If You Believe Advertising Works Then Don't Argue Against the UK HFSS Ad Ban

The online ban on high fat, sugar and salt food advertising has drawn criticism

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Presenter Vanessa Feltz’s BBC Radio London researcher messaged me last week asking whether I’d be happy to give an industry insider response on-air to the news that, in an effort to curb childhood obesity, the British government had enacted a new watershed TV and online ban on high fat, sugar and salt (HFSS) food advertising.

I’d seen the official industry response, and it had made me uneasy.

The Advertising Association declared themselves to be “dismayed” by the news. The Food and Drink Federation said that they were “disappointed …the proposals would make it difficult to advertise many products that have been carefully reformulated or created in smaller packaging. … Many food and drink companies won’t be able to advertise new product innovations … and larger food-on-the-go, pub and restaurant chains may not be able to tell their customers about their menus.”

Elsewhere, the IAB wrote that the ban “will create untold damage to the advertising industry” and that banning ads online will achieve “next to nothing in terms of reversing children’s obesity rates.” The News Media Association declared the ban “draconian.”

I am aware that I am in a position of privilege in so much as I work as an independent strategy consultant, so I’m not beholden to a global agency network and can consequentially give my opinion and not have toe the party line. But there comes a point when we all have to be honest about what we’re hearing and feeling.

At a fundamental level, we have to make a choice: either we believe advertising works or we don’t.

The moral issue

If we think advertising does work, then we probably shouldn’t be getting to upset about a pre-9 p.m. junk food advertising ban aimed at children. If, however, we believe that advertising doesn’t work then we’re probably in the wrong business.

When I posted about the HFSS ban on Twitter, the strategy community seemed divided and conflicted. I was warned about culture wars, told that “no government should be allowed to tell me what I can eat or drink,” that obesity has nothing to do with advertising. I had Jeremy Bullmore, author and former chairman of JWT London, quoted at me as saying, “Advertising’s role is to provide the best advice to clients to meet their business objectives. It has no remit to take a stance on issues.”

Really? I felt so sure this quote was not something Bullmore would actually say. So I emailed him, and he said the quote is fake.

“I’m pretty sure I’ve never written anything along those lines. It’s meaningless anyway since a company’s known stance on issues can help or impede the meeting of its business objectives,” he responded.

I have also heard a lot of anger at the perceived hypocrisy of our industry. Anger at (unnamed) IPA Effectiveness winners declaring at an ISBA conference that HFSS advertising had no significant effect on consumption.

HFSS food pun intended, our industry wants to have our delicious cake and eat it.

During Cannes Lions, when our industry is heartily patting each other on the back for the brilliance of our social purpose advertising campaigns that have apparently changed hearts and minds around the world, it just seems funny how advertising doesn’t do anything when it comes to HFSS.

Thank you for smoking

There’s a brilliant dark comedy Thank You for Smoking in which Aaron Eckhart, the lobbyist for Big Tobacco, tries to remain a role model for his 12-year-old son while simultaneously doing his job standing up for the cigarette industry. Spoiler alert: He fails.

The language that our industry is using around HFSS and children seems to be remarkably similar to the language the self-titled MOD (Merchants of Death) Squad tobacco, firearms and alcohol lobbyists use in this damning satire. It got me thinking about whether we use the same language back in 2003 when cigarette advertisements were finally banned.

Trying to understand from a client that was grappling with the new implications and impact of the ban, I spoke to Ross Farquhar, CMO of cult mochi ice cream brand Little Moons.

Ross and the Little Moons team worry this ban is devastating. “For a company like McDonald’s, Dominos or Unilever, they can side-step the ban because they can still run brand adverting that doesn’t show product. Our brand isn’t that widely known yet so we can’t do that.”

One of the loopholes would be that a company like McDonalds, so long as they didn’t show hamburgers, would be fine. In fact, they can actually advertise chicken nuggets as those fall within the acceptable HFSS range.

Farquhar’s point was that for a company like Little Moons that has yet to break into the mass mainstream and doesn’t have the brand awareness has to talk about product, especially when it’s a Japanese product that is not very well known. Now they’ve lost that opportunity on television.

There are a number of other loopholes and exceptions. OOH advertising is still permitted; small- and mid-sized businesses with less than 250 employees will not be impacted by the ban. However, Little Moons produces all their ice cream in the U.K., so while they are a small company, their headcount takes them above the magical 249 number and they’re therefore applicable to the new ruling.

My overarching view remains the same. We have the most overweight children in all of Europe. It’s a health time bomb of epic proportions, and we need an honest approach to tackling it, of which advertising is a part. For our industry to deny that advertising can shape desire and prompt purchase is simply mealy-mouthed.