The Food and Nutrition team at the Global Health Advocacy Incubator (GHAI) recently submitted a detailed response to the Australian Department of Health and Aged Care's public consultation on options to limit unhealthy food marketing to children. This is a crucial initiative to address past failures to appropriately restrict marketing of unhealthy products to children, often due to industry interference or reliance on voluntary approaches. Moreover, the consultation acknowledges the latest conflict-free research, free from industry intervention and influence, which supports restrictions for all forms of advertising, marketing and publicity that children encounter.

The Australian government opened this topic to consultation to gather input and expertise from stakeholders and the public. This approach ensures that a wide range of perspectives are considered in the development of policies to limit unhealthy food marketing to children. It is essential for the government to make informed decisions that benefit the health and well-being of children in Australia based on evidence free of conflict of interest. Our response will be made public by the Australian Department of Health and Aged Care.

Our submission underscores the importance of respecting, protecting and fulfilling human rights, particularly in relation to health and adequate nutrition. We emphasize that Australia has an obligation to regulate business activities impacting health, such as marketing and sponsorship of unhealthy food products, while ensuring access to sufficient quality and quantity of food for children. With this submission, we hope to contribute to the strengthening of food policies that are based on evidence free of conflict of interest and in line with human rights standards.

GHAI specifically advocated for the following:

Mandatory Regulations: GHAI recommends that Australia adopt a mandatory approach that regulates all unhealthy food marketing to children. Such an approach requires monitoring and enforcement led by the government. This approach aligns with international human rights obligations and ensures effective regulation of unhealthy food marketing targeted toward this vulnerable group.

Comprehensive Marketing Restrictions: GHAI recommends restricting all advertising, irrespective of whether it is child-directed or occurs within specific times. Research from other countries, such as Chile, indicates that partial restrictions do not effectively reduce children's exposure to advertising.

Evidence-Based Nutrient Profile Model (NPM): We propose that the marketing restriction policy be informed by an evidence-based NPM. This model can also guide other policies, such as front-of-package labeling. Dietary guidelines developed by experts without conflicts of interest and without links to the industry can supplement the NPM. Along with our partners, GHAI prepared a position paper that presents best practices for defining, selecting and using effective NPMs, available here.

Broad Definition of Marketing: GHAI advocates for a broad interpretation of marketing, in line with the World Health Organization's definition. This includes all forms of commercial communication that promote product recognition, such as food packaging, digital marketing, broadcasting and advertisements.

Definition of Children: We urge Australia to define children as individuals under 18 years old, in accordance with the Convention on the Rights of the Child. This aligns with the Committee on the Rights of the Child's recommendation to Australia.

Countering the Targeting of Vulnerable Groups: Our submission highlights how the marketing of unhealthy products targets vulnerable populations, including children, racial and ethnic minorities, and socially disadvantaged groups.

Best Interest of the Child: GHAI emphasizes that all state actions to restrict unhealthy food marketing should prioritize the best interest of children over commercial interests. Children's well-being should be the primary consideration in policy development and implementation.

GHAI's response to the public consultation stemmed from our engagement with local organizations at the Food Governance Conference held last February in Australia. The Conference, hosted by Sydney Health Law at the University of Sydney, was attended by GHAI’s team members Kate Konopka, Legal Director and Juan Carballo, Senior Legal Advisor. It aimed at facilitating interdisciplinary dialogue and collaboration among attendees to address challenges and explore solutions for creating more sustainable, equitable, and healthy food systems. It also examined the legal, regulatory, and policy frameworks that shape food systems globally, as well as explored the intersection of food, health and sustainability.

GHAI recognizes the critical role marketing plays in influencing consumer behavior, especially in the realm of food and nutrition. Marketing restrictions are crucial for curbing the promotion of unhealthy products, particularly those high in trans fats, sugar and salt, which contribute to non-communicable diseases like obesity, diabetes and cardiovascular diseases. By advocating for and implementing effective marketing restrictions, we can protect public health, particularly among vulnerable populations such as children and low-income communities and create environments that support healthier choices.

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