Submission Number: 00251
Received: 7/5/2011 10:49:39 AM
Commenter: Chris Wright
Organization: MInnesota Timberwolves
Agency: Federal Trade Commission
Initiative: Preliminary Proposed Nutrition Principles to Guide Industry Self-Regulatory Efforts; Project No. P094513
Attachments: No Attachments
July 5, 2011
Federal Trade Commission
Office of the Secretary
Room H-113 (Annex W)
600 Pennsylvania Avenue, NW
Washington, DC 20580
Re: Interagency Working Group on Food Marketed to Children: FTC
Project No. P094513
To Whom It May Concern:
This Comment is submitted by The Minnesota Timberwolves in opposition to the ban on advertising of food to children and adolescents, as proposed by the FTC, USDA, FDA and CDC. The Minnesota Timberwolves organization supports food companies in their opposition to this unwarranted restriction on their ability to advertise their products, even products that the FDA defines as “healthy” under its own regulations.
A particularly troubling aspect of the proposed advertising ban is its overbroad assessment of what constitutes “marketing to kids.”
Even if one were to proceed on the unsupported assumption that banning advertising of any foods would combat obesity, and even if one were to make the further leap and assume that it somehow would be sensible to ban the marketing of foods that FDA defines as “healthy” to kids, it would still be important to look at the precise definitions of the marketing activities that would be banned.
These definitions, which are referred to, but not explicitly listed in the regulatory proposal itself, are far broader than they are portrayed. Among the activities that would be banned:
• Portrayals of athletes or celebrities that are “highly popular”
• Sponsorships of charities that benefit children.
• Depictions of characters like the Easter Bunny or even Crunch, our
• Advertising or promotional activities at events (like sports events
attended by children.
These are incredibly broad definitions, and will suppress speech directed to, and received by, adults.
We are deeply concerned about the ill-defined and overbroad restrictions these guidelines place on marketing in general. As an all-family entertainment outlet, we see these guidelines as a threat to our business and to the businesses of our partners in the food industry.