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Product: Food & Beverages (Food)
Advertiser: Kellogg Marketing and Sales Company (UK) Limited
Medium: Social Media (Instagram)
ASAI Code 7th Edition: 2.4(c), 8.4, 8.6, 8.18
Advertising for Kellogg’s on their Instagram platform featured a post containing four different breakfast meals. Each meal was given a star rating. The images and star ratings were as follows:
“Kellogg’s kelloggs uki
Coco Pops and Warm Milk
Full English Breakfast
Coco Pops and Milk
Avocado on Toast
The caption beneath the post read as follows:
“Kelloggs.uki Let’s face it, this is the deliciousness of breakfasts. We don’t make the rules.”
The Irish Heart Foundation (IHF) considered that the post in question (published on 13th April 2021) encouraged viewers to believe that a large portion of Coco Pops and a full Fried Breakfast were better and therefore received far more “Stars” than a small portion of avocado on toast which only received one “Star”.
The IHF considered that if one were to count the calories included in the large portion of Coco Pops or the full Fried Breakfast and compared them to the calories of the avocado on toast that the food with the more stars may not be the healthier option. They considered the post to be clearly disparaging the healthier choice and that it was irresponsible marketing by a brand loved by young people and therefore in breach of the following Code rules:
They said that marketing communications for high fat sugar and salt brands (HFSS) should not
• Condone or encourage poor nutritional habits or an unhealthy lifestyle in children
• Condone or encourage excessive consumption, an unhealthy lifestyle or unbalanced eating
• Marketing communications for HFSS brands should not disparage good dietary practice
The advertisers said they take compliance with the ASAI Code very seriously and much effort is taken, and due diligence paid to ensure that their marketing communications meet the requirements of the Code and the recommendations of the Authority.
They considered that it was necessary to highlight at the outset of their response that the Instagram post submitted by the complainants was incomplete as it had excluded the accompanying post caption. They said the Post had to be considered in its entirety, including the Post caption. When the entire Post was read in light of the context in which it was made, it was clear that the Post was about taste preference, as reflected in the comments which accompanied it and had nothing to do with health.
The advertisers said that the Post was published more than 5 months (13th April) before the Complaint was received (29th September) and within a matter of days from receipt of the ASAI’s notification of the Complaint, they took steps in good faith to eliminate the cause of concern and removed the post. Notwithstanding the removal of the post, the advertisers said that it had been published in the context of a series of similarly themed posts on the topic of taste preference across their social media channels. The Post had further used a star ranking format which was trending across social media platforms at the time.
They said that the inclusion of Coco Pops twice, each receiving different star rankings for warm milk and cold milk respectively, distinctly demonstrated that the Post had focused on taste preference and enhanced flavours. This concurred with the definition of deliciousness. The Post had further included a Full English Breakfast and Avocado on Toast which were recognised as popular breakfast dishes in addition to cereals. The Great British Breakfast survey found that the Full English Breakfast was the UK’s most popular breakfast, followed by cereal in second place and avocado (and poached egg) on toast in 18th place. The Full Irish Breakfast variation has been ranked as the most popular Irish breakfast food. They said both data sets were in the public domain and were not Kellogg initiated data sets.
The advertisers went on to say that Coco Pops Original cereal and the Coco Pops brand are currently, and were at the time of the Post, non-high fat salt and sugar (HFSS) food in accordance with the UK Nutrient Profiling Model proposed to be incorporated in the updated Code effective only on1 December 2021. They said that this fact went to the heart of the Complaint. Coco Pops as depicted in the Post was not a HFSS product, and therefore, had not breached the requirements of the Code.
The advertisers said that if counting calories, however, as outlined in the complaint, when the depicted portions of each of the (i)bowl of Coco Pops Original and milk (ii) Full English Breakfast; and (iii)Avocado on Toast were compared based on calories, Coco Pops and milk had the lowest calorie count with174 calories, followed by the Avocado on Toast with 334 calories and the Full English Breakfast with 709 calories. Accordingly, it was inaccurate to say that “it is not better for the health of a young person to be eating the portions with many stars”. The advertisers reiterated, however, that the Post was made purely to indicate the deliciousness of the depicted breakfasts based on taste and the ranking of each breakfast dish was in no way associated with health.
In conclusion the advertisers said that their post had not been targeted at children and 95% of their Instagram followers are over the age of 18. They contended once again that when the post was viewed in its entirety that it had not breached the requirements of the Code.
The Complaints Committee considered the detail of the complaint and the advertisers’ response. The Committee noted, based on statistics provided for the target audience for the advertisement, that it had not been targeted at children. They also noted the complaint had referred to high fat sugar and salt brands (HFSS). While provisions related to HFSS product marketing communications would be effective in the ASAI Code from 1st December, the advertising in question had been published prior to the 1st December 2021. They also noted in any event that in accordance with the UK Nutrient Profiling Model (which is the model that would be used by the ASAI), Coco Pops do not fall under the category of HFFS food.
The Committee noted the Post caption referred to “…the deliciousness of breakfasts” and when the post was viewed in its entirety, it was evident that the star ratings provided related to taste preferences for the breakfast options outlined.
While noting that the post in question had been removed, the Committee concluded that it was not in breach of the requirements of the Code and did not uphold the complaint.
No further action required.