Children watching tv

Television advertising of unhealthy food to children - have your say!

Consultation on Children's Commercial Communications Code

The Broadcasting Authority of Ireland (BAI) is the body responsible for the regulation of broadcasting in Ireland and is currently reviewing the Children's Commercial Communications Code - the code that regulates television advertising to children. The BAI is seeking submissions from parents, the general public and organisations to gather their views on how the promotion of foods high in fat, sugar or salt (HFSS) to children should be regulated.  The Broadcasting Act 2009 requires the code to protect children, particularly with regards to public health. The current health status of Irish children, with 1 in 4 primary school children either overweight or obese, is of major public health concern and there is robust scientific evidence that food marketing and advertising has damaging affects on children's diet and health (see notes below). The Irish Heart Foundation and the National Heart Alliance have long called for a ban on the television advertising of unhealthy foods to children from 6am until 9pm.

On behalf of the National Heart Alliance and the Irish Heart Foundation,  I ask for 10-15 minutes of your time to support this important public health  issue by sending in a submission to the BAI.

I have prepared a draft template which answers questions asked by the BAI in their consultation document and reflects the submissions from both the Irish Heart Foundation and the National Heart alliance.  You can of course send in your own submission;  use the template below - as is;  use the template below without referring to the Irish Heart Foundation/National Heart Alliance ; or simply just take the first  paragraph below in the letter as your submission.
Please submit your own response to the BAI no later than Friday, October 14th 2011.  Responses can be sent by post or email to : sowens@bai.ieor to the address below:

Submission template:

September 2011

Sinéad Owens
Children's Code Consultation
Broadcasting Authority of Ireland
2-5 Warrington Place
Dublin 2

Dear Ms Owens,

RE: Consultation on Children's Commercial Communications Code

(Insert Name/Organisation), would like to endorse the Irish Heart Foundation and the National Heart Alliance  position on the Children's Commercial Communications Code and call for a restriction on all advertising of food high in fat, sugar and salt, as defined by the Nutrient Profiling Model, from 6:00am to 9:00pm. (Name/Organisation)  believe/s this is a necessary and proportionate measure to protect children from exposure to advertising of unhealthy foods and the damaging effects this has on their dietary health and wellbeing.
Response to key questions in the consultation document is as follows:
• (Name/Organisation ) fully and unequivocally accept/s  the five recommendations of the Expert Working Group.
• The Nutrient Profiling Model (NPM) has been reviewed for effectiveness in relation to food advertising and used successfully in the UK. The BAI should fully adopt the NPM of the Food Standards Agency.
• The Co-regulation approach has worked well in the UK with the advertiser/manufacturer taking responsibility for the assessment  of products based on the NPM but with a statutory oversight and enforcement of the restrictions.
• Restrictions on advertising for all foods high in fat, sugar and salt, as defined by the NPM, should be from 6am to 9pm.  The only suitable measure is a restriction based on time bands.

Thanking you for the opportunity to submit my/our views on this important public health issue.
(Insert Signature)
(Insert Printed Name)

BAI Consultation document:   O r for more information  see

Areas on which the BAI is gathering views - questions can be found on page 34 of the BAI Consultation document:

• Expert Working Group Report - The BAI convened an expert working group to examine issues pertaining to the health and nutrition of children in Ireland and to make recommendations on the Children's Commercial Communications Code.  (See page 24 of the BAI Consultation document).  The Irish Heart Foundation and National Heart Alliance  endorse all five recommendations fully and completely.

• Nutrient Profiling Model - The UK Food Standards Agency has developed a model that differentiates foods and beverages on the basis of their nutritional composition, categorizing them as healthy or less healthy (See 4.1 page 24 of the BAI Consultation document). This has been used successfully in the UK to place advertising restrictions on certain products. (See page 25 of the Consultation document). The Irish Heart Foundation and National Heart Alliance fully endorse this model as an appropriate, specific and scientifically rigorous tool and calls for its full implementation by the BAI in Ireland.

• Regulatory Options - The BAI is evaluating whether the code should be enforced by the government (statutory) or by the industry (self-regulatory) or by some combination of both. The BAI is also evaluating whether restrictions should come in the form of time based restrictions. (Regulatory options and measures on page 29 of the BAI consultation document).  The Irish Heart Foundation  and National Heart Alliance call  for an outright ban on advertising of foods high in fat, sugar and salt (as determined by the Nutrient Profiling Model) between the hours of 6am and 9pm. This should be implemented as a statutory regulation, overseen by the BAI.

The case for the 6am - 9pm ban:

• 1-4 primary school children and 1 in 5 teenagers aged 12 -17 years are overweight or obese.
• Overweight and obesity are themselves risk factors for cardiovascular disease -  the leading cause of death in Ireland among all ages and accounting for about 2,000 premature deaths.
• Irish children and young people are showing early signs of other risk factors such as increasing levels of blood pressure, cholesterol and higher blood sugar/insulin levels, leading to Type 2 diabetes.
• Overall the diet of Irish children is high in fat, sugar and salt.
• Most of the foods advertised to children are high in fat, sugar and salt, contrasting sharply with the recommended diet.
• There is robust and compelling evidence which links the marketing of foods high in fat, sugar and salt to children, and specifically television advertising, to poor diets and obesity.



Read the consultation document here.
Read the BAI press release here.
Read the Irish Heart Foundation press release here.

The Mulcahy Lecture "Protecting Children from Unhealthy Food Marketing" took place in Dublin on Thursday, April 7th.

The lecture examined the marketing of unhealthy food to children in Ireland and around the world and how it influences the global obesity epidemic in children. It looked at how food companies market their products to children and the impact this has on healthy food choices. Many thanks to all who attended. Please find copies of the presentations below:

Opening Presentation: Dr. Edna Roche, Head of Department of Paediatrics, University of Dublin, Trinity College and Consultant Paediatrician, National Children's Hospital, AMNCH, Tallaght, Dublin 24.

Dr.Roche's presentation provided a thorough background on the current extent of the childhood overweight and obesity epidemic in Ireland.

Keynote Address: Sue Davies, Chief Policy Adviser, WHICH? UK.

Sue's presentation discussed policy developments in the UK including a ban on advertising of unhealthy food to children that has been implemented. Sue also examined other (non-broadcast) marketing techniques (e.g. sponsorship, the internet and new media). 

Marketing of Food and Beverages to Children - Stakeholder view on policy options in Ireland

New: Visit our Tips for Parents, showing what you can do as parents to help your children understand advertising.

Every day children are targeted by hundreds of adverts for unhealthy foods (foods high in fat, sugar or salt, such as confectionary, salty snack foods, fizzy sugary drinks and fast food). These adverts appear on television, on the Internet, in shops, on packaging and in many more ways.

The National Heart Alliance and the Irish Heart Foundation are calling for a ban on TV advertising of these unhealthy foods to children because there is a vast amount of scientific evidence linking these foods to a poor diet and obesity in young people.

Parents' Concern
Parents too are very concerned and a survey has found that 78% of Irish parents said they would like to see a ban on television adverts up to 9pm.

NHA and IHF Recommendations
The Children's Food Campaign led by the National Heart Alliance and the Irish Heart Foundation has created a paper on all forms of unhealthy food marketing to children. 

 The main recommendations are:         - A healthy eating policy in schools.

- More support for parents and guardians on encouraging healthy eating in the home. 

- A healthy eating policy for children's healthcare facilities.
- The retail sector and manufacturers have a vital role to play.
 - The type and amount of food marketing to children needs to be monitored.

Sharing Information
This website's aim is to keep parents, policy makers and other interested parties informed on issues relating to food marketing to children and to encourage ongoing debate on the issue. 

We would love to hear your views on the matter, so share your views on our guestbook or send us an email and tell us what you think!  

Check the latest news section regularly for updates.....

Find out why food marketing to children is a real issue in Ireland and what we can do about it - The Children's Food Campaign Position Paper  


Find out what Irish parents think about food marketing to children - Research on Parents Opinions on Food Marketing to Children