ARCON-Advertising-Regulatory-Council-of-Nigeria

FOOD ADVERTISING: DANGER IN THE PACK AND THE PRICE OF REGULATORY SILENCE

By Wale Aderinokun


A STORY YOU ALREADY KNOW
You have seen it a hundred times. You are standing in a shop, hungry, tired, maybe in a hurry. Your eyes land on a pack. The image on it is beautiful — steaming noodles piled high in a ceramic bowl, slices of tender beef laid across the top, green vegetables, maybe a soft-boiled egg, the whole thing glowing with colour and warmth.

You buy it.

You get home. You boil the contents. What arrives in your bowl is a pale tangle of thin noodles, a small seasoning sachet full of sodium and flavour chemicals, and the distinct absence of everything that made you buy the product in the first place. No beef. No vegetables. No egg. Just the memory of that photograph.

If you look very carefully at the bottom corner of that pack, in letters so small you almost need a magnifying glass, you will find two words: Serving Suggestion.

Those two words are doing a lot of work. They are the legal fig leaf behind which one of the most widespread forms of consumer deception in the world hides, every single day, across millions of
products, in nearly every country on earth.


This article is about that deception. It is about how it works, who it protects, what it is doing to our bodies — especially our children’s bodies — and why governments that will readily ban a cigarette advertisement still look the other way when a soda company puts a bowl of food on its packaging that is not actually in the pack.


 

Hungryman-pack-use
Hungryman-pack-use

THE DECEPTION IS EVERYWHERE, LET’S NAME IT.

Once you start looking, you cannot stop seeing it.
The noodle pack shows beef, vegetables, garnish — none of which are included.

The Semovita pack shows a full, beautiful family meal: a smooth mound of swallow, a rich pot of soup, a happy household gathered at the table. What is in the bag is semolina powder. The soup, the happiness, the family — those are yours to arrange.

Cereal packs have been doing this for decades. A box of cornflakes shows a bowl overflowing with golden flakes bathed in fresh milk, topped with strawberries. The milk is not in the box. The strawberries are not in the box. The portion in the picture is three times what the “serving size” on the nutrition label says you should eat.

Instant coffee containers show smooth, dark liquid steaming in an artisan mug in a sunlit kitchen. The cream swirl on top? Not in the tin. The ambience? Entirely imaginary.

Margarine shows toast so thick and golden it looks like it was baked in a five-star hotel. The bread is not included.
Pasta sauce shows chunky, herb-rich tomato with fresh basil leaves and glistening olive oil. The fresh basil is decorative. The olive oil is not in the jar. That jar contains tomato, sugar, modified starch, and preservatives.

Cigarette packs — for decades — showed rugged men on horseback, freedom, open plains, vitality. Inside the pack was a substance that, as research would eventually prove, was killing its users, while the manufacturers had internal documents confirming they knew. The cowboys were not a lifestyle. They were a distraction.

Calls have been growing for high-sugar drinks to be taxed in the same way as cigarettes, precisely because the drinks industry’s resistance echoes that of the tobacco industry’s denial in the 1960s. The playbook is identical: sell an image, suppress the science, and lobby hard against any regulation that might force you to tell the truth on the packet.

Coca-Cola sells Jollof parties. It sells laughter, sweat after a football match, family, friendship. What it does not advertise is that a standard 50cl bottle contains roughly 53 grams of sugar — more than double the World Health Organisation’s recommended daily limit for an adult, delivered in a single serving, to a child who has not been told any of this.


THE FINE PRINTS: A LEGAL SYSTEM DESIGNED TO PROTECT THE SELLER

The phrase “serving suggestion” is not an accident. It is a legal instrument — and a remarkably effective one.
The phrase is used as legal fine print with a picture of the product. The photo attempts to portray the manufacturer’s food in the most favourable or appetising way possible, sometimes including other foods that the package does not contain. The serving suggestion disclaimer serves to remove any legal obligation on the part of the manufacturer to provide the other items pictured with their product.

In other words: the beef, the vegetables, the egg, the steam, the ambience — the manufacturer has legally absolved itself of all of it. Two words buried in small print at a corner of the pack. That is all it takes.

CONSIDER TIC-TACS

Tic-Tacs are approximately 93% sugar. Yet on their nutrition label, they legally declare zero grams of sugar per serving. How? Because the FDA allows manufacturers to round down to zero any nutrient present in less than 0.5 grams per serving, and the official serving size of a Tic Tac is one single mint — a 0.49-gram piece, which technically contains 0.47 grams of sugar, which rounds to zero. This isn’t just a technicality; it’s a deliberate distortion — a loophole that allows a manufacturer to market a product as “sugar-free” when it is, in reality, almost entirely sugar.

Under EU law, the minimum font size required for mandatory information on food labels is just 1.2mm — and for small packaging, a mere 0.9mm. Legibility can also be reduced by a lack of contrast between the text colour and the background, and none of these factors are adequately defined by law. Think about what that means. The law requires that you be told the truth — but it permits the truth to be printed in letters smaller than a grain of rice, in colours that blend into the background, on the back of the pack while attractive promotional content occupy the entire front. As a result, consumers are often misled by the information on the front labels.

So the law says: tell them. Industry says: yes, and we will tell them in 0.9mm font, in grey text on a white background, on the back of a product they bought because of a photograph they saw on the front. Technically compliant. Functionally deceptive. And entirely legal.


HOW ADVERTISING CHANGED: FROM TELLING YOU TO SELLING YOU.

It was not always this way. Food advertising once described food. In the 1700s and 1800s, advertisements told you what a product contained and what it cost. When refrigeration and canning allowed manufacturers to distribute across wider regions, they backed their products with information-based campaigns. Heinz, Pillsbury, Campbell’s — the big names of that era built trust on consistency and clarity.

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The decisive shift came in the 1950s, when advertising agencies discovered something transformative: you did not need to tell people why a product was good. You just needed to make them feel something when they saw it. If a product could be attached to a feeling — freedom, family, love, fun, status — the rational question of “what is actually in this?” simply never arose.

One of Coca-Cola’s most famous ads, “Hilltop,” which originally aired in 1971, carried a loud, clear message: the world would be a much better place if everyone had a Coke. Today’s branding is much more subtle, focusing on the consumer rather than the product itself.

That subtlety is the danger. When advertising talks about ingredients, it can be checked against facts. When it sells happiness, it is beyond audit. The food moved from the foreground to the background of its own marketing, replaced by an aspiration the buyer could only imagine.

Consumers thrive on transparency, yet marketing has evolved in the opposite direction. There has been more change in the past decade than in the 20 years before it — in terms of sustainability, sourcing, and what is inside products — but that change has been driven by pressure from consumers, not by industry goodwill.

 


ADVERTISEMENTS TARGET CHILDREN

There is a reason food and beverage companies focus their most creative, most expensive, and most relentless advertising on children. A child who develops a taste preference for a brand before the age of ten is likely to remain a customer for decades. The industry knows this. It has built entire departments around it.

According to the Rudd Center for Food Policy and Obesity, children and teens view more than 4,000 food and beverage advertisements on television every year — an average of ten advertisements every single day. GMO/Toxin Free USA
Coca-Cola uses traditional media advertising, as well as videos and advergames on the internet, marketing in theme parks, licensing of its logos for toys, product placements on television, tie-ins with Hollywood films, social media, apps, sponsorships with sports teams and entertainers, and advertising in and around schools. Some of that marketing is aimed at young children, while much of it may be intended primarily for the general public or teenagers, but is still highly attractive to young children.

Coca-Cola has pledged not to advertise to children under 12 globally, since 2013 and included in the headlines of press releases. Yet violations have been documented repeatedly.

For example, when Coca-Cola sponsored the refurbishment of public parks in Washington D.C., its branding were prominent in playgrounds frequented by children, the message to children was unmistakable: you do not have to worry about drinking Coke as long as you exercise. That is not a health message. It is advertising dressed as philanthropy says the Union of Concerned Scientists.

In Poland, when the Ministry of Culture proposed an amendment to restrict advertising of unhealthy products like soda to children under 16, the soda industry rallied and successfully defeated the policy. Coca-Cola’s local team was described as “instrumental in rallying local industry to defend the self-regulatory approach.” A Coca-Cola VP reacted to news of this policy defeat by calling it “good progress.”

Good progress — in an industry vocabulary — means: we successfully stopped a law that would have protected children from our advertising.

Influencers and celebrities have been enlisted who can command the attention of even the youngest children. Children’s exposure to the marketing of unhealthy foods plays a significant role in the continued increase in childhood obesity rates worldwide.


WHAT THESE DOES TO OUR BODIES

The health evidence is no longer preliminary or contested. It is comprehensive, peer-reviewed, and alarming.
The current evidence supports that greater consumption of ultra-processed foods is associated with weight gain and increased risk of obesity, cardiovascular disease, type 2 diabetes, and all-cause mortality. The available literature also supports an association with hypertension, cancer, and depression.

Since 1990, the rise in childhood overweight and obesity has surged across every continent, almost doubling in prevalence. Globally, Asia has nearly half of all overweight children under the age of five, and Africa has one-quarter of such children.

A large-scale national surveillance dataset tracking 2008 to 2023 in the US shows a 253 percent increase in extremely severe obesity in youth, with a significant correlation between obesity severity and metabolic dysfunction, including fatty liver disease, insulin resistance, and type 2 diabetes.

A 2024 study showed a dramatic 500 percent increase in colon cancer among children aged 10 to 14 between 1999 and 2020. Researchers found that the rate also increased 333 percent among 15-to-19-year-olds, and 185 percent among 20-to-24-year-olds. “Colorectal cancer is no longer considered just a disease of the elderly population,” the lead researcher said.

UNICEF warned in a major report that obesity has skyrocketed among children and adolescents bombarded by “unethical” marketing of junk food, outpacing undernourishment to become the leading form of malnutrition worldwide for the first time among those aged five to nineteen. Ultra-processed food is “increasingly replacing fruits, vegetables, and protein at a time when nutrition plays a critical role in children’s growth, cognitive development and mental health.”

In Nigeria specifically, the picture is just as urgent. A report by CAPPA warns that “sugar-sweetened beverages are killing us slowly,” with non-communicable diseases now accelerating among children and low-income communities whose food preferences are being shaped by aggressive advertising patterns that are hard to change later in life.

The kidney disease, the childhood diabetes, the liver damage — these are not coincidences. They are the predictable outcomes of a food system that has been engineered to prioritise addiction over nutrition, and protected by advertising that ensured most people never knew what they were consuming.


THE LOBBYISTS WHO ARM-TWIST GOVERNMENT

No conversation about food regulation is complete without naming the mechanism that prevents it: industrial lobbying.
The food and beverage industry has studied the tobacco industry’s playbook carefully — because it worked so well for so long.

Big Tobacco had discovered a strategy called state or “ceiling” preemption: promoting weaker state public health laws to override stronger local laws. Between 1986 and 1991, the tobacco industry pushed through seven state preemption laws in the US. In the following five years, the industry gained steam, foisting 17 additional preemption policies on states. The food industry has adapted every part of this strategy.

In 2016, just days before Vermont’s first-in-the-nation GMO labelling law was set to take effect — as food companies were already printing new labels — industry lobbyists persuaded Congress to pass a weaker national standard that preempted Vermont’s law and banned states from enacting their own, while exempting highly refined ingredients and most ultra-processed foods from labelling at all.

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A recent Axios/Ipsos poll found that 69 percent of Americans believe foods containing pesticides or artificial dyes are unsafe to eat, even when approved by the FDA. Fewer than half said they trust current federal food safety standards. The public has sensed the problem. The regulation has not followed, because the industry has ensured that the regulation does not follow.

In Nigeria, CAPPA’s Executive Director acknowledged policy actions like the introduction of the Sugar-Sweetened Beverages Tax and recent sodium reduction guidelines but stated that enforcement remains weak, and called for urgent and effective regulatory reforms, including mandatory front-of-pack warning labels and stronger restrictions on marketing around schools. The policies exist. The enforcement does not. That gap is not accidental — it is manufactured by the same interests that fund the advertising.

 


NUMBERS THAT SHOULD WORRY ANY GOVERNMENT 

For policymakers inclined to treat this as someone else’s problem, or a problem for later, here are the projections that define what “later” looks like.

Obesity has reached epidemic proportions, with over 1 billion people classified as obese in 2022. Since 1975, obesity rates have tripled. By 2035, around 1.9 billion adults will be affected. By 2050, it is estimated that more than half of the anticipated global adult population — approximately 3.8 billion adults — will be living with overweight or obesity.

Approximately 159 million children and adolescents were living with obesity in 2022. If current trends persist, that figure will rise to 254 million by 2035, and 390 million by 2050.

The global economic costs of obesity are projected to rise from just below US$2 trillion in 2020 to over US$3 trillion by 2030, over US$4 trillion by 2035, and to US$18 trillion by 2060.

By 2050, more than 1.31 billion people are projected to have diabetes. The expected diabetes prevalence rates are highest in north Africa and the Middle East at nearly 17 percent — a region that shares food advertising conditions and regulatory gaps with much of sub-Saharan Africa.

Obesity is projected to be the number one preventable risk factor for non-communicable diseases by 2035. Preventable. That word deserves to sit on its own. This is a crisis that does not have to happen at this scale. It is happening because the policy tools to slow it exist and are not being used — and in many cases are being actively blocked.

For Nigeria, a country already losing over N200 billion annually from inadequate SSB tax implementation alone, a continuation of regulatory indifference means carrying the healthcare cost of a diabetes and hypertension epidemic on a health system that is already under severe strain — while the companies whose advertising helped engineer that epidemic repatriate their profits.


WHO MUST ACT, WHAT MUST THEY DO,  AND WHEN

The answer to the question of who must act is not complicated. It is the same entities that regulate everything else that affects public health at scale.

Governments must treat food advertising with the same seriousness applied to tobacco and alcohol. This means banning the advertisement of ultra-processed foods and sugar-sweetened beverages in any media with documented high child viewership — television, streaming, social media. It means making advertising restrictions law, not voluntary pledges.

Regulatory bodies — NAFDAC in Nigeria, EFSA in Europe, FDA in the US, and their equivalents across Africa — must be adequately funded, politically independent, and empowered to impose penalties that actually deter rather than penalties that function as the cost of doing business. A fifty-thousand-naira fine for deceptive food labelling is not a deterrent for a multinational corporation. It is a rounding error.

Labelling law must be rewritten so that the most important information appears on the front of the packaging, in readable font, in plain language — not hidden on the back in microscopic text. The “serving suggestion” loophole must be closed. If an ingredient or food item appears on the front of the packaging, it must be in the product.

Schools must be explicitly protected from food and beverage marketing, in their grounds, their digital spaces, and their sponsored programmes.

Civil society and the media must continue doing what organisations like CAPPA are doing — naming the products, naming the companies, publishing the research, and keeping the issue in front of both the public and their elected representatives.
The timeline is now. Obesity is projected to become the number one preventable risk factor for non-communicable diseases by 2035. That is nine years. The children who are being aggressively advertised to today will be the adult patients of that crisis.


 

FOOD SCIENTISTS AND THEIR MAGIC

FOOD ADDICTION:
Pharmacology has been applied to food to cause food addiction. Food industry critics say companies have made ultra-processed foods addictive, to achieve the “bliss point”: the precise combination of sugar, salt, fat, and texture that maximises craving and minimises the sense of fullness. It is a game of comparison to cigarettes. It is sickening to put an addictive substance in front of a child without advertising and then claim neutrality about the outcome.

MICROBIOME.
Emerging research is showing that ultra-processed foods disrupt the gut bacteria that regulate immunity, mood, and metabolism — effects that compound over a lifetime and may be particularly severe when the disruption begins in infancy.

Consumption of ultra-processed foods among children under 24 months is rising worldwide, triggering not only the potential of developing obesity but also decreased immunological protection. A child’s immune system is being shaped before they can read — by products being advertised to their parents with images that have no relationship to the product’s actual contents.

TRUST EROSION.
Every time a government fails to act on documented evidence of harm from a commercial product, it erodes the public’s trust in institutions. The lesson people draw is not “regulators are working.” It is: “no one is protecting us.” That lesson, absorbed at scale across a generation, has consequences far beyond food.

THE LAST THING
The data is clear — in hospital beds, in dialysis centres, in the rising childhood diabetes wards across our private and public hospitals. Who protects the people from commercial interests, from lobbyists who shape regulations, from manufacturers, from the impact on human resources and healthcare system’s balance sheet.

 


 

Mr. Wale Aderinokun contributed this article from Abuja, Nigeria

 

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