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Argument_Analysis_6_Targeting_Kids_with_TV_Ads.pdf

Argument Analy sis 6: Targeting Kids with TV Ads

T here a re 2 a rg uments here, be s ure to rea d both a nd dec i de who ha s the better a rg ument.

Argument 1:

Margo Wootan against targeting kids… Guidelines for Responsible Food Marketing to Children

These “Guidelines for Responsible Food Marketing to Children" are for food manufacturers, restaurants,

supermarkets, television and radio stations, movie studios, maga zines, public relations and advertising

agencies, schools, toy and video game manufacturers, organizers of sporting or children's events, and others

who manufacture, sell, market, advertise, or otherwise promote food to children. The Guidelines provide

criteria for marketing food to children in a manner that does not undermine children's diets or harm their

health. We hope the Guidelines will be helpful to parents, school officials, legislators, community and health

organizations, and others who are seeking to improve children's diets.

Over the last 20 years, the rates of obesity have doubled in children and tripled in teens. Even for children at

a healthy weight, few (only 2 percent) eat a nutritious diet as defined by the U.S. Department of Agriculture.

Currently, children's diets are too high in calories, saturated and trans fats, refined sugars, and salt and too low

in fruits, vegetables, whole grains, and calcium. This increases their risk of heart disease, cancer, diabetes,

osteoporosis, and other serious and costly diseases.

Although children's food choices are affected by many factors, food marketing plays a key role. Studies show

that food marketing attracts children's attention, influences their food choices, and prompts them to request

that their parents purchase products.

Parents bear the primary responsibility for feeding their children. However, getting children to eat a healthful

diet would be much easier for parents if they did not have to contend with billions of dollars' worth of

sophisticated marketing for low-nutrition foods.

Parental authority is undermined by wide discrepancies between what parents tell their children is

healthful to eat and what marketing promotes as desirable to eat. In addition, while many parents have limited

proficiency in nutrition, companies have extensive expertise in persua sive techniques. Companies also have

resources to influence children's food choices that parents do not have, such as cartoon characters,

contests, celebrities, and toy giveaways.

The Guidelines for Responsible Food Marketing to Children apply to children of all ages (less than 18 years

of age). Society provides special protections for chil dren, including measures to protect their health, such as

requiring use of car safety seats or prohibiting them from buying cigarettes or alcoholic beverages. However,

even in the absence of legislative or regulatory requirements, marketers should act responsibly and not urge

children to eat foods that could harm their health.

Nutrition Guidelines

Responsible food marketing to children must address not

only how food is marketed but also which foods are mar-

keted to kids. Uniquely, the Guidelines for Responsible

Food Mark eting to Children set criteria for which foods

are appropriate to market to children.

Ideally, companies would market to children only the

most healthful foods and beverages, especially those that

are typically underconsumed, such as fruits, vegetables,

whole grains, and low-fat dairy products.

However, nutrition criteria that would allow o nly mar-

keting of those foods seem unrealistically restrictive.

Instead, we recommend a compromise approach. These

Guidelines set criteria that allow for the marketing of prod -

ucts that may not be nutritionally ideal but that provide

some positive nutritional benefit and that could help chil-

dren meet the Dietary Guidelines for Americans.

Some marketing efforts do not promote individual

products but instead promote a line of products, one

brand within a company, or a whole company. For exam-

ple, a campaign might encourage children to go to a

particular restaurant without marketing a specific menu

item. A company logo or spokescharacter featured on a

hat or Web site might promote a whole line of products.

Companies should not conduct general b rand marketing

aimed at children for brands under which more than half

of the products are of poor nutritional quality, as defined

below. If multiple products are shown in an advertise -

ment, if one product does not meet the nutrition criteria

below, then the advertisement is considered to promote

foods of poor nutritional quality.

Beverages

Low-nutrition beverages (as defined below) should not be

marketed to children.

Nutritious/Healthful Beverages

 Water and seltzer without added sweeteners

 Beverages that contain at least 50 percent juice and

that do not contain added sweeteners

 Low-fat and fat-free milk, including flavored milks and calcium-fortified soy and rice beverages

Low-Nutrition Beverages

 Soft drinks, sports drinks, and sweetened iced teas

 Fruit-based drinks that contain less than 50 percent

juice or that contain added sweeteners

 Drinks containing caffeine (except low-fat and fat-

free chocolate milk, which contain trivial amounts of

caffeine)

Foods

Foods marketed to children should meet all of the follow-

ing criteria (nutritionally poor choices or low-nutrition

foods are those that do not meet the criteria):

Nut r ie nt C r it e r ia

Fat i

No more than 35% of total calories,

excluding nuts, seeds, and peanut or

ot he r nut but t e r s

Sa t ur a t ed

plus trans fat

No mor e t ha n 10% of ca lorie s

Added

sugars

Le s s t ha n 35% of a dde d s ugar s by

weight (added sugars exclude naturally

occurring sugars from fruit, vegetable,

a nd da ir y ingr edie nts)

Sodium No mor e t ha n;

I. 230 mg per serving of chips, crackers,

che e s es , ba ked goods, F r ench f rie s,

a nd ot her s nack it e ms

2. 480 mg per serving for cereals, soups, pastas, and meats

3. 600 mg f or piz z a , s a ndwiches , a nd ma in dis he s

4. 770 mg f or me a ls Nutrient

content C ont a ins one or mor e of t he f ollowing:

10% of t he DR I (die t a r y r e f e r e nce

int a ke ) of (na t ur a lly occur r ing/wit h out

f or t ificat ion) v itamins A , C , or E;

ca lcium; ma gne s ium; potas sium; ir on; or

f ibe r

2. Ha lf a s e r v ing of f r uit or v e ge t a ble

3. 51% or more (by weight) whole-

gr a in ingr edients

Portion Size Limits for Foods and Beverages

Individual No larger than the standard serving size

items used for nutrition facts labels (except for

fruits and vegetables, which are exempt

f r o m p o r t i o n s i z e l i m i t s )

Meals No more than one-third of the daily

calorie requirement for the average

child in the age range targeted by the

marketing

"For C A RU's guidelines, go to httpliwww,curui.orgiguidelinesi guidelincs.pdf.

*Margo G. Woot an, "Guidelines for Responsible Food Market ing t o Children," January 6, 2006. Cent er for Science in t he P ublic Int erest (CSP I).

" January 21395; second printing, January 2006. The full Guidelines for Responsible Food Marketing to Children are av ailable online (free of charge) at

ht t p://www:espinet .orgimarket ingguidelines.pdf

Marketing Techniques

When marketing foods to children, companies should:

Product Characteristics and Overall Messages

 Support parents' efforts to serve as the gatekeepers of sound nutrition for their children and not undermine parental authority. Marketers should not encourage children to nag their parents to buy low-nutrition foods.

 Depict and package/serve food in reasonable portion sizes and not encourage overeating directly or indirectly.

 D e ve l op ne w produc ts tha t hel p c hi ldren ea t healthfully, especially with regard to nutrient density,

energy density, and portion size.

 Reformulate products to improve their nutritional quality, including adding more fruits, vegetables, and

whole grains, and reducing portion sizes, calories, sodium, refined sugars, and saturated and trans fats.

 Expand efforts to promote healthy eating habits consistent with the Dietary Guidelines for Americans and

to promote healthful products, such as fruits, vegetables, whole grains, and low-fat milk. Do not portray

healthful foods negatively.

Specific Marketing Techniques and Incentives

 Should not advertise nutritionally poor choices during television shows (1) with more than 15 percent of

the audience under age 12; (2) for which children are identified as the target audience by the television

station, entertainment company, or movie studio; or (3) that are kid-oriented cartoons.

 Not us e produc t or brand pl ac e m ents.

 Only offer premiums and incentives with foods, meals, and brands that meet the nutrition criteria

described above.

 Use/allow licensing agreements or cross-promotions (such as with movies, television programs, or video

games) or use cartoon/fictional characters or celebrities from television, movies, music, or sports to market

to children only those foods that meet the above nutrition criteria. This includes depictions on food pack-

ages, in ads, as premiums, and for in-store promotions.

 Not put logos, brand names, spokescharacters, product names, or other marketing for low-nutrition

foods/brands on baby bottles, children's apparel, books, toys, dishware, or other merchandise made

specifically for children.

 Incorporate into games (such as board, Internet, or video games), toys, or books only those products and

brands that meet the nutrition criteria.

 Use sponsorship of sporting, school, and other events for children only with brands and foods that meet the

above nutrition criteria.

 Not exploit children's natural tendency to play by building entertainment value into low-nutrition foods.

Additional Guidance for Schools

 Schools are a unique setting. Companies should support healthy eating in schools and not market, sell,

or give away low-nutrition foods or brands anywhere on school campuses, including through logos, brand

names, spokescharacters, product names, or other product marketing on/in vending machines; books,

curricula, and other educational materials; school supplies; posters; textbook covers; and school property

such as scoreboards, signs, athletic fields, buses, and buildings; educational incentive programs that provide

food as a reward (for example, earning a coupon for a free pizza after reading a certain number of books);

incentive programs that provide schools with money or school supplies when families buy a company's

food products; in-school television, such as Channel One; direct sale of low-nutrition foods; and school

fundraising activities.

 Should not mislead children regarding the emotional, social, or health benefits of a product or exploit

children's developmental vulnerabilities and emotions to market any food.

Argument 2:

Robert Liodice defending targeting kids

''Robert Liodice, "Advertising and Freedom of Speech; Beware of the Food Nanny," January 24, 2005,

littp://anablogs.comiliodice12005/01/ america-free_sp.htinl.

Free speech is the most important and fundamental right we have as Americans. It is the foundation

for the free exchange of ideas and ideals that drives the lifestyles and livelihoods in this most free of

countries. Free speech is the basis of choice and personal responsibility. Without the free exchange of

information, we limit the ability of Americans to be fully informed to make the choices that are inherently

theirs to make. When those freedoms are jeopardized, we all lose. When you begin to chip away, even

marginally, at those freedoms, we all run the risk of sliding down that slippery slope of diminishing rights

and privileges. That is why I felt most compelled to address the recent release of the "Guidelines for

Responsible Food Marketing to Children" (PDF) by the Center for Science in the Public Interest (CSPI).

I am rather stunned that CSPI—or any organization for that matter—would suggest restricting or

modifying the free speech of perfectly legal enterprises as an approach to solve a problem. We all

recognize that there are a host of societal issues—childhood and adult obesity stands out as one of the

most "curable" of them all. But seeking a cure should not follow the path of trampling on our core rights

and privileges of Americans. Without question or argument, there are a range of reasonable alternatives

and approaches that can be considered and aggressively pursued—and they should [be pursued] with full

vigor. But trampling on the First Amendment, whether through government controls or unsupported self-

regulatory edicts, should not even be on anyone's radar screen—as a way to solve problems. Accordingly, I

have addressed CSPI's "guidelines" in today's Ad Age editorial.

Last week the Center for Science in the Public Interest (CSPI) did something that was neither based on

science nor beneficial to the public interest. They released a set of ill-conceived, heavy-handed food

marketing guidelines. [On the basis of] flawed data and backed by the threat of lawsuits, they intend to

coerce the food and marketing industries to conform to their misguided views of what constitutes good

nutrition and what represents appropriate commercial communication with consumers.

In issuing these guidelines, CSPI misstates the facts about food advertising and childhood TV viewing;

they overlook the broad array of factors—beyond marketing—that influence childhood food

consumption; they disregard the significant efforts of food companies to enhance the nutritional

content of their products; and they ignore the fact that food and other advertising are already among

the most stringently regulated areas in the United States.

Styling themselves as the nation's food nanny, CSPI has proposed a set of extraordinarily overreaching

regulations, which specify acceptable nutritional content, portion size, packaging design and logo use.

They further seek to control communications in TV shows, video games, web sites, and books. And the y

attempt to dictate use of premiums, incentives, licensing arrangements, cross -promotions,

sponsorships and even the aisles within supermarkets where food products are displayed!

The guideline specifics are ridiculously restrictive. For example, children are defined as "anyone under 18;"

low-nutrition beverages are defined as "drinks with less than 50 percent real juice;" and banned TV shows

are those "for which more than a quarter of the audience is children." They are an affront to and

broadside attack on—the marketing freedoms of food and restaurant businesses, broadcasters,

entertainment companies, and the entire marketing industry,

We won't be intimidated! Nor will American consumers who—unlike CSPI—recognize the importance

of personal and parental responsibility, public education, dietary balance and moderation and, of course,

physical activity in addressing the issues of childhood nutrition and obesity.

So let me specifically address the major flaws inherent in CSPI's guidelines.

First, CSPI speciously claims that the amount of marketing aimed at kids has doubled in the last ten

years. In examining measured media, however, a detailed study by Nielsen Media Research covering

the period of 1993 to 2003 concludes otherwise. Adjusting for inflation in order to hold the value of

dollars constant, real expenditures on food and restaurant advertising on television (including cable)

fell over this ten-year period. Furthermore, the actual number of food ads seen by children under 12

declined by 13 percent from the first four years of this period to the last four years. Rather than

being increasingly bombarded by restaurant and food advertising, as CSPI would have people believe,

kids 12 and under are actually seeing fewer food and restaurant ads today.

Second, CSPI's report states that "parents bear the primary responsibility for feeding their

children." However, the guidelines then ignore this point and the fact that adults make the vast

majority of food purchases for their families, particularly for younger kids. They also disregard what the

majority of food experts inherently know: that the best way to encourage good childhood nutrition is

to promote healthy, well-balanced diets, rather than attempting to characterize some products as

"good foods" and others as "bad foods." When other countries have attempted to ban or severely

restrict children's advertising, those efforts have consistently failed to lower obesity rates in compari -

son to countries where there are no such restrictions.

Finally, let's take a look at the significant, positive steps the food and marketing industries are

taking—and have historically taken—to address the special concerns of children. Thirty years ago,

the marketing industry established the Children's Advertising Review Unit (CARU) specifically to

recognize that material which might be truthful and non-deceptive for adults could still mislead

young people. CARU created a detailed code, available at www.caru.orgiguidelines, which proactively

works to [ensure] that children are not taken advantage of in the advertising marketplace. CARU

diligently carries out its own monitoring and receives complaints from regulators, consumer advocates,

Attorneys General, competitors, and the public at large, The record of industry compliance with

CARU's guidelines demonstrates an extremely high level of effectiveness.

Equally important are the many, significant steps that food and restaurant companies are taking to

bring healthy new offerings to market. For example, they are reformulating products to be lower in

cholesterol, fat, and calories.

They are removing trans fats, reducing sodium and sugar content, introducing whole grains, and

offering more milk products and salad menu items.

T here i s no ques ti on tha t c hi l dhood nutri ti on a nd obe sity are serious societal issues. However,

as the Surgeon Genera l c onc l uded i n hi s g roundbrea ki ng 2001 report, "There is no simple or

quick answer to this multifaceted c ha l l eng e." Unl i ke C SPI' s g ui del i nes whi c h mi s l ea d the

publ i c by na rrowl y f oc us i ng on f ood a dverti s i ng , the Surg eon Genera l ' s report c onta i ns

thoug htf ul , s pec i f i c rec ommenda ti ons on how to a ddres s the c ha l l eng e i n a ba l a nc ed,

c omprehens i ve wa y. It f urther c a l ls on a l l of us —c ompa ni es , i ndi vi dua l s , f a mi l i es , s c hool s ,

g overnments a nd the medi a —to work tog ether i n wa ys tha t wi l l bring better health to

everyone in this country. We accept thi s c ha l l eng e a nd s ta nd rea dy to c ol l a bora te wi th a l l

other i nteres ted, res pons i bl e pa rti es to i denti f y s ol uti ons tha t wi l l trul y work.