Can Unilever deliver its pledge to end marketing to kids?

Unilever has said it will stop marketing its brands to children under the age of 16 across both traditional and social media. This places it ahead of regulation governing advertising to children in most regions of the world, the company said.

Enhanced marketing principles include promises not to target under 16s with ‘any marketing or social media communications’. This will apply across Unilever’s food and refreshment portfolio, which includes ice cream.

Unilever already refrains from promoting its brands in schools, unless invited to join specific educational initiatives. And in 2020 the company said it will stop marketing foods and refreshments to children under the age of 12 in traditional media and under the age of 13 in social channels. The biggest shake-up in this latest update – and also the greatest challenge – lies in the company’s efforts in the digital space. 

From January 2023, Unilever will not collect or store data on under 16s. It will no longer use influencers or celebrities who are either under 16 or whose ‘primary appeal’ is to children and it will provide ‘clear and prominent disclosure’ of provisions to influencers, limiting child appeal to influencer content. The commitment includes online behavioural targeting of those under 16 years old as this is a form of online targeted advertising, FoodNavigator understands. 

“Recognising the power that social media and influencer marketing can have on children’s choices, we believe it’s important to raise the bar on responsible marketing to a minimum age of 16 years old across both traditional and social media,”​ Unilever’s President of ice cream Matt Close said.

“By making these changes, our goal is to continue to reduce children’s exposure to advertising from the food and beverage industry, and instead support parents to select appropriate treats, to be enjoyed from time to time.”​

But, in the digital world where brands only have so much control over who is exposed to their content, is this easier said than done?

There are certainly some challenges Unilever will need to overcome in order to deliver on this commitment, Adam Freeman, Managing Partner at digital marketing agency MediaVision, told FoodNavigator.

“Control for a brand in a digi-ecosystem is very hard. Unilever is saying there is a difference between active and passive advertising… They are going to make active changes to how their brands interact with families,”​ Freeman suggested.

Digital advertising is ‘like the Wild West’

Perhaps the biggest challenge that Unilever faces is the fact that digital advertising, targeting and data collection – in many ways the entire digital ecosystem – is relatively unregulated, uncontrolled and – until recently at least – unscrutinised compared to the physical sphere.

“From an industry point of view, [digital advertising] is like the Wild West… The internet is the only place in our world where kids are treated the same as adults,”​ Freeman observed. “This is difficult. In the EU you do have GDPR, but you certainly don’t have that level of protection for consumers in other parts of the world.”​

Big tech companies like Apple and Google are tightening up some of their targeting and tracking policies on a voluntary basis. Apple is beginning to offer users more opportunities to opt out of having their activity tracked, while Google is adjusting its cookies policy. In June last year, Google said it will phase out third party cookies from Google Chrome by late 2023. The tech giant said the move should be part of web community efforts to develop ‘open standards’ that ‘fundamentally enhance privacy on the web’, giving people more ‘transparency and greater control over how their data is used’.

“Third-party cookies are often used by marketers and advertisers to track users’ activity across multiple sites, to better understand their behaviour and preferences, as well as to create tailored, relevant advertisements,” ​D​aniel Schmidt, biz dev and FMCG Director at loyalty solution provider Loylogic told FoodNavigator recently​. “Food and beverage brands risk becoming totally disconnected from their customers.” ​

This is certainly a big shake-up in the world of marketing. But Freeman is sceptical that these changes will do much to protect children from exposure to undesirable advertising. “Big tech companies like Google, Facebook and Apple do nothing that doesn’t help their own business model… Platform owners have the biggest opportunity and have done the least to control the content children are exposed to online.”​

In this context, he applauds Unilever’s efforts. “This is a great, brave, sensible move. With their scale of investment, they can make a real difference,”​ he told us.

Freeman suggested that this will come back to active and passive choices. In a world where targeted advertising is poised to become harder, ‘context is coming back’ as an advertising concept. This means the content you choose to advertise your brand alongside and it represents an active choice for brands. He also suggested that the company can exert a degree of control over its organic search results, upgrading and downgrading different aspects of its brands to target relevant audiences.

In channels where Unilever is ‘more dependent on others’ – gaming websites, third party apps, etc – the company is ‘working closely’ with these partners to ‘encourage and advocate’ for improved processes to ensure the most accurate targeting takes place, FoodNavigator understands. But, for his part, Freeman believes ultimately Unilever will have to limit partnerships to truly deliver on its commitments.

Freeman predicts that the company will increase investment in other areas of its digital presence, including channels that are educational for parents and areas that the group can build direct relationships such as clubs, subscription services and direct delivery.