United Baking Company 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 in response to the IWG s proposed ban on advertising to children and teens. Our company, United Baking, is part of the food industry, and the industry is going to be hit hard by this ban. It is our observation that food companies are already acting responsibly in their marketing to children through self-regulation. The proposed standards are unnecessary and would actually do more harm than good as it relates to the fight against child obesity. While everyone would agree that childhood obesity is a problem, we cannot understand how this advertising ban will provide a viable solution to it. There is no evidence that the type of advertising the IWG proposes to ban causes kids to become obese. In fact, all evidence suggests that child food advertising has been declining in recent years, while obesity has been on the rise. And the types of foods most frequently advertised to kids (for example, cereals and other fortified products) actually promote public health by providing key nutrients to children. Before subjecting an entire industry to economic hardship, there should be a clear showing of precisely what this ban will achieve. There has been no such showing. And given that the ban affects numerous products that contribute markedly to public health, there can be no such showing. This proposed ban should not move forward.