Last week, the UK government released its consultation on a total online advertising ban for HFSS (high in fat, salt and sugar) food and drink. This follows July’s plan for a pre-watershed ban on TV as part of the government’s tackling obesity strategy – but goes further than that, proposing a total ban of online advertising of HFSS products, irrespective of any age- or time-targeting capabilities of the online media.
The blanket ban, as opposed to a watershed approach to protect children, is disappointing and represents a vote of no confidence in the advertising and food industries in a number of ways.
First, the impact assessment predicts the ban will cost online media owners £4.6bn in lost revenue, while ad agencies stand to lose £66m – a blow that the industry can ill afford to take right now, with the pandemic, economic recession and known unknowns of Brexit still to come. A joint statement from the AA, ISBA, IPA and IAB called it a “severe and disproportionate measure that goes far beyond the government’s objective of protecting children”.
There is no recognition of the ability of the communications sector to drive positive change in the complex area of tackling Britain’s unhealthy lifestyles. Obesity is a multifaceted problem that warrants a co-ordinated solution, and promoting healthy lifestyles, education on food choices and the role of exercise are all major challenges the ad industry could help with.
Another approach could be to require HFSS food brands to contribute towards educational campaigns, much like the way the betting industry is now obligated to promote "If the fun stops, stop" ads, or alcohol ads have to contain the "Drink responsibly" warning. There is no reference to this kind of solution in the government’s proposals.
Of particular pain for some of our clients is that the proposed legislation draws no distinction between highly processed foods and natural staples such as butter, cheese and oil (such as in the Waitrose ad pictured) – which are unlikely to appeal to, or be bought by, children.
Similarly, a whole raft of innovative products from plant-based yoghurts made with coconut to better-for-you snacks such as popcorn will be hit, despite the positive choices these products represent versus their mainstream alternatives, being made with natural and sustainably sourced ingredients, rather than artificial nasties. At Yonder Media, we have several purpose-driven, B-corp clients who will be affected by such a ban: shouldn’t government policy be encouraging food businesses that are sustainable, eco-friendly and a force for good, not throttling their growth? The list of unintended consequences grows.
The next vote of no confidence seems to be in the online ad ecosystem itself. The consultation proposal is damning in its view that because no independent or gold-standard measurement system is in place for online (unlike Barb for TV) then it lacks confidence that any age-based content restrictions are robust enough. This might focus the minds of the various trade bodies making slow progress on a standardised measurement framework for online media.
It then dismisses the application of a watershed for online advertising on the grounds of fairness – worrying that platforms that offer that capability may stand to gain more in any redistribution of ad budgets than those that don’t. In a world where ad tech can verify a domain’s authenticity, detect the presence of bots and pre-read website content for inappropriate keywords, all in a split second, it’s hard to hear that a simple time-targeting solution can’t be applied because it might be too difficult. I remind you that the current acceptable solution for restricting access to an alcohol brand’s website is a box to enter your date of birth.
The consultation lasts just six weeks but much is at stake for our industry, for a proposal many agree is a hastily formed fig leaf on a massive and complex issue.
The industry needs to set out the positive impact that agencies can make to solve the obesity problem. Current squabbles over measurement standards need to be set aside so we can prove that we can control who sees ads and who doesn’t.
We need to educate policymakers on the direction of travel of advertising technologies, with verified, ID-based targeting a reality today.
As TV moves steadily to an online-style delivery model, it seems curious that the proposal backs a panel-based approach, where 25% of the ads could still be seen by children, over a model where kids could be entirely excluded from exposure.
And lastly, with £4.6bn in online media revenues set to be lost, now would be a good time for the online-platform giants to bring some of their tech solutions to the table for the wider benefit of the industry.
Ed Cox is founder at Yonder Media
Image: Waitrose & Partners ad for olive oil, which would be banned from running online under government proposals