The Food Marketing Workgroup (FMW) has sent a July 16, 2014, letter to Kraft Foods Group, Inc., questioning how the company purportedly markets its Lunchables product line to children. Signed by Rudd Center for Food Policy and Obesity Director of Marketing Initiatives Jennifer Harris and Center for Science in the Public Interest Director of Nutrition Policy Margo Wootan, the letter cites a recent Rudd Center report alleging that just five out of 42 Lunchables meet nutrition standards under the Children’s Food and Beverage Advertising Initiative (CFBAI). In particular, FMW claims that even though Kraft restricts its child-directed advertising to only those products that comply with CFBAI, the use of sweepstakes offers, in-store displays and other tactics could still contravene industry guidelines.

“In the supermarket, less nutritious versions of Lunchables outnumber the healthier ones by six to one, and the healthier varieties are most likely to be stocked on the top shelf, above eye level for both children and adults,” states the letter. “Further, the advertised varieties appear on the top shelf while the products that contain candy, cookies, and sugary drinks are placed directly at children’s eye level.”

Arguing that this practice violates CFBAI, FMW urges Kraft to adopt a comprehensive policy that covers all marketing techniques, including shelf placement, in-store displays and on-package advertising. The group also recommends that this policy align with guidance set forth by the Federal Trade Commission (FTC), which “considers in-store and on-package marketing that prominently features child-oriented characters, themes, activities or celebrities or athletes popular with children to be child-directed marketing.” In addition, the letter calls on Kraft to extend its marketing policy to cover children ages 12 to 14, opining that this age group “is heavily targeted with newer forms of social and mobile media marketing that is often disguised as messages from peers, making it difficult for children ages 12 to 14 to recognize and taking advantage of this age group’s susceptibility to peer pressure.” See Rudd Center Press Release, July 16, 2014.