Frequently Asked Questions 

CFBAI is a voluntary self-regulation pledge program created to improve the children’s food and beverage advertising landscape. Food and beverage companies and quick serve restaurant companies that participate in CFBAI have agreed to the CFBAI Core Principles to help address the challenge of childhood obesity. Under the Core Principles, participants commit that, in advertising primarily directed to children under age 13 in the United States (U.S.), they will either not advertise any foods or beverages to children in this age group or will advertise only foods or beverages that meet CFBAI’s Category Specific Uniform Nutrition Criteria.

CFBAI is administered by BBB National Programs, which also administers the Children’s Advertising Review Unit (CARU). CARU’s Guidelines apply to all companies that advertise to children and address how all products, including foods, are advertised to children. CFBAI’s Core Principles apply only to CFBAI participants and determine what foods they can advertise to children in covered media.

In 2006, BBB National Program’s predecessor organization, the Council of Better Business Bureaus, and leading U.S. food and beverage advertisers created CFBAI to respond to recommendations from the Federal Trade Commission (FTC) and the Institute of Medicine (IOM) that self-regulation do more to address concerns about food and beverage advertising to children in light of the national problem of childhood obesity. IOM had recommended that food and beverage companies shift their child-directed advertising emphasis to foods and beverages that are lower in calories, fats, salt, and added sugars, and higher in nutrient content. FTC had recommended that self-regulation could do more to address concerns about how foods are marketed to kids. CFBAI was created with the goal of improving the children’s food advertising landscape through nutrition standards for foods advertised in child-directed media.

Originally 10, now the 21 leading food and restaurant companies that participate in CFBAI have evolved the foods they advertise to children and how they advertise to do their part to help address childhood obesity in the U.S. The founding CFBAI participants were Campbell Soup Company; The Coca-Cola Company; General Mills, Inc.; The Hershey Company;  Kellogg Company; Kraft Foods Inc.; Mars, Inc.; McDonald’s USA, LLC; PepsiCo, Inc.; and Unilever USA.

CFBAI is a dynamic program that has demonstrated continuous incremental improvement since its launch. Its Core Principles have regularly been updated to reflect changes in children’s media environments and evolving government dietary guidance.

Currently 21 of the leading U.S. food, beverage, and restaurant companies participate in CFBAI.

• Burger King Corporation
• Campbell Soup Company
• The Coca-Cola Company
• Conagra Brands, Inc.
• Danone North America, PBC
• Ferrara Candy Company
• Ferrero USA, Inc.
• General Mills, Inc.
• The Hershey Company
• Hostess Brands, LLC
• Kellanova
• Keurig Dr Pepper, Inc.
• The Kraft Heinz Company
• Lindt & Sprüngli USA Inc. 
• Mars, Incorporated
• McDonald’s USA, LLC
• Mondelēz Global, LLC
• Nestlé USA
• PepsiCo, Inc.
• Post Foods, LLC
• Unilever USA

Overall, these companies represent the vast majority of food advertising directed to children in terms of the number of ads and the ad spend. Participating companies vary in their product portfolios. While some participants may advertise products to children in accordance with CFBAI’s standards, others have committed to not advertise foods or beverages to children at all.

CFBAI participation is open to all food, beverage, and restaurant companies and not all companies that advertise foods generally or to children participate in the program. CFBAI actively seeks out and is always open to new participants. Responsible marketing practices, especially regarding children, are an important part of corporate social responsibility and CFBAI welcomes non-participants to join the program or use its strict Uniform Nutrition Criteria when advertising to children.

CFBAI’s Core Principles focus on advertising on child-directed media, specifically advertising on TV, radio, print, and digital media, including company and third-party websites, mobile media and apps, child-directed content on open-access platforms such as YouTube, influencer communications, DVDs, product placements, product integrations, and word-of-mouth communications.

Packaging, in-store, and point-of-sale communications are forms of marketing that are primarily directed to the person making the food purchasing decision, which almost always is an adult gatekeeper. Therefore, these types of communications are not covered under CFBAI’s Core Principles. 

For some media, there is reliable audience demographic data to measure the age of an audience. CFBAI refers to these as “measured media.” For measured media such as TV, advertising primarily directed to children means advertising in media in which 30% or more of the audience is under the age of 13. Some participants use an even stricter 25% threshold. This audience demographic standard covers most advertising on child-directed TV networks such as Cartoon Network, Disney, Disney XD, Nickelodeon, Nicktoons, TeenNick and others.

In digital media, when audience composition is known, CFBAI considers advertising to be primarily directed to children under age 13 if 30% or more of the site, app, or content visitors are children under age 13. Because audience measurement data for children is more readily available in the U.S. for children under age 12, CFBAI participants may apply a 27% audience threshold for children under 12 as an approximation (proxy) for a 30% audience threshold for children under 13. In the digital environment, however, reliable audience composition data may not be available to make this determination. In such cases, an ad will be deemed primarily directed to children under age 13 based on an evaluation of multiple factors. These factors include age demographics for the site or digital content, an assessment of the overall nature of the content (e.g., the subject matter of the site or video, the visual content, the language used, the kind of music or audio content, the age of influencer or influencers featured in the content), and actions taken to restrict children’s access to the site or content. Platforms or content developers also may provide content identifier tools that indicate whether content is child-directed. Advertisers also can use age-targeting tools, interest-based or behavioral factors, and “do not serve” lists to avoid serving an ad to children under age 13.

CFBAI participants’ child-directed food advertising should clearly and prominently feature qualifying foods that meet CFBAI’s nutrition criteria. 

The Core Principles apply to advertising primarily directed to children under age 13 on platforms such as YouTube that may have content or channels that are primarily directed to children under age 13.

CFBAI refers to YouTube because it is the leading example of an open-access platform with content directed to children. CFBAI views media platforms that restrict children under age 13 differently. A platform’s use of valid age verification to restrict access creates a presumption that an advertiser on such platforms is not intending to primarily direct its advertising to children under age 13.

Content on participants’ corporate or brand social media sites should not be primarily directed to children under age 13.

Yes. If participants advertise a food or beverage through a child-directed influencer communication, that food or beverage must be a qualifying food or beverage (Section II.E of the Core Principles).

As noted in the Core Principles, influencer communications directed to children also must comply with CARU’s Self-Regulatory Guidelines for Children’s Advertising as well as FTC advertising disclosure requirements, including that ads should clearly and prominently disclose if influencers have been paid or otherwise compensated or incentivized to endorse a food or beverage. 

As explained in CARU’s Guidelines, which apply to all products advertised to children, content generated by a user who has no material connection to a product, service, character, or brand mentioned or depicted in that content is not advertising. Accordingly, such content would not be covered by CFBAI’s Core Principles. However, if a participant uses or incorporates such content in advertising primarily directed to children, then the use or incorporation of such content is covered by CFBAI’s Core Principles.