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Jan Gooding: To ban or not to ban?

Jan Gooding: To ban or not to ban?

Reflecting on her experience marketing a popular tobacco brand, Jan Gooding wonders whether adland’s reaction to the junk food ad ban will see it fall on the wrong side of history again

The howl of anguish from the advertising industry as the UK government accelerated their plans to ban ‘junk food’ advertising on TV before 9pm, and outlawing them completely online, has been painful to witness. In a year that has been full of shocks and setbacks for a sector already reeling from a collapse in advertising investment, just as audience numbers soared, the timing seemed particularly cruel.

It seemed to come out of the blue, pushed by the Department of Health, and hard on the heels of the launch of the Treasury’s almost contradictory, ‘Eat out to help out’ scheme. Both equally blunt policy interventions, and each building on two strong marketing truths – that advertising and price reductions increase demand for goods and services.

We have been here before with tobacco

When I started work at Ted Bates in the early 80s I worked on the Benson and Hedges international account, creating campaigns designed to persuade people in developing markets in Africa and South America to buy more cigarettes.

I recall being astonished to learn that in countries like Kenya, cigarettes were so expensive they were bought as a single item, and not in packets. We were tasked with persuading people to buy three cigarettes a day instead of two.

This was at a time when the devastating negative health impacts of cigarette smoking was well established. Arguments raged in USA and Europe as to whether tobacco ads should be banned. I remember the forceful arguments made at the time that such a move would not be effective.

The industry argued strongly against a ban

Firstly, it was asserted that advertising drove brand choice, not cigarette consumption per se. The argument was that smoking was stimulated by peer pressure and social culture, not advertising, and therefore the role of advertising was simply to make one brand attractive over another.

Secondly, the point was made that advertising bans had been tried in other countries and been ineffective. The government was encouraged to spend money educating children about the dangers and encouraging adults to quit the habit.

And for some, the position was entirely simple. If it was legal to sell cigarettes it should be legal to advertise them. For them, smoking was a matter of adult choice and the government shouldn’t interfere.

Sound familiar?

Regulation led to even more effective advertising

Over time, cigarette advertising was regulated so heavily it was almost impossible to show any images of people or write motivating copy at all. The constraints led to some of the most admired and creative advertising executions of its generation. Such as the iconic Benson and Hedges ‘Silk Cut’ posters of cut purple fabric on a white background, mirroring the brand’s distinctive packaging. Images so arresting they skilfully drew the viewer’s eye away from the increasingly large and disturbing mandatory health warnings.

It seemed to me that the more restrictions cigarette advertising was subjected to, the more bold, iconic and desirable the ads became, and the more difficult it was to make the case that they were not effective.

Societal change needs more than an advertising ban

Over time the whole marketing mix was disrupted. In addition to advertising and packaging constraints, high taxes drove up prices, and ‘anti-smoking’ campaigns encouraged people to kick the habit.

Arguably the most profound and positive intervention was the restrictions driven because of the proven harmful effects of passive smoking. The banishment of smoking from meeting rooms and workplaces, and then pubs and restaurants, dramatically reduced the opportunities to smoke.

It is still legal to buy cigarettes, but government policy has been to make it as expensive and inconvenient as they can. Certainly, banning the advertising and regulating the packaging on their own would not have been sufficient to change attitudes and behaviour. But combined with high taxes, education and other policy interventions, the lack of brand advertising reinforcing brand choice and stimulating sector demand must also have played its part.

The problem is that advertising works

If we believe advertising works, we can’t argue that its absence has no impact. It just isn’t logical. And there is something about the industry denying that advertising is part of the problem that makes me uneasy.

Any CMO who announced they were going to stop advertising would be met with a deluge of IPA Effectiveness case studies warning of the harmful short term impact on sales and long term impact on brand reputation from their agencies.

Junk food contributes to early death

I listened to an online debate between Professor Graham MacGregor, chair of Action on Sugar and Action on Salt, and representatives from AA and IAB. He made the point that ‘we had to face the fact that unhealthy food is now the biggest cause of death in the world and the UK and a major factor in causing obesity.’

Once we are talking about foods that cause the death of millions, any defence of advertising, which is designed to create demand, is just going to come across as wilfully blind.

The advertising sector is indignant nevertheless

The point has been made that as a result of the industry adjusting its own code of advertising practice, children’s exposure to high fat, salt and sugar ads on TV has declined by 70% since 2008, and yet obesity trends among children has continued to rise over this time. So clearly there is much more driving obesity than the demand created by advertising junk food.

Tessa Gooding, communications director at IPA, summed up how unbalanced the focus on banning advertising is when she said, ‘It’s like allowing the ice cream van to come to your street but not letting them turn on the chimes.’

I do have sympathy with the argument that if we are serious about making changes to reduce the appeal of junk food we need to look at the whole of the marketing mix, not just advertising. We can all agree that without some pretty radical interventions on price, product composition, labelling and the easily availability of junk food, the impact on obesity as a whole by banning advertising will be relatively small.

The government will have to go much further

We have already witnessed the ‘sugar tax’ and no doubt there will be others. Banning promotions such as ‘buy one get one free’ designed to both reduce the price and fill up your cupboards with more than you would otherwise buy are already on the cards. Better labelling to help consumers understand the quantity of calories in what they are buying must help people make better choices. And discouraging impulse purchasing by changing the display and availability of these products will also have an effect.

You can’t only blame advertising

It may be true that in terms of the biggest drivers behind the nation’s overeating and love affair with junk food, advertising is not the biggest culprit. There is increasing evidence that junk food has addictive properties, just like drugs and tobacco. Mental health issues can lead to comfort eating. Poverty leads to poor diets.

There are complex issues at play here and I understand the frustration the marketing industry feels that banning advertising is an easy bit of virtue signalling with no meaningful positive outcome with regard to tackling obesity and ill health.

There is time to adjust

The food industry has been given two years to get its house in order before the measures come into place. There will be consultation to address issues like olive oil, butter and cheese being scooped up unnecessarily in the broad definitions of the government’s Nutrient Profile Model. There will be the opportunity to reformulate to reduce the offending ingredients. There will be time to innovate and launch healthier alternatives.

It will be interesting to see how the industry’s creativity will be applied to this window of opportunity.

Banning advertising has amplified awareness

In attacking the ability of brands to advertise the government is sending a big message to us all. The consumption of junk food needs to radically reduce. It is not being consumed in a balanced way and that is profoundly harmful. It has become a mass killer.

Anyone involved in the production and selling of junk food has been served notice that there is more regulation, and possibly taxes, to come.

Are we sure we are on the right side of history?

I regret that I ever worked on a cigarette brand, even though it offered me employment at the time. Tobacco doesn’t kill all of its consumers, but it causes enough damage to make most people agree we should never have used advertising to encourage people to smoke.

The advertising industry did itself no favours by arguing against an advertising ban then, clearly driven by vested interests, rather than doing the right thing.

Reluctant as I am to say it, I fear that the advertising industry is in danger of repeating the same mistake with its reaction to the ban on advertising junk food. Even if advertising plays a relatively small part, it is uncomfortable seeing it defended.

Jan Gooding is one of the UK’s best-known brand marketers, having worked with the likes of BT, British Gas, Diageo, Unilever and Aviva. She is also the chair of PAMCo, Given (London), the president of the Market Research Society, and the former chair of Stonewall. She writes for Mediatel News each month.

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MikeBaker, Director, Negotiation Gym, on 25 Aug 2020
“Great piece Jan. Clear and sharp, lovely prose. I'm sure you are right that the industry will have to let this one go eventually, like tobacco. A walk down any high street tells you why. Obesity is a national shame and the fast food industry is rightly in the dock.”

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