Policy update on restricting food advertising primarily directed at children: Appendices
Note: On June 9, 2023, Table 1 in Appendix B was updated to clarify that the same thresholds for saturated fat apply to foods with a reference amount of 30 g/ 30 ml or less, and foods with a reference amount greater than 30 g/ 30ml (except for main dishes).
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- Appendix A: Examples of how to determine whether an advertisement is primarily directed at children under the age of 13
- Appendix B: Nutrient profile model
Appendix A. Examples of how to determine whether an advertisement is primarily directed at children under the age of 13
To determine whether an advertisement is primarily directed at children, it is necessary to assess the context of the advertisement's presentation and, in particular, the following factors:
- Factor 1: The nature and intended purpose of the medium where the ad is communicated; and,
- Factor 2: Whether the advertisement targets, or is reasonably expected to appeal particularly to, children.
The assessment of these factors would be contextual. If a food advertisement is considered to be primarily directed at children, the food would be assessed using the nutrient profile model. Foods with added sodium, free sugars, or added fat that exceed the 'low in' nutrient content claim thresholds for sodium, sugars, and/or saturated fat would be subject to advertising restrictions.
The examples provided below are intended to illustrate the process of how each advertisement could be assessed.
Example 1: A banner ad for a salty snack on a website
A food company places a banner ad for its salty snack on the homepage of a popular gaming website that offers games for children under the age of 13 as well as games for teens and young adults. The salty snack ad features an image of the product along with the tag line "So Tasty!".
Despite appearing on a website visited by children, the medium where the ad is communicated would be considered intended for a general audience (factor 1). The advertisement itself does not appear to target children (digital targeting) and is not reasonably expected to appeal particularly to them (factor 2). Based on the contextual assessment of both factors, this ad would not likely be considered primarily directed at children. Given that the ad is not considered primarily directed at children, the nutrient profile of the advertised food would not need to be assessed.
However, the same banner ad could be considered primarily directed at children if it appeared on the child-specific section of the gaming site or if it appeared on an entirely separate gaming website that was specifically intended for children under the age of 13. It would be restricted because the advertised food has added sodium (salt) and exceeds the proposed nutrient thresholds for sodium.
Example 1 - Text description
A banner advertisement for a salty snack shown on a website for a general audience (image on the left), and a website or page intended for children under the age of 13 (image on the right).
Example 2: Ad for a sugary beverage on a television broadcast
An ad showing the Green Grape Monster Smoothie is aired during a television program rated C, which is programming intended for children according to the Canadian ratings and classification system for broadcast media. The sugary drink ad features the product with some special effects.
Considering that the television advertisement is being broadcast during a television program rated C (intended for children), the medium where the ad is communicated is considered specifically intended for children (factor 1) and would likely be considered primarily directed at them because children are the primary audience of that program.
While special effects are used in the advertisement, they are not reasonably expected to appeal particularly to children (factor 2). Based on the contextual assessment of both factors, this ad would likely be considered primarily directed at children since it was broadcast on a television program specifically intended for children (factor 1) and would be restricted because the advertised food has free sugars and exceeds the proposed nutrient threshold for sugars.
However, the same advertisement would not likely be restricted if it was aired during an unrated professional sports broadcast because the medium where the ad is communicated would not be specifically intended for children and the advertisement would not reasonably be expected to appeal particularly to them.
Example 2 - Text description
An advertisement for a sugary drink “Green Grape Monster Smoothie” shown during a program rated for children (image on the left), and during a professional sports broadcast (image on the right).
Example 3: Online ad for cookies
Chocotastic Cookies advertises their cookies in a new online game on their company website. In this digital advergame, the brand's cartoon bear character needs to complete the maze and catch all the Chocotastic Cookies.
The medium where the ad is communicated (company website) would be considered for a general audience (factor 1). However, the advertisement itself is reasonably expected to appeal particularly to children given the nature of the advergame (easy skill level, design of game) and use of the brand's cartoon mascot (factor 2). Based on the contextual assessment of both factors, this ad would likely be considered primarily directed at children and would be restricted because the advertised food has free sugars and exceeds the nutrient threshold for sugars.
Example 3 - Text description
An online game called “Chocotastic Cookies” showing a cartoon bear mascot standing in front of a maze lined with chocolate chip cookies.
Example 4: Brand advertisement on television
An ad for a snack product brand airs during a television program rated C, which is considered specifically intended for children. The advertisement does not show an identifiable food or reference the unique name of a food, but instead includes the brand's logo (the smiling mouth), mouthing the tag line "Ohhh yummm".
Since this advertisement only includes food brand elements (such as a logo, tag line), but does not show an identifiable food or reference the unique name of a food, it would be considered a brand advertisement and therefore not be captured by the restrictions. Likewise, this brand advertisement would not be restricted if aired during a program intended for a general audience, such as a PG-rated sitcom or unrated sports broadcast.
Example 4 - Text description
An advertisement for a “Cruncho” snack food showing the brand image (smiling mouth) and slogan “Oh yummm” shown during a program rated for children (image on the left), and during a program intended for a general audience (image on the right).
Appendix B. Nutrient profile model
Health Canada's proposed nutrient profile model takes a health protection approach by focussing on 3 nutrients of public health concern: sodium, sugars and saturated fat. A large body of evidence has shown the negative health impacts of these nutrients when consumed in excess.
Most of the food categories that are frequently advertised to children add sodium, sugars or saturated fat and therefore contribute to excess intakes of these nutrients.
The proposed nutrient profile model classifies foods with added sodium, free sugars, or added fat that exceed the 'low in' nutrient content claim thresholds for sodium, sugars, and/or saturated fat as being subject to advertising restrictions. Additionally, the thresholds in the nutrient profile model are based on regulated nutrient thresholds that are already familiar to the food industry.
Health Canada's proposed nutrient profile model has strong alignment with Canada's food guide. It would not restrict advertising of foods recommended by Canada's food guide. This includes vegetables and fruits, whole grain foods and protein foods with no added sodium, free sugars, or added fat. In addition, other foods or prepared meals and snacks that are 'low in' sodium, sugars and saturated fat would not be subject to restriction.
It strongly aligns with guidance to:
- choose foods that have little to no added sodium, sugars or saturated fat
- limit processed foods that contribute to excess sodium, free sugars or saturated fat
The model recognizes that these nutrients are found naturally in whole foods, so it focuses only on those foods that have nutrients of concern added to them, which leads to excess consumption and elevated health risk.
Based on extensive food pattern modelling, there is very little room in a healthy diet for foods that contribute to excess intakes of sodium, sugars and/or saturated fat. Children with an eating pattern based on nutritious foods with little to no added sodium, sugars and saturated fat are at lower risk of exceeding the maximum recommended daily amounts of these nutrients.
The nutrient profile model applies both to prepackaged foods and foods prepared in restaurants and other food service establishments. In the case of restaurant meals, each component would be assessed separately. For example, the entrée, side dish and drink would each need to be assessed against the nutrient thresholds to determine if the meal could be advertised to children.
'Low in' nutrient content claim threshold values
The 'low in' nutrient thresholds for sodium, sugars and saturated fat are equivalent to 6%, 5%, and 10% of the Daily Value, respectively (see Table 1 below).
The nutrient levels of advertised foods would only need to be assessed if the food has added sodium, free sugars or added fat. Each nutrient threshold would be applied and assessed independently, triggered by the presence of an added sodium, free sugar or added fat ingredient. For example, if a food contains an ingredient that adds sodium then the sodium threshold would be applied. Likewise, if the food contains an added sugar ingredient, including fruit juice, fruit juice concentrate, honey or syrup, then the sugars threshold would be applied.
Health Canada assessed the potential impacts of using the higher nutrient thresholds established for the Front of Package nutrition labelling regulations. While these thresholds would restrict the advertising of foods classified as 'high in' sodium, sugars or saturated fat, they would not adequately protect children, a vulnerable population with lower maximum recommended daily nutrient intakes than adults. The proposed policy has a different objective and requires different nutrient thresholds to achieve the desired outcome.
The 'low in' nutrient content claim thresholds are based on the reference amount assigned to the food. See the Table of Reference Amounts for Food for more information.
- Foods with small reference amounts (30 g or less) are assessed at 50 g
- Foods with standard reference amounts (greater than 30 g—except for main dishes) are assessed against either the reference amount, or stated serving size, whichever is larger
- Foods classified as a main dish with a reference amount of 200 g or more are assessed at 100 g
| Nutrient content claim | % Daily value equivalent | If the food has a reference amount of 30 g/30 mL or less | If the food has a reference amount greater than 30 g/30 ml, unless the food is a main dish | If the food is a main dish with a reference amount of 200 g or more |
|---|---|---|---|---|
| Low in sodium | 6% DV | 140 mg or less of sodium per 50 g | 140 mg or less of sodium per reference amount and serving of stated size | 140 mg or less of sodium per 100 g |
| Low in sugars | 5% DV | 5 g or less of sugars per 50 g | 5 g or less of sugars per reference amount and serving of stated size | 5 g or less of sugars per 100 g |
| Low in saturated fatty acids | 10% DV |
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Note: The threshold values in this table were extracted from Health Canada's Table of permitted nutrient content statements and claims . The nutrient content claims refer to 'prepackaged meals'. The term 'main dish' includes prepackaged meals and is used here to align with the language used in the Food and Drug Regulations. Main dish means a combination dish, as set out in the Table of Reference Amounts, that does not require the addition of ingredients, other than water, for its preparation and that contains food from at least 2 of the following categories:
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A food advertisement would be subject to restrictions when the advertised food exceeds 1 or more of the thresholds described in the table above. Table 2 below provides examples of how select food categories would typically be assessed by the proposed nutrient profile model.
| Not restricted | Restricted |
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Foods that have no added sodium, free sugars, or added fat, like:
Other foods that are 'low in' sodium, sugars and saturated fat, like:
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