The Robert Wood Johnson Foundation’s (RWJF) Healthy Eating Research initiative has published a January 2015 report seeking to close alleged loopholes in industry efforts to regulate the marketing of foods and beverages to children. Focusing on children younger than age 14, Recommendations for Responsible Food Marketing to Children notes that although new advertising standards have led to improved nutritional profiles for many products, these guidelines often exclude product packaging, in-store promotions, toy incentives, and other strategies from their definitions of child-directed marketing.

To this end, the report offers model definitions that aim to cover diverse brand architectures as well as new media and venues for marketing activities. The authors recommend that companies restrict their advertising to products that meet nutritional criteria when (i) “children constitute 25 percent or more of the audience (e.g., viewers, listeners, readers, participants, or visitors) at the time of ad placement based on projected attendance,” (ii) “children are the target demographic based on the company’s media or marketing plan, the developer’s designation, or the description of the projected viewership, listeners, readers, participants or visitors,” or (iii) “an assessment of the marketing strategies, techniques, characteristics, and venue suggests that children are the target demographic for the advertising or marketing.” Among other things, the report argues that guidelines should cover entire brands and not just individual products, claiming that “companies should not market products within brands that contain other products that do not meet nutrition criteria unless the product that meets nutrition criteria is the key focus and featured prominently in the marketing.”

The authors also discuss several strategies, techniques and qualitative characteristics that would fall under their recommended child-directed marketing guidelines, including character licensing and cross-promotions, celebrity endorsements, product placements, sponsorships, merchandising, and animated or anthropomorphic objects or animals. In addition to addressing ads, logos and other brand-identifiers that appear in child-oriented and retail settings, these guidelines would apply to television, radio, print, digital platforms, movies, video games, email or text messages, games and apps, social media posts, and other media platforms, as well as viral or word-of-mouth marketing campaigns.

“These recommendations are intended to provide guidance to a broad range of stakeholders, including food and beverage manufacturers, retailers, restaurant companies, media and entertainment companies, industry trade associations, advertisers, marketers, government agencies, regulators and other policymakers, advocates, and researchers,” states the report. “This guidance provides a comprehensive framework that, when paired with sound nutrition criteria, will assist stakeholders’ efforts to continue to improve food marketing to children.”

Meanwhile, the report has drawn criticism from New York University Professor of Nutrition, Food Studies and Public Health Marion Nestle, who writes in a January 20, 2015, Food Politics article that the recommendations stop short of requiring mandatory guidelines. “These are tweakings of voluntary guidelines,” she opines. “If we really want the food industry to stop marketing unhealthy foods and drinks to kids, the guidelines can’t be voluntary and tweakings are unlikely to help.”