Introduction to Our Commitment
Campbell Soup Company is a charter participant in the Children's Food and Beverage Advertising Initiative created under the auspices of the Council of Better Business Bureaus ("Initiative"). Consistent with our corporate Global Guidelines for Responsible Advertising to Children and our most recent Commitment Concerning Advertising to Children under the Initiative that was applicable beginning with our Fiscal Year 2009, we make this amended and restated Commitment Concerning Advertising to Children ("Commitment") for the period commencing on January 1, 2010 ("this year"). It applies to all of our advertising1 primarily directed to children younger than 12 years of age in the United States ("advertising to children") and may be further amended in agreement with the Executive Director of the Initiative. Pursuant to our Global Guidelines for Responsible Advertising to Children, we do not address any advertising to audiences consisting primarily of children younger than 6 years of age. Because much of our Commitment concerns nutrition, as a part of the Initiative, we have made a number of significant changes to our products advertised to children to improve their nutritional profiles and we intend to continue to do so.
Our Advertising Messages to Children
Our advertising messages to children – including what products we advertise to them - should be consistent with our well-informed understanding of nutrition and wellness, supported by the advice of our highly-qualified staff of resident nutritionists. Accordingly, we will support families by assuring that all the products we advertise to children are sound food choices. How we implement this aspect of our pledge is explained in the discussion on "Implementing and Measuring Message Delivery." Schedule A describes the products we will advertise to children this year. They are sound food choices and meet the criteria set forth below. The Schedule includes ingredient statements and nutrition facts for the qualifying products. Schedule B is a chart summarizing the sound food choice criteria.
We Advertise Only "Sound Food Choices" to Children
Soups. Overweight and obesity, particularly among children, is an important public health concern.2 Soups are useful in maintaining a healthy weight because practically all canned soups have low energy density3. According to the 2005 Dietary Guidelines Committee Report, eating foods with low energy density may be a helpful strategy to reduce energy intake when trying to maintain or lose weight. Consumption of foods with a low or very low energy density by children should be encouraged as a means of reducing caloric intake. Therefore, we will only advertise soups having 150 or fewer calories4 to children so as to encourage the consumption of foods with a very low energy density.5
Soups frequently contain ingredients whose consumption by children should be encouraged, such as vegetables and lean meats. Soups also support good hydration. Many soups provide a meaningful amount of positive nutrition such as a serving of vegetables, or a vitamin or mineral at the level of 10% of the Daily Value and those soups we currently intend to advertise to children this year provide at least one of those benefits.
With all the nutritional benefits they offer children, soups should nonetheless be controlled for nutrients that are recognized by the Dietary Guidelines for Americans as nutrients that should be controlled in the diet. We will only advertise soups to children that are low in both fat and saturated fat, i.e. have no more than 3 grams of total fat and no more than 1 gram of saturated fat (and, no more than 15% of calories from saturated fat)6. Furthermore, those soups must have zero grams of trans fat as labeled and contain no more than 12 grams of sugar from sources other than vegetables, fruit, and dairy.7 Since January 2009 we have only advertised soups to children that have a sodium level of 480 mg or less.8
Baked Snacks (Crackers and Cookies). Children need snacks because they typically do not consume sufficient calories by eating three meals per day. They are actively growing and metabolize food more quickly than adults. This makes snacking an important behavior. But, healthful snacking should be encouraged. The Dietary Guidelines recommend limiting fat intake to 25-35% of calories for children ages 4 through 18, limiting saturated fat to less than 10% of calories and keeping trans fat as low as possible. They also recommend limiting intake of sodium and added sugars.
Due to the important concerns about obesity and overweight, cited above, a snack cracker or cookie will be considered to be a sound food choice and may be advertised to children if the product depicted is packaged in a portion control pack of 100 calories or less. A snack cracker or cookie will also be a sound food choice that may be advertised to children if it has 170 calories or less9 and no more than 35% of calories from fat, no more than 10% of calories from saturated fat, zero grams of trans fat as labeled, and no more than 12 grams of sugar (other than from fruit, vegetables, or dairy).10 Beginning as of April 1, 2010, cookies and snack crackers must have no more than 290 mg of sodium per serving to be a sound food choice and advertised to children. Even though snack crackers are typically consumed as a separate snack item, they may also be depicted as an accompaniment to meal items, such as soup, as long as appropriate portions are shown.
Canned Pasta. Canned pasta is a convenient and nutritious meal-time main dish option for parents to serve to their children. Such products typically provide a serving of vegetables, and often provide a serving of grains or a source of protein. Vegetables are a key component of a healthy diet, according to the Dietary Guidelines, and it is important for Americans to eat more of them. Except for starchy vegetables like potatoes, children consume less than half of the recommended amount of vegetables and mixed dishes are a child-friendly way to consume them. Mixed dishes, such as canned pasta, are also good foods with nutrients for children's diets . To be considered a sound food choice and to be advertised, canned pasta products, as a main dish, must make a significant contribution to a nutritious diet. They must contribute a serving of vegetables or a one-ounce equivalent of whole grains, plus a good source of two or more nutrients, but they also must have no more than 300 calories11 and contain no more than 12 grams of sugar from sources other than vegetables, fruit, and dairy.12 The levels of fat, saturated fat, and trans fat in canned pasta should depend on whether the food contains meat or does not contain meat. Canned pasta without meat will only be advertised if it has no more than 35% of calories from total fat, no more than 10% of calories from saturated fat, and zero grams of trans fat, as labeled. Canned pasta with meat will contribute more of these fats to the diet due to its meat content. Consequently, we evaluate such products by the USDA nutrient content claim standard for "lean."13 As such, canned pasta with meat will only be advertised to children if it has no more than 10 grams of fat and 4.5 grams of saturated fat. Furthermore, it must have no more than 0.5 grams of trans fat, as labeled, and the trans fat may only come from meat and dairy. Finally, to be advertised to children, a canned pasta product must have no more than 600 mg of sodium per serving as from July 31, 2010.,14 Until such date, a canned pasta product must have 25% less sodium than the largest-selling canned pasta item or SKU in the canned pasta product category15.
We Provide Healthy Lifestyle Messages for Children
Most marketing campaigns are interactive. To the extent those campaigns engage with children, we believe it is important that they contain or model healthy lifestyle messages, such as those in support of efforts to reduce obesity among children. We will continue to provide healthy lifestyle messages in some part of our advertising to children.
Advertising supports a healthy lifestyle when it addresses a recognized need of children, either (a) to control caloric intake or increase activity level to help achieve a healthy weight or (b) with respect to positive emotional, social, or physical development. Children's attitudes affect both their development during childhood and their developing attitudes as they mature into adulthood. Children with positive attitudes and positive thinking skills are better able to resist depression and anxiety and perform better, both in and out of school. In addition, many children do not know how to construct a healthy diet or avoid over-indulging in calorie-dense but nutrient-poor foods and beverages. Finally, with a reduced commitment to physical education and activity in the nation's schools, many children are not engaging in the regular physical activity that is an essential lifelong habit to support good health.
Our children can be helped to develop healthy attitudes towards themselves, their diets, and the pursuit of physical activity with messages and information in advertising that promote the development of positive thinking or coping skills; better understanding of how to construct a healthy diet and/or avoid overindulgence; and/or positive attitudes about regular physical activity.
Our Use of Licensed Characters, Celebrities and Movie Tie-Ins
When we use licensed third party characters, celebrities (including athletes) and movie tie-ins in our advertising to children, they will support sound food choices.
Our Practices Concerning Product Placement
We do not actively seek to place our products in the program/editorial content of any medium primarily directed to children, for the purpose of promoting the sale of those products, or pay for such a placement. In considering placement in movies, we will not rely upon Motion Picture Association of America ratings to evaluate whether content is primarily directed to children, but will evaluate PG and PG-13 movies based upon our best judgment of the likely audience, taking into account both in theater viewing and anticipated home viewing in such evaluations. Moreover, we will not actively seek to place our Goldfish products in the program/editorial content of any medium whether or not it is primarily directed to children.
Our Use of Product in Interactive Games
Interactive games are activities (in any format, online, disk or cartridge) in which the user is challenged to attain a score, beat a competitor, or master a level. Any interactive game primarily for use by children and provided free or at a nominal charge which includes a depiction of one of our food or beverage product varieties, or product packaging for a product variety, will depict only sound food choices.
Advertising in Elementary Schools
As a formal supporter of the Guidelines for Competitive Foods under the Schools Program of the Alliance for a Healthier Generation, we have recognized that schools provide a special environment. We have chosen to limit our activity in elementary schools (pre-K through 6th grade) to (a) communicating public service messages through materials provided to foodservice personnel, school administrators, or teachers and designed for use in either classrooms or the lunchroom; (b) supporting charitable fundraising activities or other programs benefiting schools, through such efforts as our Labels for Education program; (c) providing product display materials to foodservice personnel; (d) charitable donations; and (e) providing items to administrative personnel for their personal use.
Information on Implementation and Measuring Message Delivery
When we intend to communicate in our advertising to any particular group of people, such as women between the ages of 25 and 49 or children from ages 6 through 11, our agencies identify specific media outlets, such as television programming and websites, where we will be able to reach that group of people. We advertise the products discussed in this Commitment to both children and adults. The advertising itself, the tonality of the advertising, and the messages in the advertising differ based on the intended audience. Advertising is also placed in different media to reach different audiences.
For purposes of this Commitment, we will consider advertising to be primarily directed to children under 6 years of age or under 12 years of age if that demographic is estimated to comprise 35 percent or more of the audience for the particular medium.
Our advertising to children this year will be on television, in print publications, on the internet, on radio and on our own websites designed for use by children. We will measure our compliance with the standards set forth in this Commitment by considering planned media impressions as reported by A.C. Nielsen, for television, print (based on total circulation), and the internet; and actual page views for our own websites.
We will consider advertising as supporting a sound food choice if qualifying product varieties or SKUs are identified and are, in fact, the only product varieties identified in the advertising or whose packaging is shown.
Our specific undertakings in this Commitment are effective for the time period indicated above. The Commitment applies to our businesses in the United States, and may be amended at any time. Commitments effective for future time periods and any amendments to this Commitment will be submitted for consultation and acceptance to the Children's Advertising Initiative of the Council of Better Business Bureaus, Inc. Commitments are monitored by the Initiative. Notice of any amendment will be posted on campbellsoup.com and www.us.bbb.org/advertisers4healthykids/.
1 Namely, advertising in measured media (TV, radio, print, internet). Our Commitment also applies to (a) websites and micro-sites we own or control, (b) computer games, (c) movie DVDs, (d) digital media, (e) mobile media such as cell phones and PDAs, (f) smart phone apps, and (g) word of mouth advertising. Our Commitment applies to EC games without determining whether they are directed to children under 12 because EC games are inherently so directed. Advertising does not include in-store communications or packaging.
2 Campbell is a founding member of the Healthy Weight Commitment Foundation and works with it in support of its vision to partner to reduce obesity, especially childhood obesity, in the United States, by 2015.
3 Energy density is a measure of the number of calories a food contains in relation to its weight in grams; it is calculated by dividing the number of calories in a serving by the weight of that serving in grams.
4 All nutritional values for soups are per eight ounce serving.
5 A food with an energy density of no more than 0.6 – e.g., 150 calories in an eight ounce serving – is considered to have a very low energy density according to Dr. Barbara Rolls, the leading authority on energy density, and her Volumetrics™ weight control plan. Almost all canned soups have fewer than 200 calories.
6 Consistent with FDA criteria for "low in fat" and "low in saturated fat."
7 IOM suggests that added sugar intake be no more than 25% of calories. In a 2000 calorie diet, this means that added sugar would be limited to 125 grams. If an individual food represents 10% of caloric intake, then sugar should be limited to 12.5 grams per serving. We have reduced this amount to 12 grams.
8 Consistent with FDA criterion for acceptable sodium levels for a claim of "healthy" for an individual food.
9 Per 30 gram serving. A desirable benchmark for the contribution of calories by snacks to the diet is that they should represent about 10% of calories. Recent research suggests that snacks actually contribute about 20% or 25% of calories in the diets of American children. Applying a 10% benchmark to a 2,000 calorie diet would suggest that a snack should be limited to 200 calories. We have reduced this to 170 calories which we believe to be a desirable and responsible limit for the calories contributed by a baked snack.
10 Fat, saturated fat, and trans fat values are per guidance in the Dietary Guidelines. With respect to sugar, IOM suggests that added sugar intake be no more than 25% of calories. Accordingly, in a 2000 calorie diet, added sugar would be limited to 125 grams. If a snack represents 10% of caloric intake, then sugar should be limited to 12.5 grams per serving. We have reduced this amount to 12 grams.
11 All nutritional values for canned pasta are per eight ounce serving. Canned pasta is a meal-time main dish. As such, 300 calories in a serving allows sufficient additional calories to complete the meal in the context of overall calorie guidelines for children of 1200 to 2200 calories per day.
12 IOM suggests that added sugar intake be no more than 25% of calories. In a 2000 calorie diet, this means that added sugar would be limited to 125 grams. If an individual food represents 10% of caloric intake, then sugar should be limited to 12.5 grams per serving. We have reduced this amount to 12 grams.
13 Fat content is typically higher in meat-containing products than in products not containing meat. Meat is, in fact, an important component of the diet of many Americans.
14 Consistent with FDA criterion for acceptable sodium levels for a claim of "healthy" for a main dish product.
15 In the event of a change in the nutrient composition of the reference food prior to such date, we will conform advertised products to the 600 mg standard as soon as reasonably possible.