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The EU Pledge, a voluntary initiative by Europe’s leading food and beverage companies to change the way they advertise
to children, has expanded the original focus on advertising on television to include all company, brand and third-party
websites, and – from December 2016 – product placement, interactive games, mobile and SMS marketing (225).
To date, there has been limited independent monitoring of these industry-led approaches to restricting digital food
marketing to children. A new initiative from the governments of the Nordic countries to develop a joint monitoring protocol
that covers digital marketing may go some way to addressing this challenge and will make an important contribution to our
knowledge on this issue (238). As noted above, self-regulatory schemes generally report high compliance with their own
agreed standards – yet these have a narrow scope and weak criteria. It is perhaps not surprising that the studies cited above
indicate that these approaches have not been particularly effective in limiting digital marketing of HFSS foods to children.
Defining foods high in saturated fat, salt and/or free sugars across Europe and beyond: the WHO
Regional Office for Europe nutrient profile model
The foods most frequently marketed to children are consistently shown to be “non-core” (or “eat less”) foods, such as
sugary breakfast cereals, sugar-sweetened beverages, confectionery and savoury snack foods (239). Such HFSS foods
are clear targets for restrictions; however, without explicitly defined nutritional criteria or thresholds, implementing
restrictions becomes practicably impossible, a challenge that has been one of the biggest obstacles to policy
development (240).
One tool for addressing this challenge is a nutrient profile model. Nutrient profiling is “the science of classifying or
ranking foods according to their nutritional composition for reasons related to preventing disease and promoting
health” (241). Of the 53 countries in the European Region, prior to 2015, only Denmark, Ireland, Norway, and the
United Kingdom had developed or endorsed nutrient profile models for restricting HFSS food marketing to children
(220, 242–244). A number of food companies and the EU Pledge (245) had also devised nutrient profile models.
Recent political mandates in Europe, notably the Vienna Declaration on Nutrition and Noncommunicable Diseases (33)
and the European food and nutrition action plan 2015–2020 (34) reinforced a commitment to adopt strong measures
to reduce all forms of marketing to children, raising calls for nutrient profile tools. In response, the WHO Regional
Office for Europe prepared a nutrient profile model (141) to define those foods for which marketing to children is
not permitted. The model specifies five food product categories for which marketing to children is never permitted:
chocolate and sugar confectionery; cakes, sweets and biscuits; energy drinks; fruit juices; and edible ices. These are
generally not recommended in national dietary guidelines, and other nutrient profile models restrict similar categories
of product (including EU Pledge nutrition criteria). For other product categories, the nutrient profile model establishes
thresholds per 100 g for fats (total and saturated), sugars (total and added), salt and energy (kcal). The content of
these nutrients in products must fall below these thresholds if the products are to be permitted to be marketed.
Thus, there is now clear guidance on defining foods and non-alcoholic beverages that should not be marketed to
children. Where statutory restrictions are implemented, they can clearly indicate that foods assessed as HFSS in
accordance with a nutrient profile model may not be marketed to children (as in the current Irish and United Kingdom
broadcast restrictions). The same would apply for digital HFSS marketing restrictions. The onus would be on the actor
placing or disseminating the advertisement, promotion or sponsorship on the Internet to include nutritional criteria
as part of overall compliance with marketing restrictions and on government authorities to monitor and enforce
compliance.
Since its publication, the WHO Regional Office for Europe nutrient profile model has received substantial attention
and is being applied in countries in the Region and incorporated into national policy. Three other WHO regional offices
have pilot-tested the model and made only slight modifications. It therefore now has considerable potential for global
application.
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