| Comment Number: | 526194-00019 |
| Received: | 12/20/2006 6:05:55 PM |
| Organization: | Public Health Institute |
| Commenter: | Victoria Berends |
| State: | CA |
| Agency: | Federal Trade Commission |
| Rule: | Food Industry Marketing Practices to Children and Adolescents |
| Attachment: | 526194-00019.pdf Download Adobe Reader |
Comments:
Food Industry Marketing to Children Report FTC File No. P064504 I am responding to your request for comments on a proposal to collect information from food and beverage companies and quick service restaurants on marketing activities and expenditures targeted toward children and adolescents. We support the FTC’s efforts to collect this information. As stated in the proposal, the Senate requests that the FTC’s report include an analysis of commercial advertising time on television, radio, and in print media; in-store marketing; direct payments for preferential shelf placement; events; promotions on packaging; all Internet activities; and product placements in television shows, movies, and video games. We are concerned that marketing expenditures in schools are not being captured and urge the FTC to collect school marketing data from the industry. School-based marketing has expanded in the last decade as schools struggle with budgets. Many companies engage in a variety of marketing activities and sales in schools. In 2004, the Government Accountability Office (“GAO”) issued a report on commercial activities in schools documenting a range of direct advertising and indirect marketing. In 2006, the Public Health Institute commissioned Samuels and Associates to conduct a study, Food and Beverage Marketing on California High School Campuses Survey. The study found the vast majority of all advertising – posters, vending ads, events, etc. – came from soda, beverage, fast food and junk food companies. Among the findings, nearly 65 percent of vending machine ads and 71 percent of logos displayed on equipment were for soda and other sweetened beverages. While these reports give a glimpse into the strategies and techniques used by the industry to develop brand loyalty among student and gain lifelong consumers, it does not look at the expenditures and percentage of industry marketing budgets devoted to such activities. Industry has a full range of strategies and tools to create, support, and sustain consumer demand for products in schools of which have a major impact on healthy lifestyles including healthful diets and regular physical activity. We urge the FTC to collect school-based marketing data that ranges from looking at a company’s product portfolio and marketing resources devoted to developing, packaging, and promoting products that contribute to healthy lifestyles; marketing data on pricing strategies and consumer food purchases; and expenditures devoted to marketing research. Thank you for your consideration, Victoria Berends Public Health Institute PO Box 997413, MS 7211 Sacramento, CA 95899-7413 (916) 552-9894