Submission Number: 07841
Received: 7/14/2011 2:57:22 PM
Commenter: Mary Kelly Persyn
Organization: Ramsey & Ehrlich
Agency: Federal Trade Commission
Initiative: Preliminary Proposed Nutrition Principles to Guide Industry Self-Regulatory Efforts; Project No. P094513
Attachments: No Attachments
Childhood obesity is a tragedy and a crisis. In the United States, one-third of children are overweight or obese, and the number is rising. Studies suggest that the advertising of low-nutrition, high-calorie foods and drinks to children increases their consumption of these obesity-inducing items. The fact that the industry is resisting even voluntary regulations on advertising--nothing close to regulation of the products themselves--speaks volumes about its own confidence in the efficacy of advertising, as does its $2 billion yearly spend on advertising to children.
The costs of childhood obesity, which are completely externalized by the industry, are staggering, and they are rising too. Estimates peg these costs at $3 billion for children covered by Medicare and $11 billion for children covered by private insurance. Overall costs for obesity are approximately $147 billion per year. We literally cannot afford to ignore this crisis. Voluntary regulation of junk-food advertising to children is a small initial step, but a step we absolutely must take, for our children and for our nation.
For more comments, please see a blog post by California Endowment Director of Community Health Marion Standish and me, in the American Constitution Society blog, available at http://www.acslaw.org/acsblog/why-soda-sucks-and-what-you-can-do-about-it-ftc-requests-public-comment-on-advertising-regul.
Mary Kelly Persyn, Ph.D., J.D.
Associate, Ramsey & Ehrlich
Steering committee member, Women's Leadership Council, United Way of the Bay Area
Appointee, California State Bar Association Standing Committee on the Delivery of Legal Services