The Rudd Center for Food Policy & Obesity has published a study urging a broader definition of “child-directed” TV advertising than the one currently employed by the industry-backed Children’s Food and Beverage Advertising Initiative (CFBAI). Jennifer Harris, et al., “Redefining ‘Child-Direct Advertising’ to Reduce Unhealthy Television Food Advertising,” American Journal of Preventative Medicine, March 2013. According to the study, CFBAI covers TV advertising only “during programs for which children make up 35% or more of the viewing audience.” By comparison, Rudd Center Director of Marketing Initiatives Jennifer Harris and her colleagues have suggested that broadening the definition of child-directed advertising “to include programs with a child-audience share of 20% or higher and/or 100,000 or more child viewers would cover 70%-71% of food advertising seen by children but just one third of ads seen by adults.”

To support this recommendation, the study’s authors used Nielsen data from all national TV programs aired in 2009 to estimate what percentage of the total audience comprised children ages 2-11 years. They also examined Nielsen advertising data on “the number of food and beverage advertisements viewed by preschoolers (aged 2-5 years); older children (aged 6-11 years); and adults (aged 18-49 years) during programs with various child-audience compositions.” Their results evidently indicated that, although food advertising during programs with “a very high” child-audience share (greater than 50 percent) had declined between 2009 and 2004, “food advertising viewed by children during other programming also appears to have increased.”

“In 2004, children viewed approximately 2000 ads for food and beverages during programming with a child-audience share <20%,” states the study. “In 2009, children viewed more than 2300 ads for these products during similar programming. As adults viewed 29% more food advertising in 2010 versus 2004, it appears that increased adult-targeted advertising also has affected ads viewed by children.”

In addition, the study notes that expanding CBFAI’s definition to include programs with a greater than 20 percent child-audience share or more than 100,000 child viewers would cut down on advertisements for “the leasthealthy” products, including carbonated beverages, baked goods and candy. It also proposes adopting nutrition standards for all food advertising and expanding the definition of children to cover youths older than age 12.

“The present analysis suggests that the [Federal Trade Commission] could regulate food advertising during child-directed programming under its jurisdiction over unfair and deceptive marketing. Or the U.S. Congress could legislate such restrictions without infringing on companies’ right to communicate with adults,” conclude the authors. “Although any government restrictions would likely result in legal challenges by the industry, prohibiting marketing of nutrient-poor foods on TV programs with a child-audience share of 20% or higher would affect just 7% of food ads that adults now view, and therefore should withstand these challenges.”