, and has been revised on a few occasions, most recently in 2012 and 2014. It consists of two main minimum commitments: •
No advertising for food and beverage products to children under the age of twelve on TV, print and internet, except for products, which fulfil specific nutritional criteria based on accepted scientific evidence and/or applicable national and international dietary guidelines.
•
No communication related to products in primary schools, except where specifically requested by, or agreed with, the school administration for educational purposes.
Individual companies can apply corporate standards that go above and beyond these common rules and the initiative is open to any food and beverage company active in Europe and willing to subscribe to the EU Pledge commitments. All participating companies have made their individual corporate commitments within the framework of the EU Pledge programme. EU Pledge member companies represent over three quarters of food and beverage advertising expenditure in the EU. For a list of signatory companies in the EU Pledge, see table 1.
Figure 1.
The EU pledge. Data source: http://www.eu-pledge.eu/.
for the effectiveness of the pledge but point to various shortcomings in the design and raise some scepticism as to whether it can deliver results that are comparable with public regulation. Still, a number of aspects of the pledge have not been examined, for example, the incentives driving companies' participation or non-participation in the EU Pledge and the companies’ follow-up commitments. Against this backdrop, the objective of the present study is to characterize participating companies and to examine the actual commitments made by these companies, for the purpose of assessing the effectiveness of the EU Pledge in regulating signatory companies’ marketing activities. First, we investigate the selection of companies joining the pledge, and second we analyze the companies' stated commitments within the pledge and the extent to which these commitments de facto restrict the companies' marketing opportunities. MATERIALS AND METHODS Although the food and beverage industry may have a key incentive to engage in self-regulation to avoid public regulation, the incentives to join and remain members of the EU pledge vary between companies. In this study, the decision to join and stay in the pledge is considered as the outcome of a trade-off between direct losses associated with restricting marketing activities on the one hand and indirect gains of improved image and increased probability of avoiding public regulations on the other hand. These gains and losses vary among companies, depending on their product portfolio and their market orientation. Companies with product profiles and market orientations closely associated with products appealing to children and with low nutritional value may see larger potential gains in the participation in voluntary self-regulation schemes, such as the EU Pledge, than companies with other profiles or market orientations. In self-regulation schemes, companies have the opportunity—and an incentive—to influence the design of the regulation in such a way that the reputational and political benefits relative to the sales hampering effect are maximized. Companies may therefore formulate self-regulations that seem stringent and far-reaching in scope, and are easy to communicate, but which at closer inspection appear to be less transparent and less binding for the company than what is perceived at first glance. Data regarding EU Pledge signatory companies for the current study were collected from the EU Pledge website18 and from the respective company websites (http://www.burgerking.com; http://www.coca-cola.com; http://www.ferrero.com; http://www.danone.com; http://www.generalmills.com; http://www.kraftfoodsgroup.com/home/index.aspx; http://www.mars.com; http://www.kelloggs.com; http://www.unilever.com; http://www.maarud.no; http://www.pepsico.com; http://www.mcdonalds.com; http://www.nestle.com; http://www.frieslandcampina.com/english/; http://www.intersnack.com; http:// © 2015 Macmillan Publishers Limited
www.orklacs.fi/en/frontpage.html; http://www.lorenz-snackworld.com/; http:// www.zweifel.ch/de/produkte/chips-snacks/original-chips/; http://www.sancarlo.it/ it/default.asp). Data for a reference group consisting of all Food and Drink Europe company members that had not joined the EU Pledge were collected from the respective websites of these companies (http://www.agrokor.hr/en-GB/ Brands.html; http://www.barilla.de/; http://www.cargill.com/; http://www. heineken.com/AgeGateway.aspx;http://www.heinz.com/our-food/key-brands. aspx; http://www.suedzucker.de/de/Homepage/; http://www.tateandlyle. com/Pages/default.aspx; http://www.ulker.com.tr/en). All website data were collected in August 2013, except data on the role of childappealing products in companies’ public image, which were collected in May 2014. Data about EU Pledge signatory companies' commitments were obtained from the EU Pledge website, and with links to the underlying information (for example, detailed nutritional criteria), when relevant: ●
● ●
Detailed description of the individual companies’ commitments in terms of target audience for television (TV) advertising and nutritional requirements for being eligible for advertisement to children Detailed description of the individual companies' commitments in terms of promotion activities in schools Description of the companies' commitments regarding other promotion activities towards children
On the basis of the most recent financial statement (annual report 2012) of the EU Pledge companies and the reference group, estimates of foods and beverages sales revenues in Europe were obtained for all companies by combining information on their total global sales with information on its distribution on product categories and geographical areas. As the companies in the study are quite heterogeneous in terms of product portfolio, geographical coverage, jurisdiction and legal structure, there was some variation in the accessible information regarding economic variables (Supplementary A1). Content analysis of company websites was conducted in order to obtain data on the role of low-nutritious child-appealing products in the companies' product profiles. Appearance of child-appealing brands (such as, for example, Ferrero’s Kinder brand or Danone’s Danonino brand) or products (for example, within sugared drinks, chocolate, sweets, biscuits/cookies, ice cream, savoury snacks, sweet breakfast cereals, fast food products) on the websites was evaluated on a 4-point scale (0: none, 1: less than one-third of the brands/products, 2: between one-third and two-thirds of the brands/products and 3: more than two-thirds of the brands/products). Furthermore, it was assessed, whether children (not clearly older than 12 years, that is, within or close to the age range targeted by the EU Pledge) or child-appealing characters (for example, spokes-characters or licensed cartoon characters) were used in the presentation of the companies' products. Because of the potential subjectivity of this method, the websites were evaluated by both authors European Journal of Clinical Nutrition (2015) 896 – 901
The EU pledge for responsible food marketing JD Jensen and K Ronit
898 independently, and their evaluations were subsequently consolidated by consensus. Companies' stated commitments in the EU Pledge and the companies' specific definitions were carefully recorded. For example, that a company declares ‘not (to) place any advertising for any of our products on any media that is primarily directed to, and has an audience of 50% or more, children under the age of 12’ (http://www.coca-cola.com). To enable comparison of companies’ stated commitments (which were elaborated in many different formats), these commitments were reinterpreted into one common format across all participating companies. For example, the bindingness of Kellogg’s commitment not to market products with more than 12 g added sugar per serving (http://www.kelloggs.com) was assessed by calculating the maximum energy percentage (E%) from added sugar among all Kellogg’s products complying with this commitment. According to this, a serving of Kellogg’s Frosted Flakes (30 g, as defined by Kellogg’s (http://www.kelloggs.com)) contains 110 calories and 11 g added sugar per serving, corresponding to 41 E% added sugar. For the present analysis, data on three parameters regarding TV advertising to children were procured for all signatory companies: one parameter characterizing companies' precise definition of target audience in terms of share of below 12-year-old children, and two parameters representing the companies' nutritional criteria (maximum E% saturated fat and E% added sugar) for products eligible for marketing.
RESULTS EU signatory companies’ product image Figure 2 compares the distribution of EU Pledge members on different levels of child-appeal image with the corresponding distribution for the reference group. EU Pledge signatory companies have a product profile strongly based on products with appeal to children, whereas only few of the reference group companies are identified with such products. Thus, Figure 2 indicates that companies producing goods with appeal to children are aware of their social responsibility and see participation in the EU Pledge as an image-improving activity, even though participation may limit their marketing activities. EU Pledge member companies’ commitments Almost all EU Pledge member companies have stated companyspecific commitments on these two above-mentioned items (not to advertise for food and beverage products to children under the age of 12 years on TV and so on, and not to undertake communication related to products in primary schools, cf.
percent of companies
70% 60% 50% 40%
Figure 1), but several of the companies have also stated commitments with regard to other marketing tools aiming at children (Table 1). Nine companies stated commitments regarding their use of licensed characters in promotion of products to children, the use of product placement and interactive games were subject to commitments by four and two companies, respectively, and commitments regarding portrayal of children in marketing were stated by one company. Four of the signatory companies committed themselves to efforts in the fields of public education and health promotion. The EU Pledge sets common standards for regulating signatory companies' marketing behaviour towards children, but further scrutiny of the companies' stated commitments reveals considerable variation in the actual content of these commitments. Definition of child audience in companies’ commitments It is generally accepted6 that the definition of child audience in a specific media, TV show and so on, hinges on these children's share of the target audience for this TV show and so on, but there is some variation in companies' operationalization of this definition. Some companies consider a TV show to be targeted towards children under 12 years, if this group of children comprises at least 30% of the target audience, whereas other companies set this threshold at 50%—making more TV shows eligible for advertisement. Figure 3 shows this variation and indicates companies with different thresholds’ share of total EU pledger companies’ sales in Europe. Companies considering 30% or less children in the target audience as the threshold represent about 15% of the EU-pledging companies’ total sales revenue, whereas companies considering 35% children as the threshold represent about 50% of the pledgers’ aggregate sales. It should be noted that during the revision of the EU Pledge in 2012, 35% has become the general standard in this respect. According to Figure 3, this revision may have some consequences for companies representing about 30% of EU Pledge member companies' total sales revenue in Europe. Nutritional criteria in companies’ commitments There is considerable variation among companies, as regards specification of nutritional criteria making their products eligible for marketing to children. Some companies base the assessment of nutritional value (for example, content of saturated fat or added sugar) by benchmarking the products against recommended average daily intake (that is, in terms of saturated fat or sugar's share of total energy intake, in E%; for example, McDonald's (http://www.mcdonalds.com)), others base their assessment on average actual intake per day (Danone (http://www.danone.com), Campina (http://www.frieslandcampina.com/english/)), and yet others evaluate the products against figures that could be
30% 20%
Table 1. Overview of EU Pledge member companies' stated commitments on marketing to children
10% 0% None
Low
Medium
High
Commitments on…
No. of EU pledge companies
Appearance of child-appealing products on company website EU pledge members
Reference
Figure 2. Distribution of EU Pledge members and reference group according to product image. Note: Hatched part of bars represent share of companies associating children with consumption of their products on their website. ‘Appearance of child-appealing products on company website’: None (no appearance), Low (o 33% of brands/products with appeal to children), Medium (33–67% of brands/products), High (467% of brands/products). Reference group: Food and Drink Europe members not participating in the EU Pledge (see Supplement A.1). Data source: Own data compiled from content analysis of company websites. European Journal of Clinical Nutrition (2015) 896 – 901
TV-, print-, Internet advertisement to children Marketing in schools Licensed characters Portrayal of children in marketing Product placement Interactive games Public education, health promotion Other initiatives Total number of companies in EU pledge
19 18 9 1 4 2 4 2 19
Data source: EU Pledge website (http://www.eu-pledge.eu/).
© 2015 Macmillan Publishers Limited
The EU pledge for responsible food marketing JD Jensen and K Ronit
899 interpreted as average nutritional composition of the market portfolio of products within the same product category (for example, the group of breakfast cereals; Kraft (http://www. kraftfoodsgroup.com/home/index.aspx), Kellogg's (http://www. kelloggs.com), Unilever (http://www.unilever.com), Nestle (http:// www.nestle.com)). This variation in the formulation of nutritional criteria reduces the transparency and consistency of these criteria. To compare criteria across companies, the individual companies’ criteria were converted to criteria regarding E% added sugar or saturated fat in the products. Figure 4 illustrates the betweencompany variation in these criteria, with maximum acceptable added sugar content and maximum acceptable saturated fat contents as examples. Some of the companies state that they will totally abstain from advertising their products to children, cf. discussion above (CocaCola (http://www.coca-cola.com), Ferrero (http://www.ferrero. com), Mars (http://www.mars.com), PepsiCo (http://www.pepsico. com)). They represent about 30% of the total sales in Europe from the EU Pledge member companies. Other companies (representing about 25% of the pledgers' total sales in Europe) have nutritional standards, which imply an upper limit of 10 E% sugar, corresponding to the recommended maximum daily intake (although there are currently considerations to lower this recommendation22). Companies representing about 45% of the EU pledgers' total sales in Europe have nutritional standards that allow more than 10 E% sugar in products advertised to children, most pronounced among producers of breakfast cereals, where the energy share of sugar may exceed 40 E% and still be eligible for advertisement to children younger than 12 years.
Share of EU pledgers' European sales 2% 15% 28%
