Policy Research Programme - Children’s holistic exposure to advertising of food and drink high in fat, sugar and salt (HFSS)
|Deadline for applications||2 November 2021|
|Notification of Outcome||January 2022|
|Project start||March 2022|
The National Institute for Health Research’s Policy Research Programme invites proposals for a research project to capture a baseline assessment of children’s exposure to advertising of food and drinks high in fat, sugar and salt (HFSS) to contribute to a post-implementation review, a form of regulatory evaluation completed up to five years after a policy has been fully implemented. This research will also support policymakers in the Department of Health and Social Care (DHSC) and the Department of Digital, Culture, Media and Sport (DCMS) to shape future policy on advertising of HFSS food and drinks.
At the end of 2022, the Government will introduce a 9pm TV watershed for HFSS products and a restriction of paid-for HFSS advertising online. These restrictions aim to reduce children’s exposure to HFSS advertising, which could help to reduce purchases of HFSS food and drink and associated overconsumption of these products. The Nutrient Profile Model (2004/05) is used to determine whether a product is HFSS. A score of 4 or more for food products and 1 or more for drinks, would define the product as ‘HFSS’
Research is needed to understand and assess the totality of HFSS advertising to which children are exposed, from all types of media, during the course of their daily lives (from when they wake until they go to bed). This will form a baseline of exposure prior to the new restrictions on advertising coming into law. A further phase of the research should be developed by the successful applicants in discussion with officials from the DHSC and DCMS to capture changes to volume and type of exposure following implementation (see section on specific guidance for this call below).
Currently, there are gaps in our understanding of children’s exposure to HFSS advertising from different media throughout the day. Therefore, this is a significant opportunity to contribute to building an evidence base on a high profile and important policy area of significant interest to the Government and other countries around the world.
Since 2016, the Government has published four documents outlining its strategy to tackle obesity . In June 2018, the Government published ‘Chapter 2 of the Childhood Obesity Plan’  which set out how the Government planned to halve childhood obesity by 2030 and significantly reduce the gap in levels of obesity between children from the most and least deprived areas. In July 2020, as part of the ‘Tackling Obesity’ strategy, the Government announced its intention to implement a 9pm watershed on TV for HFSS advertising and further consult on measures to introduce online. The Government also recently re-iterated its commitment to tackling childhood obesity in light of COVID-19 .
Obesity is one of the biggest long-term health problems England faces , with one in three children leaving primary school overweight and one in five living with obesity . Nearly two thirds of adults are above a healthy weight, and around half of these live with obesity . Obesity is a risk factor for a range of chronic diseases including type two diabetes, cardiovascular disease, and some cancers. The issue has become even more pressing recently as evidence shows that excess weight increases the risk of poor outcomes from COVID-19 .
Obesity prevalence is highest among the most deprived groups in society. Children in the most deprived parts of this country are more than twice as likely to have obesity compared with their peers living in the richest areas.
Many different cues can affect food and drink purchases, including price, taste, parental and peer influence, and public health campaigns. However, it is clear from academic evidence that advertising can also be effective at influencing child preferences and purchases of food and drink . Advertising of unhealthy, high calorie food has been identified as a contributory factor to the increasing prevalence of childhood obesity, with relatively small but consistent levels of excessive calorie consumption as a key driver.
Current evidence suggests that children’s exposure to advertising for food and drinks HFSS can affect what they eat and when they eat [9, 10, 11], both in the short and longer term by shaping food preferences from a young age [12, 13]. There is also evidence to suggest advertising exposure has more impact on people from low income households who tend to be exposed to more advertising  and are more likely to have overweight or obesity. A meta-analysis of the positive relationship between minutes of food advertising exposure and calorie consumption in children found that exposure to 4.4 mins of food advertising was found to increase children’s consumption by around 62.5 kcal when using weighted averages . Additionally, research also shows that exposure to HFSS advertising, in experimental settings, results in children who already have overweight or obesity consuming more calories compared with peers with a healthy weight. The direction of evidence suggests that additional advertising restrictions could benefit those most in need and contribute to reducing health inequalities.
Despite existing rules outlined and enforced by the Advertising Standards Authority (ASA) relating to advertising HFSS products in programming or content of particular appeal to children, we estimate children were exposed to 2.9 billion HFSS TV impacts and 11 billion impressions online in 2019 . Therefore, the Government has introduced legislation that will restrict the amount of HFSS advertising to which children are exposed. The restrictions will apply to broadcast TV and online advertisements only. These new restrictions are in addition to existing rules relating to advertising HFSS products in programming or content of particular appeal to children.
The full policy is set out in the Government’s response to the 2019 and 2020 consultations, ‘Introducing further advertising restrictions on TV and online for products high in fat, salt and sugar’. This includes the product categories we anticipate will be in scope of both broadcast TV and online restrictions in Annex 1. We anticipate that the 2004 to 2005 Nutrient Profile Model (NPM) will be used to determine whether items within these categories are HFSS products. Food items that score four or more, or drink items that score one or more using the 2004/2005 NPM will be defined as HFSS. The restrictions outlined below will apply to products defined as HFSS.
Overview of the restrictions:
- A 9pm broadcast TV watershed for HFSS products and a restriction of paid-for HFSS advertising online. All on-demand programme services (ODPS) under UK jurisdiction (i.e. ODPS or video-on-demand - for example ITV hub, All4, My5), and therefore regulated by Ofcom, will be included in the TV watershed for HFSS advertising. Non-UK ODPS (for example, AppleTV+), will be included in the restriction of paid-for HFSS advertising online.
- Restrictions for the following types of paid-for online advertising:
- online display advertising (e.g. banner ads on news websites and apps, swipe to buy);
- online video advertising (e.g. video ads served before or during items on video sharing websites);
- advergames and advertorials;
- Social media advertising (e.g. in-feed advertising);
- search listings (e.g. sponsored links on search engines);
- advertisements through web widgets (e.g. those located on the sidebar of websites);
- listings on price comparison or aggregator services (e.g. sponsored listings on food delivery services);
- influencer marketing (e.g. influencer posts paid for/sponsored by an advertiser);
- in-game advertising (e.g. banner ads in games apps); and
- newsletter advertising (e.g. banner ads in a cookery newsletter).
- The restrictions will not apply to owned media. Owned media is any online property owned and controlled, usually by a brand. For owned media the brand exerts full editorial control and ownership over content; such as a blog, website or social media channels. There will also be exemptions for:
- brand advertising, for example, brand advertisements, which only show the brand of a product rather than the product itself (i.e. Coca Cola, rather than the can of Coca Cola) - this applies to both the TV watershed and online restrictions;
- small and medium enterprise advertisers: businesses with 249 employees or fewer that pay to advertise HFSS products that they manufacture and/or sell - applies to both the TV watershed and online restrictions);
- audio only advertising (applies to online restrictions only) – content on audio only media (e.g. podcasts, online only radio);
- broadcast radio is not included in the policy - as highlighted in the 2019 consultation, we did not propose further restrictions on other forms of advertising regulated by the ASA’s BCAP (radio) and CAP codes (including print, outdoors, direct marketing and cinema);
- business-to-business advertising (applies to online restrictions only); and
- transactional content (applies to online restrictions only).
The legislation which introduces these restrictions will need to be formally reviewed as per the requirements for Post Implementation Review . The analysis undertaken of the policy’s impact on consumers and businesses set out in the Impact Assessment was based on a number of assumptions which will need to be updated where possible.
The Impact Assessment used a variety of data sources to determine the baseline level of child exposure to HFSS advertising measured in impacts or impressions, then, using other information, converted these impacts to a time of exposure per day to apply the evidence above on calorie consumption per minute of advertising exposure to estimate the reduced intake, and therefore the health impacts of the policy. There were a number of assumptions made owing to a lack of comprehensive data on children’s exposure and Government would like to strengthen this analysis for the Post Implementation Review of the policy. This research should ideally contribute to this process by improving our understanding of children’s exposure to advertising. Owing to the complexity of advertising, individuals' interactions with it and measuring its effects on calorie consumption, it is likely models will be used in assessing the impacts of the restrictions and the exposure evidence from this research will form part of such a model.
Officials from DHSC and DCMS will work with successful applicants to ensure the restrictions are fully understood.
For further detail on the policy, there are various documents published online that applicants may find useful:
- 2019 Consultation document: Further advertising restrictions on TV for HFSS products
- 2020 Consultation document: Introducing a total online advertising restriction for HFSS products
- Government’s response to the 2019 and 2020 consultation: Introducing further advertising restrictions on TV and online for products high in fat, salt and sugar
- Government’s Equality assessment: Introducing further advertising restrictions on TV and online for products high in fat, salt and sugar.
- Government’s Impact assessment: introducing a 2100 to 0530 watershed on TV and online restriction for paid advertising of HFSS food and drink
- Health and Care Bill 2021 (currently in the House of Commons)
Primary data collection is required to assess children’s holistic exposure to advertising of food and drink high in fat, sugar and salt. The following types of advertising media should be included in addition to TV broadcast and online advertising in scope of the policy: streetscape (i.e. billboards, phone boxes, bus stops, vehicle advertisements); audio-only media (i.e. on broadcast radio, on online only radio, on podcasts or music streaming services); owned media (i.e. manufacturers blogs, websites); earned media (where customers advertise content without payment from a company or customers give their contact details for companies to contact them with offers etc.); on print media (i.e. leaflets, magazines and newspapers); and at the cinema. This is not an exhaustive list and applicants should seek to include all media that children are exposed to in their daily lives.
In order to provide a baseline ahead of the restrictions coming into law, all data must be collected as early as possible prior to implementation in December 2022. The successful applicant must be in a position to start as soon as contracts are signed.
Applicants should seek to answer the following research questions:
Primary research questions
- What volume of advertisements are children exposed to during daily life?
- What volume of total food and drink advertisements are children exposed to during daily life?
- What volume of advertisements for food and drinks HFSS are children exposed to during daily life? The Nutrient Profile Model (2004/05) is used to determine whether a product is HFSS.
- What proportion of these adverts are ‘in scope’ of the advertising restrictions?
- What volume of food and drink advertisements are children exposed to via the different media? Does this differ by HFSS food and drink and non-HFSS food and drink?
- Where appropriate, (e.g. broadcast TV, on-demand programme services and online advertising) what proportion of these advertisements are ‘in scope’ of the advertising restrictions?
- How many advertisements for HFSS food and drink are product-specific versus brand advertisements?
What is the proportion of product versus brand advertisements for HFSS food and drink by different media
Secondary research questions
- Where possible, what was the average duration of exposure to an individual advert (in minutes and seconds) by media and what was the time of viewing?
- For online media only, what proportion of adverts were: ‘paid for’ (i.e. a company has paid to advertise their product); ‘owned media’ (i.e. online property that is owned and controlled by a brand, for example, their company website); or ‘earned media’ (i.e. online content about a brand posted by the public or included in media coverage but not paid for by the brand or product owner)? What was the type of advertisement (e.g. video, audio, search or text based, swipe up, banner or paid-for post)?
- Where possible, what was the range of businesses advertising HFSS food and drinks to which children are exposed? We welcome applications that consider the types of business by size, either small and medium enterprises (SMEs) or large businesses.
We are interested in understanding the extent of HFSS advertising for children from age 5 to 16 years old (primary school to secondary school age). However, we recognise that attempting to cover a wide range of ages (particularly younger children) may compromise the feasibility of the research given the set timescales. We welcome applicants’ views on whether different methodology might be applied to capture exposure for different age groups; and whether a focus on secondary age children would allow data collection to be completed on time with a high level of data quality. We are cognisant that acquiring ethical approval, which ensures that children taking part are appropriately safeguarded, is of paramount importance but will necessarily take time. We would like a representative sample of children to take part in the research from a wide range of demographic groups. This includes, but is not limited to, socio-economic status, body mass index (BMI) status, ethnicity and gender.
We are interested in the use of innovative technologies and methods that can track what children are exposed to throughout the course of the day in order to answer the questions set out above and we welcome applications that collaborate with the providers of these technologies and methods.
Areas out of scope for this programme of work
For the research questions stated, our preference is for quantitative findings with qualitative research to provide additional insight. We would like the research to be participatory, using a range of primary qualitative and quantitative methods rather than using routinely collected data sources to assess children’s exposure. We are not looking for systematic reviews.
Additional guidance for a phased approach to commissioning
Due to the need to capture baseline data for this policy ahead of regulations becoming law, this research will be commissioned through a one-stage process. Applicants will complete an extended stage one application form; additional space is provided to set out the research design, methodology and analysis in more detail than usually requested at stage one. This will form phase 1 of the required work. The successful applicants will be provided feedback by both the funding committee and by officials in DHSC and DCMS and will be asked to make adjustments accordingly through a fully costed application form.
During phase 1, the successful applicant will work with officials at DHSC and DCMS to understand the research requirements for post-implementation research (phase 2) which assesses the changes that have taken place since the policy was enforced. Once the parameters of the phase 2 research are decided, and providing the first phase of the research has shown to be feasible and has been completed to a high standard, the contracted research team will be asked to submit an application for the post-implementation phase. This application will be subject to independent review to determine whether a contract for phase 2 will be awarded. If unsuccessful, phase 2 will be commissioned through open tender.
Outputs for phase 1 should include:
- interim reports and updates as agreed at project scoping;
- draft publishable report and final publishable report, with executive and lay summary in a form suitable for policy colleagues in a 1:3:25 format;
- a presentation of findings to DHSC and DCMS colleagues and key stakeholders.
The successful applicant will produce a final phase 1 report, fully accessible to policymakers and members of the public and circulate to DHSC and DCMS. When the study is complete, the successful applicants will place a final report summary on the NIHR Policy Research Programme website, where outputs resulting from public expenditure are available for public scrutiny. It is important the final report summaries are easily accessible to lay readers.
Applicants should consider the full range of potential audiences and describe how to disseminate research findings most effectively so lessons from this research affect policy and practice.
It is expected that the data generated within this project should be made accessible to the scientific community. Plans for making the data widely available for future research should be outlined.
Applicants are asked to consider the timing and nature of deliverables in their proposals. Policymakers will need research evidence to meet key policy decisions and timescales, so resource needs to be flexible to meet these needs. A meeting to discuss policy needs with DHSC and DCMS officials will be convened as a matter of priority following contracting.
Budget and duration
A total of £250-350k is available for this research. Costings can include up to 100% full economic costing (FEC) but should exclude output VAT. Applicants are advised that value for money is one of the key criteria that peer reviewers and commissioning panel members will assess applications against.
We expect phase 1 of the research to be completed within 18-24 months of contracting.
A research advisory group including, but not limited to, representatives of DHSC and DCMS, and the successful applicants for the research should be established. The advisory group will provide guidance, meeting regularly over the lifetime of the research. The successful applicants should be prepared to review research objectives with the advisory group, and to share emerging findings on an ongoing basis. They will be expected to:
- Provide regular feedback on progress
- Produce timely reports to the advisory group
- Produce a final report for sign off
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- Department of Health and Social Care, childhood-obesity-a-plan-for-action-chapter-2.pdf (publishing.service.gov.uk). June 2018.
- Department of Health and Social Care, Tackling obesity: empowering adults and children to live healthier lives July 2020.
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- Cairns G, Angus K, Hastings G. (2009). The extent, nature and effects of food promotion to children: a review of the evidence to December 2008. World Health Organization, WHO Press.
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- Thomas, F. Hooper, L. Petty, R. Thomas, C. Rosenberg, G. Vohra, J. (2018) “A Prime Time for Action: New evidence on the link between television and on-demand marketing and obesity” Policy Centre for Cancer Prevention, Cancer Research UK.
- Russell, Simon J., Helen Croker, and Russell M. Viner. "The effect of screen advertising on children's dietary intake: A systematic review and meta-analysis." Obesity Reviews (2018).
- Department for Digital, Culture, Media & Sport, Impact assessment: Introducing a 2100-0530 watershed on TV and online restriction for paid advertising of food and drink that are High in Fat, Salt and Sugar (HFSS) products. May 2021
- Department for Business, Energy, and Industrial Strategy (BEIS), Producing post-implementation reviews: principles of best practice. August 2021).