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Department of Policy and Business Practices
Content Monitoring and Review Section
Australian Communications and Media Authority (ACMA)
PO Box Q500
Queen Victoria Building NSW 1230
31 August 2007 CPI//hpe
Subject: Submission on the Australian Children’s Television
Standards Review
Dear ACMA,
As the world business organization,
the International Chamber of Commerce (ICC) represents thousands of
member companies and associations from some 130 countries, including
Australia, operating in every major industrial and service sector.
For more than 70 years, ICC has worked to promote high standards of
business ethics through the development and dissemination of rules,
codes and guidelines.
I am writing to provide our
perspective on the Children’s Television Standards (CTS) Review,
specifically on the issue of advertising to children. ICC
appreciates CTS’s dual objectives of providing for children to be
specifically catered for in programming and of providing for the
protection of children from possible adverse effects of television.
Similarly, ICC appreciates the context of the CTS Review given
concerns about possible links between food advertising and obesity.
In September 2006, ICC itself issued a new revision of its
Consolidated Code on Marketing & Advertising Communication Practice,
in which ICC strengthened provisions on responsible and
appropriate marketing to children. In October 2006, ICC introduced
an additional Framework for Responsible Food and Beverage Marketing
Communications to supplement the Consolidated Code, providing
specific guidance for food and beverage marketers to adhere to high
ethical standards for responsible practice. The Australian
Association of National Advertisers (AANA) was the first in the
world to adapt this framework into a local Food & Beverages
Advertising & Marketing Communications Code in November 2006, which
has been endorsed by the Australian Food and Grocery Council.
Furthermore, ICC recognizes the important role that foreign
investment plays in supporting children’s programming in Australia,
and hence we feel our input valuable to the CTS Review.
In brief, regulators must not attempt
to assume the role of nutritional arbiters; to deal effectively and
successfully with the complex cultural, social, and economic factors
that influence obesity requires a different and much more
comprehensive approach. Given that a broad consensus exists on the
multi-factoral nature of the obesity problem, addressing the issue
requires a multi-dimensional response. We feel that prohibitions,
bans and restrictions do not promote awareness nor change behavior.
The freedom to make informed choices from a range of options is a
basic freedom that should not be violated. The key is rather to
promote and encourage responsible marketing communications.
ICC and the business community
recognize the need for a legal infrastructure, targeting misleading
or otherwise deceptive practices and geared particularly towards
dealing with the so-called rogue traders. However, those legal
mechanisms should always leave ample room to be complemented by
effective self-regulatory measures, which are better suited to deal
with ethical aspects in fast-moving markets. ICC applauds ACMA’s
recognition of the role that self-regulation in Australia has played
alongside law, and the review process should continue to recognize
the synergies that can result from such a combination that
regulatory intervention cannot, and will not, achieve by itself. In
short, ACMA should continue to work with the industry concerned, not
against it. Business has a fundamental interest in building and
sustaining strong consumer confidence over the longer term.
A variety of studies and policy
statements by major regulatory institutions confirm that compliance
with robust self-regulatory frameworks is high, and that these
frameworks serve as effective and legitimate instruments in
regulating commercial advertising. The ICC’s Consolidated Code and
Framework set an internationally agreed standard for responsible
marketing communications, with many countries then using this common
baseline to go further on specific codes, responding as appropriate
to national and cultural sensitivities. The codes developed by the
AANA are a good example of how national codes complement ACMA’s
regulatory authority. As demonstrated by the AANA’s current review
of its Code for Advertising to Children, such codes of
self-regulation evolve to address society’s concerns in a rapid,
efficient, non-bureaucratic and cost-effective manner.
Any outcomes from the CTS Review
should incorporate the importance of providing consumers, including
children, with more information – not restricting or eliminating it.
Business and business organizations have repeatedly demonstrated
their willingness to engage in dialogue, to respond to changing
consumer demands, and to work constructively with other stakeholders
to promote responsible marketing to all consumers, recognizing that
consumers and society as a whole benefit from receiving truthful
information about commercially available products and services
geared to their level of understanding.
We would welcome the opportunity to
discuss these issues further and stand ready to assist in a dialogue
aimed at practical and workable solutions.
Sincerely,
John F. Manfredi
Chairman, Commission on Marketing & Advertising
International Chamber of Commerce
Enc: ICC Framework for Responsible Food and Beverage Marketing
Communications
ICC Consolidated Code of Advertising and Marketing Communication
Practice
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