The workshop of the PromoKids Network in Bergen 12 June 2019. Kaja Lund-Iversen.

1. PromoKids, workshop 12 June 2019, Bergen
Kaja Lund-Iversen, senior adviser food and nutrition policy, The Norwegian Consumer Council
Digital food marketing in adolescence – surveys
conducted in a Norwegian context

2. The Norwegian context
• One in six children and one in four teenager are overweight or obese
• Children and adolescents consume on average more sugar and
saturated fats and less F&V than rest of population
• Among 10th graders - 14% and 24% of girls and boys drink soda 5
times per week or more often
• Half of all 10-18 year olds drink caffeinated energy drinks
• High levels of use of social media among children and adolescents
Sources: Nasjonalt Folkehelseinstitutt; Helsedirektoratet; HBSC survey, Universitetet i
Bergen (HEMIL); Forbrukerrådet; Barn- og medieundersøkelsen, Medietilsynet

3. Regulation of HFSS marketing
• Follow-up of the WHA 2010, government
consultations on draft legislation to ban
marketing of HFSS foods to children.
• Industry-led self-regulation scheme (MFU)
established in 2013, came into force January 2014
• As a supplement to the Acts that regulate
marketing and marketing to children, in order to
protect child health
• Limitations according to WHO Evaluation of
implementation of the WHO recommendations
(2018):
• The age-limit only protecting <13 of age
• The narrow scope and definition of marketing
• Regulations focus exclusively on channels and
techniques aimed at children

4. Study:
The marketing of unhealthy food
and beverages in social media –
a focus group study with
teenagers 13 and 15 of age
May 2017
English version
https://fil.forbrukerradet.no/wp-
content/uploads/2017/05/report-marketing-
in-some-final-norwegian-consumer-council-
may2017.pdf
4

5. • Triple-E-techniques –
Engagement, Emotions and
Entertainment – are the most
common marketing techniques
in the social media.
• The ads are conveyed through
entertainment, amusing tasks
and competitions, all of which
makes it less obviously an ad
and more interesting to the
target group.
«Advertainment»

6. Main findings
• Experience that they are regularly exposed to
advertising when online
• Don’t think of advertainment as marketing,
before we start asking
• Difficult to recognize advertainment as
marketing,
• User- and peer-generated
• Humour and entertaining
• Competitions, prizes
• Marketing go under the radar, are subtle, they
think they are influenced without being fully
aware
• Branded products become part of
adolescents' social networks online
• 13 year olds were more aware and sceptic
than the 15 year olds
Not regarded as an ad
because it is "voluntary"

7. Guidelines for labelling of ads on social media
• The Norwegian Consumer
Authority and the Norwegian
Media Authority have developed
guidelines for labelling of ads on
social media
https://www.forbrukertilsynet.no/lov-og-
rett/veiledninger-og-retningslinjer/veiledning-
reklame-some
https://www.medietilsynet.no/globalassets/doku
menter/produktplassering/youtube_veileder.pdf

8. Disclosure of ads in youtubers video, little
effect on snacking, new study shows

9. Study:
Young and exposed to unhealthy
marketing – a monitoring survey
of digital food marketing with
focus on influencers
March 2019
English version:
https://fil.forbrukerradet.no/wp-
content/uploads/2019/02/young-and-
exposed-to-unhealthy-marketing-digital-food-
marketing-using-influencers-report-february-
2019.pdf
9

10. 10
• Identified 16 Norwegian youtubers with
channels popular among children and adolescents
• 50.000 - 300.000 followers
• Monitored all videos uploaded in 2018 with focus
on content marketing
• 11 did promote food or drinks
• In total 31 videos promoting food and drinks identified
• 2/3 of the videos was promotion of Coca Cola
Monitoring of Youtubers

11. 11
• 11 brands own pages
• A lot of contests, less like, comment and share
• Use of peers and youth culture
• Everyday life and role models
Monitoring of Facebook

12. NCC filed 7 complaints
2014 – 2019
1. Packaging of sugary cereals - rejected
2. 2-for-1 promotion of Coca Cola - rejected
3. IceTea promotion on Facebook - rejected
4. Chocolate milk on Facebook and Snapchat -
rejected
5. Chocolate TV-commercial before 9 pm - rejected
6. Coke TV on Youtube - partly sustained
7. Happy Studio McDonalds mobile game to 6-12 year
olds - sustained

13. Conclusions
• Adolescents are not sufficiently protected against marketing of HFSS foods online
• The age limit of the regulation need to be set higher in order to protect
teenagers, but also younger children who also are exposed to marketing aimed at
older children / adolescents
• Third-party independent evaluation of MFU will be conducted in 2019
• NCC and the NCD-Alliance ask the evaluation to include:
• A survey of digital marketing that children and adolescents are exposed to
• An evaluation of the self-regulation against WHO Set of Recommendations
• An evaluation and the state’s obligation as of the Convention of the Rights of the Child
• Involvement of NGO’s and civil society organisations in a constructive way
Thank you!
Contact: Kaja Lund-Iversen, e-mail: kajlun@forbrukerradet.no