advertising (Wilcox et al., 2004). This finding is consistent with the policy statement of the American Academy of Pediatrics that “advertising directed toward children is inherently deceptive and exploits children under eight years of age” (AAP, 1995). A child is unable to critically evaluate these messages’ content, intention, and credibility in order to assess their truthfulness, accuracy, and potential bias (Wilcox et al., 2004).

In general, children are exposed to up to one hour of advertising for every five hours of television watched (Horgen et al., 2001). This proportion complies with the Federal Communication Commission’s enforcement of the Children’s Television Act of 1990, which limits advertising to no more than 12 minutes per hour during the week, and fewer than 10.5 minutes per hour on the weekend, for television programs reaching children under 12 years old (FCC, 2002). However, this exposure to advertising may represent a conservative estimate given the growth in unregulated advertising reaching children through cable television and the Internet (Dale Kunkel, University of Arizona, personal communication, August 17, 2004).

After reviewing the evidence, the committee has concluded that the effects of advertising aimed at children are unlikely to be limited to brand choice. Wider impacts include the increased consumption of energy-dense foods and beverages and greater engagement in sedentary behaviors, both of which contribute to energy imbalance and obesity. The committee concurs with the APA Task Force’s finding (Wilcox et al., 2004) that advertising targeted to children under the age of 8 is inherently unfair because it takes advantage of younger children’s inability to attribute persuasive intent to advertising. There is presently insufficient causal evidence that links advertising directly with childhood obesity and that would support a ban on all food advertising directed to children. Additional research and public dialogue are needed regarding the potential benefits and consequences of instituting a food advertising ban for children. Recommending a ban may not be feasible due to concerns about infringement of First Amendment rights and the practicality of implementing such a ban (Engle, 2003).

There are historical insights that can be gained from the prior federal government efforts related to advertising food products to children. In 1978, the FTC proposed a rule that would ban or significantly restrict advertising to children, based on a long-standing and widespread concern about the possible adverse health effects from television advertising of food and beverage products to children. The FTC staff sought comment on the issues, including three proposed alternative actions (Engle, 2003).

During this process, the FTC presented a review of the scientific evidence with the conclusion that television advertising directed at young children is unfair and deceptive. The government rulemaking process found that the evidence of adverse effects of advertising on children was inconclusive, despite acknowledging some cause for concern; furthermore, it was



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