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EPC response to the Commission's Green Paper on "Promoting healthy diets and physical activity: Towards a European strategy for the prevention of overweight, obesity and chronic diseases"

14 March 2023

The European Publishers Council (EPC) is a high level group of leading European media corporations whose interests span newspapers, magazines, books, journals, online database and internet publishing as well as in many cases significant interests in private television and radio. A list of our members is attached.

Obesity poses a growing risk to the health of people within the European Union, and not least to the health of children and young people.

At the end of last year, the Commission published a Green Paper to initiate a consultation process on promoting healthy lifestyles and finding ways to encourage people to eat healthily and engage in more physical activity.

The EPC wishes to make the following statements regarding the contribution of the media to this debate and secondly more specifically to the advertising related aspects of the Green Paper:

1. There is NO proven link between food advertising and obesity

Section V.1. of the Green Paper suggests that the Commission assumes a causal relationship between food advertising and obesity. The EPC would like to ask the Commission to recognise the complexity of the problem. Whilst advertising is one of a range of factors that affects choices in nutrition, diet, patterns of activity and/or lack of fitness, which can be associated with obesity, research has found that obesity is rather a multifaceted problem. There are numerous factors regarding the causes of increased rates of overweight and obesity. Among these are:

  • A general change in the economy that has reduced the physical labour needed to perform many jobs. Therefore obesity could rise as a result of a decline in energy expenditure.
  • Lifestyle changes have prompted greater demand for convenience food and fast food and at the same time we have seen a gradual increase in serving sizes.
  • Television viewing as well as playing video games are sedentary activities; thus, at least some of the time that adults and children spend watching television or playing video games might otherwise, at least in the past, have been spent on more active pursuits. This suggests that it may be the sedentary nature of television and other similar activities rather than advertising, which can be linked to the rise in obesity.

-  Therefore the EPC would like to raise a fundamental question: Even if feasible, would restricting food advertising do anything to reduce obesity or even slow its trends, and would the social benefits of banning advertising outweigh the costs to the media of such an action?

- Thorough research should be conducted in order to find a satisfactory answer to this question.

2. The media can be part of the solution

The EPC believes that the media industry can make a considerable contribution to this debate by way of producing editorial content helping to raise awareness of the importance of health, nutrition and physical activity amongst EU citizens.

DG SANCO itself has recognised the role of the media in the provision of health messages to citizens launching the 'European Health and Information Platform' project. This project is co-financed from the EU Public Health Programme and managed by the European Broadcasting Union.

EPC members are already providing information about health, nutrition and physical activity to EU citizens in form of television documentaries, radio broadcasts and articles on the Internet but particularly in print where special supplements are often produced to complement general news and features in newspapers and magazines.

Some of our members are operating in the scientific and educational sectors, providing high value and flexible information solutions to professional end users, schools and parents, with increasing emphasis on Internet delivery. Their repertoire includes specialist journals on nutrition and healthy eating as well as publications associated with school curricula.

More importantly EPC members have the ability to reach a large spectrum of EU citizens from all backgrounds. Health, leisure and cookery magazines as well as tabloid newspapers furnish a lot of information on general and very specific issues including, for example, the levels of fat, sugar and salt in foods, thus enabling the consumer to make an informed choice about his/her diet. These easily accessible sources of information help the public to follow debates about science and medicine and make it more digestible for the average consumer.

For instance the Bild am Sonntag, part of the Axel Springer AG, reaches 10.85 million readers, provides 4 to 6 pages dedicated to health, physical activity and nutrition and publishes a monthly 8 to 12 page health journal. Gruner + Jahr Magazines like Health Living publish information for a healthier lifestyle. Healthy Living is a full-service health monthly. The magazine caters to adult women who see themselves as health managers in their partnerships and families. The title takes an up-to-date, competent, and service-oriented approach to meeting the growing demand for health-related information. It combines the latest research results from the fields of medicine and health with a high everyday use value developed by a team of medical editors, doctors, nutritional scientists, cosmetics and sports experts and experienced service journalists as well as researchers from various universities and university clinics. The EPC can provide further such examples from all across the European Union upon request.

  • The media can help create the right spirit amongst EU citizens to tackle obesity and adjust to more healthy lifestyles.
  • The media can encourage people to think about serious, scientific and technical matters.
  • The media can play an important part in changing behaviour by encouraging physical activity and providing information about what we eat and what it affects us.

3. Advertising is the lifeblood of a dynamic and independent media industry

The EPC welcomes the fact that Commission's Green Paper on Promoting Healthy Diets and Physical Activity does not contain any proposals for advertising bans/restrictions at the moment although we are aware of pressure from some quarters to reverse this.
Advertising is a vital source of revenue for newspapers and magazines and helps keep their prices low. The same applies to television and indirectly to movies. Advertising also plays a vital part in the national economy because it helps manufactures to talk freely to consumers providing important information about their goods and services. In fact this freedom is so important that it is protected by the European Convention on Human Rights. Proposals and ideas for new European laws, which might restrict advertising, threaten the competitiveness of the European media.

  • Less freedom to advertise means fewer newspapers and magazines, less consumer choice and less information.

4. Food advertising is already well regulated throughout Europe

There seems to be an impression, wrongly, that advertising generally and in this case food advertising is taking place in an unregulated environment. This is however not the case as European level legislation is already in place regulating how food manufacturers may engage in commercial communication; including:

  1. The Directive 2000/13/EC on the approximation of the laws of the Member States relating to the labelling, presentation and advertising of foodstuffs;
  2. The Directive 2005/29/EC concerning unfair commercial practices; and
  3. The Television without Frontiers Directive 1997/ /EC also contains detailed provisions on advertising to children.

In addition to EU legislation advertising standards and ethics are governed by a well-developed system of self-regulation in Europe and the industry is committed to a continuous process of improvement. Statutory control should be kept to the bare minimum and only ever be contemplated on the basis of developing the competitiveness of the internal market. Therefore, any statutory intervention must be fully justified and proportionate and should always be based on the principles of country of origin control, which reduces the regulatory burden.

The EPC is actively involved in promoting responsible advertising through its participation in EASA (European Advertising Standards Alliance) and as a member of the Advertising Roundtable set up by DG SANCO. EPC fully supports the efforts of DG SANCO to bring the industry and consumer/health groups together to forge a greater understanding of the role and effectiveness of advertising self-regulation.

  • The EPC is asking the Commission to continue its efforts in promoting self-regulation as an effective alternative approach to regulation and acknowledge the commitment as well as achievements which the industry has made.

On behalf of the European Publishers Council

Chairman: Mr Francisco Pinto Balsemão, Chairman and CEO, Impresa, Portugal

Mr Kjell Aamot, CEO, Schibsted, Norway
Ms Sly Bailey, Chief Executive, Trinity Mirror plc, UK
Sir David Bell, Chairman, Financial Times Group, UK
Mr. Jose-Maria Bergareche, CEO, Vocento, Spain
Mr Aldo Bisio, CEO RCS Quotidiani S.p.A Italy
Mr Carl-Johan Bonnier, Chairman, The Bonnier Group, Sweden
Mr Oscar Bronner, Publisher & Editor in Chief, Der Standard, Austria
Dr Hubert Burda, Chairman and CEO, Burda Media, Germany
Dr Carlo Caracciolo, President, Editoriale L'Espresso, Italy
Mr Juan Luis Cebrian, CEO, Groupo Prisa, Spain
Sir Crispin Davis, Chief Executive, Reed Elsevier,
Dr Matthias Döpfner, Chief Executive, Axel Springer AG, Germany
Mr. Andy Hadjicostis, CEO, Sigma TV, Dias Publishing, Cyprus
Mr Leslie Hinton, Executive Chairman, News International, UK
Dr Stefan von Holtzbrinck, Verlagsgruppe Georg von Holtzbrinck GmbH
Mr Tom Glocer, Chief Executive, Reuters plc
Mr Steffen Kragh, President and CEO, The Egmont Group, Denmark
Dr Bernd Kundrun, Chief Executive, Gruner + Jahr, Germany
Mr Christos Lambrakis, Chairman & Editor in Chief, Lambrakis Publishing Group, Greece
Mr Murdoch MacLennan, Chief Executive, Telegraph Group Ltd, UK
Sir Anthony O'Reilly, Chief Executive, Independent Newspapers PLC, Ireland
Ms Wanda Rapaczynski, CEO, Agora, Poland
Mr Jaakko Rauramo, Chairman and CEO, SanomaWSOY Corporation, Finland
Mr Gerald de Roquemaurel, Chairman and CEO, Hachette Filipacchi Medias, France
Mr Michael Ringier, President, Ringier, Switzerland
The Rt. Hon. The Viscount Rothermere, Chairman, Daily Mail and General Trust, UK
Mr A.J. Swartjes, CEO, De Telegraaf, Netherlands
Mr Antoine de Tarle, Chief Executive, Societe Ouest-France S.A., France
Mr Christian van Thillo, Chief Executive, De Persgroep, Belgium

Executive Director: Angela Mills Wade
Press relations: Heidi Lambert