A group representing Canadian advertisers is criticizing proposed restrictions on marketing food and beverages to children, saying that suggested changes to policy go too far.

Health Canada's consultations on how it should approach restricting advertising "unhealthy food and beverages" to kids began in June and concluded this week. In its submission under the consultations, the Association of Canadian Advertisers said the proposals are "significantly overbroad" and "should be reconsidered from the ground up."

Health Canada's proposed policy changes would allow advertising of "healthy" foods including "vegetables, fruit, whole grains and protein-rich foods … when processed or prepared with no added sodium, sugars or fat" with a full list of foods exempt from restrictions to be provided later.

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It asked for comment on two options for restricted-food ads: those for foods with more than approximately 5 per cent of the daily value of saturated fat, sugars or sodium; or a slightly more lax restriction on foods with more than 15 per cent of those daily values. Either option would restrict items such as regular soda, ice cream, candies, most sugar-sweetened cereals, cheese and juice. The broader option would also restrict ads for foods such as granola bars, potato chips, French fries, and calorie-reduced cheese. The proposal also suggested restricting ads for beverages with sweeteners such as aspartame and sucralose.

Health Canada proposed banning such ads on television on weekday mornings and evenings (6 a.m. to 9 a.m. and 3 p.m. to 9 p.m.) and most of the day on weekends (6 a.m. to 9 p.m.). And it suggested curbs on ads in other environments where "significant numbers of children are likely to be exposed to marketing," including schools, theme parks, movie theatres, grocery stores and in digital media.

"We do believe in responsible marketing to children. However, the proposals are in effect an outright ban on most food and beverage marketing in Canada," said Ron Lund, president and CEO of the ACA.

The ACA's submission argued that there is no correlation between advertising and rising rates of childhood obesity, citing a U.S. study that estimated children's exposure to food ads on television fell by about 9 per cent between 1977 and 2004. It also argued that Quebec's obesity rate has remained comparable with other provinces, while it has had a ban on advertising to children under age 13 since 1980. The submission also claimed that foods such as apples and bananas would be designated unhealthy by these standards, despite Health Canada's specification that fruits and vegetables are foods "foundational" to health that would be exempt. In an interview, Mr. Lund questioned why foods such as cheese, which could be considered healthy when consumed in moderation, would be banned in ads.

The ACA also questioned the proposal to extend the restrictions to teenagers younger than 17, calling such a ban "paternalistic."

"We know it's not just younger kids. Teenagers are very much affected by advertising, by social media," said Hasan Hutchinson, director general of Health Canada's Office of Nutrition Policy and Promotion. In response to the ACA's criticisms, he said Health Canada would consider all the submissions under the consultation.

"This is a real consultation. If you don't like it, tell us why, and give us the evidence," he said. "The bottom line here has to be driven by health."

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The ACA's submission estimated that Canadians see roughly 159.5 billion ads for food each year on television – representing about one-fifth of all TV ads – and that the proposals would ban more than half of those. However, that estimate depends on a broad assumption that 98 per cent of food ads would be banned during the proposed broadcast hours. The submission argued that such a restriction would inhibit food marketers' ability to reach adults with their messages, as well. It cited similar problems with banning ads on digital platforms such as Google, Facebook and YouTube. The suggestions make inaccessible "broad swaths of the Internet."

Mr. Lund said the ACA is working on counterproposals to suggest reasonable restrictions on such advertising.

The ad industry already has some self-regulatory restrictions in place, under the Canadian Children's Food and Beverage Advertising Initiative. That program, in which many major food companies are participants, sets out nutrition criteria for products that can be advertised in environments where kids under 12 make up 35 per cent or more of the audience. Some participants agree not to advertise at all in such environments.

Mr. Hutchinson praised that initiative, but said that a standard applying to all food advertisers – not just those signatories – would "level the playing field."

The Stop Marketing to Kids Coalition, led by the Heart and Stroke Foundation, has been advocating for many of the proposed changes.

"Everything they're proposing would have high-impact return on investment from a public health point of view," said Manuel Arango, Heart and Stroke's director of health policy and advocacy. "Industry's agenda is to improve their bottom line. That's all well and good, but when you're developing health-related legislation, you have to focus on the health needs of Canadians.As long as the measures are reasonable, and have high impact, that's a worthwhile initiative."

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Health Canada has the authority to regulate advertising under Canada's Food and Drugs Act. Its deliberations on possible changes to its approach are happening at the same time as a Senate bill is under consideration, proposing an amendment to the act to restrict food and beverage marketing to children. That bill, introduced last September, has gone through its own committee hearings and a third reading in the Senate is expected in the fall.