9th September 2016, Volume 129 Number 1441

Cliona Ni Mhurchu, Tara Mackenzie, Stefanie Vandevijvere

Promotion of unhealthy foods and beverages to children is a significant, modifiable risk factor for child obesity and development of diet-related non-communicable diseases.1 Comprehensive, independent reviews of the evidence consistently find that commercial food marketing has a direct effect on children’s food preferences, purchase requests, consumption patterns and diet-related health.2-4

Current marketing practices in New Zealand predominantly promote unhealthy foods and drinks to children.5 The most common categories of food products promoted to children are pre-sugared breakfast cereals, soft drinks, savoury snacks, confectionery and fast foods.3 Estimates of the proportion of food marketing promoting these product categories to children vary from 60% to 90%.3 A US federal Trade Commission survey of industry expenditure reported 63% of the marketing spend directed to children was for carbonated drinks, fast food and breakfast cereals.6 Analysis of UK television channels popular with young people found six of the 10 most frequently advertised food items were fast food, high sugar/low fibre breakfast cereals, confectionery and snack foods.7 A similar study in New Zealand reported that 66% of food advertisements on a free-to-air channel popular with children were for foods high in fat, salt or sugar.8

Several national governments and food and beverage manufacturers have acted to restrict unhealthy food marketing to children or to allow the promotion of healthier choices only. Countries such as Norway, Sweden and the province of Quebec, Canada have statutory regulation (a formal legislative requirement by government) restricting the advertising of any product to children, and Ireland, UK and South Korea have regulations to restrict advertising of specified foods and beverages during children’s programming or peak viewing times.9 A number of food and beverage companies have also responded with voluntary pledges (non-legislatively required commitments) to change their marketing activities directed to children, and the mix of foods advertised to children.10,11 New Zealand does not have statutory legislation on the advertising of foods to children but 67% of the major packaged food manufacturers and 20% of the biggest fast food restaurants have a voluntary policy on food marketing to children on their company website. However, none of those include an accepted nutrient profiling model.12

A systematic review of the impact of statutory and voluntary codes to limit the advertising of foods to children found a sharp division in the evidence however, with scientific peer-reviewed evidence showing small or no reductions in promotion of less healthy foods and children’s exposure to food marketing, except in response to statutory regulation. 9 In contrast, industry-sponsored reports indicate high adherence to voluntary codes.9 Discrepancies are likely to be due to lack of complete coverage of voluntary codes across all food companies, differences in audience definitions (times children are likely to be watching television versus ‘children’s programming’ times), and different systems to classify foods as unhealthy or ‘non-core’. Adherence to voluntary codes may therefore not sufficiently reduce the advertising of unhealthy foods or children’s exposure to such advertising.9

An accepted food classification or nutrient profiling system is necessary to classify foods as suitable/unsuitable for marketing to children and to implement restrictions. Examples of systems used for this purpose are the UK Ofcom model, the Scandinavian Keyhole model, the US Interagency Working Group proposals13 and the World Health Organization (WHO) Regional Office for Europe Nutrient Profiling Model.14

In February 2016, the Advertising Standards Authority (ASA) announced a review of the ASA Children’s Codes (Code for Advertising to Children and Children’s Code for Advertising Food).15 The consultation document contained a specific question on the role of nutrient profiling systems in the Children’s Codes, Is there a role for a nutrient profiling system such as the health star rating system in the Children’s Codes? If yes, in what way and which system would you suggest?

To inform our response to this question, we compared three accepted nutrient profiling systems: the Health Star Rating (HSR), the Ministry of Health Food and Beverage Classification System (FBCS) and the World Health Organization (WHO) Regional Office for Europe Nutrient Profiling Model (WHO Model) to identify the best system to protect New Zealand children from exposure to the marketing of unhealthy foods and beverages.

Methods

Selection of Nutrient Profiling Systems

Three nutrient profiling systems were selected for comparison. Two were established New Zealand systems: the HSR and the Ministry of Health FBCS, and one was an international system: the WHO Model. Table 1 provides an overview of each system.

Table 1: Summary of criteria used under each nutrient profiling scheme.

Nutrient profiling system

Purpose

Scoring

Nutrients to limit

Nutrients or components to promote

Examples

HSR16

Front-of-pack nutrition labels

on packaged foods to assist consumers in discriminating and comparing foods within categories

 

Products receive a Health Star Rating between ½ star and 5 stars from an overall score based on food components with positive or negative associations with chronic disease.

 

Energy, saturated fat, total sugars, sodium

Protein, fibre, percentage of food that is fruits vegetables nuts and legumes

Sugar sweetened soft drinks = 100% of products receive <3.5 stars

 

Frozen vegetables = 100% of products receive >3.5 stars

FBCS18

Guidelines for schools to identify healthy food and drink options for sale on campus

 

Foods are either ‘everyday’

‘sometimes’ or ‘occasional’ foods depending on alignment with food and nutrition guidelines

 

Added fat, added salt, added sugar

 

Sugar sweetened soft drinks = ‘occasional’ 

 

Frozen vegetables = ‘everyday’

WHO Model14

Restriction of marketing of unhealthy foods to children

Foods are either ‘permitted’ or ‘not permitted’ according to nutrient thresholds for different food categories

 

Total fat, saturated fat, total sugars, added sugars, non-sugar sweeteners, salt, energy

 

Sugar sweetened soft drinks = ‘not permitted’

 

Frozen vegetables = ‘permitted’

HSR is an interpretive, front-of-pack nutrition labelling scheme adopted by New Zealand in 2014.16 HSR rates the nutrition content of packaged foods in half-star increments from half a star (least healthy) to 5 stars (most healthy) and is designed to help consumers compare foods within categories. The number of stars is calculated based on the nutritional profile of the food. To calculate the HSR score, a product is placed in one of six HSR food categories; baseline points are calculated based on energy, saturated fat, total sugar and sodium content per 100g; modifying points are calculated based on the amount of fruits, vegetables, nuts and legumes (V points) and in some instances, protein (P points) and fibre (F points). The final HSR score = Baseline points – (V points) – (P points) – (F points). Lower scores indicate a better (healthier) nutrient profile. HSR is a continuous scoring system with scores ranging from approximately -24 to +45 (unpublished analysis of a 2012 database of approximately 17,000 New Zealand packaged products), and a cut point to dichotomise foods as healthy/unhealthy has not yet been widely agreed. However, work commissioned by the New South Wales Ministry of Health on the alignment of HSR with existing Traffic Light schemes and the 2013 Australian Dietary Guidelines reported that “healthy core foods with a HSR of ≥3.5 can be confidently promoted in public settings as healthier choices”.17 This cut point has been proposed for use in New Zealand as a means of identifying packaged foods consistent with District Health Boards’ Healthy Food Policy and suitable for sale in hospitals.

The FBCS was developed by the Ministry of Health in 2007 to support healthy eating environments in New Zealand schools and identify healthy foods suitable for provision in schools.18 The FBCS classifies foods and beverages as ‘everyday’, ‘sometimes’ or ‘occasional’ foods based on the Food and Nutrition Guidelines for Healthy Children and Adolescents. ‘Everyday’ foods are from the four core food groups, whilst ‘sometimes’ foods are mostly processed foods with some added fat and/or salt and/or sugar, and ‘occasional’ foods are high in saturated fat and/or salt and/or added sugar (eg confectionery, deep-fried foods and sugar-sweetened drinks). The FBCS is the basis for the Heart Foundation’s Fuelled4Life programme19 and the TVNZ and Mediaworks ThinkTV children’s food advertising guidelines.20

The WHO Model was specifically designed for the purpose of restricting the marketing of foods to children and was published in 2015.14 It was developed following extensive consultation with European member states, and is based on three nutrient profile models currently in use in Europe for restricting marketing to children. It encompasses 17 food categories including fruit, vegetables and ready-made meals. Certain food categories are not permitted to be marketed to children under any circumstances. These include chocolate and confectionery, cakes and sweet biscuits, juices and energy drinks. Conversely, unprocessed meat and fish, and fresh/frozen fruit and vegetables can be marked without restriction. Maximum nutrient level cut points are applied to determine the eligibility of foods in all other categories to be marketed to children.

A key difference between HSR and the other two systems is that HSR is for packaged foods only whilst the FBCS and the WHO Model also incorporate fresh, mixed and cooked meals.

Database of New Zealand packaged foods

In order to compare nutrient profiling schemes, a common set of products were classified using each scheme and compared. The 2014 New Zealand Nutritrack packaged food database was used for this purpose. Nutritrack food composition data are collected directly from labels of all packaged foods and non-alcoholic beverages available in four Auckland supermarkets during field surveys undertaken between February and May each year. Standardised data collection methods were developed for an international collaborative project to compare and monitor the nutritional composition of packaged foods.21 Supermarkets chosen for data collection represent the biggest retail brands of the main supermarket retailers in New Zealand (Foodstuffs (54% grocery market share) and Progressive Enterprises (38% market share) 22 and stores were selected for their large product ranges. Nutrition information is recorded for all packaged products displaying a Nutrition Information Panel. Alcohol and products that do not carry a Nutrition Information Panel, eg fresh produce, bakery and delicatessen items are excluded.

For each packaged product with a Nutrition Information Panel, the brand name, product name, ingredient list and content of energy, protein, total fat, saturated fat, total carbohydrate, sugars, fibre (where available) and sodium per 100 g or mL are recorded in a searchable web-based database. Nutritional information recorded is for products ‘as sold’ (ie not ‘as prepared’) in order to maximise within-category product comparability (since preparation instructions vary and can have a significant impact on final composition) and different pack sizes of the same product are recorded as separate items. All data are checked and cleaned before analysis. Any data entry errors identified by value range checks and random checks are corrected using source data (product photographs). Each product is assigned to a basic food group (Level 1, 13 groups) and a specific food category (Level 2, 41 categories).21 Level 4, the most finely grained food grouping in the system, has 428 categories. Where fibre content is not listed on a product Nutrition Information Panel (it is not mandatory), we apply the food category average. We also apply a standardised category-specific fruit, vegetable, nut and legume (V Points) value, based on expected content within food category, in order to calculate HSR scores.

Analysis

A total of 13,066 packaged food products across 14 broad food categories were analysed after exclusions were made. Food categories in the Nutritrack database not included in the analysis were: alcoholic beverages, herbs and spices, coffee and tea, sugars and baking ingredients, coatings/breadcrumbs, baby food and supplements, as these were not covered by the three nutrient profiling systems.

The remaining 13,066 packaged foods were classified as ‘restricted’ or ‘not restricted’ as per the WHO model; ‘everyday/sometimes’ or ‘occasional’ as per the FBCS model; and ‘<3.5 stars’ or ‘≥3.5 stars’ as per the HSR model. The FBCS does not apply to certain food groups, including cooking oils, sauces and spreads, jam and marmalade, honey, butter and margarine, pickled vegetables, so these were excluded (N/A) for that model. The proportion and types of packaged foods that met the criteria for all three systems or none of the systems and the types of food products classified as restricted under the WHO model but classified as ‘everyday/sometimes’ (FBCS model) or as having >3.5 stars, were determined.

Results

There was a fairly even distribution of New Zealand packaged foods across the 10 HSR categories from 0.5 to 5 stars, although proportions of packaged foods with 4.5 stars (5%) or 5 stars (5%) were noticeably lower than those in other HSR categories (range 8–14%, mean 10%) (Figure 1).

Figure 1: Proportion of New Zealand packaged foods (n=13,066) within each Health Star Rating category.  

c

The three nutrient profiling systems were broadly similar in their proportional classification of permitted foods overall with approximately one-third (29–39%) of packaged foods meeting the eligibility criteria for each system: 29% under the WHO model, 36% under the HSR system (>3.5 stars), and 39% under the FBCS system (everyday or sometimes foods) (Table 2).

Table 2: Classification of New Zealand packaged foods (n=13,066) by each nutrient profiling system.

 Food category and key sub-categories

HSR

WHO Model

FBCS

<3.5 stars

≥3.5 stars

R

NR

O

E/S

N/A

All foods

13,066

63.7

36.3

70.9

29.1

41.4

39.3

19.2

Bread and bakery products

1,603

73.1

26.9

74.3

25.7

63.6

36.4

0.0

       Biscuits

736

88.5

11.5

99.7

0.3

89.1

10.9

0.0

       Bread 

484

30.6

69.4

15.3

84.7

7.0

93.0

0.0

       Cakes, muffins and pastries

383

97.4

2.6

100.0

0.0

85.9

14.1

0.0

Cereal and cereal products

1,264

38.8

61.2

50.4

49.6

34.7

65.3

0.0

        Breakfast cereals

358

22.9

77.1

66.5

33.5

24.6

75.4

0.0

       Cereal bars

221

80.5

19.5

100.0

0.0

92.8

7.2

0.0

Confectionery

804

89.2

10.8

100.0

0.0

94.7

5.3

0.0

Convenience foods

726

44.2

55.8

66.3

33.7

16.7

83.3

0.0

     Pre-prepared salads and sandwiches

51

35.3

64.7

92.2

7.8

11.8

88.2

0.0

     Pizza

54

74.1

25.9

100.0

0.0

63.0

37.0

0.0

     Ready meals

274

31.0

69.0

97.4

2.6

19.3

80.7

0.0

     Soups

330

49.7

50.3

29.1

70.9

3.6

96.4

0.0

Dairy

1,743

67.4

32.6

85.9

14.1

39.3

60.7

0.0

     Cheese

600

78.0

22.0

86.7

13.3

0.0

100.0

0.0

     Cream

50

98.0

2.0

98.0

2.0

98.0

2.0

0.0

     Desserts

172

78.5

21.5

100.0

0.0

65.1

34.9

0.0

     Ice cream and edible ices

336

96.7

3.3

100.0

0.0

82.4

17.6

0.0

     Milk

293

21.5

78.5

70.3

29.7

59.4

40.6

0.0

     Yoghurt and yoghurt drinks

292

46.2

53.8

73.6

26.4

25.0

75.0

0.0

Edible oils and oil emulsions

303

46.9

53.1

20.1

79.9

 0.0

0.0

100.0

Eggs

76

0.0

100.0

0.0

100.0

0.0

100.0

0.0

Fish and seafood products

484

18.8

81.2

10.3

89.7

12.0

88.0

0.0

Fruit, vegetables and nut products

1,539

35.7

64.3

62.8

37.2

10.1

68.5

21.4

     Fresh packaged fruit and vegetables

51

0.0

100.0

0.0

100.0

0.0

100.0

0.0

     Dried fruit

179

56.4

43.6

98.9

1.1

19.0

81.0

0.0

     Frozen fruit

40

0.0

100.0

0.0

100.0

0.0

100.0

0.0

    Fruit bars

35

42.9

57.1

100.0

0.0

100.0

0.0

0.0

    Nuts and seeds

198

41.9

58.1

37.4

62.6

40.4

59.6

0.0

    Jam and marmalades

151

96.0

4.0

100.0

0.0

0.0 

0.0

100.0

     Canned vegetables

263

23.2

76.8

44.1

55.9

0.0

100.0

0.0

     Frozen vegetables

120

0.0

100.0

0.8

99.2

0.0

100.0

0.0

     Frozen potato products

81

4.9

95.1

79.0

21.0

7.4

92.6

0.0

Meat and meat products and alternatives

1,069

69.9

30.1

40.3

59.7

69.6

30.4

0.0

     Processed meat

1,005

72.5

27.5

37.9

62.1

73.9

26.1

0.0

Non-alcoholic beverages

1,116

74.6

25.4

89.1

10.9

91.1

8.9

0.0

     Beverage mixes

69

100.0

0.0

100.0

0.0

100.0

0.0

0.0

     Sugar-sweetened cordials

71

98.6

1.4

95.8

4.2*

100.0

0.0

0.0

     Sugar-sweetened energy drinks

69

100.0

0.0

100.0

0.0

100.0

0.0

0.0

     Fruit and vegetable juices

361

38.2

61.8

100.0

0.0

88.4

11.6

0.0

     Sugar-sweetened soft drinks

265

100.0

0.0

98.1

1.9**

100.0

0.0

0.0

     Sugar-free soft drinks

54

100.0

0.0

96.3

3.7

90.7

9.3

0.0

     Waters, including flavoured

158

63.9

36.1

32.9

67.1

67.1

32.9

0.0

Sauces and spreads

1,765

90.3

9.7

90.0

10.0

 0.0

0.0

100.0

Snack foods

373

89.3

10.7

98.1

1.9

97.3

2.7

0.0

Sugars, honey and related products

162

97.5

2.5

100.0

0.0

14.8

15.4

69.8

R: Restricted; NR: Not restricted
O: Occasional foods; E/S: Everyday or Sometimes foods; N/A: Food groups not included in the FBCS system
*3 blackcurrant fruit juice syrup products
**5 carbonated juice drinks 

In general, the WHO Model applies stricter eligibility criteria and fewer foods would be permitted to be marketed to children under this system. However, there were important differences between the three systems in their classification of specific food categories. Notably, the WHO Model would only permit marketing of 33.5% of New Zealand breakfast cereals included in this analysis, whereas the HSR and FBCS would permit marketing of 77% and 75% of breakfast cereals respectively. The HSR system would also permit marketing of substantially more fruit bars and fruit/vegetable juices (57% and 62% respectively) compared with the WHO Model (0% for both) and the FBCS (0% and 12%). In contrast, the FBCS would permit marketing of substantially more convenience foods and dairy products (83% and 61% respectively) compared with the WHO Model (34% and 14%) and HSR (56% and 33%) (Table 2).

Whilst 87–88% of packaged foods restricted under the HSR system (<3.5 stars) and the FBCS system (occasional foods) would also be restricted under the WHO Model, 42% of those permitted under the HSR system and 47% permitted under the FBCS system would be restricted under the WHO Model (Table 3).

Table 3: Classification of foods under the HSR and FBCS systems compared with WHO Model.

 

N

% restricted (WHO)

% not restricted (WHO)

HSR nutrient profiling model

   Foods with HSR <3.5 stars

8,323

87.2

12.8

   Foods with HSR ≥3.5 stars

4,743

42.3

57.7

MOH food and beverage classification system

   Occasional foods

5,415

87.9

12.1

   Everyday/sometimes foods

5,140

47.3

52.7 

The most common packaged foods restricted under the WHO Model but receiving 3.5 stars or more were fruit and vegetable products (22%, of which 27% were fruit in juice or syrup, 17% dried fruit and 14% frozen potato products), dairy products (19%, of which 25% were cheese and 23% yoghurt and yoghurt drinks), convenience foods (14%, of which 66% were ready meals and 18% soups), cereals and cereal products (14%, of which 61% were breakfast cereals and 16% cereal bars) and non-alcoholic beverages (11%, of which 99% were fruit or vegetable juices) (Figure 2).

Figure 2: Types of products restricted by the WHO Model but receiving a HSR rating of >3.5 stars. 

c 

The most common types of products restricted under the WHO Model but classified as ‘everyday/sometimes’ by the FBCS system were dairy (34%, of which 62% were cheese and 17% yoghurt and yoghurt drinks), fruit and vegetable products (21%, of which 28% were dried fruit, 26% fruit in juice or syrup and 12% frozen potato products), convenience foods (15%, of which 59% were ready meals) and cereals and cereal products (11%, of which 66% were breakfast cereals) (Figure 3).

Figure 3: Types of products restricted by the WHO Model but classified as everyday or sometimes foods by the FBCS. 

c 

In total 17% of all New Zealand packaged foods met the criteria for all three nutrient profiling systems and would be eligible to be marketed to children under any selected system. Table 4 lists the top 10 food categories, representing 79% of all foods meeting the criteria for all three systems.

Table 4: Products permitted under all three systems.

Type of food

N

%

Plain pasta, couscous, quinoa, noodles and rice

328

14.7

Mixed grain, white, wholemeal, flat and other bread

317

14.2

Canned fish and seafood

231

10.3

Fresh packaged and frozen fruit and vegetables

210

9.4

Canned and dried vegetables

176

7.9

Frozen and chilled fish and seafood

111

5.0

Unsalted nuts

98

4.4

Dairy milk, natural and fruit-based yoghurt

91

4.1

Canned and chilled soup

86

3.9

Frozen, canned, sliced and meat

107

4.8 

In total 32% of packaged foods did not meet the criteria for all three systems. Table 5 lists the top 10 categories, representing 66% of the foods that did not meet the criteria for any of the three nutrient profiling systems.

Table 5: Products not permitted under any of the three systems.

Type of food

N

%

Sweet filled and unfilled, plain dry and savoury biscuits

586

14.1

Chocolate-based confectionery

424

10.2

Sugar-sweetened soft drinks, energy drinks and cordials

418

10.1

Ice cream and edible ices

270

6.5

Sugar-based chocolate and sweets

255

6.1

Potato crisps, pretzels, popcorn, corn chips

211

5.1

Cereal- and nut-based bars, and fruit bars

176

4.2

Cakes

146

3.5

Fruit juice

134

3.2

Pastries

131

3.2 

Discussion

Under the three nutrient profiling systems assessed, approximately one-third (29-39%) of New Zealand packaged foods would be permitted to be marketed to children. The WHO Model would permit marketing of 29% products; the HSR system (using a cut point of 3.5 stars) would permit 36%; and the FBCS system (everyday or sometimes foods only) would permit 39%. Food category differences between three systems were notable however; in particular HSR and FBCS systems would permit marketing of substantially more high-sugar breakfast cereals than the WHO model. HSR would also permit marketing of fruit bars and fruit juices, products largely not permitted by the two other systems. All three systems classified a number of food categories as inappropriate for marketing to children, including biscuits, confectionery, sugar-sweetened drinks and ice cream.

It is to be expected that the three nutrient profiling systems perform differently in some key food categories when they are underpinned by different nutritional criteria. All three systems consider nutrients or components to limit but there are differences in the number and types considered. The WHO Model considers total fat, saturated fat, total sugars, added sugars, non-sugar sweeteners, salt and energy; HSR considers energy, saturated fat, total sugars and sodium; and FBCS considers added fat, added salt and added sugar. The HSR system also takes into account nutrients or components to promote (protein, fibre, and fruit, vegetable, nut and legume content) and these positive constituents can offset the negative components in the total score. The major food category differences observed between the systems (breakfast cereals, fruit bars, fruit/vegetable juices and dried fruit) appear to be due mainly to the different weighting that each system gives to sugar with HSR in particular and FBCS to a lesser extent, notably more lenient in classifying more high sugar products as eligible/permitted. There were also some notable differences in the convenience foods and dairy categories with FBCS in particular and HSR to a lesser extent, classifying more products as eligible/permitted compared with the WHO model. This may reflect the FBCS greater emphasis on core food groups than nutritional composition, and the HSR and FBS classifying substantially more desserts, ice creams and yoghurts as eligible/permitted.

Our investigation has several strengths. It is the first to compare two well-known and accepted New Zealand nutrient profiling systems, HSR and FBCS, with an international system, the WHO Europe model that was developed for explicit purpose of restricting marketing to children. More than 13,000 packaged foods available for sale in major New Zealand supermarkets in 2014 were classified using each scheme and compared. Our study therefore provides a comprehensive assessment of the potential of three nutrient profiling systems to protect New Zealand children from exposure to marketing of unhealthy foods and indicates that the best system for this purpose is the comprehensive WHO Europe model.

Some limitations should be considered. HSR and FBCS were not designed to limit marketing of unhealthy foods to children and are not ideally suited for this purpose. For example, HSR is a front-of-pack nutrition labelling system for packaged foods and has no accepted threshold to dichotomize foods as healthy or unhealthy although analysis suggests 3.5 stars is an appropriate cut point17 and this threshold is being used to identify healthier packaged food options in the DHB National Healthy Food and Drink Policy. FBCS includes a broader range of food categories but was designed for the school setting and classification of foods as “sometimes” foods depends on portion size in many cases and thus can be ambiguous.3 Nevertheless both systems have been proposed as potential options for limiting the marketing of unhealthy foods to New Zealand children, in the ASA Consultation document itself and in submissions made by a number of bodies. Our analysis is therefore of direct relevance to current consideration of New Zealand marketing standards for children. Further, our database only included packaged foods so we were unable to compare the three nutrient profiling systems for fresh foods, fast foods and mixed dishes. Finally, our analysis could not take into account the frequency with which products in the Nutritrack database are actually marketed to New Zealand children because such data were not available, and some products included in the analysis might never be marketed to children. However, previous research has shown that the most common categories of food products promoted to children internationally are pre-sugared breakfast cereals, soft drinks, savoury snacks, confectionery and fast foods.3 As such, implementation of any of the three systems examined should significantly limit the marketing of unhealthy foods to New Zealand children. All three prohibit marketing of soft drinks and confectionery, for example. The WHO system would also impose limits on types of breakfast cereals, savoury snacks and fast foods that could be marketed to children.

A limited number of other studies have compared nutrient profiling systems for restricting the marketing of foods and drinks to children. Brinsden and Lobstein compared two industry-led nutrient profiling schemes with three government-led schemes and found that government-led schemes were more restrictive than industry-led schemes, primarily due to more stringent sugar criteria.23 The two industry-led schemes examined would permit 49% and 41% of products analysed to be advertised, compared with 37% under the UK Ofcom regulations, 14% under the US Interagency Working Group Proposals and 7% under the Danish Forum co-regulatory code.23

In 2013, Rayner et al provided an overview of some nutrient profiling models currently used or designed for regulation of the advertising of foods to children.24 The 10 models summarised encompassed both industry pledges and government-led schemes, and emanated from a range of countries including Brazil, Denmark, Korea and the US. The authors highlight that the proliferation of nutrient models means that there is less of a need to develop models from scratch and that for the purposes of regulating marketing of foods to children it may be possible to adapt a model developed for a completely different application such as food labelling.24

Since publication in 2015, the WHO Model has stimulated debate and policy development in a number of European countries. In some countries exploring regulations (eg new broadcast advertising restrictions), the WHO Model has been used in national monitoring exercises to compare against existing industry voluntary pledges (eg Malta). Other countries, such as Turkey and Slovenia, have incorporated the WHO Model into national regulatory advertising codes with only minor adaptation. Most recently, Portugal in its new amendments to marketing legislation, made explicit reference to the WHO Model nutritional criteria.

We selected the HSR and FBCS nutrient profiling systems for comparison with the WHO Model because they are currently in use in New Zealand by various sectors of the food industry and have been suggested as potentially appropriate to classify foods as suitable/unsuitable for marketing to children. However, there are other nutrient profiling systems that also bear consideration including the Fuelled4Life school food classification system, which is based on FBCS but has adopted additional criteria to distinguish occasional, sometimes and everyday foods.19 A disadvantage of the Fuelled4Life system in terms of its suitability for adaptation for marketing however is that it relies on serving size restrictions to distinguish between occasional, everyday and sometimes foods in some categories.

Another nutrient profiling system currently in use in the region that could be potentially adapted to limit children’s exposure to unhealthy food marketing is the Food Standards Australia New Zealand Nutrient Profiling Scoring Criterion (NPSC) system used to determine the eligibility of foods to carry health claims.25 The NPSC system was based on the UK Ofcom model used to differentiate foods on the basis of their nutritional composition in the context of television advertising of foods to children. It also formed the basis for the HSR system but differs from HSR in using cut points to dichotomise foods as eligible or not eligible to carry health claims. A previous analysis of New Zealand packaged foods reported that 41% were eligible to carry health claims based on their NPSC categorization.26 This suggests that the NPSC would be even more lenient than HSR or FBCS and thus unlikely to be an appropriate classification system in its current form for limiting marketing of unhealthy foods to children.

Our findings have important implications for the ASA review of its Children’s Codes and the New Zealand Childhood Obesity Plan. Existing nutrient profiling systems need to be utilised or adapted to limit New Zealand children’s exposure to marketing of unhealthy foods. The three systems we evaluated classified just 29% to 39% of New Zealand packaged foods as eligible for marketing to children. Use of any of the three systems would provide an objective, evidence-based classification system to identify foods suitable for marketing to children. Our analysis demonstrates clearly however that the WHO Model is the most robust system because it restricts marketing of unhealthy foods more effectively than the other two systems evaluated. The HSR and FBCS systems would permit marketing of a number of food products of concern, particularly high-sugar breakfast cereals, fruit juices and ready meals.

Based on the findings of our analysis, we recommend that the WHO Regional Office for Europe Nutrient Profiling Model be used as the nutrient profiling system to underpin the new ASA Children’s Code for Advertising Food. Given the recognised weak nutritional standards employed by industry for defining healthy foods and because many child-oriented food marketers do not participate in self-regulation,27 the new Children’s Code for Advertising Food should be subject to evaluation by an independent body. If the revised voluntary code still proves ineffective in reducing New Zealand children’s exposure to the marketing of unhealthy foods and drinks, additional policy and regulatory actions will be necessary.

Summary

Marketing of unhealthy foods and drinks to children is an important, changeable risk-factor for child obesity and development of diet-related diseases. An accepted food classification system is necessary to classify foods as suitable/unsuitable for marketing to children and to implement restrictions. We compared three accepted systems to identify the best one to protect New Zealand children from exposure to the marketing of unhealthy foods and drinks. Under any of the three systems, only about one-third of New Zealand packaged foods would be permitted to be marketed to children. The World Health Organization Europe Model restricts marketing of unhealthy foods more effectively than the other two systems, and should underpin the Advertising Standards Authority revised Children’s Code for Advertising Food.

Abstract

Aim

Promotion of unhealthy foods and drinks is a significant, modifiable risk factor for child obesity and diet-related non-communicable diseases. We compared three accepted nutrient profiling systems: the Health Star Rating (HSR), the Ministry of Health Food and Beverage Classification System (FBCS) and the World Health Organization (WHO) Regional Office for Europe Nutrient Profiling Model, to identify the best system to protect New Zealand children from exposure to the marketing of unhealthy foods and beverages.

Method

13,066 packaged foods from the 2014 New Zealand Nutritrack database were classified as ‘restricted’ or ‘not restricted’ as per the WHO model; ‘everyday/sometimes’ or ‘occasional’ as per the FBCS model; and ‘<3.5 stars’ or ‘≥3.5 stars’ as per the HSR model. The proportion and types of packaged foods that met the criteria for all three systems or none of the systems, and the types of food products classified as ‘restricted’ under the WHO model but classified as ‘everyday/sometimes’ (FBCS model) or as having >3.5 stars, were determined.

Results

Under any of the three nutrient profiling systems, approximately one-third (29–39%) of New Zealand packaged foods would be permitted to be marketed to children. The WHO Model would permit marketing of 29% of products; the HSR system would permit 36%; and the FBCS system would permit 39%. The WHO Model restricts marketing of unhealthy foods more effectively than the other two systems. The HSR and FBCS systems would permit marketing of a number of food products of concern, particularly high-sugar breakfast cereals, fruit juices and ready meals.

Conclusion

Conclusion: The WHO Regional Office for Europe Nutrient Profiling Model should underpin the Advertising Standards Authority revised Children’s Code for Advertising Food. The effectiveness of the new Code in reducing New Zealand children’s exposure to marketing of unhealthy foods and drinks should be subject to evaluation by an independent body.

Author Information

Cliona Ni Mhurchu, Professor & Programme Leader Nutrition, National Institute for Health Innovation, University of Auckland, Auckland; Tara Mackenzie, MHSc Student, School of Population Health, University of Auckland, Auckland; Stefanie Vandevijvere, Senior Research Fellow, Epidemiology & Biostatistics, University of Auckland, Auckland.

Correspondence

Professor Cliona Ni Mhurchu, National Institute for Health Innovation, University of Auckland, Private Bag 92019, Auckland Mail Centre, Auckland 1142, New Zealand.

Correspondence Email

c.nimhurchu@auckland.ac.nz

Competing Interests

Cliona Ni Mhurchu is a member of the New Zealand Health Star Rating Advisory Group. The New Zealand Health Star Rating Advisory Group had no role in in study design, data collection and analysis, decision to publish or preparation of the manuscript.

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