RepoRt CaRd on Food-MaRketing poliCies - A- an analysis oF Food and enteRtainMent CoMpany poliCies RegaRding Food and BeveRage MaRketing to ChildRen doc

A
D+
A-
F
B+
B-
C
AN ANALYSIS
OF FOOD AND
ENTERTAINMENT
COMPANY
POLICIES
REGARDING
FOOD AND
BEVERAGE
MARKETING
TO CHILDREN
REPORT CARD
ON FOOD-MARKETING POLICIES
This study on corporate policies on the marketing of food to children was conducted,
and the report written, by Margo G. Wootan, DSc, Ameena Batada, DrPH, and Ona
Balkus. Additional help with data collection and analysis was provided by Arianne
Corbett, RD, Lauren McLarney, Seth Coburn, Lindsey Vickroy, and Annalisse Leekley.
CSPI and the Nutrition Policy Project
The Center for Science in the Public Interest (CSPI) is a nonprofit organization
based in Washington, D.C. Since 1971, CSPI has been working to improve the
public’s health through its work on nutrition, food safety, and alcohol issues.
CSPI is supported primarily by the 850,000 subscribers to its Nutrition Action
Healthletter and philanthropic foundations.
CSPI’s Nutrition Policy Project works with concerned citizens, health professionals,
government officials and other nonprofit organizations to strengthen national,

state, and local policies and programs to promote healthy eating and reduce obesity.
Our goals are to help reduce the illnesses, disabilities, and deaths caused by
diet- and obesity-related diseases and conditions, such as heart disease, cancer,
high blood pressure, and diabetes.
For more information on CSPI’s projects and other policies to promote healthy eating
and reduce obesity, visit
www.cspinet.org/nutritionpolicy.
Report Card on Food-Marketing Policies: An Analysis of Food and Entertainment
Company Policies Regarding Food and Beverage Marketing to Children
is available on-line, free of charge at www.cspinet.org/marketingreportcard.
Acknowledgements
The Center for Science in the Public Interest deeply appreciates the financial
support provided for this report by the Robert Wood Johnson Foundation’s
Healthy Eating Research project and CSPI members.
We thank the members of the Food Marketing Report Card advisory committee
for their advice in determining which companies to include in the study,
evaluating our assessment/grading criteria, and reviewing the report:
Angela Campbell, JD, LLM
Georgetown University
Sana Chehimi, MPH
Prevention Institute
Lisa Craypo, MPH, RD
Samuels & Associates, Inc.
Lori Dorfman, DrPH
Berkeley Media Studies Group
Roberta Friedman, ScM
Rudd Center for Food Policy
and Obesity, Yale University
Marvin Goldberg, PhD
Penn State University

Josh Golin, MA
Campaign for a
Commercial-Free Childhood
Jeff McIntyre, MA
Children NOW
Suzen Moeller, PhD
American Medical Association
Ellen Wartella, PhD
University of California, Riverside
Laurie Whitsel, PhD
American Heart Association
Makani Themba-Nixon
Praxis Project
© MARCH 2010
F
or more information,
model policies, and other
materials, contact:
MARGO G. WOOTAN, DSc
CENTER FOR SCIENCE
IN THE PUBLIC INTEREST (CSPI)
PHONE:
202 777 8352
FAX:
202 265 4954
EMAIL:

G
RADE COMPANIES GRADE COMPANIES
A

—
B+
M
ars, Inc.
B
QUBO Venture, LLC;
Procter & Gamble Company (Pringles)
B-
Nestlé USA; Kraft Foods Global, Inc.; Cadbury Adams
USA, LLC; Hershey Company; Dunkin’ Brands;
General Mills, Inc.
C+
Post Foods, LLC; PepsiCo Inc.; Public Broadcasting
Service (PBS); Coca-Cola Company
C
Walt Disney Company (including ABC, Funschool, and
Pixar); Burger King Corporation; Campbell Soup
Company; Sesame Workshop; Hostess Brands, Inc.;
Kellogg Company; ConAgra Foods, Inc. (Chef
Boyardee, Kid Cuisine, Peter Pan)
C
-
Unilever (Popsicle, Skippy); Highlights for Children,
I
nc.; Dannon Company; McDonald’s USA, LLC; H.J.
Heinz Company (Bagel Bites); Viacom International
Inc. (Nickelodeon)
D+
Sunny Delight Beverages Co.; Krispy Kreme
Doughnut Corporation; Cartoon Network;

Ruby Tuesday, Inc.
D
Doctor’s Associates Inc. (Subway);
Yum! Brands, Inc. (KFC, Pizza Hut, Taco Bell);
CEC Entertainment Concepts, L.P. (Chuck E. Cheese’s)
D-
—
F
Bob Evans Farms, Inc.; CBS Corporation;
American Dairy Queen Corporation; Discovery
Communications, LLP; Mattel, Inc.; NBC Universal,
Inc.; Univision Communications Inc.; Warner Bros.
Entertainment Inc. (New Line Cinemas)
REPORT CARD
1
FOOD-MARKETING POLICY
1
Within each grade, companies are listed from highest to lower scores.
20th Century Fox
Activision (Sierra Studios, video games)
Alloy Media and Marketing (Channel One)
AMC Entertainment
American Girl Magazine
American Greetings Corporations
Arby’s Restaurant Group, Inc.
Blizzard Entertainment (video games)
Blue Sky Studios (Ice Age, Robots)
Boys’ Life Magazine
Brinker International (Chili’s Grill & Bar)
Buffalo Wild Wings Grill & Bar

Cajun Operating Company (Church’s Chicken)
Carmike Cinemas, Inc.
Cheesecake Factory Assets Co. LLC
Chick-fil-A, Inc.
Cinemark USA, Inc.
Chipotle Mexican Grill, Inc.
CKE Restaurants, Inc. (Carl’s Jr., Hardee’s)
Darden Concepts, Inc. (Red Lobster,
Olive Garden, Longhorn Steakhouse)
Denny’s, Inc.
DineEquity, Inc. (Applebee’s, IHOP)
Domino’s Pizza
E.W. Scripps Company (Peanuts Comic)
Electronic Arts, Inc. (video games)
Golden Corral
Girls’ Life Acquisition Co. (magazine)
Hansen Beverage Company
Hasbro, Inc.
HIT Entertainment Limited (Barney, Bob
the Builder, Thomas the Train)
Hollywood Theaters, Inc.
HP Hood LLC
Jack in the Box Inc.
Kerasotes ShowPlace Theatre
Kids Discover (magazine)
Klutz (crafts and games)
LFP Publishing, LLC
(Tips & Tricks Magazine)
Little Caesar Enterprises, Inc.
Lucasfilm Ltd.

Major League Soccer, L.L.C.
Marcus Corporation (movie theater)
Marvel Characters, Inc.
McKee Foods Corporation
(Little Debbie snack cakes)
MGA Entertainment, Inc. (Bratz)
Microsoft Corporation (XBox)
MLB Advanced Media, L.P.
(Major League Baseball)
National Amusements Inc. (movie theater)
National Association for Stock Car Auto
Racing, Inc. (NASCAR)
National Geographic Society
(National Geographic Kids)
National Hockey League
National Wildlife Federation
(Wild Animal Baby Magazine,Your
Big Backyard Magazine, Ranger Rick)
NBA Properties, Inc.
NFL Enterprises LLC
Nintendo of America, Inc.
OSI Restaurant Partners, LLC
(Outback Steakhouse)
Panda Restaurant Group, Inc.
(Panda Express)
Panera Bread
Papa John’s International, Inc.
Pearson Education, Inc. (Fun Brain)
Perfetti Van Melle S.p.A. (Airheads)
Perkins & Marie Callender’s Inc.

Pilgrim’s Pride Corporation
Pinnacle Foods Group LLC
(Aunt Jemima, Lender’s, Duncan Hines)
Pokémon Company
Popeyes Louisiana Kitchen
(AFC Enterprises, Inc.)
QIP Holder LLC (Quiznos)
Rave Motion Pictures, LLC
Red Robin International, Inc.
Regal Entertainment Group
Romano’s Macaroni Grill
Ryan’s Restaurant Group, Inc.
(Hometown Buffet/Old Country Buffet)
Sara Lee Corporation
Scholastic Inc.
Schwan’s Home Service, Inc.
Sizzler Restaurants
SONIC Corp.
Sony Corporation of America
(Play Station, Sony Motion Pictures)
Sunkist Growers, Inc.
T.G.I. Friday’s Inc.
Texas Roadhouse, Inc.
Time Inc. (Sports Illustrated for Kids,
Time for Kids)
Topps Company, Inc. (Bazooka,
Ring Pop, Baby Bottle Pop)
Waffle House, Inc.
Wendy’s International Inc.
Whataburger Restaurants LP

World Wrestling Entertainment, Inc.
Zoobooks
no
poli
c y
F
Summary
The National Academies’ Institute of Medicine (IOM) concluded that television food
advertising affects children’s food choices, food purchase requests, diets, and health.
Yet, companies spend approximately $2 billion a year on marketing foods and beverages
to children, mostly for foods high in calories, fats, sugars, and sodium, and low in
fruits, vegetables, whole grains, and key nutrients.
In 2008, the Federal Trade Commission (FTC) recommended that “all companies that
market food or beverage products to children [should] adopt and adhere to meaningful
nutrition-based standards for marketing their products” and that marketing include
all advertising and promotional techniques.
In the past few years, a number of food and entertainment companies have
announced policies on food marketing to children independently or through the
Council of Better Business Bureaus’ (CBBB) Children’s Food and Beverage Advertising
Initiative (CFBAI). This report examines whether companies that market food to
children have adopted a policy on marketing to children, and if so, the adequacy
of that policy. The report does not assess whether companies complied with
their policies in practice.
During the summer of 2009, CSPI staff conducted telephone interviews and searched
company Web sites, articles in the Nexis news service, and used Google keyword
searches to collect company policies on marketing to children. We evaluated food
and beverage manufacturers, chain restaurants, and entertainment companies that
market food to children. We assessed policies for marketing to children under the age
of 12 years old and for marketing in elementary and secondary schools. Although
some children in middle schools and all children in high

schools are not under 12, schools are a unique space that
should be free of the marketing of low-nutrition foods.
We evaluated the strength of the companies’ nutrition
standards, scope of media covered by their policies,
and their definitions for “child-directed” media.
Of the 128 companies analyzed, two-thirds (68%) did
not have a policy for food marketing to children. A much
larger proportion of food and beverage manufacturers
(64%) had marketing policies than did restaurants (24%)
or entertainment companies (22%).
No company received an A for its policy. The company
with the strongest policy was Mars, which received a B+. The Mars policy did not
allow for its products to be marketed to children under 12 years old and covered most
of the key media approaches used to reach children (with the exception of on-package
marketing and most marketing in high schools).
REPORT CARD
ON FOOD-MARKETING POLICIES
AN ANALYSIS
OF FOOD AND
ENTERTAINMENT
COMPANY
POLICIES
REGARDING
FOOD AND
BEVERAGE
MARKETING
TO CHILDREN
“All companies that market food
or beverage products to children [should]
adopt and adhere to meaningful nutrition-based

standards for marketing their products” and that
marketing should include all advertising and
promotional techniques.
–Federal Trade Commission, 2008
The only entertainment company to get a B was Qubo Venture (which has a
television channel, Web site, and broadcasts its programming on NBC Saturday
mornings, ION Television, and Telemundo). Qubo had a comprehensive policy,
applying reasonably good nutrition standards to its full range of marketing.
One food company received a B, six got a B-, 17 got a C, and 7 a D. Ninety-five
companies received an F; of those, eight had very weak marketing policies and
87 did not have a policy.
Food manufacturers and restaurants were more likely to have policies for television, radio,
print, the company’s own Web site, advertising on third-party Internet sites, product
placement, and use of licensed characters in advertising. The companies were less
likely to have policies or policies were weaker for digital marketing, on-package
promotions, and marketing programs in schools.
Eight in ten entertainment companies (45 companies) did not have
a food marketing policy. When they did, those policies were generally
more limited in scope than were the policies of food and beverage
manufacturers. If entertainment companies had a marketing policy,
it most likely addressed the use of licensed characters. Policies generally
were weaker or did not exist for television, radio, print, company
Web sites, other digital media, and product placement. For example,
the Cartoon Network applied nutrition standards to the licensing of
its characters, but not to its television advertising or Web site, which
are the primary means by which it markets to children.
Of the companies with policies for marketing to children, almost all
(94%) of the food and beverage manufacturers surveyed had nutrition
standards or had policies not to market any of their products to children
under 12 years of age. Fifty percent of restaurants and 46% of entertainment

companies with marketing policies had nutrition standards.
Companies have not complied with the FTC’s recommendation to standardize
nutrition criteria for marketing to children. Each company had a different set
of standards.
ii
Center for Science in the Public Interest | www.cspinet.org
Food and Beverage
Manufacturers (n)
Companies with
marketing policies
64% (18) 24% (10) 22% (13)
Of companies
with policies,
% with nutrition
standards or did not
allow marketing
of any foods
94% (17) 50% (5) 46% (6)
Chain
Restaurants (n)
Entertainment
Companies (n)
Pizza Hut’s “Book It”
program provides pizza
as a reward for reading.
Food rewards can cultivate
unhealthy relationships
with food.
Perfetti Van Melle’s Web site
for Airheads candy includes

characters from the popular
children’s movie, Alvin
and the Chipmunks: the
Squeakquel, as well as
games and a kids’ club.
Nutrition standards were strongest for saturated fat and trans fat among all types
o
f companies.
Food companies and restaurants also tended to have strong policies for total fat.
It was more common for food manufacturers and restaurants to have weak policies
or no policy for sodium and added sugars.
Among the entertainment companies that had policies, sodium and
total fat policies were generally weak or absent.
Across all companies, a requirement for marketed food to provide positive
nutritional value — such as whole grains, fruits, vegetables, vitamins, or
minerals — was often weak or not included in the nutrition standards.
Several previous reports found that company compliance with their policies
on food marketing to children was high. However, the meaningfulness
of that compliance is questionable in light of this study finding that most
companies that market to children did not even have a policy (68%), and
the majority of existing policies were weak; three-quarters were graded
as C, D, or F.
In order for self-regulation of food marketing to children to be effective:
All food and beverage manufacturers, restaurants, and entertainment companies
that market to children should have a written food marketing policy that is readily
available to the public. Companies that do any marketing to children, even if not
during children’s television programming, should have a marketing policy.
• Although its program conditions are not ideal, all companies should belong to
the CBBB’s Children’s Food and Beverage Advertising Initiative, since its member
companies’ policies are generally clearly spelled out, available in one place for

public viewing, and compliance is monitored by the CBBB.
• The CBBB and entertainment companies should work together to develop
a set of entertainment-company-specific criteria for the CFBAI, and
entertainment companies should join the Initiative.
All companies should use a uniform set of strong nutrition standards.
Company marketing policies should cover all approaches used to market
to children. Many companies need to strengthen their policies for digital
marketing, on-package/in-store promotions, and practices in elementary,
middle, and high schools.
• Companies should adopt a uniform set of definitions for marketing “directed
to children.” A set is expected to be recommended by the Interagency Working
Group on Food Marketed to Children.
Without more significant progress in the next two years, the country will need to
rely on government regulation, rather than self-regulation, as the means to address
food marketing to children.
iii
Center for Science in the Public Interest | www.cspinet.org
1
Center for Science in the Public Interest | www.cspinet.org
Introduction
Food marketing affects children’s diets and health
In December 2005, the National Academies’ Institute
of Medicine (IOM) released a comprehensive review
of research on the influence of food marketing to
children (IOM, 2006). The IOM concluded that television
(which is by far the largest medium for advertising
to children) food advertising affects children’s food
choices, food purchase requests, diets, and health.
In addition, the committee concluded that the
foods and beverages marketed to children are out

of balance with current dietary recommendations.
Marketing to children is extensive
Companies spent approximately $2 billion in 2006 on marketing foods and beverages
to children (including toy give-aways with children’s meals at fast-food restaurants)
(FTC, 2008). Companies market food to children through traditional media, such as
television, radio, magazines, product packaging, and in-store
displays and promotions. In addition, they use many other
approaches, such as the Internet and other new electronic
media, ads in movie theaters, school-based marketing, product
placement in movies and video games, marketing in amusement
parks, food-themed toys, clothing and other merchandise, and
almost anywhere a logo or product image can be shown. Food
marketing techniques include the use of spokescharacters,
celebrities, cartoons, children’s meals and menus, premiums
(such as toys or other items distributed in product packaging,
with restaurant meals, through contests, or redeemable via
coupons, codes, or proof of purchase), games, contests, kids’
clubs, viral marketing, event sponsorship, and more.
Low-income and racial-minority populations are disproportionately exposed to television
and other media (Rideout et al., 2010), which results in heightened exposure to the marketing
of unhealthy foods. Some studies suggest that marketing of low-nutrition foods is
particularly prevalent on television channels targeting African Americans, such as BET
(Tirodkar & Jain, 2003), and Hispanic populations, such as Univision (Thompson et al., 2008).
Young people are uniquely vulnerable to food marketing
Children lack the skills and maturity to comprehend the complexities of good nutrition
or to appreciate the long-term consequences of their actions, such as that their dietary
patterns can result in cancer, diabetes, and heart or other diseases. Children of different
ages face different vulnerabilities to food marketing and diverse challenges to
healthful eating.
“Among many factors, food and beverage

marketing influences the preferences and purchase
requests of children, influences short-term
consumption, may contribute to less healthful
diets, and contributes to an environment that
puts their health at risk.”
–Institute of Medicine, 2006
REPORT CARD
ON FOOD-MARKETING POLICIES
Chuck E. Cheese “Pizza
Maker Play Set” includes
sauce powder that has
to be mixed with ketchup
and “cheese”, which has
maltodextrin as the
first ingredient.
2
Center for Science in the Public Interest | www.cspinet.org
Y
oung children do not understand the persuasive intent of advertising and are easily
misled. Based on an extensive research review, the American Psychological Association
concluded that until the age of about 8 years old children are unable to understand
the persuasive intent of advertisements (Kunkel et al., 2004). According to the IOM,
children as old as 10 years may not understand the persuasive intent of advertising
(IOM, 2006). Older children, who still do not have fully developed logical thinking,
have considerable spending money and opportunities to make food choices and
purchases in the absence of parental guidance and the absence of understanding
the long-term consequences of poor nutrition.
Most of the foods and beverages marketed to children are unhealthy
The primary reason food marketing has a negative effect on children’s diets and health
is that the overwhelming majority of marketing aimed at children is for foods of poor

nutritional quality (IOM, 2006). A study of Saturday morning children’s television
found that 91% of the advertisements promoted foods that were high in saturated
fat, added sugars, or sodium, or low in fruits, vegetables, or key nutrients (Batada
et al., 2008). A 2000-calorie diet of advertised foods would exceed recommended daily
values for total fat, saturated fat, and sodium and provide nearly 1 cup of added sugar
(Harrison and Marske, 2005). Carbonated beverages, fast food, and breakfast cereals
make up 63% of the total amount spent on marketing to youth (FTC, 2008).
Foods Advertised on Saturday Morning Television
SNACK FOODS
18%
CANDY
14%
BEVERAGES
10%
YOGURT
4%
BREAKFAST
PASTRIES
3%
FROZEN NOVELTIES
3%
PACKAGED MEALS
& ENTREES
3%
RESTAURANTS
19%
CEREAL &
CEREAL BARS
27%
3

Center for Science in the Public Interest | www.cspinet.org
P
arental authority is undermined by the wide discrepancies between what parents
tell their children is healthful to eat and what marketing promotes as desirable to eat.
In addition, while many parents have limited proficiency in nutrition, companies have
extensive expertise in persuasive techniques. They hire psychologists and research firms
to conduct marketing and neuroscience research to determine
how to most effectively influence children’s food preferences
and choices. Companies encourage children to choose foods
for fun and social acceptance, not for their nutritional or
health value (Page & Brewster, 2007). Companies also have
ready access to techniques to affect children’s food choices
that parents do not have, such as cartoon characters, contests,
celebrities, and toy give-aways.
Parents, of course, bear the primary responsibility for feeding
their children. Most parents try to get their children to eat
a balanced and healthful diet, but billions of dollars spent
on marketing low-nutrition foods to children makes it
exceedingly difficult.
Children (8 to 12 years old) view an average of 21 food ads
on television each day (Gantz et al., 2007), along with many
additional marketing messages delivered through Web sites, schools, on food
packaging, etc. Given how often companies communicate with children about food,
those who manufacture, sell, and promote food to children have an enormous, and
usually deleterious, effect on parents’ ability to feed their children a healthful diet.
Self-regulation of food marketing to children
Based on the types of food marketed to children and the research that
shows that marketing has a negative impact on children’s diets and health,
the IOM (2006) concluded that, “current food and beverage marketing
practices put children’s long-term health at risk.” Among the IOM’s key

recommendations is that food and entertainment companies should
improve the balance of foods marketed to children within two years
of the report’s 2006 issuance; otherwise, the report recommended,
Congress should step in to regulate food marketing to children.
Since the IOM report was released, a number of food and entertainment
companies have implemented policies on food marketing to children.
The Council of Better Business Bureaus (CBBB) announced the Children’s
Food and Beverage Advertising Initiative (CFBAI) in November 2006.
Thus far, sixteen food manufacturers and restaurants, representing
about 80% of television food advertising expenditures (Peeler et al.,
2009), have pledged not to market to children under 12 years old any
of their products or products that do not meet individual company
Children’s Food and Beverage
Advertising Initiative Participants:
Burger King
Cadbury Adams
Campbell Soup Company
Coca-Cola Company
ConAgra Foods
Dannon
General Mills
Hershey
Kellogg
Kraft Foods
Mars
McDonald’s USA
Nestlé USA
PepsiCo
Post Foods
Unilever United States

4
Center for Science in the Public Interest | www.cspinet.org
n
utrition standards. To participate in the CBBB Initiative, companies are asked to
address advertising through measured media (television, radio, print, and Internet),
product placement, and some types of advertising in elementary schools.
A number of beverage and snack food companies have agreed to
limit the sale of low-nutrition beverages and snacks in elementary,
middle, and high schools through an agreement with the Alliance
for a Healthier Generation, a partnership of the William J. Clinton
Foundation and the American Heart Association. The School
Beverage Guidelines and the Competitive Food Guidelines were
adopted in 2006 (AHG, 2009).
Several entertainment companies also have announced efforts to
address food marketing to children, primarily by setting nutrition
standards for foods which can be associated with characters that
they license. In addition, a few companies have announced that
they will apply their standards to other types of marketing, such as sponsorships and
the company’s own Web site. No entertainment companies belong to the CBBB’s CFBAI.
Food marketing to children report card
Studies have found that companies’ compliance with their own policies on food
marketing to children is high. The CBBB has completed two assessments on the
compliance of companies that belong to the Children’s Food and Beverage Advertising
Initiative with their marketing policies (Peeler et al., 2009; Peeler & Kolish, 2008).
The CBBB evaluated compliance through company reports and monitoring of 54
hours of children’s television programming in 2009 (Peeler et al., 2009). The Center
for Science in the Public Interest (CSPI) also found high compliance by CFBAI companies
with their stated marketing policies by evaluating the nutritional quality of products
approved by companies for marketing to children and monitoring advertising in
28 hours of children’s television programming on Nickelodeon in 2009 (Batada

& Wootan, 2009).
If compliance is strong, the next key question is “compliance with what?” How strong
are company policies for food marketing to children? If the U.S. Congress, Federal
Trade Commission, other policy makers, advocates, and parents are to assess the
effectiveness of self-regulatory efforts, they need a comprehensive analysis of company
marketing policies.
The Federal Trade Commission has recommended that “all companies that market
food or beverage products to children should adopt and adhere to meaningful
nutrition-based standards for marketing their products” and that marketing should
include all advertising and promotional techniques (FTC, 2008). Previously, CSPI
summarized company marketing policies and the nutrition standards for marketing
to children for a number of food manufacturers, restaurants, and entertainment
companies (CSPI, 2009a; CSPI, 2009b). However, a need has been identified to analyze
in more detail the strength of those policies and the policies of additional companies.
Imagination Farms
uses popular Walt Disney
characters to promote
fresh produce to children.
5
Center for Science in the Public Interest | www.cspinet.org
I
n this study, we set out to meet that need by assessing many more companies’
policies and evaluating the relative strength of each policy. This assessment was a
challenging undertaking given that each company has a different policy that applies
to different media and that has unique nutrition standards and different definitions
of media considered to be directed at children. Unlike content analyses that have
measured the balance of less nutritious versus more nutritious foods advertised
to children, the Report Card on Food-Marketing Policies assesses the strength of each
company’s marketing policy.
Methods

Our initial sample included 142 food and entertainment companies that market food to
children: 42 food and beverage manufacturers, 42 chain restaurants, and 58 entertainment
companies.
2
To identify companies that market food to children, we consulted previous
studies and reports, including the FTC’s 2008 report on food marketing expenditures
to children (FTC, 2008) and studies on food marketing on the most popular children’s
Web sites (by number of visits) (Moore, 2006; Lingas et al., 2009).
We included companies identified as the top 100 food processors (Fusaro, 2008) and
top 100 restaurants (Hume, 2008). Of those 200 companies, we determined which
had children’s sections on their Web sites, children’s meals/menus, corporate programs
for children or schools, or other marketing for children. In addition, we included
companies that license the most popular children’s characters; that were one of the
top movie-theater chains, children’s television channels, or video-game producers;
and that produced the top children’s movies or magazines (NATO, 2009; FTC, 2008;
Jones, 2008; Nielsen, 2008; Ad Age, 2003). All 16 companies that have policies through
the Council of Better Business Bureaus’ Children’s Food and Beverage Advertising
Initiative were included in the study.
Although they were included in the FTC expenditures study (FTC, 2008), we did not
assess policies for three check-off programs (i.e., commodity promotion boards).
3
We also excluded from the grading 11 produce companies.
4
While, ideally, all companies
that market to children should have a marketing policy, those companies market
only fruits and vegetables — healthful foods that are greatly under-consumed by
children. Thus, we evaluated a total of 128 companies (142 companies minus three
check-off programs and 11 produce companies).
2
In most cases, we analyzed the marketing policy of the parent company. Several of the parent companies

in the study operated more than one restaurant concept or media subsidiary that markets to children. For
example, Yum! Brands operates KFC, Pizza Hut, and Taco Bell.
3
California Milk Advisory Board, California Milk Processor Board, and National Fluid Milk Processor
Promotion Board (MilkPEP).
4
Boskovich Farms, California Giant Berry Farms, Chiquita, Delmonte Fresh Produce, Dole Food Co.,
Grimmway Enterprises, Imagination Farms, Ready Pac Produce, Stemilt Growers, Summeripe Worldwide,
and LGS Speciality Sales.
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Center for Science in the Public Interest | www.cspinet.org
W
e evaluated company policies for marketing to children under 12 years old.
We included an assessment of not only primary schools, but also secondary school
marketing policies. Middle schools include children under 12 (the average sixth
grader is 11 years old). Although, all high school students are over 12 years old,
schools are a unique place, where children are required to be in attendance
and parents are not present to help guide their food choices.
We called each company and administered a questionnaire that explored each
company’s policies and nutrition standards for food marketing to children. The
questionnaire was developed in consultation with the project’s advisory board,
including experts in the areas of child health and welfare, marketing, media, policy,
health, and nutrition. In addition, we searched for publicly available information
about the company’s marketing practices and policies through reviews of company
Web sites and Nexis news service and Google keyword searches.
During the summer of 2009, research assistants called each company and
asked to speak with a staff person who would be able to answer questions
pertaining to the company’s policy for food marketing to children. Of 128
companies, 11 refused to participate and 27 contact people did not respond to
repeated (more than five) calls, for a response rate of 70%. If a contact person

did not respond to repeated calls and no marketing policy was identified through
the company Web site and Nexis and Google searches, we categorized the
company as not having a policy for food marketing to children (27 companies).
Information from the completed questionnaires and Internet searches was analyzed
to determine how many companies had policies and the content of each company’s
policy. The policies were rated in comparison to the model policy outlined in CSPI’s
Guidelines for Responsible Food Marketing to Children (CSPI, 2006), which are based
on key nutrition recommendations in the Dietary Guidelines for Americans (DHHS
& USDA, 2005), and in consultation with the project advisory board. Criteria included:
Strength of the nutrition standards:
• Beverage standards were evaluated by categories of beverages not permitted
for marketing (for example, soda, sports drinks, juice drinks, and high-fat milk).
• Food and meal standard were assessed for limits on total fat, saturated fat,
trans fat, sodium, and added sugars, and a requirement for positive nutritional
content (whole grains, fruits, vegetables, or key vitamins or minerals).
• For companies that had different nutrition standards for different categories
of foods, we scored each set of nutrition standards and averaged them.
• Companies that had policies not to market any food products to children
received the maximum allotted points for nutrition standards.
Scope of media covered by the policy and the strength of definitions
of child-directed media.
7
Center for Science in the Public Interest | www.cspinet.org
•
The points assigned to different types of media were weighted based on
the predominance of the media type in the FTC’s marketing expenditures
study (FTC, 2008). For example, more weight was given to policies for
television than for radio and print marketing.
• While the criteria for food companies and entertainment companies were
identical for the nutrition standards, there were some differences for the

assessment criteria for media approaches:
For food and beverage manufacturers and restaurants, we assessed
polices for television; radio; print; company-sponsored Web sites; third-
party Internet advertising; other digital marketing, such as through cell
phones, email, and portable electronic devices; use of licensed characters
and cross promotions with movies and television programs; product
placement; packaging and in-store displays; marketing in elementary,
middle, and high schools; and marketing in out-of-school settings
for children.
For entertainment companies, the same marketing approaches were
analyzed, with the exception of third-party Internet sites and schools.
Those two approaches were excluded, since entertainment companies
market their own products (movies, television shows, magazines, etc.),
not food, through those outlets.
Entertainment companies’ scores were based on the types of child-directed
media outlets owned by the company. For example, Highlights for Children
(publisher of Highlights Magazine) was graded on their marketing policies for
print, company-sponsored Web site, cross promotions, and product placement.
Its score was not affected by marketing outlets that the company did not
own, such as television or radio.
As we undertook the study, we realized that we could have included even
more categories of companies. For example, one limitation of the study is that
it did not include grocery chains or book publishers (other than Scholastic, which
was included along with the publishers of other top children’s magazines).
This analysis was cross-sectional at one point in time; some company policies
may have changed since we collected our data in the summer of 2009. In
addition, it is important to reiterate that we examined company policies on
food marketing to children, not practices. For many companies, their policies
and practice align. We did note a few companies where they did not. For
example, Subway and Ruby Tuesday appear to have stronger practices than

their policies reflect. We suspect that some companies that have not used,
and perhaps have no plans to use, certain marketing practices did not include
them in their policy. We encourage companies to strengthen their policies
to reflect their practices and to cover all media available to them.
8
Center for Science in the Public Interest | www.cspinet.org
Results and Discussion
Two-thirds of companies lack a marketing policy
Of the 128 companies that we analyzed that market foods
to children, one-third (32%) had a policy to govern their
marketing practices. A much larger proportion of food
and beverage manufacturers (64%) had marketing policies
than did restaurants (24%) or entertainment companies
(22%) (Figure 1).
No company received an A for its policy. The company
with the strongest policy for food marketing to children
was Mars, which received a B+. The Mars policy did not
allow for its products to be marketed to children under
12 years old and covered most of the key media approaches
used to reach children (with exception of on-package
marketing and most marketing in high schools).
The only entertainment company to get a B was Qubo
Venture (which has a television channel, Web site, and
broadcasts its programming on NBC Saturday mornings,
ION Television, and Telemundo). While most entertainment
companies’ policies covered only a small segment of their
marketing to children, Qubo applied reasonably good
nutrition standards to its full range of marketing. Procter
& Gamble, which advertised Pringles, also received a B.
70

60
50
40
30
20
10
18
10
10
32
13
45
FOOD AND
BEVERAGE
(64%)
RESTAURANTS
(24%)
ENTERTAINMENT
(22%)
Figure 1: Companies with Marketing Policies
NO POLICY POLICY
Type of company
(% of companies with marketing policies)
Number of companies
Examples of Vague Marketing Policies:
Warner Bros. Entertainment, Inc.: “Balance
our portfolio of licensed/promotional food and
beverage products featuring our entertainment
characters to include an assortment of healthier
or better-for-you offerings” (no definition of

healthier foods was given).
American Dairy Queen Corporation:
“ADQ does not intentionally target children
with national or local TV, radio or print
advertising, nor market food or treats to
children in school settings.” (While this policy
sounds promising, no definitions of child-
directed advertising were specified. Also,
the company markets to children through
its child-directed Web site, deeqs.com, and
kids’ meals).
Discovery Communications, LLC: “Will only
license characters to use with better-for-you
foods…based on internal nutrition standards”
(the company would not share the nutrition
standards).
9
Center for Science in the Public Interest | www.cspinet.org
S
ix companies earned a B-, 17 received a C, and 7 a D. Those companies had key
weaknesses in their nutrition standards, the range of marketing covered, and/or
definitions of child-directed marketing. Ninety-five companies received an F. Eight of
those companies had marketing policies, but the policies were extremely weak or vague.
The other 87 companies did not have policies and thus, received an F grade. Some
companies responded to our questionnaire stating that they do not market food to
children. However, while many of those companies did not advertise on children’s
television, they did market to children in other ways. For example, many chain
restaurants that did not have marketing policies marketed to children through
children’s menu items and menus, fundraisers for schools, toy give-aways, movie
tie-ins, children’s sections on company Web sites, youth sports sponsorships, and

kids’ clubs. No national movie theater chain had a marketing policy, though many
marketed to children through advertisements before movie showings, kids’ foods
or combo deals at concession stands, kids’ movie clubs, and contests.
Marketing policies varied by type of media
Food manufacturers and restaurants
The strength of food manufacturers’ and restaurants’ policies for food marketing
to children varied by the type of media (Figure 2). Of the 28 food manufacturers
and restaurants with marketing policies, slightly over 50% had good
5
policies for
5
A company policy in the top half of the highest possible score for a particular medium was categorized as
good, and scores in the bottom half were classified as weak. For example, the top score for a company’s
television policy was eight. Television scores of 5 to 8 were categorized as good, and scores of 1 to 4 were
categorized as weak.
100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
15
8
4
T
V

RAD
IO
PRINT
DIGITAL
COMPAN
Y
WEB
SITE
IN
TERN
ET
ADVERTISIN
G
CH
ARACT
ERS/
T
IE-IN
P
RODU
CT
P
LACEMEN
T
ON
-PACKAGIN
G/
IN
-STORE
Figure 2: Food Company and Restaurant Policies By Media Type

GOOD WEAK N/AVAGUE/NO POLICY
Type of media
1
14
7
6
1
15
5
7
1
15
6
7
0
13
7
8
0
10
4
11
3
15
5
7
1
21
1
6

0
7
4
17
0
Percentage of companies
Many food companies and restaurants,
including Panda Express, have children’s
sections on their Web sites.
10
Center for Science in the Public Interest | www.cspinet.org
t
raditional measured media, such as television, radio, and print (mostly children’s
magazines), as well as for the company’s own Web site. Slightly under half (46%)
had good policies for advertising on third-party Internet sites. Nineteen percent to
30% of food manufacturers and restaurants had weak policies for the above media,
and 15-29% had no policy to address those media or the policy was so vague as
to be meaningless.
Definition of child audience: A company’s definition of what is considered to be
child-directed marketing is a key determinant of the scope of where a company ends up
marketing its products. Yet, many companies had vague definitions and did not specify
the audience composition for what they considered to be child-directed marketing.
Companies with clearer policies defined child-directed marketing as having an
audience that ranged from about 18% to 50% under 12 years old. Eight companies
defined television advertising as targeting children if more than 50% of the audience
was under 12 (Figure 3). Six companies defined child-directed marketing as having
more than 35% of the audience under 12. Three (Burger King, Hershey, McDonald’s)
used a cutoff of 30%, and one (Mars) used a cutoff of 25%. Campbell used the strongest
cutoff, of about 18% (twice the proportion of children in the U.S. population). Higher
scores were given to companies with policies that coupled lower audience cutoffs

with additional criteria, such as if the medium was identified as targeted to children
or included child-directed themes, characters, or animation.
Seven companies had policies that did not permit any of their products to be marketed
to children under six (even if the products met nutrition standards) (Table 1). Six
additional food manufacturers and two restaurants, as well as one entertainment
company, had policies to not market any of their products to children under 12.
Such protections are commendable given that young children do not understand
the persuasive intent of advertising and are easily misled (Kunkel et al., 2004).
35% OR MORE
30% OR LESS
NONE
Figure 3: Definition of “Child-Directed”:
Food and Restaurant Companies
50% OR MORE
8
6
5
9
A coloring sheet available
from Red Robin’s Web site
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Center for Science in the Public Interest | www.cspinet.org
Product placement: Of all the different types of marketing other than television, food
processors and restaurants were most likely to have policies on product placement
(i.e., the integration of product marketing into movies, television programming, video
games, or other media). Of the food companies with marketing policies, 75% had policies
on product placement (Figure 2). In contrast, only a third (33%) of entertainment
companies had policies on product placement [that was of companies that 1) had a
marketing policy and 2) that had media into which product marketing could be integrated].
Licensed characters and cross promotions: Use of licensed characters and tie-ins

with movies, television programs, or other media are common marketing techniques,
amounting to $208 million worth of marketing a year (FTC, 2008). About half (56%) of
the manufacturers and restaurants with marketing policies had good policies for the
use of licensed characters and tie-ins (Figure 2). A common weakness of the policies
was that they had vague definitions of when the use of licensed characters would be
considered to be directed to children. In addition, many of the policies applied only
to the use of characters in advertising and not to on-package marketing. Finally, the
policies did not apply to the company’s own equity characters (i.e., company-owned
characters such as, Keebler elves, the M&Ms characters, or the Trix rabbit). Many of
those characters are well-known to children and attract children to product packages
or advertisements.
Digital media: Policies were weakest for digital media and on-package/in-store
marketing to children (Figure 2). Only 40% of food manufacturers and restaurants that
had marketing policies had good ones regarding digital media (other than television
or Internet), such as social networks, text messaging, mobile phones, and other new
media. Sixteen percent had weak policies and 44% had vague or no policies.
The Kaiser Family Foundation’s study of children’s media use found that the increase
in children’s media use over the last five years was driven by mobile media (Rideout
et al., 2010). Ownership of cell phones by 8 to 18 year olds has increased from 39%
to 66% of children and MP3 ownership has increased from 18% to 76% of kids. Given
the growth of the digital market place (in part due to lower costs for many of these
“NO ADVERTISING”
TO CHILDREN UNDER 6 POLICY
“NO ADVERTISING”
TO CHILDREN UNDER 12 POLICY
Campbell Soup Company
General Mills
Kellogg Company
Kraft Foods
Nestlé USA

Post Foods
Unilever
Cadbury Adams
Coca-Cola Company
Dunkin’ Brands
Hershey Company
Highlights for Children
H.J. Heinz Company
Krispy Kreme Doughnut Corporation
Mars, Inc.
Procter & Gamble Company
Table 1: Policies to Limit All Marketing to Children
Topps Company’s Facebook
page for Ring Pop candy
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Center for Science in the Public Interest | www.cspinet.org
m
arketing approaches relative to traditional media, and children’s
ready adoption of new media) and the ability of companies to precisely
target such marketing, it is essential for companies to have strong
policies on digital marketing to children.
On-package and in-store marketing: Sixty-one percent of food
manufacturers and restaurants with marketing policies did not
have a policy, or had only a vague policy, regarding on-package
and in-store marketing (Figure 2). On-package marketing includes
licensed characters, cross-promotions with television shows and
movies, company-owned equity characters, games, promotion
of company Web sites, images of premium give-aways, contests,
and the general design of packaging to make the product stand
out and appeal to children.

In-store promotions include product samples, events, signs, and
displays. Companies also pay slotting fees to acquire strategically
positioned shelf space so that children can see and reach their
products without assistance from their parents.
Only 25% of food companies and restaurants had a good policy
for on-package/ in-store marketing (including General Mills, Hostess
Brands, Kellogg, Nestlé, and Procter & Gamble). The FTC marketing
expenditures study found that companies spent $195 million a
year on such marketing, the second highest category of marketing
expenditures after television (FTC, 2008).
Entertainment companies
Entertainment companies market foods to children through
ads on their television channels, radio stations, Web sites, and in
magazines; licensing their movie or television characters to appear
on product packaging or in ads; allowing products to be integrated
into the content of their movies, television programs, books,
or video games; showing ads in their movie theaters or DVDs;
and other means.
Compared to food manufacturers and restaurants, entertainment
companies’ policies covered fewer types of marketing approaches.
The type of marketing most often addressed by entertainment
companies was licensed characters (Figure 4); 50% of the entertainment companies,
which had policies and characters that could be licensed, had good policies that
limited the use of their characters to foods that meet nutrition standards.
One-third (33%) of entertainment companies had good policies for restricting food
product placement through its programs or other media outlets (Nickelodeon, PBS, Qubo,
and Sesame Workshop). A quarter had good policies for television advertising (27%)
or marketing on their own Web sites (25%; Disney, Highlights Magazine, and Qubo).
Unilever’s Web site for Popsicles
features characters from the

Twentieth Century Fox film
Ice Age: Dawn of the Dinosaurs.
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Center for Science in the Public Interest | www.cspinet.org
Qubo was the only entertainment company to receive the maximum allotted points for
television advertising. Disney, PBS, and NBC
6
had policies that included some steps to
address television advertising. For example, the main Disney Channel’s policy was to
not accept any outside advertising (including for food) and to set nutrition standards
for sponsorship spots. Other Disney-owned channels, however, such as Disney XD
and ABC, did not have nutrition standards for children’s television advertising. PBS’s
policy limited advertising to “sponsorship spots,” which could not include depictions
of specific products including food. However, spots for brands, such as McDonald’s
and Chuck E. Cheese’s, which include predominantly low-nutrition foods, were not
limited by PBS.
Finally, one entertainment company (Disney) had a good policy for digital marketing,
one had a good policy for print advertising (Highlights Magazine), but none had a good
policy for radio advertising.
School-based marketing
In schools, children are a captive audience. Unhealthy foods are available in many
schools, but parents are not present to guide their children’s food choices or mitigate
the influence of marketing. Schools are a major channel for food marketing to children.
According to the FTC’s 2008 food marketing expenditures report, marketing in schools
was the third-largest category of marketing to children, with $186 million spent in a year.
6
Though NBC had a policy to address television, it lacked nutrition standards to make the implementation
of that policy meaningful.
100%
90%

80%
70%
60%
50%
40%
30%
20%
10%
3
2
6
2
TV
1
3
9
RADI
O
1
2
6
4
PRI
NT
3
2
7
1
COM
PANY

WEB SI
T
E
1
6
6
6
6
1
DI
G
I
T
AL
CH
ARACT
ERS/
T
I
E-
I
N
P
RODU
CT
P
LACEM
EN
T
3

1
6
3
Y
OU
T
H
SET
T
I
N
G
S
GOOD WEAK VAGUE/NO POLICY N/A
Percentage of companies
Type of media
Figure 4: Entertainment Company Policies by Type of Media
0
0
4
8
1
0
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Center for Science in the Public Interest | www.cspinet.org
Other than on-package marketing, school marketing policies were the weakest
component of food manufacturers’ and restaurants’ marketing policies (Figure 5).
We did not assess school marketing policies for entertainment companies, as they
market their own company or its products (movies, channels, shows, magazines,
etc.), not food, in schools.

More food manufacturers and restaurants had policies for marketing in elementary
schools (79%) than in middle (46%) or high schools (46%). However, the percentage
of companies with good policies was only slightly higher for elementary schools
(29%) than for middle (25%) or high schools (21%).
Many companies’ policies fell short because they applied only the minimal standards
for school-based marketing called for in the Children’s Food and Beverage Advertising
Initiative (CFBAI, 2009). Those standards are insufficient to address food marketing
on school campuses for several reasons.
One is that the CFBAI guidelines only cover elementary schools. While we understand
that the CFBAI is limited to children under 12 years of age, the program should, at
the very least, cover any school in which there are children under 12 years attending,
including most middle schools, where the average 6th grader is 11 years old.
As many companies acknowledge, schools are a unique environment. Just as children
under 12 years are vulnerable to the persuasive intent of television and other commercial
media messages, older students have other unique vulnerabilities. Older children have
more money and opportunities to make food purchases without their parents’ guidance.
Parents should be assured that all schools are healthy places that do not undermine
efforts to feed their children (of all ages) healthfully. The CFBAI should expand its guidance
to include high schools, where a great deal of in-school food marketing takes place.
100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
8

14
5
1
7
6
14
1
6
7
14
1
ELEMENTARY
SCHOOL
MIDDLE
SCHOOL
HIGH
SCHOOL
GOOD WEAK VAGUE/NO POLICY N/A
Percentage of companies
Figure 5: In-School Marketing Policies
by Food Manufacturers and Restaurants
Krispy Kreme markets their
doughnuts to children through
school-based fundraisers.
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Center for Science in the Public Interest | www.cspinet.org
A
nother major problem with the CFBAI school advertising guidelines is that they only
cover a part of food marketing in schools – direct advertising, which the CFBAI describes
as “commercial sales messages,” such as those on posters, signs (when not part of a

display), coupons, and cafeteria tray liners (when not related to a specific product that
a school is selling) (CFBAI, 2009) (Table 2). Other types of marketing for low-nutrition
foods are allowed, including food sales, display devices (e.g., racks, coolers, and vending
machines), branded fundraisers, public service announcements including brands (if the
brand is not a prominent part of the PSA), and other approaches.
The CFBAI program omits product sales themselves as a form of in-school marketing,
despite the fact that product sales are a major — and perhaps the most influential — type of
marketing in schools. Nationally, 83% of elementary schools, 97% of middle/junior high
schools, and 99% of senior high schools sell foods and beverages through vending machines,
school stores, or a la carte in the cafeteria (O’Toole et al., 2007). Although healthier foods and
beverages are becoming increasingly available, common items sold outside of school meals
include candy, sugary drinks, chips, cookies, and snack cakes (CSPI, 2004; Kann et al.,
2005; O’Toole et al., 2007; USDA, 2007). The sale of low-nutrition foods outside of school
meals is associated with increases in children’s body mass index (BMI) (Kubik et al., 2005).
A number of companies (including, Coca-Cola, PepsiCo, Campbell, Dannon, Kraft, and
Mars) have agreed to the Alliance for a Healthier Generation’s nutrition standards for food
and beverage sales in elementary, middle, and high schools (AHG, 2009). However, many
other companies did not have nutrition standards for the foods they sell in schools.
Other school fundraising activities also are omitted from the CFBAI school marketing
standards. Children are marketed to through a variety of branded fundraising programs
and activities in schools, such as enlisting students to sell Hershey candy bars or Little
Caesars pizza kits, promoting Subway cards through the schoolPAX program, holding
fundraising nights at McDonald’s, Pizza Hut, or Chik-fil-A restaurants, and participating in
Campbell or General Mills label redemption programs. The majority of foods sold through
school fundraisers are of poor nutritional value. For instance, about half of elementary
schools and two-thirds of high schools sell chocolate candy through fundraisers (O’Toole
et al., 2007). Given the high rates of childhood obesity and children’s poor diets, companies
should not enlist students in selling low-nutrition foods to help schools raise money.
Regardless of the CFBAI guidelines, all food manufacturers and restaurants should
apply their companies’ nutrition standards to any foods or brands that are part of

school fundraising activities.
Through the CFBAI, companies may provide “personal appearances of spokescharacters or
third-party celebrities, taped announcements featuring celebrities, posters or functional
items such as book covers” (CFBAI, 2009). Whether a company actually shows a picture of
a Happy Meal (which is not allowed) or has Ronald McDonald visit the classroom (which
is allowed), both are marketing for McDonald’s — marketing all its meals, including those
that do not meet its nutrition standards. Similarly, educational curricula and incentive
programs often still contain marketing even if the brand logo is small compared with
the other text on materials. For example, getting pizza in return for reading books is
central to the Pizza Hut’s Book It! Program.
Marketing via vending machine
exteriors is not covered by the CFBAI.
16
Center for Science in the Public Interest | www.cspinet.org
Table 2: School Food Marketing Approaches Covered
by the CFBAI Elementary Food Advertising Principles
Not AllowedType of Marketing
Product Sales — All food sales
Advertising Direct advertising —
Displays & other
marketing promoting
food sales
— • Vending machine exteriors
• Menus & menu boards
• Branded display racks
• Branded coolers &
refrigerator cases
Posters directed
at students
Posters or tray liners that

feature specific products
or brands not tied to or
related to items being
offered for sale
Posters, signage, and tray
liners that feature specific
products or brands tied to
or related to items being
offered for sale
Teaching materials
and incentive programs
Branded curricula and
other materials with sales
messages or embedded
branded products
• Branded curricula and
other materials that identify
sponsor or provider of
materials
• Branded food reward
programs (e.g., for reading,
good grades, or good
conduct) and adult-directed
marketing materials about
reward program
Materials for students
and staff
Coupons, food samples,
pencils, book covers, etc.
• Branded materials for staff

(e.g., caps, calendars,
aprons, etc.)
Fundraising and donations
— • Fundraising programs (e.g.,
label redemption programs)
• Formal gift-giving programs
• In-kind donations of
branded food (e.g., ready-to-
eat or packaged)
• In-kind donations of branded
supplies (e.g., plates or cups)
• Events off school campus
(e.g., fundraising nights at
restaurants and the in-school
promotions for those events)
Other
Public service
announcements with
prominent brand or product
depictions
• Events after the extended
school day (e.g., family nights)
• Spokescharacters,
celebrities, and other public
service announcements, as
long as company name or
brand is “not central”
Allowed
17
Center for Science in the Public Interest | www.cspinet.org

T
he CFBAI and its member companies unpersuasively argue that some types of school
marketing do not target students, but are simply a way to inform school staff and
parents. For example, a large collection bin for General Mill’s Box Tops for Education
placed in the front hallway of a school is not considered marketing to students. Also,
students usually are the ones to bring the box tops into school. In addition, branded
mementos and promotional items, such as branded caps, aprons, cups, and calendars,
may be given to school staff and faculty, and often are seen by children. We see no
difference between such items and a poster, and disagree that such marketing is
only incidentally viewed by children (CFBAI, 2009).
Finally, the CFBAI covers the entire school campus, grounds, and buses for the regular
school day, but omits school-sponsored activities that take place through the extended
school day. Children should not be exposed to marketing for low-nutrition foods at
any school events, at any time.
Nutrition standards
Of the food and beverage manufacturers with policies for marketing to children,
almost all (94%) had nutrition standards or had policies not to market any of their
products to children (Figure 6). In addition, 50% of restaurants and 46% of entertainment
companies with marketing policies had nutrition standards. Sixty-one percent of food
processors, 50% of restaurants, and only 15% of entertainment companies had good
7
nutrition standards or had policies not to market any food to children.
8
100%
90%
80%
70%
60%
50%
40%

30%
20%
10%
11
6
1
5
5
2
4
7
FOOD AND
BEVERAGE
RESTAURANT ENTERTAINMENT
Figure 6: Nutrition Standards by Company Type
GOOD OR NO MARKETING WEAK VAGUE/NO POLICY
Type of company
Percentage of companies
0
7
Overall nutrition standards in the top 30 percent of the highest possible score were categorized as good.
For individual nutrient standards (i.e., fats, sodium, added sugars, etc.), a standard in the top half of the
highest possible score was categorized as good, and scores in the bottom half were classified as weak. For
example, the top score for sodium standards was eight. Sodium standard scores of 5 to 8 were categorized
as good, and scores below 5 were categorized as weak.
8
Companies that had policies not to market any food products to children under 12 (see Table 1) received
the maximum allotted points for nutrition standards.
18
Center for Science in the Public Interest | www.cspinet.org

100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
13
1
TOTA
L FA
T
S
AT
URAT
ED FAT
TR
AN
S
FAT
ADDED
SU
G
ARS
SODIU
M
P

OSITIVE
N
U
T
RIT
ION
CON
TEN
T
P
ORT
ION
SIZE
Figure 7: Food Company and Restaurant Nutrition Standards
GOOD WEAK NO POLICY
12
1
1
14
9
3
2
8
6
2
8
4
10
1
3

Percentage of companies
F
ood companies and restaurants
Most food manufacturers and restaurants that had nutrition standards
h
ad strong standards for total fat (93% of companies), saturated fat (86%),
and trans fat (100%) (Figure 7). A smaller proportion of companies had good
standards for sodium (64%), added sugars (57%), or portion sizes/calories
(71%). Several companies that make foods high in sodium had weak or no
sodium standards, including Subway, McDonald’s, and Campbell’s (which
had reasonable standards for soups, but not for Pepperidge Farm-brand snacks).
9
The major cereal manufacturers had weak added-sugars standards.
10
While almost three-quarters (71%) of companies had a policy for ensuring that
marketed products have some positive nutritional value, only 14% of those policies
were good. A common weakness was that the policies allowed for the positive
nutritional value to be provided through fortification. For children to get the
most benefit from foods, the positive nutritional value provided by a marketed
product should be naturally occurring in the product, rather than through
added vitamins or minerals.
9
Since our data was collected, Campbell announced it would reduce the sodium in SpaghettiOs canned pastas.
10
Since our study was conducted, General Mills announced a strengthening of its sugars standard for cereals
advertised to children.
19
Center for Science in the Public Interest | www.cspinet.org
O
nly a small number of companies had nutrition standards for marketing beverages

to children. Nestlé had excellent and PepsiCo had okay beverage standards. Nestlé’s
policy limited marketing of high-fat milk and juice drinks. PepsiCo’s policy did not allow
soda or juice drinks to be advertised to children. However, the company lost points
for allowing the marketing of sports drinks (Gatorade) to kids. While sports drinks
are lower in calories than regular soda, they are empty-calorie beverages that get
all of their calories from sugars.
Entertainment companies
Few entertainment companies had nutrition standards (Figure 8); only Cartoon Network,
Disney, Qubo, and Sesame Workshop did. In addition, Highlights Magazine had a policy
that did not allow any food advertising (thus, it did not have nutrition standards and
is not included in Figure 8).
Entertainment companies with nutrition standards were most likely to have
good standards for portion sizes/calories, saturated fat, trans fat, and added
sugars. Standards for sodium and total fat were evenly split between good
and weak standards. All company standards for ensuring that marketed
foods provide positive nutritional value were weak.
100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
2
6
2
TOTA

L FA
T
S
A
T
URA
T
ED FA
T
TR
AN
S
FAT
ADDED
SU
G
ARS
SODIU
M
P
OSIT
IVE
N
U
T
RIT
ION
CON
T
EN

T
P
ORTION
SIZE
Figure 8: Entertainment Company Nutrition Standards
GOOD WEAK NO POLICY
3
7
7
3
2
2
6
3
6
1
4
6
4
6
Percentage of companies