Dato: 24.10.2024 Svartype: Med merknad We contribute to the food market in Norway and being a voluntary member of the EU pledge we assist path the way to ensure children under the age of 13 are not exposed to unfair marketing practices to promote the benefit of a varied, balanced and healthy diet. In response to your consultation we strongly support that the proposed restrictions are already successfully managed by the MFU and largely already covered through self-regulation including the food categories considered to be less healthy products. The MFU not only set clear guidelines but also offer a business helpline to assist businesses with compliance. On close examination of the proposed regulations we would like to offer the following comments:- Section 8 needs to clearly specify the definition of “aimed at children”. When is marketing communication considered to be aimed at children. Section 8 greater clarification is needed for the distribution of samples. For example would it be acceptable to give a sample to the accompanying adult. Please give greater clarification to the definition of snacks in Appendix I. It states that all products are covered – however does this, for example include soft cheese with breadstick/cheese with crackers. The UK has a similar list of products restricted for placement in supermarkets, promotional offers and soon to be covering TV advertising, however a two tier approach has been taken. Before a product in the listed category is restricted its nutritional profile first has to be assessed. It is possible to have snacks which add a benefit to the diet; which provides a healthier alternative. When it comes to setting the age threshold for children, both government policies and industry self-regulatory standards around the world tend to set the age of a child, in the context of food marketing restrictions, somewhere between under 13s and under 16s. Most academic reviews recognize that by the age of 12m children develop their behaviour as consumers, effectively recognize advertising and can adopt critical attitudes towards it. A landmark review by Sonia Livingstone [1] found no justification for why older children, e.g., those above 12 years of age, should be targeted for restrictions on food advertising. She concluded: Before the age of four or five, children regard advertising as simply entertainment. Between four and seven, they begin to be able to distinguish advertising from programs. By the age of eight, the majority has generally grasped the intention to persuade. After eleven or twelve they can articulate a critical understanding of advertising. This is confirmed by other studies which have had similar findings In addition, teenagers over the age of 16 in Norway are allowed to babysit, to start practice driving, to open a bank account and even to carry firearms. It is quite difficult to suggest that youth who are old enough to do these things are still too young to see a food or beverage ad. In Norway; we support that there is already sufficient regulations to manage issues that could arise from marketing to children clearly defined in particular in the Marketing: act Lov 2009-01-09-2 which amongst other controls protects children from hidden marketing practices. For this reason we believe that the current consultation needs a deeper dive and research to find out if it is necessary to put restrictions on advertising of less healthy foods to under 18 years, how we can better differ between healthier alternatives and less healthy food without blank covering a category, and if the proposal will have the impact it is intended for. We also ask that updates of this proposal are widely communicated beyond the trade bodies to ensure that businesses can adapt as necessary. Please do keep us informed of any verbal consultations and webinars on this subject. Thank you for this opportunity to respond to your consultation. [1] Ofcom, Childhood Obesity - Food Advertising in Context (review of academic research conducted by Prof. Sonia Livingstone, LSE, London, UK), 22 July 2004 Helse- og omsorgsdepartementet Til høringen Til toppen <div class="page-survey" data-page-survey="133" data-page-survey-api="/api/survey/SubmitPageSurveyAnswer" data-text-hidden-title="Tilbakemeldingsskjema" data-text-question="Fant du det du lette etter?"
