By Katharine Jenner, Registered Nutritionist and Campaign Director at Action on Sugar

When it comes to selling food and drink products, advertisers have a few tools at their disposal, such as image, price, packaging and distribution.  But one important element that tends to be overlooked, is ad placement.

I used to be a media planner, never heard of it? This is a strategic communications role whereby you have access to untold riches of commercially sensitive data about consumer behaviour (that my now nutrition research colleagues would only dream of). The data is used to brief media buyers on where to place adverts to reach the most potential customers.

Advertising works

You will have heard that ‘advertising works’, but you might not have heard that media planning works. Media planners know the exact combination of media (where you advertise and in what format) and the frequency of ads to reach their desired market, with minimal wasted ‘impacts’, to prompt a purchase.

Current loopholes

Under current Government rules unhealthy food and drink, which is high in fat, salt or sugar (HFSS) is not allowed to be advertised on children’s TV or any other media channel where children are disproportionately represented compared to adults. Broadcasters say these rules are ‘one of the strictest in the world’[1].  However, because of loopholes, media planners can (if they wish) simply use other tactics to get around the rules such as peak-time family TV, TV on demand, radio, online, social media, apps, in-game, cinema and digital outdoor advertising on billboards.  Marketing budgets can also be ‘displaced’ on non-direct advertising, such as on in store promotions, sponsorship, PR and even on cartoons on child friendly packaging[2].

How do close the loopholes?

Health campaigners, including Action on Sugar, want to close the loopholes that allow this to happen by implementing the comprehensive Childhood Obesity Plans in their entirety.  This would mean including restrictions on price and place (where they are located in store), promotions and a 9pm watershed for unhealthy HFSS food and drinks.  While these policies were developed to protect children, they would bring about huge health benefits for adults, especially the socially deprived.

There is comprehensive evidence showing the harmful effect of unhealthy food and drink advertising. Furthermore, the Government has consulted on plans for a 9pm watershed last June – the outcome of which is yet to be announced[3].  The response from the broadcasters and the ad industry has been unanimously hostile to this policy. Rumour has it that they have even got the ‘newly enlightened’ Boris on the back foot, and he is considering excluding this vital policy from his soon to be released plans to address the nation’s health[4].

Need for a 9pm watershed on junk food adverts

Programmes such as Britain’s Got Talent (23 May) air ads promoting Haribo sweets and Walkers crisps, attracting nearly three quarters of a million child viewers, yet it is exempt from the Government rules, just because it is also popular with adults[5].  A 9pm watershed would have prevented that.

In May this year, Action on Sugar and Sustain’s Children’s Food Campaign exposed Kellogg’s for irresponsibly advertising its Pringles snack products to families at the start of PE with Joe exercise sessions on YouTube[6]. Again, a 9pm watershed would have prevented that too.

Even a pandemic doesn’t stop junk food ads

I am sad to report that calls for companies to cease unhealthy advertising even during this pandemic fell on deaf ears. Instead, we have been bombarded with unhealthy adverts throughout.  Cancer Research UK showed that for over 80% of the ‘less healthy’ products advertised before 9pm in 2019, there was a healthier alternative from within the same company that could have been advertised instead – showing advertisers could have easily and voluntarily made a switch, yet didn’t[7].

It should be noted, that some of the more responsible manufacturers have decided not to advertise to children, switching to promoting healthier products from their portfolios, or reformulating their existing products with less fat, salt or sugar so they could be advertised. As much as we wished everyone would do this, as it is entirely voluntary, many have not.

Not MY problem

So why doesn’t a voluntary approach work? Whilst the advertising industry is full of very lovely, bright, creative and morally-sound individuals, there is a sometimes a disconnect between ‘selling your product’ and the real-life consequences.  When each action makes such a tiny contribution to a problem, why should it be YOUR problem?

‘The placement of MY advert didn’t make you fat.

Sound familiar?  Even the great ‘Mad Men’ overlooked glaring evidence about the harms of smoking to hit those sales targets.

Media consumption (for example, time spent watching TV and online):

Encourages sedentary behaviour (lazing)


Drives sales based on adverts seen (gazing)


Increases calorie intake (grazing)


One of the many causes of obesity.

The broadcasters don’t appear to want to acknowledge their contribution, but then boasts they are part of the solution to obesity by promoting the ‘Daily Mile’ or running a few ads for ‘Veg Power’[8].  Sorry guys, but this will not offset your calorific footprint. Not when, for instance, The Food Foundation showed that food companies spend 27 times more on advertising than the Government spends on healthy eating promotions[9].

It goes without saying, NOW is the time for a complete ‘health check’ on every aspect of a marketing campaign. Instead of encouraging a culture of lazing, gazing and grazing, marketeers must support the Government in normalising healthy eating behaviours, and not stand in the way of a 9pm watershed for junk food advertising.  The nation’s health must come first.







[7] Cancer Research UK research published in The Grocer 18 July 2019