1. Junk food adverts significantly influence children’s food choices

There is wealth of strong, peer-reviewed evidence proving that the food adverts children see, influence the foods they choose and how much of it they eat. Junk food marketing in particular is linked with strong preference for junk food[1], more snacking[2] and greater intake of junk food and lower intake of healthy food overall.[3]

Recent studies by Cancer Research UK found that junk food advertising on TV is a clear, consistent and cumulative risk factor for high junk food consumption and increased weight amongst young people. Being bombarded by TV ads for unhealthy, high calorie food could lead teens to eat more than 500 extra snacks like crisps, biscuits and fizzy drinks throughout the course of a single year compared to those who watch less TV. [4] The likelihood of a young person being obese more than doubles when they can recall seeing unhealthy food and drink adverts on television every day.3

The advertising industry frequently quotes a figure attributing just 2% of children’s food choices to advertising. This figure is based on a small study that is over 15 years old. The academic evidence has moved on significantly since then.

  1. UK marketing regulations are NOT among the strongest regulations in the world

There are other countries taking much stronger action than the UK. One example is Chile. Like the UK they restrict junk food adverts from TV programmes and websites aimed at children. Recognising the many loopholes in this approach, this year they will also ban these adverts from TV, radio and cinemas between 6am – 10pm. Chile have also banned use of cartoon characters from sugary cereal boxes – an area we have no regulation on in this country despite their obvious appeal to children.

Meanwhile the Canadian Government has recently consulted on new rules which aim to totally ban junk food advertising on all TV channels watched by children during peak viewing hours and on websites and social media channels used by children, even if they are popular with adults too.

In Norway, there is a ban on all direct advertising to children under 18 in connection with children’s programmes on broadcast media. Brazil prevents “abusive publicity” which includes any form of market communication (TV, radio, internet, apps) intended to persuade children (up to 11 years) or adolescents (12-18 years) to consume a product or service.

The current rules are full of loopholes and do not apply across all forms of media

The rules cover TV, online, outdoor adverts, radio and cinema. But the restrictions only apply when a TV programme, film or website is deemed ‘of particular appeal’ to children.

This means media which is universally popular with both adults and children does not meet the threshold. Imagine a YouTube video which may be watched by 20 million viewers. As long as 15 million of them are adults, five million children also watching could be seeing adverts for junk food. Or what about a billboard in a busy London train station? Considering up to 4.8 million passenger journeys are made per day, the rules would mean up to 1.2 million journeys could be made by children everyday exposing them to junk food advertising because the restrictions will not be applied. This high possible exposure and its impact on young people is the basis of the Mayor of London’s proposal to ban junk food adverts across Transport for London estates.

The current rules also exclude free giveaways and event or sport sponsorship. Crucially, they do not cover packaging, meaning child-friendly characters and figures can be used on packets of sweets, crisps and sugary cereals.

  1. The current rules mean children are continually exposed to junk food adverts during their favourite TV programmes

The current rules apply to TV programmes made specifically for children which tend to be watched by younger children. In fact they only apply to 26% of children’s viewing time.[5] Children’s viewing time peaks between 6-9pm during a period known as ‘family viewing time.’ Worryingly, young people reported seeing the most junk food adverts on genres made up by ‘family viewing shows’.3 The programmes most popular with children aged 4-15 are the entertainment programmes and soaps. In 2017 the programme watched by the highest number of children was Britain’s Got Talent, shown at 8pm on a Saturday.5 In 2017 the Obesity Health Alliance analysed the number of HFSS adverts seen by children when watching their favourite programmes shown between 6-9pm. They found that the majority of food and drinks adverts shown during these programmes are for HFSS products and children can see up to nine HFSS adverts during one 30 minute TV programme.[6]

  1. Levels of child obesity have not decreased since the current advertising restrictions were bought because they are ineffective

The advertising restrictions don’t go far enough and have not been updated with children’s evolving viewing habits. Children may not be seeing HFSS adverts during children’s programming, but HFSS adverts are still being shown during the programmes they watch the most.

Evening and family programmes, shown between 7-9pm, are now most frequently watched by children and are not covered by existing legislation. An independent review of the 2007 regulations found that children were still exposed to the same amount of adverts for unhealthy foods as they had been before the restrictions.[7] The importance and effectiveness of food adverts during peak family viewing time has been highlighted by takeaway pizza brand Domino’s who said the start of the X Factor final on 2 December was the “catalyst for our biggest day of sales for the year” – with sales up 25% over the average Saturday across the year.[8]

Furthermore, studies show that even a one-off exposure to food advertising will increase children’s food intake by around 30 to 50 calories.[9] We know that in the region of 48 to 71 calories extra per day is all that is required over time to generate weight gain in children.[10][11] The goal of restrictions should be to protect children from any exposure to HFSS adverts as part of a wider package of messages to reduce childhood obesity.

  1. There is no evidence that a 9pm watershed would impact broadcasters’ ability to produce high quality programming

In 2010 Ofcom asked broadcasters to provide advertising revenue data to assess any negative impact of the current restrictions. Broadcasters were not able to provide this at the time and have not provided any new evidence on the impact of a 9pm watershed on revenues and programme development for public scrutiny.

Broadcasters are not reliant on HFSS food and drink advertising to fill peak time slots. Analysis of programmes popular with both children and adults shown before 9pm saw significant variation in level of HFSS advertising – for example, in The Voice 75% of food and drink adverts were for HFSS products, but in Ninja Warrior it was just 8%.6 While this low amount of HFSS adverts is certainly not the norm during programmes broadcast in family viewing time, this exception demonstrates that these prime-time shows are not dependent on advertising for unhealthy food and drink.

Other options for food advertisers include: shifting advertising to promote non-HFSS products before 9pm; reformulate their products so that they would be exempt from restrictions; shift their HFSS advertising to post-9pm to reach adults. Other non-HFSS brands could come in and take prime advertising space.


[1] Boyland EJ, Harrold JA, Kirkham TC, Corker C, Cuddy J, Evans D, Dovey TM, Lawton CL, Blundell JE, Halford JCG (2011). Food commercials increase preference for energy-dense foods, particularly in children who watch more television. Pediatrics, 128(1): e93-e100.

[2] Boyland EJ, Nolan S, Kelly B, Tudur-Smith C, Jones A, Halford JCG, Robinson E (2016). Advertising as a cue to consume: a systematic review and meta-analysis of the effects of acute exposure to unhealthy food or non-alcoholic beverage advertising on intake in children and adults. American Journal of Clinical Nutrition, 103: 519-533.

[3] Thomas C, Hooper L, Petty R, Thomas F, Rosenberg G, Vohra J (2018). 10 years on: New evidence on TV marketing and junk food consumption amongst 11-19 year olds 10 years after broadcast regulations. Cancer Research UK, available from: http://www.cancerresearchuk.org/sites/default/files/10_years_on_full_report.pdf

[4] A Prime Time for Action: New evidence on the link between television and on-demand marketing and obesity.” Fiona Thomas, Lucie Hooper, Robert Petty, Christopher Thomas, Gillian Rosenberg and Jyotsna Vohra, 2018

[5] Ofcom (2017) Children and parents: media use and attitudes report

[6] Obesity Health Alliance (2017), A ‘Watershed’ Moment: Why it’s Prime Time to protect Children from Junk Food Adverts

[7] Effect of Restrictions on Television Food Advertising to Children on exposure to Advertisements for ‘Less Healthy’ Foods: Repeat Cross-sectional Study, Jean Adams, Rachel Tyrrell, Ashley J Adamson, Martin White. PLoS ONE

[8] https://news.sky.com/story/dominos-pizza-raises-profit-guidance-as-sales-grow-11228616

[9] Sadeghirad B, Duhaney T, Motaghipisheh S, Campbell NRC, Johnston BC (2016). Influence of unhealthy food and beverage marketing on children’s dietary intake and preference: a systematic review and meta-analysis of randomized trials. Obesity Reviews, 17: 945-959.

[10]  van den Berg SW, Boer JM, Scholtens S, de Jongste JC, Brunekreef B, Smit HA, Wijga AH. Quantification of the energy gap in young overweight children. The PIAMA birth cohort study. BMC Public Health 2011, 11(1).

[11] Plachta-Danielzik S, Landsberg B, Bosy-Westphal A, Johannsen M, Lange D, Muller M. Energy gain and energy gap in normal-weight children: longitudinal data of the KOPS. Obesity (Silver Spring) 2008, 16(4).