Framework for Responsible Food and Beverage MARKETING Communication

October 19, 2011 


The increasing worldwide attention to diet, physical activity and health is increasing the role and the responsibilities of the food and beverage industry and to the broader business community towards the communication of such products. While recognizing the freedom of commercial speech, in the same time the responsible communication of food and beverages suggests that the advertising and marketing communication should be not only legal, honest, fair, and not misleading, but to give consumer a good understanding of the role of the healthy eating and physical activity in the balanced way of living.

The National Council for Self-regulation (NCSR) pays particular attention to the standards for communication reaching children, given their lack of experience and their still undeveloped ability to assess the information they receive through advertising and marketing communication. This is why the current framework for responsible food and beverage marketing communication, adopted by NCSR, pays special attention to the advertising and communication reaching children. At the same time, the responsibility that parents and other adults have for children’s well-being and health, including dietary choices and physical activity, must be taken into account. Moreover, parents, teachers, the media and other institutions are responsible for developing children’s ability to distinguish and understand marketing messages so that they are well informed and equipped to make responsible decisions for themselves.

The current Framework for responsible communication constitutes an integral part of the National Ethical Rules for Advertising and Marketing Communication (Code of Ethics). The Framework specifies the application of some of the general rules of the Code to the foods and beverages and should be interpreted and applied along with the Code itself.      

General Terms 

1.     Information on the nutritional properties of foods and beverages and claims of nutritional and health benefits should be based on sound scientific evidence.    

2.    Claims should be conveyed consistent with the nature and scope of the evidence, providing the consumer with information that can be corroborated. 

3.     Nutrition information and claims should also be judged by the likely perception of the reasonable consumer, especially where children and young people are concerned.

4.     Marketing communication relating to food and beverages should not encourage or condone excess consumption and portion sizes should be appropriate to the setting portrayed.

5.     Marketing communication should not undermine the importance of healthy lifestyles.

6.     Marketing communication should respect the spirit and the rules of   NCSR for self-regulation in advertising and marketing communication in Bulgaria and the branch systems of self-regulation.


7.   Where claims or terminology used in marketing communication might reasonably be interpreted by a consumer as health or nutrition claims, they should be supportable with appropriate scientific evidence.


8. Text, sound and visual presentations in marketing communication for food and beverage products should accurately represent the essential characteristics of the advertised product, such as taste, size, content, nutritional ingredients or health benefits, and must not mislead consumers as to any of these characteristics.  

9. Food products not intended to be substitutes for meals should not be represented as such. 

Use of technical/scientific data and terminology  

10.      All nutritional and health benefit information and claims made about food and beverage products should have a sound scientific basis.    

11.     The tastes or preferences of an individual consumer should not be used in a way that might imply statistical validity if there is none.

12.     Recommendations from individuals should be based on well accepted and recognized opinions from experts.   

Safety and Health 

13.   Food and beverage marketing communication should not undermine the promotion of healthy balanced diets, nor the importance of a healthy active lifestyle.  

Children and adolescents

14.   Food and beverage advertising should not lead to physical or moral damage to children.

15.   Food and beverage marketing communication should not mislead children and adolescents about nutritional and health benefits, including status or popularity among others, success in school or sport, or intelligence, derived from the consumption of a given product.

16. Techniques acting on the subconscious should not be used in marketing communications. When fantasy, including animation, is used in communicating with children, care should be taken not to exploit a child’s imagination in a way that could mislead him/her about the nutritional benefits of the product involved. When using cartoon characters, refrain from using techniques that do not allow children to distinguish the main programme from the advertisement.

Techniques for subliminal perceptions are indirect methods not designated as commercial messages and are not recognized as such by the audience but may form a subconscious psychological response and attitude in the audience to the goods and services presented.   

17. Food and beverage marketing communication should not undermine the role of parents and other adults responsible for a child’s welfare in guiding diet and lifestyle choices.

18. Marketing communication of food and beverages should not directly appeal to children to buy these food products, taking advantage of their inexperience and easy gullibility.

19.  Food and beverage commercial communication should not directly induce children to get their parents or third parties to purchase these products.

20. Marketing communication of food and beverage products aimed at children should not create a sense of urgency to purchase the product.

21.  Promotional messages relating to food and beverages addressed to children must contain information about the terms of the promotional offer, sweepstakes or contest in a manner that can be understood by children.

22.  Marketers should aim to make sure that, if there is such a condition, children should know that they need to purchase a product to get the extra benefit offered, and, for lotteries and competitions, know the conditions of entry, the type of prizes and the likelihood of winning.

23. Advertising and commercial communication, accompanying or included in children’s programmes for foods and beverages containing food ingredients and substances with a nutritional or physiological effect, in particular those such as fat, trans-fatty acids, salt/sodium and sugars, excessive intake of which in the overall diet are not recommended, shall comply with the following criteria: 

        1.     to be presented in such a way as not to abuse children’s confidence in the quality of the products contained; 

        2.     the information about the taste, portion size and nutritional value of the product should be truthful, complete and clearly understandable;         

        3.      the advertising of the amount of carbohydrate, fat or salt etc. contained in these products cannot misleadingly suggest positive effects on a balanced diet (e.g. food products high in carbohydrate cannot be advertised by referring to their low or no fat or salt content and vice versa);

          4.     the special trust that children have in parents, teachers and other authority figures (‘children’s idols’) should not be abused to counteract balanced nutrition and healthy lifestyles;

“Children idols” are considered celebrities (including virtual figures like comics), which due to their popularity appear in ads aimed at children and therefore have the function of an example (role model, authority). 

        5.     must not contradict a healthy, active lifestyle. In particular, advertising must not suggest that an inactive lifestyle is preferable to physical exercise;

        6.     must not contradict or detract from a balanced and healthy diet. In particular, it cannot deny or discourage the consumption of fresh fruit and vegetables.

        7.     should not support or encourage excessive or unilateral consumption of the advertised products and beverages;  

      8.     positive presentation of unhealthy eating habits is unacceptable; refusal to consume such food or beverages should not be presented in a negative light;

      9.     no link whatsoever should be created between improving school performance and consumption of these products;  

     10.     no suggestion should be made about any therapeutic or disease-preventing effects of these products;  

       11.     Not to suggest or describe a food or beverage as a substitute for a meal unless it has been specifically developed for that purpose, with appropriate nutritional values; 

       12.     low-calorie versions of these food products and beverages (so-called light versions) may not encourage excessive consumption of the low-calorie product.