We will change our food advertising to children." This first line in the recently drafted India Pledge, signed by seven food and beverage majors, is perhaps the beginning of a new chapter of communication in that space in India. Or is it?
On July 19, Hindustan Unilever, Coca-Cola India Inc, General Mills India, Kellogg India, Nestle India, Mars International India and PepsiCo India Holdings came together for a voluntary, self-regulation initiative to help promote healthier, active lifestyles to Indian children. A few days later, Cadbury too announced that it would join in very soon.
What led to this change of heart? How will the creative and media plan change for these companies? What are the legal guidelines in this regard? And most importantly, what are the social and moral implications of communicating to children? afaqs! Reporter seeks some answers.
India is the 12th country to be party to such a pledge. The India Pledge is modelled on the EU Pledge, and it is among the few developing nations on that list to be a part of this 'movement'.
The India Pledge seems to be a product of a global school of thought and companies that have signed on have probably done so because of a global directive - so far, only Indian arms of internationally networked companies have signed on. No Indian company has yet come to the fore expressing interest in it. Shalini Degan, category director, delight and lifestyle, Britannia Industries, thus responds to our question of why Britannia isn't party to the pledge: "Our products are approved by the FDA (Food and Drug Administration) and are healthy, which is probably why we were not approached. There is no need for us to say 'From now on we will …'. Britannia is not looking for mileage like that. I mean, who will that document really reassure?"
While that is clearly subjective, the signatories themselves are touting the India Pledge as a major milestone for the food and beverage industry. Says a Coca-Cola India spokesperson, "We have collectively worked in identifying a best practice model of self-regulation." Sidharth Singh, vice-president and head, processed foods, HUL adds, "This is a voluntary response by the leaders in the space and we are confident that more Indian companies will join us in our commitment towards responsible advertising to children."
More to it…
Not everyone thinks the reason behind the India Pledge is as simple as a global directive.
To understand the full implications of this 'voluntary' pledge, take a look at the legal framework concerning this matter. The government of India had set up the Food Safety and Standards Act, 2006 which created a body called the Food Safety and Standards Authority of India (FSSAI). The FSS Act, when formed, saw the cancellation of other Acts in the space including the Prevention of Food Adulteration Act, 1954 or the Fruit Products Order, 1955. It was an initiative to give greater legal backing to issues in the food production and marketing space.
In addition to this, the Advertising Standards Council of India (ASCI) came up with a code in the food and beverage space in December 2007, which lays down certain guidelines that marketers ought to follow. There has been talk for quite some time that the FSS Act, though comprehensive, perhaps may not exactly be "sharp enough" to have marketers take it seriously. The ASCI has, therefore, recommended its own food and beverage code guidelines to the FSSAI to tighten the rope for stricter implementation. Dhananjay Keskar, director, IBS and chairman, ASCI, says that the FSSAI is considering the recommendations. According to sources, the FSSAI is likely to amend the Act as a result of these recommendations - a decision that will only be taken by this year-end or early next year.
Not everyone agrees. To Sam Balsara, chairman and managing director, Madison World, and ex-AAAI and ASCI president, all this concern for over-consumption of products like soft drinks, chips, chocolates and fast foods is unnecessary and obesity amongst kids is more of an issue in developed markets like Europe and the US.
"If one looks at the per capita consumption of these foods, barring the metros, consumption of such items is low in India. How many children here are obese because of watching advertisements of chocolates and fast foods? I think the concern is misplaced and a little far-fetched," he says emphatically.
Further, he feels that while it is a good attempt, the pledge might be an overreaction because of what's happening in the Western world, as by and large, "marketers are a responsible lot".
Metaphors and hyperbole
Children today are highly competitive, and their sense of self often comes from how richer, taller, sharper, smarter, or stronger they are than their peers. For years together, advertising has fed on the insecurities faced by kids, and in some cases, even thrived on it.
Clearly, advertising affects children across two parameters: directly, where products are targeted at them, and indirectly, where they are unwittingly made influencers in categories not meant for them. The latter could involve all sorts of categories beyond food, including cars, electronic items and toiletries, and the route taken here is often one of comparative advertising.
Here, a marketer could play on lifestyle disparities and social status, making a child belonging to a low or middle income group feel deprived, pitiable or 'uncool', or worse, a failure if his family doesn't own a particular brand. This also affects his relationship with his family members. Also, here, often one aspect of a product - such as a sound system in a car - is made the hook for the overall product.
In case of products meant for children, encouraging over-consumption, or exaggerated claims can harm a child. Over-consumption of food items could lead to obesity, a tangible effect, which is why perhaps the Food and Beverage category is the first one to come under the scanner when issues of marketing to children come to the fore. Exaggerated claims on the other hand, could have disastrous effects on a child's psyche and this is not always measurable.
Over time, snack brands have attempted going the healthy route, but some brands take 'benefits' to an extreme. Shailaja Bajpai, media critic and consulting editor, The Indian Express (and co-author of the 1996 book The Impact of Television Advertising on Children), recounts past campaigns for brands such as Complan that made 'tall' claims of making children taller with consumption. "Over indulgence is not good," she states, "and without scientific evidence, to make preposterous claims that your child will grow taller, or that one energy drink or biscuit will make your child a genius, is obviously unethical." Furthermore, children have vivid imaginations and marketers should be cognizant of that. Surely, there's no harm in experimentation, but one needn't go over the top. "Marketers cannot expect kids to understand hyperbole," says Degan of Britannia. "I mean, the kids could replicate stunts seen in ads. These are formative years and the line between imagination and reality blurs for them."
Sociologists attribute the increased effect of ads on children to two factors: first, the high exposure to media and second, the parents themselves. According to Nandini Sardesai, sociologist and member of ASCI's CCC (Consumer Complaints Council), media explosion is making children more materialistic, status and price conscious. Years ago, clothes and textbooks were passed onto siblings. Today's child knows the concept of my room… my books… my things. Children are now 'proud' owners of Facebook ids under false names, and also want make-up, hair curls and other such things in blatant emulation of adults. This makes them soft targets for marketers. Sardesai talks of the four effects which repetition and reinforcement in advertising generate: projection, imitation, suggestion (subtle or not) and role-play (a kid puts himself in the 'superior' boy's shoes).
While these are the obvious effects, there are subliminal messages that advertising gives out, such as lifestyle imagery, or social stigma. The psychological impact could include a child getting enamoured by a fast car in an ad. Thinking 'speed' becomes cool. A young girl who is dark may not immediately associate herself with the 'repercussions' of her skin colour, but the impact will remain with her. "Unwittingly, a child is being educated with the kind of lifestyle he sees in advertising," says Bajpai. "These images stay with them when they grow up, on how they should be, what they should look like, how they should dress or the kind of cars they should drive," he adds.
Change of plans?
Television accounts for, on an average, 80-90 per cent of ad budgets for food and beverage companies (depending on the brand, the market), following which come print and the internet. This development could probably spell a change in media plans for the signatories.
For instance, it will make a difference to the way kids' channels are utilised by these brands. While these advertisers may not stay away completely from a kids' channel, they may be forced to target shows meant specifically for older children, and stay away from those meant for the under-12 age band. Some of these signatories such as Coca-Cola and Unilever already have strict marketing-to-children policies in place and, therefore, don't target certain products on shows meant for 8-12 year olds. "And most in the impulse category, such as soft drinks, anyway don't address that age group," says Punitha Arumugam, group CEO, Madison Media. "But the pledge could imply a change in TV spots for those in the snacking business, like biscuits and chocolates," he adds.
Generally, FMCGs dominate a kids' channel, and food and beverages come next. But as the media environment does not operate in silos, an advertiser could, by default, end up reaching a younger child even by putting up a spot on Balika Vadhu. "Perhaps what 'responsibly' means is that you don't intentionally target these kids, is all. These marketers are talking about responsible advertising. They're not talking about not advertising," shrugs Arumugam.
On-ground activities in schools need not suffer, as long as the property has something to do with the constructive growth of the child, such as awarding recognition to talent or organising quizzes. But these too, will clearly be for the older child, as the pledge clearly instructs signatories to stay away from primary schools, unless certain nutrition criteria are met.
On the creative front, preposterous or exaggerated claims will be shown the door. Content changes could include not showing that the happiness or intelligence of a child depends on 'a' product, or not casting children below a certain age for some products. Abhijit Avasthi, co-NCD, Ogilvy India, feels that if one borrows something from life and uses it in an interesting way, all's well, as long as one is not planting a 'devilish' thought in a child's mind. "Today's kids see far more contorted stuff in films. They have a fair sense of TV advertising and know not to take it too seriously," he says. The smart marketer knows that he can't fool children. Perhaps the India Pledge is a manifestation of that 'smartness'.
Having said that, the creative fraternity feels the use of imagination in storytelling is a vital ingredient while communicating to children. "Just like cartoons, comics or fairytales, they accept it as a legitimate form of storytelling and laugh it off," shrugs Avasthi, and if there is a moral in the ad story, it is even better.