Center for Digital Democracy Takes Aim at Digital Food Marketing to Kids

The Center for Digital Democracy (CDD) is calling on the Federal Trade Commission and Congress to regulate digital marketing of junk food to kids. In a far-reaching report published today, the organization contends digital marketing efforts by food and beverage brands — from mobile and game marketing to behavioral profiling — contribute to the scourges of poor nutrition and obesity among children.

The report, published in conjunction with a letter sent to the FTC, calls for the trade regulator to require food and drink purveyors to report all digital marketing and market research practices aimed at children and adolescents, and requests regular monitoring of digital marketers and the impact of their efforts on kids’ nutrition and health.

The goal of the report, said CDD Executive Director Jeff Chester, is to “explain to policy makers, health professionals and nutrition advocates as well as parents that the media world has changed….One has to take a 360 degree approach to understanding where marketing is now occurring when it comes to children and youth and unhealthy food products.” Chester is the co-author of the “Interactive Food and Beverage Marketing: Targeting Children and Youth in the Digital Age” report, along with Kathryn Montgomery, Ph.D. and professor at American University.

Citing companies including the Kellogg Company, McDonald’s, Viacom and Pepsi, the 98-page document also submits that the FTC, FCC and Congress should collaborate with other organizations to develop new regulations for kid-targeted food and drink marketing. In addition, it requests private and public funds to support “broad, multi-disciplinary research on the interactive media and their relationship to the health of children and adolescents.”

“Congress is going to have to pass legislation,” continued Chester, who said the CDD has spoken with members of the Senate Agriculture Committee regarding digital marketing of food and beverage products to children.

The report details several marketing campaigns, claiming, “When used to promote certain food products, the aggregation of these new marketing tactics could have harmful consequences.” Viral marketing campaigns from P&G, Cadbury Schweppes and Frito-Lay are mentioned, along with CGM campaigns created for Wendy’s and Pizza Hut, game-related campaigns on Viacom’s for Kraft Foods and Nestle and avatar efforts for Kellogg’s Go-Tarts and Coca-Cola.

Mobile campaigns from The Kellogg Company and McDonald’s are also alluded to as potentially dangerous for young people. Stephanie Retblatt, “chief brainiac” at youth market research and strategy consulting firm, Smarty Pants, isn’t so sure young children are engaged enough with mobile devices for such campaigns to have an impact on them.

“More often than not, payment plans are tied to their parents,” she said, adding parents often determine whether they can or cannot send pictures or text messages. “Younger children are just not in that world yet.” Teens, and even tweens, however, are far more involved with mobile media. “The use of digital media obviously increases with the age of a child,” continued Retblatt.

The CDD mentions the use of profiling and tracking technologies to guide campaigns for Pepsi and General Mills, and concludes, “The unprecedented ability of digital technologies to track and profile individuals across the media landscape, and engage in ‘micro’ or ‘nano’ targeting, raises the twin specters of manipulation and invasion of privacy.”

“I’m somewhat skeptical of doing behavioral profiling of kids online,” Retblatt said. “Behaviors are monitored by their parents or very often [kids are] logged on by their parents,” she added.

The report laments viral and peer-to-peer campaigns that aim to turn kids and teens into “brand advocates,” stating, “Business models underlying youth-oriented Web sites such as are based on using technology to tap into these complex social relationships, enabling marketers to pass on branding messages through a daisy chain of hundreds and thousands of connected friends and acquaintances.”

The report comes a month after the FTC proposed to send information requests to 44 purveyors of candy, snack foods, juice, breakfast cereal, carbonated beverages and other specific food items frequently marketed to children and adolescents. In a document published April 18, the commission said it would ask the unnamed companies about the types of measured and unmeasured media techniques they use, the amount spent on marketing in those media, the nature of the marketing activities, and any marketing policies, initiatives, or research being conducted in relation to marketing their food products to kids. The FTC intends to use the information “to provide Congress and the public with a complete picture of the types of marketing techniques the industry is using to reach children and adolescents,” according to the document.

In November, food purveyors such as McDonald’s, General Mills, Hershey and Coca-Cola pledged to limit their marketing of junk food to kids, but made little mention of interactive media beyond game marketing.

The CDD also said today that food firms should be required to provide psychosocial information collected through interactive marketing efforts, and make public the digital marketing ad firms, agencies and consultants they work with.

Although many paid digital marketing efforts may be difficult to separate from those simply inspired by kids themselves, the CDD’s Chester believes regulation is possible. “[Regulations] simply would say [marketers] couldn’t engage in direct promotion [to kids]…using such technologies as virtual reality, broadband communication and mobile messaging,” he said. “We’re likely to ask that the Children’s Online Privacy Protection Act be extended to include teens and involve other safeguards.”

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