June 15, 2023
The Right Hon. Justin Trudeau, P.C., M.P Office of the Prime Minister of Canada House of Commons
Ottawa, Ontario K1A 0A6
By email: justin.trudeau@parl.gc.ca and pm@pm.gc.ca
The Hon. Jean-Yves Duclos, P.C., M.P. Minister of Health
House of Commons Ottawa, Ontario K1A 0A6
By email: jean-yves.duclos@parl.gc.ca and hcminister.ministresc@canada.ca
Bureau of Policy, Intergovernmental and International Affairs, Food Directorate Health Products and Food Branch, Health Canada
251 Sir Frederick Banting Postal Locator 2204C Ottawa, ON K1A 0K9
By email: bpiia-bpaii@hc-sc.gc.ca
Subject: Health Canada Consultation on restricting food advertising primarily directed at children on television and digital media.
Dear Prime Minister Trudeau and Minister Duclos:
We thank you for your continued commitments to supporting healthy eating initiatives including the recent announcements on a policy update for restricting food advertising to children and proposed regulatory changes.
Ontario Dietitians in Public Health (ODPH) is the independent and official voice of Registered Dietitians (RDs) working in Ontario’s public health system. We are writing to offer additional considerations for the policy and future regulatory frameworks.
It is the position of ODPH to support a ban on commercial advertising of all food and beverages to children and youth under the age of 18 (M2K Backgrounder 2019).
Additionally, it is our position that focusing this policy on obesity prevention exacerbates weight bias which contributes to discrimination, oppression and social injustices (Addressing Weight Bias). Instead the focus should be on creating a supportive food environment for children and youth.
Health Canada should consider:
- Restricting food advertising of all foods not just foods that are high in sodium, sugars and saturated fats
- Broadening the definition of children to include all children under the age of 18.
- Expanding restrictions to include other forms of advertising beyond television and digital media
- Reframing this policy away from obesity prevention which exacerbates weight bias and subsequent consequences.
- We strongly encourage Health Canada to consider restricting advertising of all foods to have a stronger impact. All forms of marketing to children and youth is an ethical concern because it intentionally takes advantage of the inability of children and youth to understand the intent of the advertising and make an informed decision (ODPH, 2019). Restricting advertising to certain categories of food will moralize food choices and reinforce harmful dietary attitudes and behaviours that are major risk factors for the development of eating disorders and growth issues (Haines et al., 2006; Hilbert et al., 2014; Larkin et al., 2005; Stice et al., 2017). Creating criteria for what can and cannot be advertised to children does not support the development of a positive relationship to food among children and youth, and opens the door for loopholes and further manipulation of food products and the criteria.
- ODPH also recommends that Health Canada broaden the definition of children to encompass individuals under the age of 18. Children are targeted because they are unable to critically assess advertisement messages, they can influence family spending, and they provide an opportunity to establish brand loyalty at a young age (ODPH, 2019). However, it is crucial to acknowledge that adolescents are equally susceptible to the influence of food marketing (Quttenia, De Backer & Smits, 2019). Due to their ongoing brain development and the vulnerable nature of adolescence, they tend to make impulsive decisions and may rely on brands and materialism to enhance their self-esteem (Harris et al., 2021; Quttenia, De Backer, & Smits, 2019; Truman & Elliot, 2019). We know that industry uses this additional vulnerability intentionally. Furthermore, industry is likely to increase intensity of advertising to older children in response to restrictions on food marketing to younger children (Powell et al, 2013; The Regional Office for Europe, 2018). Moreover, it is worth noting that marketing efforts targeting older children, youth, and/or adults often reach younger children. Consequently, a narrow age definition may not adequately safeguard the interests of younger children (Hawkes, 2004), warranting an extension of the age restriction to all under the age of 18.
- Although television remains the main source of advertising targeting children, food and beverage manufacturers use multiple channels and locations to strategically target children and influence their purchasing requests. We encourage Health Canada to consider broadening the restrictions to include other forms of advertising beyond television and digital media (e.g., product packaging, print, radio, signage, promotional items) and settings (e.g., child care, schools, cinemas, recreation centres) to align with past versions of Health Canada’s policy proposal that were more comprehensive.
The policy should also include brand advertisements (even if no identifiable food is shown or referenced by name). Advertising works to raise awareness of brands and instilling brand loyalty is a commercial interest (Elliot, 2012). Children are explicitly targeted with using a brand logo or mascot without reference to a specific food because this tactic can be influential on children’s purchase requests (Wilking 2011). Restaurants frequently use brand advertisements with missing nutritional information (Potvin Kent et al., 2023) and are likely to continue to take advantage of this policy loophole. - Finally, it is our position that focusing this policy on obesity prevention exacerbates weight bias which contributes to discrimination, oppression and social injustices (ODPH, 2018). Weight bias, stigma and discrimination are independently linked to poorer mental and physical health including for children (Public Health Agency of Canada, 2019). Additionally, it ignores the fact that all children and youth regardless of body size can benefit from improved nutritional intake (Alberga et al., 2018).
As part of ongoing monitoring and evaluation on the impact of the policy, we suggest Health Canada consider using the Healthy Eating Food Index (Brassard et al., 2022) to measure changes in dietary patterns of children (e.g. decreased consumption of salt, sugar and saturated fat and/or improved overall diet quality), which is the overall goal of the policy. The focus on obesity and obesity related metrics (i.e. BMI) should be removed from all aspects of the policy and/or legislation (Bill C-252). Removing the focus on obesity prevention would ensure a healthy public policy and the creation of supportive environments for children.
Children need to be protected from advertising and harmful industry tactics. Moving forward on this federal commitment to begin restricting food advertising will help protect children from manipulative advertising strategies and support families and caregivers. We encourage Health Canada to continue their efforts to expand beyond television and digital media and to include children and youth under 18 years of age.
Thank you for the opportunity to provide our feedback on this very important public health issue and look forward to participating in the next phase of consultation.
Sincerely,
Laura Abbasi, MHSc RD
Co-Chair ODPH Executive
Elizabeth Smith, MPH RD
Past Chair ODPH Executive
CC:
Stephen Lucas, Deputy Minister, Health Canada, stephen.lucas@hc-sc.gc.ca
Pam Aung Thin, Associate Assistant Deputy Minister, Health Canada, pamela.aung-thin@hc-sc.gc.ca Dani Saad, Senior Policy Advisor, Prime Minister’s Office, dani.saad@pmo-cpm.gc.ca
John Broadhead, Dir of Policy, Prime Minister’s Office, john.brodhead@pmo-cpm.gc.ca
Jared Valdes, Sr. Parliamentary Affairs Advisor, Ministry of Health, Jared.Valdes@hc-sc.gc.ca Nathanielle Morin, Policy Advisor, Ministry of Health, nathanielle.morin@hc-sc.gc.ca
Celia Lourenco, Associate Assistant Deputy Minister, Health Products & Food Branch, Health Canada, celia.lourenco@hc-sc.gc.ca
References:
Alberga, A.S.,, McLaren, L., Russell-Mayhew, S., & von Ranson, K.M. (2018). Canadian senate report on obesity: Focusing on individual behaviours versus social determinants of health may promote weight stigma. Journal of Obesity, 2018, 1-7.https://doi.org/10.1155/2018/8645694
Brassard, D., Elvidge Munene, L.A., St-Pierre, S., Guenther, P.M., Kirkpatrick, S.I., Slater, J., Lemieux, S., Jessri, M., Haines, J., Prowse, R., Olstad, D.L., Garriguet, D., Vena, J., Vatanpatast, H., L’Abbe, M.R., & Lamarche, B. (2022). Development of the Healthy Eating Food Index (HEFI)-2019 measuring adherence to Canada’s Food Guide 2019 recommendations on healthy food choices. Appl Physiol Nutr Metab,47, 595-610. https://doi.org/10.1139/apnm-2021-0415
Elliot C., Marketing Foods to Children: Are We Asking the Right Questions? (2012. Childhood Obesity 2012 8:3, 191-194. https://doi.org/10.1089/chi.2012.0013
Haines, J., & Neumark-Sztainer, D. (2006). Prevention of obesity and eating disorders: a consideration of shared risk factors. Health Education Research, 21(6), 770-782. https://doi.org/10.1093/her/cyl094
Hawkes, C. (2004). Marketing Food to Children: the Global Regulatory Environment. World Health Organization. http://nepc.colorado.edu/files/CERU-0405-215-OWI.pdf
Government of Canada. (2023). Policy update on restricting food advertising primarily directed at children:
Overview. Government of Canada. Retrieved June 8. 2023 from
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Harris, J.L., Yokum, S., & Fleming-Milici, F. (2021). Hooked on Junk: Emerging Evidence on How Food Marketing Affects Adolescents’ Diets and Long-Term Health. Current Addiction Reports, 8, 19-27. https://doi.org/10.1007/s40429-020-00346-4
Hilbert, A., Pike, K., Goldschmidt, A., Wilfley, D., Fairburn, C., Dohm, F-A, Walsh, T.A., & Weissman, R.S. (2014). Risk factors across the eating disorders. Psychiatry Res, 220(1), 500-506. https://doi.org/10.1016/j.psychres.2014.05.054
Larkin, J., & Rice, C. (2005). Beyond “healthy eating” and “healthy weights”: Harassment and the health curriculum in middle schools. Body Image, 2(3), 219-232. https://doi.org/10.1016/j.bodyim.2005.07.001
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Powell, L., Harris J., Fox, T. (2013). Food Marketing Expenditures Aimed at Youth: Putting the Numbers in Context. American Journal of Preventive Medicine, 45(4), 453-461. https://doi.org/10.1016/j.amepre.2013.06.003
Public Health Agency of Canada (2019). Addressing stigma: Towards a more inclusive health system. The Chief Public Health Officer’s Report on the State of Public Health in Canada (Pub: 190383). Health Canada.https://www.canada.ca/content/dam/phac-aspc/documents/corporate/publications/chief-public-he alth-officer-reports-state-public-health-canada/addressing-stigma-what-we-heard/stigma-eng.pdf
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Stice, E., Gau, J,M,, Rohde, P., & Shaw, H. (2017). Risk Factors that Predict Future Onset of Each DSM-5 Eating Disorder: Predictive Specificity in High-Risk Adolescent Females. J Abnorm Psychol, 126(1),
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The Regional Office for Europe. (2018). Evaluating implementation of the WHO Set of Recommendations on the marketing of foods and non-alcoholic beverages to children: Progress, challenges and guidance for next steps in the WHO European Region. World Health Organization. https://apps.who.int/iris/handle/10665/345153
