Archway Marketing Services, Inc.
Preliminary Proposed Nutrition Principles to Guide Industry Self-Regulatory Efforts, Project No. P094513
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 Archway, in opposition to the proposed ban by the FTC, USDA, FDA, and CDC on advertising of food to children and adolescents. Archway supports the food companies in their opposition to this unwarranted restriction on their ability to advertise their products. We are disturbed to see how broadly the proposed restrictions define marketing to children. Under this definition, marketing to adults would also be impacted significantly, because prohibited marketing activities under this proposal would include advertising directed to an audience in which the majority (as much as 70% to 80%) may be adults. It is inconceivable to think that four agencies of our federal government would so boldly infringe on the rights of both businesses as well as citizens, by limiting the flow of communication and therefore inhibiting individual choice. This approach does not represent sound public policy. In addition, the purported aim of this ban is to address the dire issue of child obesity in our society today. And yet, there do not appear to be any facts that would support the idea that advertising to kids causes obesity. In fact, there is strong evidence to the contrary. While childhood obesity has been on the rise, advertising directed at children has been on the decline. This shows that there is not a causal connection between child advertising and childhood obesity. This is not sound or constructive public health policy, and we oppose this. Michael Moroz President Archway Marketing Services, Inc.