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A Framework for Implementing the Set of Recommendations on the Marketing of Food and Non-alcoholic Beverages to Children has just been released by WHO intended to assist national governments in implementing the recommendations agreed by the World Health Assembly in 2010.

While the 2010 Recommendations offered a wide range of policy options, these guidelines seem to favour statutory restrictions over self-regulation.

Rationale
The overall policy objective should be to reduce both the exposure of children to, and power of, marketing of foods high in saturated fats, trans-fatty acids, free sugars, or salt.

Policy development

• The document goes on to describe factors to consider when specifying the details of policy options:
• The age of a child: the report leaves room for Member States to make the decision as to what age group should be protected from the impact of marketing of foods high in saturated fat but warns that a narrowly-defined age range may not adequately protect younger children since exposure is not always limited as intended;
• The communication channel and marketing technique targeted by the policy: all channels and techniques should be subjected to limitations to avoid higher exposure on channels and techniques that are not covered. International co-operation may be needed to address the problem of channels originated in another country;
• What constitutes marketing to children: the report suggests national policymakers should consider the food product promoted, when it is scheduled, the viewing audience, the place where the marketing takes place and the content of the marketing communication;
• Restricted foods: the existence of national dietary guidelines should be taken into account when drafting the policy or the definitions set by scientific bodies if such guidelines do not exist. This approach involves identifying and restricting the marketing of foods high in fat, sugar and salt (HFSS foods).

Policy implementation
Statutory regulations are seen as the best option since while non-statutory approaches may be faster to develop and may also be adapted more quickly to changes in the marketing environment, it can be difficult to gain agreement across industry groups and sectors to ensure key definitions of the policy are broad enough to achieve high effectiveness. For example, different industry groups are likely to favour nutrient profiling models with outcomes that favour their products.

Effective enforcement is an integral part of effective implementation. The report lists a range of corrective measures in case of infringement and insists that governments should ensure that the nature and extent of the sanctions and penalties imposed are appropriate in their country context.

Policy monitoring and implementation
All policy frameworks should include a monitoring system to ensure compliance with the objectives set out in the national policy, using clearly defined indicators. A system of evaluation should also be included to assess the impact and effectiveness of the policy.


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