Restricting Marketing of Unhealthy Food and Beverages to Children in Canada


This report presents a summary of what we heard from the consultation on restricting marketing of unhealthy food and beverages to children. Ipsos analysed and reported on feedback submitted by participants via an online document between June 10, 2017 and August 14, 2017.

Defining “Unhealthy Foods and Beverages”

Most contributors agreed with the focus of the restrictions on nutrients of concern (i.e., sodium (salt), sugars, and saturated fats). Some indicated that the focus could be expanded to include other factors such as the level of processing, portion sizes, calories, or other negatively impactful nutrients or food additives such as caffeine and trans fat. Some were opposed to focusing on the nutrients identified in the consultation document, saying there are foods high in sodium, sugar, and saturated fats that contain positive nutrients (e.g., full fat dairy products), while others low in these nutrients may provide little nutritional value.

A few contributors commented on the use of “unhealthy” within the proposal and suggested that the terminology be reframed from “unhealthy/healthy” to language such as “food allowed to be marketed/food not allowed to be marketed”. This would support the notion that although these foods cannot be marketed to children, they are still available for sale and can be consumed.

Most contributors agreed with the stricter threshold for nutrients of concern proposed in Option 1. Of those supporting Option 1, some felt this stricter threshold would further protect children and support healthier food choices.

Others preferred the less strict Option 2. For some, Option 2 was more appropriate as it allows some whole foods (e.g., calorie-reduced cheese) to be permitted, even though they are naturally higher in the target nutrients.

Some, however, felt that using the daily value percentage as a measurement for this threshold might not be the best approach because it does not account for other nutrients in the food or reflect overall dietary patterns.

The proposed restriction to the marketing of non-sugar sweeteners to children was very positively received, overall. Most agreed with the proposal, especially when it came to artificial sweeteners like aspartame and sucralose. Others were concerned that it did not consider perceived potential benefits of natural non-sugar sweeteners (e.g., stevia) which should perhaps be permitted. Other comments included the potential positive benefits of non-sugar sweeteners as alternatives to sugar, for example, related to dental caries or calorie intake. There was also some concern expressed regarding the evidence base for supporting the restriction of non-sugar sweeteners to children. While some felt there was no evidence these sweeteners do harm and therefore should be allowed, others felt that the lack of evidence of long-term benefit to health suggests they should be restricted.

Determining “Child-Directed” Advertising

The proposed definitions of ‘Child-Directed’ for TV and Internet advertising were appealing to many contributors as a simple and fair approach. Of those who did not support the proposed definitions, many consumers and health professionals felt they were not broad enough and suggested that the definitions be expanded to include longer periods during the day or to expand to cover channels or techniques beyond those included in the presented definition.

Industry stakeholders felt that the proposed definitions were too broad due to a risk that advertising to adults would be inadvertently restricted. In addition to concerns about the economic impact of an overbroad definition, a few identified possible infringement to freedom of expression under the Charter of Rights and Freedoms. Some also expressed concerns regarding implementation and enforcement due to the borderless nature of the digital environment and the ambiguity in defining online marketing.

Full report here

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