IAB UK’s response to Government’s proposal to ban HFSS online advertising

Following the Government's announcement that it will introduce a ban on online advertising of High Fat, Salt and Sugar foods (HFSS) before 9pm, and potentially at any time of day, by the end of 2022 (pending another industry consultation), IAB UK stands by its previously expressed view that such action disregards prevailing evidence relating to the causes of obesity in favour of tokenistic measures that the Government's own analysis showed would make little meaningful difference to obesity. It also bluntly fails to recognise digital advertising’s unique ability to target ads away from certain groups, such as children.

Reducing obesity within the UK is an important priority, and needs a strategy based on sound evidence of what works. Prevailing evidence suggests that online advertising has a negligible impact on obesity rates, with factors such as education and portion control understood to be significantly more effective in addressing the issue. The Government’s own 2017 impact assessment showed that an online ‘watershed’ would reduce children’s calorie intake by a negligible 0.3 calories per day and that the evidence of the impact of advertising on adults’ calorie consumption was, at best, ‘inconclusive’.  

In addition, the fact that the proposed outright ban would only apply online not only suggests an arbitrary approach to an incredibly multifaceted and complex issue, but also creates an unlevel playing field that disproportionately and unjustifiably penalises online media and creates perverse and contradictory outcomes; ad spend could be driven to other media that have much less sophisticated targeting capabilities than are available online. This is particularly so given that the Government’s own impact assessment shows that spend on and volumes of food and drink advertising online are already much lower than on TV and outdoor. 

While the Government's announcement of the measures points to a WHO report on the impact of HFSS advertising on children, it must be stressed that this report was published in 2008. Since then, the industry has introduced strict rules, enforced by the ASA, that prohibit HFSS ads being targeted at children online - restrictions not taken into account in the data on which the Government’s 2019 impact assessment was based. A move as drastic as a complete online ban of advertising HFSS products - to anyone, at any time - rides roughshod over the self-regulatory advertising codes and must be substantiated by robust evidence. This needs to demonstrate measurable benefits that outweigh the significant costs to business of imposing undue restrictions on its freedom to advertise.

The consequences of such draconian and unwarranted action will likely be felt across the entire digital ad ecosystem, affecting quality news publishers that are already navigating well-documented challenges and arguably stymying the tentative economic recovery of small businesses that rely on affordable and targeted digital advertising to support their trade. 

Our view is that the case has not been made for a ban on HFSS ads online - whether pre-9pm, or entirely - that will have untold negative consequences without making any meaningful contribution to the Government’s aim of reducing obesity. IAB UK will be responding to the consultation on an outright ban and will publish its response in due course.