Submission Number: 07851
Received: 7/14/2011 3:30:29 PM
Commenter: Charmaine Ruddock
Organization: Bronx Health REACH / NY CEED
State: New York
Agency: Federal Trade Commission
Initiative: Preliminary Proposed Nutrition Principles to Guide Industry Self-Regulatory Efforts; Project No. P094513
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Subject: Interagency Working Group on Food Marketed to Children: Proposed Nutrition Principles, General Comments, and Proposed Marketing Definitions: FTC Project No. P094513
Dear Secretary Vilsack, Chairman Leibowitz, Director Frieden, and Commissioner Hamburg:
Bronx Health REACH / NY CEED strongly supports the Interagency Working Group (IWG) on Food Marketed to Children’s proposed nutrition principles and marketing definitions. This is an important time to address food marketing to children and youth. Our nation faces unprecedented rates of obesity and other nutrition-related diseases. In the Bronx, 1 in 4 children in public elementary schools is obese, and nearly 4 in 10 are overweight or obese.
Bronx Health REACH, a Center of Excellence in the Elimination of Disparities as designated by the Centers for Disease Control and Prevention (CDC), is a community coalition working to eliminate racial and ethnic health disparities in obesity and diabetes. Bronx Health REACH, which works with schools, churches, and other community-based organizations, recognizes that nutrition and physical activity education – while important – are not enough to create lasting behavior change and reduce the incidence of childhood obesity. To that end, we are working on several policy-related initiatives to support the marketing of healthier products to children in schools and the community. For example, we are working with school wellness councils to create and enforce school-based nutrition policies, and we are also developing a social marketing campaign to promote healthy food choices for children.
Food companies have already taken steps to address food marketing. For example, the National Restaurant Association and Healthy Dining “Kids Live Well” initiative outlines Nutrition Criteria to assist parents and children in selecting healthful menu options when dining out. The voluntary program, which includes 18 participating restaurant chains, is a step in the right direction. However, this program does not meet the higher standards as recommended by the IWG and does not pertain to other food companies which market to children. The IWG’s standards would improve upon the voluntary efforts by these and other restaurants’ efforts to provide healthy options for its customers.
While we strongly support the overall nutrition principles proposed by the IWG, we support the additional recommendations offered by Center for Science in the Public Interest to clarify and strengthen them. Please find these recommendations in the attached letter.
Bronx Health REACH / NY CEED
Institute for Family Health