There was never any doubt that the government would introduce its so-called “junk food” advertising ban next October. After all, that was the date set by Rishi Sunak last year and Keir Starmer is even keener on big government than he was. The only interesting thing about yesterday’s “announcement” is that it came on the same day as Starmer’s big speech about reforming the NHS. As I mentioned last week, the Prime Minister genuinely believes that the slovenly public are to blame for Britain’s dismal health service. I very much doubt that he is going to reform the NHS. It is beyond reform. Instead, he is going to try to reform us.

For the next five years, the UK will be the playground of every “public health” blowhard and nanny state crank. The slippery slope of lifestyle regulation will become a runaway train. If resistance is futile, we should at least demand accountability. The advertising ban, for example, is supposed to reduce child obesity. If it fails to do so, we should repeal it and strip the academics who promoted it of their government grants. It’s only fair.

The evidence presented for the ban in the Department of Health’s 2019 Impact Assessment is risible. It estimated that the policy would cost broadcasters and online advertising platforms £2.4 billion over 25 years, but it will supposedly be worth it because it will save the NHS £800 million over the same period and there will be intangible health benefits worth £1.9 billion thanks to kids consuming fewer calories.

Where do these figures come from? The key assumption is that children who watch 4.4 minutes of TV advertising for food that is high in fat, sugar and salt (HFSS) consume an extra 60 calories. That was the conclusion of a meta-analysis published in 2018. The Impact Assessment acknowledges that there is a wide confidence interval around this estimate, ranging from 3.1 calories to 11.6.9 calories. Indeed, it is barely statistically significant at all and that is no surprise because the eleven studies reviewed in the meta-analysis were all over the place. Five of them came from the one group of activist-academics in Liverpool (Halford et al. 2004, Halford et al. 2007, Halford et al. 2008, Dovey et al. 2012, Boyland et al. 2013) and broadly supported the idea that children under the age of 12 tend to eat more food after watching “unhealthy food adverts”, but that has not been strongly replicated in other research

Taken together, the other six studies in the meta-analysis provide very little evidence that food advertising has any consistent effect on calorie intake. They are…

Anderson et al. (2015)’s study of 9-14 year olds found that seeing food advertising was associated with higher food intake among overweight girls but not among normal weight girls or any group of boys.

Anschutz et al. (2009)’s study of 8-12 year olds found that when the children had seen food commercials, food intake was higher among boys, but lower among girls.

Anschutz et al. (2010)’s study of 8-12 year olds found no association between food advertising and food consumption (“there was no main effect of exposure to the food commercials on food intake”).

Norman et al. (2018)’s study of 7-12 year olds in Australia found that the children “ate comparable amounts after both food (1933 ± 619 kJ) and non-food (1929 ± 678 kJ) advertising exposures”. 

Only Harris et al. (2009) and Emond et al. (2016) support the advertising hypothesis, but the children in the latter study were very young indeed (2-5 years) and the study was not well randomised; the group that watched the food adverts contained two obese children and six overweight while the group that watched the non-food adverts contained no obese children and four overweight children. 

In any case, none of these studies was realistic. In a typical experiment, young children were put in front of a television with no parental supervision and as much free “junk food” as they wanted. Since primary school children rarely buy their own food, there seems little reason to expect the findings of these experiments, such as they are, to translate into real world behavioural change.

How many children watch live television these days anyway? The bigger part of the ban is the total prohibition of HFSS food advertising online. Alas, there is no evidence — or, as the Impact Assessment puts it, a “very limited literature” — on the impact of online food advertising on calorie consumption and so the authors resorted to wild speculation. They assumed, without a scintilla of evidence, that online display ads are viewed for five seconds and have the same effect as a television advertisement. Online advertising agencies would be delighted if either of these implausible beliefs was true, but assuming they are, the authors calculate that one online advertisement for HFSS food “triggers” a child to consume an additional 1.1 calories. 

Although the authors don’t know how much HFSS advertising people see online (“Evidence of the volume of HFSS advertising online is limited”), they combined their guesswork and arrived at the conclusion that an online ban, alongside a TV ban before 9pm, will reduce the average child’s daily energy consumption by 2.3 calories per day which will somehow result in the nation enjoying an extra 84,000 quality adjusted life years.

… impact assessments for nanny state policies often resemble a game of Numberwang

This is, quite obviously, a pyramid of the sheerest piffle, but impact assessments for nanny state policies often resemble a game of Numberwang and reality is rarely allowed to intrude on “public health” modelling. There is real world evidence available to anyone who is minded to seek it out, but it doesn’t help the killjoy’s cause. The Impact Assessment notes that there were 12.1 billion “HFSS child impacts” — which essentially means HFSS ad views — in 2005. In 2009, after HFSS advertising was banned on children’s television, this fell to 7.7 billion. By 2017, it had fallen to 3.6 billion, of which 2.6 billion were before 9pm. 

Did rates of obesity among children decline as a result of their exposure to HFSS food advertising falling by more than two-thirds? Reader, it did not. The only notable consequence of the ban was that Children’s ITV closed down. And while the government’s Impact Assessment expects there to be a measurable decline in childhood obesity from HFSS advertising “exposure” falling to 8% of the 2005 level as a result of the new ban, I bet that doesn’t happen, because food advertising has a negligible impact on the number of calories children — and adults — consume.

Five years should be enough for us to see the ban has the desired effect. If it doesn’t, we should expect some apologies and resignations from the people who campaigned for such a costly folly. We won’t get them, of course. By then they will have moved on to demanding that the “loophole” that allows HFSS for advertising on billboards and radio be closed (they have already started). The runaway train will still be steaming along.