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In June 2024, AHPA SA Branch made a submission to a South Australian Government consultation on unhealthy food and drink advertising on South Australian buses, trams and trains.

The proposed draft evidence-based policy was developed by Preventive Health SA in partnership with the Department for Infrastructure and Transport. This was a collaborative submission from SA Branch committee members and SA members. Below is the text of the submission:

The proposed approach will be a mandatory policy, with policy development, monitoring and enforcement led by the Government of South Australia. Do you support, partially support, or not support this policy approach?

Support

The Australian Health Promotion Association South Australian Branch (AHPA SA) strongly supports the proposed approach of a mandatory policy to restrict unhealthy food and drink advertising on government property, with policy development, monitoring and enforcement led by the Government of South Australia. A mandatory government-led policy developed in consultation with public health experts, such as the members of AHPA SA, alongside members of the community, will increase the potential that the policy will achieve the objective of protecting children and families from unhealthy food marketing. AHPA SA is a member of the South Australian Public Health Consortium. In 2022, ahead of the State Election, the South Australian Public Health Consortium recommended phasing out all advertisement of unhealthy food and drinks on government-owned property by 2025. This policy is a positive step toward realising this recommendation. The World Health Organization (2023) recommends policies to protect children from the marketing of unhealthy foods and drinks (including alcohol) through mandatory Government regulation. Evaluations have demonstrated that mandatory Government-led approaches are more effective at reducing exposure to (and therefore the power of) unhealthy food and drink marketing than industry-led regulations (Boyland et al., 2022). It is critically important to note that private for-profit companies continue to utilise tactics such as lobbying to dissuade mandatory regulation (Ireland et al. 2019). AHPA SA notes that harmful industries have historically opposed government-led food and drink marketing restrictions (World Health Organization, 2023). It is abundantly clear that harmful industries which place profits before people cannot be relied upon to self-regulate marketing.

Stronger action on marketing of unhealthy foods and drinks including alcohol is critically needed to protect children from harm. Mandatory regulation ensures compliance does not rely upon voluntary commitment or self-regulation of harmful industries and eliminates the potential for market gain by companies through non-compliance (Chung, et al., 2022).

Further to this, AHPA SA recommends an appropriately resourced comprehensive monitoring and evaluation framework to support a mandatory policy. It is essential that there is no involvement of food, beverage and advertising industries in monitoring, and that results are transparent.

  • Boyland, E., McGale, L., Maden, M., Hounsome, J., Boland, A., & Jones, A. (2022). Systematic review of the effect of policies to restrict the marketing of foods and non‐alcoholic beverages to which children are exposed. Obesity Reviews, 23(8). https://doi.org/10.1111/obr.13447
  • Chung, A., Zorbas, C., Riesenberg, D., Sartori, A., Kennington, K., Ananthapavan, J., & Backholer, K. (2022). Policies to restrict unhealthy food and beverage advertising in outdoor spaces and on publicly owned assets: A scoping review of the literature. Obesity reviews : an official journal of the International Association for the Study of Obesity, 23(2), e13386. https://doi.org/10.1111/obr.13386 
  • Ireland, R., Bunn, C., Reith, G., Philpott, M., Capewell, S., Boyland, E., & Chambers, S. (2019). Commercial determinants of health: advertising of alcohol and unhealthy foods during sporting events. Bulletin of the World Health Organization, 97(4), 290–295. https://doi.org/10.2471/BLT.18.220087 
  • World Health Organisation (2023) Policies to protect children from the harmful impact of food marketing: WHO guideline,  https://iris.who.int/bitstream/handle/10665/370113/9789240075412-eng.pdf?sequence=1

The proposed food and drink classification system to be used for this policy is the Council of Australian Government (COAG) Health Council National interim guide to reduce children’s exposure to unhealthy food and drink promotion. Do you support, partially support, or not support using this classification system?

Support

AHPA SA strongly supports the use of the COAG Health Council’s National interim food and drink classification system for the proposed policy framework to identify foods and beverages that are potentially ‘harmful’ to children and to reduce children’s exposure to unhealthy food and drink (including alcohol) promotions. The World Health Organization (2023) recommends that a government-led nutrient profile model is utilised to classify foods and drinks that should be banned from marketing. The World Health Organization (2023) found that studies evaluating policies that used a government-led nutrient profile model demonstrated positive results on reducing exposure to unhealthy food marketing, while those using for-profit company-led nutrient profiles showed undesirable effects. As such, it is imperative to adopt government-led nutrient profiling. Recently published research comparing different nutrient profiling models for food marketing regulation recommended the COAG Health Council guide as the preferred system (Watson, Richmond, & Hughes, 2023). This approach also aligns with Australian Dietary Guidelines which is a proven effective category-based tool for identifying unhealthy foods.

AHPA SA also recommends that the SA Government work with public health experts, including members of AHPA SA, to interpret the COAG Health Council guide when developing the policy. This is critical to ensure harmful industries are unable to find ‘loopholes’ within the policy where seemingly ‘healthy’ food options are deceptively marketed to parents and children despite being potentially harmful (Kiefner-Burmeister & Burmeister, 2020). Examples include high sugar breakfast cereals, yogurts and infant and toddler foods. These foods are incorporated in the COAG Health Council Guide and AHPA SA strongly recommends that the SA Government work closely with us to guide the interpretation process. We add that AHPA SA is strongly supportive of the inclusion of alcohol and artificially sweetened drinks within the definition of unhealthy food and drinks that must not be marketed to children.

In line with the Council of Australian Government (COAG) Health Council guide, master branding is a specific overarching corporate brand name that serves as the main anchoring point which all underlying product brands are based. The proposed policy specifies that the master brand should not be the predominant feature of any advertisement and can only be used when in combination with the image of a healthy food or drink item. Do you support, partially support, or not support this Master Branding approach?

Support

AHPA SA strongly supports the proposed policy position that master branding should not be a predominant feature of any advertisement and can only appear when used in combination with the image of a healthy food or drink item. Evidence shows that the desirability of unhealthy food among children increases when they are exposed to brand marketing (Boyland, Kavanagh-Safran & Halford, 2015). Brand marketing that is primarily associated with unhealthy foods and drinks stimulates reward pathways in the child brain and increases preference and subsequent selection of unhealthy products (Mozaffarian et al., 2018; Thompson et al., 2021). With respect to alcohol, research shows alcohol marketing strategies increase the risk of underage drinking (Alcohol and Drug Foundation, 2024). Brand recognition has been shown to influence children’s food preferences regardless of whether the food in the advertisement is healthy. AHPA SA recommends an expansion of the policy in order to strengthen it which would mandate prohibition of the marketing of all brands strongly associated with unhealthy food and drink. It is also recommended that alcohol is not advertised at all. This would prevent harmful industries from utilising healthy foods and drinks to sell unhealthy options and lead consumers to the point of sale where unhealthier options are abundant. We also support the preclusion of advertising of zero alcohol products using the same branding used to advertise products containing alcohol (Foundation for Alcohol Research and Education, 2023). We acknowledge that this approach would require an appropriate definition of a ‘brand strongly associated with unhealthy food or drink’ or similar would need to be developed in consultation with public health experts including AHPA SA experts.

  • Alcohol and Drug Foundation (2024) Impact on children and young people, https://adf.org.au/reducing-risk/alcohol/zero-alcohol-drinks/impact-on-children/
  • Boyland, E. J., Kavanagh-Safran, M., & Halford, J. C. (2015). Exposure to 'healthy' fast food meal bundles in television advertisements promotes liking for fast food but not healthier choices in children. The British journal of nutrition, 113(6), 1012–1018. https://doi.org/10.1017/S0007114515000082 
  • Foundation for Alcohol Research and Education (2023) FARE’s statement of Hard Solo and ABAC. https://fare.org.au/fares-statement-on-hard-solo-and-abac/
  • Mozaffarian, D., Angell, S. Y., Lang, T., & Rivera, J. A. (2018). Role of government policy in nutrition-barriers to and opportunities for healthier eating. BMJ (Clinical research ed.), 361, k2426. https://doi.org/10.1136/bmj.k2426
  • Thompson, C., Clary, C., Er, V., Adams, J., Boyland, E., Burgoine, T., Cornelsen, L., de Vocht, F., Egan, M., Lake, A. A., Lock, K., Mytton, O., Petticrew, M., White, M., Yau, A., & Cummins, S. (2021). Media representations of opposition to the 'junk food advertising ban' on the Transport for London (TfL) network: A thematic content analysis of UK news and trade press. SSM - population health, 15, 100828. https://doi.org/10.1016/j.ssmph.2021.100828

The scope of this policy only applies to advertising on South Australian government owned transit assets (buses, trams and trains). However, consideration will be given to future opportunities that may strengthen and widen the remit of this policy. Do you support, partially support, or not support this initial policy scope?

Partially Support 

AHPA SA partially supports the scope of the proposed policy. We note that public transport (e.g., bus, train and tram) shelters are not included within the definition of ‘Government Owned Public Transit Assets’, and are concerned by this omission. AHPA SA strongly recommends that public transport shelters are incorporated into this definition and the scope of this policy for several compelling reasons. Research conducted in Australia shows that children experience a high level of exposure to unhealthy food and drink advertisements from a range of different advertising mediums when traveling to and from school (Richmond et al., 2020; Trapp et al., 2022). Public transport shelters commonly display promotional and marketing content and hence serve to influence children’s engagement with marketing messages (Trapp et al., 2022). Research shows outdoor advertising is a form of marketing that is rapidly increasing - 12.2 million people in Australia are exposed to an average of 26 advertisements per day (Outdoor Media Association, 2017). Expanding this policy to include shelters would importantly expand the scope of protection offered to children, and would close an obvious loophole for harmful industries to market unhealthy food and drink.  Additionally, AHPA SA recommends strengthening the scope of the policy to ensure that any Government owned assets managed by third parties or subcontracted outside of SA Government are not excluded from policy, with this requirement written into all contracts.

Further to public transport assets, the current policy scope fails to protect children from unhealthy food and drink marketing on other Government owned assets (Chung et al., 2022). Other assets include sports stadiums, billboards, naming rights and other signage at public events and public spaces. AHPA SA strongly recommends expanding the scope of policy to all Government owned assets and funded events to ensure that children are adequately and more comprehensively protected from unhealthy food and drink marketing. AHPA SA also strongly recommends that there is a clear timeline and process developed for decision-making regarding expanding the scope of this policy.

AHPA SA commends Preventive Health SA for developing this policy. This is an important step in the right direction to increasing the chances that all South Australian children get the best start in life through the creation of supportive, health promoting environments. AHPA SA also acknowledges the work occurring at a National level in this space with the recent consultation regarding the feasibility study on options to limit unhealthy food and drink marketing to children (Department of Health and Aged Care, 2024; University of Wollongong & Institution for Health Transformation, 2024). The scope of this National consultation is broader than public transport assets and incorporates television advertising, online marketing, product placement, sponsorship and more. AHPA SA strongly supports further investigation into options and actions in other marketing mediums that can be developed, implemented and enforced at a State level. This aligns with the World Health Organization (2023) recommendation that policies to restrict marketing of unhealthy food and drink (including alcohol) to children must be sufficiently comprehensive to avoid the risk of migration of this marketing to other spaces, platforms or age groups. 

Further Comments

As part of the call by the SA Public Health Consortium for the SA Government to commit to creating healthier environments for children, we would like to use this opportunity to advocate for suitable resourcing of the implementation of Right Bite Food and Drink Standards for SA Schools, and to make the revised standards mandatory.

Further to this, AHPA SA recommends the extension of the proposed prohibition of unhealthy food and drink marketing into digital spaces. There are no Government requirements regarding the marketing of unhealthy food and drink to children via social media (University of Wollongong & Institution for Health Transformation, 2024).

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