Food for health: the use of nutrient content, health, and structure/function claims in food...

The marketing of food continues to evolve from its promotion as a tasty necessity for life to a potentially health-enhancing experience. Increased interest in the connections between food and health may have been driven by time-challenged female baby boomers seeking ways to take better care

Regulatory agencies and food marketers have responded to this interest with product labeling and advertising claims that inform consumers of vital information ranging from the product's fat content to claims that its consumption may decrease the likelihood of disease such as cancer. Empirical evidence suggests that food-marketing practices may have led to positive public health outcomes and that information found in advertising and product labeling has been a factor in changing dietary habits among American consumers (Centers for Disease Control 1994; Ippolito and Mathios 1996; Stephen and Wald 1990). For example, cereal producers' use of health claims in the 1980s led to significant increases in consumer knowledge of the relationship between fiber consumption and cancer (Ippolito and Mathios 1990, 1991). USDA (U.S. Department of Agriculture) surveys of fat consumption and aggregate food production data indicated a trend away from high-fat food categories since 1977 (Ippolito and Mathios 1994).

The regulatory, marketing, and nutritional issues surrounding the use of health- and nutrition-related (HNR) advertising claims by the food industry are complex and evolving. The food industry, consumers, nutritionists, and the federal government offer varying views about effective communication of HNR messages. Some critics express concerns that the companies with the largest marketing budgets can promote health aspects more easily than nonbranded fresh foods that may contain similar or even better nutrients (Tufts University Health and Nutrition Letter 2001). Others say that some health claims in ads are "designed to deceive," because they don't provide full disclosure of the scientific evidence (Liebman 1999). One study found that most food advertising promoted "energy-dense, nutrient-poor" foods of questionable health benefits (Lohmann and Kant 1998).

It is the federal government's task to oversee the process and to ensure that ad content is not deceptive or unfair, while also encouraging marketing practices that may lead to positive health outcomes. The relationship between the incorporation of government guidelines and the advertising practices of food companies, specifically how they incorporate (or fail to incorporate) nutritionally oriented claims in food advertisements, is the subject of this paper.

This study seeks to address three general areas of inquiry related to the use of HNR claims in food advertisements through examination of a series of research questions. First, the study presents a framework for categorizing and analyzing HNR claims found in food advertisements, based on the most recent FDA (Food and Drug Administration) guidelines. The framework includes common nutrient content claims, such as "low fat," as well as FDA-authorized health claims, claims supported by research that a particular food will protect the consumer from diseases, such as cancer. Such a framework can be very useful for understanding complex regulations and food categories, and the myriad changes and additions to existing guidelines over the past decade. Unique to this study is analysis of structure/function claims, claims related to the ways that a food product affects the structure or function of the body without mention of a specific disease.

Second, the incidence and types of HNR claims, and the food groups most and least likely to utilize such claims in food advertisements, will be analyzed. The research presented here not only describes and analyzes the health- and nutrition-related messages found in food advertisements between 1998 and 2000, but also seeks to explain the underlying reasons for current industry practices.

Third, this study contributes to the advertising literature by providing additional, more recent insights into the ways that food marketers have incorporated regulatory guidelines into the advertising of food products. Although other studies have analyzed the presence and types of claims found in food ads--taste versus nutrition, for example--the findings are dated or based on claim categories that no longer fit current regulations. This study extends the research to include specific categories that resulted from passage of the Nutrition Labeling and Education Act (NLEA) of 1990 and the Dietary Supplement Health and Education Act (DSHEA) of 1994.

The following section discusses HNR claims in greater detail and provides background on their use.

RESEARCH BACKGROUND AND REGULATORY ENVIRONMENT

Much of the marketing literature related to health and nutrient content claims has focused on labels and packaging, including consumer processing of nutrition facts panel information (Mitra et al. 1999; Roe, Levy, and Derby 1999). Previous research has presented substantial evidence for the complexities of and difficulties in effective consumer processing of nutritional information (Ford et al. 1996; Jacoby, Chestnut, and Silberman 1977; Moorman 1990).

Studies that focused on the impact of regulation on food advertisements have also yielded important insights about the use of nutrient content claims by consumers and food marketers. For example, consumer awareness of diet-disease relationships actually declined during periods when nutrient content information was readily available in food advertisements (Teisl, Levy, and Derby 1999). A longitudinal analysis of margarine and oil advertisements revealed that food marketers relied more on content claims than heatrh claims during periods of regulatory change and that firms tended to direct their messages to health professionals rather than consumers during periods of tighter regulation (Pappalardo and Ringold 2000). The study's consideration of the roles of "science, politics, markets, and consumers" serves as a landmark in understanding the impact of regulation on health information in commercial speech prior to passage of the NLEA.

Content analyses of the claims found in food advertisements have consistently reported a food industry message strategy that emphasized taste and nutrient content rather than health (Hickman, Gates, and Dowdy 1993; Lohmann and Kant 2000; Lord, Eastlack, and Stanton 1987, 1988, 1989; Pratt and Pratt 1995). Two content studies, conducted prior to recent regulatory activity regarding the use of health and structure/function claims, drew somewhat different conclusions regarding industry practices and public policy, due in part to the use of different methods. Lord, Eastlack, and Stanton (1987, 1988, 1989) found that taste and quality claims were used most frequently and that health claims, and to a lesser extent, nutrient content claims, were rarely used by food marketers, whereas Hickman, Gates, and Dowdy (1993) found an overall increase in the use of nutrient-content and health claims during periods of change in nutritional public policy.

REGULATORY GUIDELINES FOR HNR CLAIMS

Guidelines governing the use of HNR labeling and advertising have undergone a number of changes since the 1970s. Prior to 1985, diet-disease claims were banned from labels and advertisements. Between 1985 and 1990, diet-disease claims were permitted, subject to existing regulations on deception (Ippolito and Mathios 1994).

Regulations changed again with the passage of the NLEA in 1990, which introduced new food labeling requirements, including the specification of nutrient content and health claims on all food packaging. Following passage of the NLEA, the FTC (1994) announced its intention to "harmonize its advertising enforcement program" with regulations for food labeling from the FDA. NLEA and DSHEA guidelines have had wide-reaching implications for the use of HNR claims in food advertisements, which will be explained in greater detail in the section that follows.

Nutrient Content Claims

Nutrient content claims utilize absolute and comparative terms to communicate the level of a particular nutrient found in foods. There are numerous nutrient content claims, such as "fat free" and "an excellent source of calcium." A special type of nutrient content claim is "healthy," a claim that has received special scrutiny and guidelines from the FDA because "healthy" is a very useful advertising term (Golodner 1993). According to FDA guidelines, a product must have low total fat content as well as low levels of saturated fat, sodium, and cholesterol to qualify as a "healthy" food.

There is also a third type of nutrient content claim, which is referred to as a "general nutrition claim" in this study. These are nonspecific terms, such as "wholesome" and "nutritious," which imply that the product is good for the consumer.

Health Claims

The use of health claims to market food became a national policy issue in the mid 1980s when Kellogg's and the National Cancer Institute launched a promotional campaign for All-Bran Cereal that emphasized the role of bran cereals in the reduction of cancer risks (Freimuth, Hammond, and Stein 1988). The campaign violated FDA policy banning the use of health claims for food products, but triggered a review of government policy, which now permits the use of health claims in well-defined circumstances (Ippolito and Mathios 1991; Walsh 1998). The inclusion of health claims in the NLEA was meant to encourage consumers to make wise food choices and manufacturers to produce more healthful products (Geiger 1998).

A health claim for food must be based on the presence or absence of a nutrient that is linked to a disease or health-related condition (FDA 2001). Authorization is based on either a review of the scientific literature by the FDA or, more recently, an "authoritative statement" from a federal agency or the National Academy of Sciences (FDA Modernization Act 1997). Authorized health claims are presented in the Appendix.

Structure/Function Claims

In 1994, the DSHEA established a new category of claim, called a structure/function claim, which applies to both food and nutritional supplements. Structure/function claims describe how a product affects the structure or function of the body, but do not mention or imply a relationship to a disease. An example of a structure/function claim would be "calcium builds strong bones" (FDA 2001).

The FTC's position on structure/function claims is not as explicit as those expressed for nutrient content or health claims (Glinsmann 1999). Structure/function claims do not require FDA preauthorization or approval and the manufacturer, not the FDA, is responsible for ensuring that the claim is accurate and truthful (FDA 2001). Heller (2001) called structure/ function claims "perhaps the biggest loophole in the U.S. regulatory scheme," and pointed out that some companies have decided to forego the health claim approval process by the FDA in favor of using structure/function claims.

STUDY OBJECTIVES AND RESEARCH QUESTIONS

Previous studies have reported the frequency of HNR claims in food advertisements (Hickman, Gates, and Dowdy 1993; Lohmann and Kant 2000; Lord, Eastlack, and Stanton 1987). However, none of the studies utilized current HNR claim categories as the unit of analysis or contrasted the use of health claims with structure/function claims, as they are defined at present. To correct for this omission, a series of research questions, based on findings and/or limitations of previous research, were developed to draw conclusions about industry practices. Answers to the following questions will contribute to the research stream on HNR claims in food advertising.

RQ1: Likelihood of HNR Claim Usage by Food Marketers

Given increased emphasis on healthy eating and increased federal guidelines for HNR claims, how likely were food marketers to employ HNR claims in food advertisements published between 1998 and 2000?

RQ2: Health Claims Versus Structure/Function Claims

Did the introduction of more health claim categories, the passage of time, and marketers' greater experience in the use of health claims result in proportionately greater usage of such claims than has been previously reported? Given the subtle verbal differences but major policy differences in the use of structure/function and health claims, how likely were food marketers to use each type of claim to communicate health-related benefits to consumers?

RQ3: Specific Versus General Claims

Based on reports of consumer skepticism of general claims (Andrews, Burton, and Netemeyer 2000), how common is food marketers' use of nonspecific nutrient content claims, such as "healthy" and "wholesome"? Given purported consumer interest in lowering dietary fat, how often is fat content mentioned in nutrient content claims? (See Hickman, Gates, and Dowdy 1993; Ippolito and Mathios 1994.)

RQ4: Relationships Among Numbers of Ads, Claims, and Food Categories

Which products are most heavily advertised? Are nutritious foods, such as fruits and vegetables, advertised as frequently as less nutritious foods, such as fats, oils, and sweets? What is the relationship between food categories and the types of claims they employ?

METHOD

The researcher used content analysis procedures cited in Krippendorff (1980) to develop greater understanding of the following advertising content areas:

1. The types of food products and categories that contain nutrient content, health, or structure/ function claims.

2. The types of claims used by food product manufacturers.

3. The incidence of claim usage by food type and product category.

Food ads from 108 issues of three popular consumer magazines published between 1998 and 2000 were collected and analyzed to draw conclusions about advertising content and industry practices. Print advertisements were used for a number of reasons, including the fact that they typically provide detailed product information (Shimp 2000). Hickman, Gates, and Dowdy (1993), who also chose print media for their research, noted that few studies of health and nutrition claims have focused on print media, despite the fact that print media are often ranked among the sources from which adults seek nutrition information.

Food industry data and methods used in earlier studies were analyzed prior to magazine sample selection. Industry data indicated that women ages 25 to 64 are the primary food shoppers (Food Marketing Institute 2001), suggesting that magazines targeted at that demographic group would be a good source of food advertisements. A number of high circulation, mainstream magazines targeted at the demographic group were considered by the researcher, including American Health, Better Homes and Gardens, Cosmopolitan, Good Housekeeping, Modern Maturity, and Prevention. Pretesting revealed that Good Housekeeping, Prevention, and Better Homes and Gardens contained the most advertisements overall, yielded the largest numbers of food ads, and contained editorial content about food and consumer health. Those three magazines also reported audiences over 75% female with median ages ranging from 44 to 50 (Marketer's Guide to Media, 1997-1998). Good Housekeeping and Better Homes and Gardens had also been used in two earlier studies (Hickman, Gates, and Dowdy 1993; Teisl, Levy, and Derby 1999).

The standard food advertisement in consumer magazines is a full-page, four-color advertisement and this was the primary unit of measure for this study. Two-page (spread) ads were counted as one ad. Ads smaller than one-quarter of a page and classified ads were not included.

Because of the common practice of frighting advertisements, a decision was made to analyze entire years of ads, rather than a sampling scheme that alternated months. The time period from 1998 to 2000 encompassed the most recent advertisements available, and it was felt that three years of data would yield a robust sample representative of current industry practices. The ads were also published within an appropriate time frame for industry to have incorporated regulatory guidelines into their ads. Ads that appeared multiple times were counted only once.

The ads were sorted systematically by publication, date, food group, food type, brand, and claim, and the data were placed in an SPSS file. Food and beverage products found in the ads were categorized into eight food groups, using the USDA Food Pyramid as a guide. Products that combined two or more categories, such as frozen meals, were called "combination" foods. Products such as condiments and beverages, which did not fit into a specific category, were classified as "other," a category also identified by Hickman, Gates, and Dowdy (1993). Products that could be classified as medicinal or nutritional supplements (e.g., nutritional drinks and energy bars) were not analyzed.

The researcher provided training regarding HNR claim categories to three content judges, two undergraduates and one graduate student. The judges were then instructed to individually examine the headline, copy, and visuals of a small subset of ads for the presence of an HNR claim. The researcher compared the results for consistency and resulting discrepancies were discussed to achieve coding consensus prior to further data categorization.

The judges then worked independently to analyze all ads. Cohen's [kappa] coefficient was calculated using SAS to determine the degree to which intercoder agreement was greater than that expected by chance. Intercoder agreement was .924 and significant at the p < .0001 level.

To develop the final data, the author reexamined those claims for which consensus had not been achieved and resolved all discrepancies in consultation with the graduate student. As a further test of the data's reliability, a sample of the claims was subjected to a second analysis. Another graduate student, who received training from the author on FDA claim categories, and who had no knowledge of the previous judges' coding, analyzed a systematic sample of 10% of the ads. The author compared the second graduate student's results with the final data, and using percentage agreement, found that 96% of the claims were coded identically. The author resolved all disagreements, which were not material, and made no further changes to the data.

RESULTS AND DISCUSSION

RQ1: Claims Usage by Food Marketers

The magazines yielded a usable sample of 1,320 unique ads that contained 674 HNR claims. Forty-one percent of the ads contained at least one type of HNR claim, whereas 59% did not contain any type of HNR claim. HNR claims from Better Homes and Gardens made up 38.7% of the sample, while Good Housekeeping and Prevention contained 31.5 % and 29.8%, respectively.

Nutrient content claims were the most common type of HNR claim, a finding supported by earlier studies (Hickman, Gates, and Dowdy 1993; Teisl, Levy, and Derby 1999). As shown in Table 1, 65.9% of all HNR claims in the sample were nutrient content claims.

RQ2: Health Claims and Structure/Function Claims

Despite the passage of time since regulatory approval and the wide availability of guidelines for the use of health claims, food marketers made very limited use of health claims. As Table 1 illustrates, 4.5% of all HNR claims were health claims.

Almost all of the health claim categories shown in the Appendix were found in the sample. Analysis revealed that 53% of health claims were related to lowering the risk of heart disease, whereas 19% claimed that use of the product would lower the risk of cancer. Two ads contained statements that the product would reduce the risk of both heart disease and cancer. Prevention of osreoporosis was mentioned in 12.5 % of health claims, and one other ad mentioned both osteoporosis and heart disease.

Health claims related to the prevention of stroke and birth defects were found in only one ad each. There were no health claims related to the reduction of dental caries and no ads contained the health claim linking plant sterol and plant stanol esters with a reduced risk of coronary heart disease. (The claim had not received final approval during the time period under analysis [FDA 2000]). Only two health claims were based on authoritative statements, as described in the Appendix.

Table 1 also illustrates that food marketers made far greater use of structure/function claims (13.1% of all HNR claims) than health claims (4.5% of all HNR claims). Most structure/function claims were related to bone health, cholesterol levels, and increased energy and well-being.

RQ3: Specific Claims Versus General Claims

Specific nutrient content claims, such as calories, vitamins, or fat content, were used more frequently than general nutrition claims, such as "wholesome," "nutritious," or "healthy." Food marketers were very likely to mention the product's fat content in nutrient content claims: Nearly two-thirds (62.6%) contained statements about low fat or the number of fat grams in the product.

The less-specific general nutrition claims and "healthy" claims accounted for 7.7% and 8.0% of claims, respectively. Some marketers do not directly make "healthy" claims about their products, but refer to the product's contribution to "healthier lifestyles" or as "a delicious way to eat healthy." The relatively low incidence of less specific claims was not unexpected, given research indicating that such claims are not as believable as nutrient content claims (Andrews, Burton, and Netemeyer 2000).

RQ4: Relationships Among Numbers of Ads, Claims, and Food Categories

Table 1 also illustrates the relative frequency of advertising for each of the food groups. Despite the USDA's recommendation that Americans consume products from this category sparingly, the highest number of ads was for products in the fats/sweets group, which accounted for 22.7% of the 1,320 ads. The bread and cereal group was the second most heavily advertised food category, accounting for 21.0% of all ads, and the food group most likely to contain an HNR claim. Some of the healthiest products were the least advertised. For example, the fruits and vegetables categories revealed the fewest number of ads: 5.9% and 4.0%, respectively.

Almost all of the 32 health claims identified in this study were found in ads for just four food groups: the bread/cereal group, fruit/juice, combination foods, and dairy. Not surprisingly, there were no health claims made for the fats/sweets category. Structure/function claims were most likely to be found in the following categories: bread/cereal, fruit/juice, and "other," which included ads for black and green teas.

Finally, analysis revealed that marketers often communicated HNR claims by depicting the product package in the ad. Package-based claims were counted as HNR claims and included in the totals. When including the package or label containing an HNR claim, food marketers often reinforced or explained the corresponding claim in the ad copy. In some cases, the picture of the package included specific nutritional information, such as "3 grams of fat" or "low sodium," but the claim was not mentioned in the ad copy.

Comparison of Findings with Previous Studies

Comparisons of these findings with studies by Hickman, Gates, and Dowdy (1993) and Lord, Eastlack, and Stanton (1987, 1988, 1989) should be made with caution. Each of the studies had a different purpose and methodology, and findings were based on somewhat different food group classifications and different claim criteria related to regulatory guidelines in effect at the time. For example, the studies by Lord and his colleagues were based on a sample of ads from general interest magazines, such as Time, Newsweek, and TV Guide, rather than magazines more likely to yield greater numbers of food ads. Also, the sampling procedure did not include beverages, which were a good source of HNR claims in this study.

It is also difficult to compare the frequency of health claims found here with those of Hickman, Gates, and Dowdy (1993), because of different HNR classification schemes. The best comparison for health claims in their study was a subcategory called "prevents illness," which ranged from 0% of ads in 1982 to 3% of ads in 1990. In any case, the frequency of health claims reported in previous studies has been small, ranging from 1 to 3% of advertisements (see Teisl, Levy, and Derby 1999).

SUMMARY AND CONCLUSIONS

This study reveals that food marketers continue to take a cautious approach with regard to the use of health claims in print advertisements and that they prefer to use nutrient content or structure/function claims. While nutrient content claims continue to be the claim "of choice" for food marketers, the continued limited use of health claims (based on studies that analyzed data from ads published in the 1970s and 1980s) may seem puzzling.

One could reasonably expect greater use of health claims due to growth in the number of approved health claims and food marketers' experience with the regulations. Also, the myriad branded fruits and vegetables to be found fresh, canned, or frozen in grocery stores would seem to be likely candidates for health claims. In fact, Geiger (1998) referenced a survey that reported that 97% of cereals qualified for at least one health claim. Increasing emphasis in the media on healthy eating and widespread government recommendations for consumers to "eat five fruits and vegetables a day" would also seem to suggest potentially greater use of health claims by food marketers.

There is also a business case to be considered, namely, that the use of health claims should be a boon for marketers hoping to create competitive advantage for their products. As Nestle (2002, p. 286) noted in Food Politics:

   The 1984 Kellogg's campaign to promote eating cereals high
   in fiber as a way to reduce cancer risk ... demonstrated beyond
   question that health claims increase the market share of
   specific products, at least in the short term, and subsequent
   studies have confirmed this observation.

Nevertheless, the FDA has acknowledged that the use of health claims has not been as great as the agency had anticipated (FDA 1995) and this study provides ample evidence that health claims continue to be found infrequently in print ads.

This study sheds light on several probable reasons for the limited use of health claims. First, nutritionally rich foods, such as fruits and vegetables, are simply not advertised as much as less nutritious food categories. Second, highly advertised, but less nutritious foods, such as fats and sweets, are not as likely to qualify for such claims, a finding consistent with previous research by Ippolito and Mathios (1993). For products that would qualify nutritionally, regulatory risk related to high levels of substantiation may be a likely reason for food marketers' reluctance to use health claims (Calfee and Pappalardo 1991; Pappalardo and Ringold 2000). The lack of health claims may simply reflect a conscious decision by marketers to avoid the stringent guidelines and lengthy FDA approval process in favor of the looser guidelines and procedures associated with the use of structure/function claims.

Speculation by Lord, Eastlack, and Stanton (1988) that "new FDA guidelines may help to alleviate marketers' reluctance to use (health) claims" was not supported by this study. The relatively light usage of health claims by food marketers suggests that the public health potential for creating greater awareness of health-enhancing foods through print advertising has not yet been realized. Nevertheless, the study's finding of two health claims based on authoritative statements provides some indication that the FDA Modernization Act of 1997 may eventually increase the number of health claims through a more streamlined approval process. In contrast, a relatively open and unresolved regulatory environment for structure/function claims probably contributed to food marketers' greater reliance on such claims. This is a topic for future research that cannot be answered from this study.

A secondary issue related to structure/function claims is clarity and the processing of such claims by consumers. This study reveals subtle differences in wording that may not be readily apparent to the average consumer. For example, a number of marketers claimed that their products would help maintain healthy levels of cholesterol, which is a structure/function claim, rather than saying that the product may also prevent heart disease, which would be a health claim. It is not clear from this study whether consumers would perceive differences in the two claims. From a marketer's standpoint, however, the decision to use a structure/function claim over a health claim could conceivably save the marketer a great deal of time and money by avoiding FDA approval requirements

On the other hand, health claims may be perceived as more powerful marketing messages, since a specific disease may be prevented. For example, a number of milk ads mentioned prevention of osteoporosis (a health claim), whereas other ads mentioned strong bones (a structure/function claim). Since the ads were published during close time periods, it is unclear why the National Fluid Milk Processor Promotion Board, the sponsor of the ads, would make such distinctions. It is possible that the advertiser was testing to see which claim would prove more memorable or persuasive. Additional information about FTC-sponsored copy tests can be found in Sims (1999).

Marketers of bread and cereal products, especially cereal marketers, were by far the most likely to utilize HNR claims in advertising. They were also more likely to advertise. Many cereal marketers have the large budgets necessary for advertising, product development to meet guidelines, and regulatory efforts to petition the FDA for health claim approval based on authoritative statements, as recent health claim petitions by General Mills and Tropicana illustrate. A potential policy issue for debate is whether smaller companies with smaller budgets are at a disadvantage in terms of the substantial time and money necessary to comply with regulations.

An intriguing conclusion from this study is that marketers continue to place great emphasis on communicating the amount of fat in the product being advertised. It is impossible to determine from this study whether and how this practice has influenced Americans' fat consumption, but such food-marketing practices remain consistent with a recent survey that reported that over half of Americans now eat less fat than previously (Wirthlin Report 2000).

LIMITATIONS AND DIRECTIONS FOR FUTURE RESEARCH

This study provides additional insights into food industry practices regarding the use of HNR claims in food advertisements. It can also serve as a baseline for future studies of the relative frequency of health, nutrient content, and structure/ function claims in food advertising.

A limitation of the study is its three-year time frame, which may represent an early stage in the understanding and use of health and structure/function claims by food marketers. Future research could use the framework presented here to develop longitudinal studies to measure whether and how such advertising claims are increasing, and to provide further insights into the long-term influence of regulation on the use of nutritional content and health claims in food advertising. Longitudinal studies could also be used to measure the incidence and impact of new health claims, as they are added to the list of authorized health claims in the future.

As policymakers expand the list of foods that qualify for health claims, they should also continue to monitor usage of such claims in other media, such as broadcast ads and on food manufacturers' Web sites. The Web may turn out to be an ideal medium for discussion and explanation of these complex terms.

There are a number of highly related areas for future study. For example, an examination of the incidence and content of scientific disclosures that sometimes accompany health claims or structure/function claims (i.e., "a study conducted by the National Institutes of Health found ...") would be useful. Future research should also incorporate the marketing of nutritional supplements and "functional" foods, defined as foods that may provide a health benefit beyond their traditional nutrients (Benecol spread and other cholesterol-lowering foods, for example). This study analyzed food advertisements in U.S. media only. Future research could be undertaken to compare and contrast the types of advertising claims made as the food supply becomes more globalized.

The primary objectives of this study were to analyze and explain marketers' responses to the government's dual goals of controlling deception while promulgating the public health benefits of food. Those objectives were realized. This study has also updated the literature to incorporate the latest health claims and insights into marketers' preferred use of structure/ function claims to either avoid the health claim approval process or as a backup plan when the product does not meet the stringent guidelines. Additional research on consumers' processing of HNR claims and other complementary areas of research are also proposed to provide further understanding of this complex area of advertising research.

APPENDIX

Authorized Health Claim Links for Food, 1993-2000

Nutritional claim          Health claim
Diets rich in calcium      Reduced risk of osteoporosis
Diets low in sodium        Reduced risk of high blood pressure
Low dietary saturated
  fat and cholesterol      Reduced risk of coronary heart disease
Low dietary fat            Reduced risk of cancer
Fiber-rich grains,
  fruits, and vegetables   Reduced risk of cancer
Fiber, particularly
  soluble                  Reduced risk of coronary heart disease
Fruits and vegetables      Reduced risk of cancer
Folate                     Reduced risk of neural tube birth defects
Sugar alcohols             Reduced risk of dental caries
Soluble fiber from whole
  oats and psyllium        Reduced risk of coronary heart disease
Soy protein                Reduced risk of coronary heart disease
Plant sterol and plant
  stanol esters (a)        Reduced risk of coronary heart disease
Whole grain foods (b)      Reduced risk of coronary heart disease and
                             certain cancers
Potassium-containing
  foods (c)                Reduced risk of high blood pressure and
                             stroke

Source: FDA Food Labeling Guide, Appendix C, November 2000.

(a) FDA Interim Final Rule, September 2000.

(b) Approval based on authoritative statement, July 1999.

(c) Approval based on authoritative statement, October 2000.

TABLE 1
Summary of HNR Claims and Ads by Food Group

                      Bread/     Comb.    Fats/     Fruit/    Meat/
                      cereal     foods    sweets    juice    protein

Nutrient content         92        45        89       31        56
  claim               (13.6%)    (6.7%)   (13.2%)   (4.6%)    (8.3%)
General nutrition        21         2         4        3         9
  claim                (3.1%)     (.3%)     (.6%)    (.4%)    (1.3%)
Healthy claim            13         9         2        2        18
                       (1.9%)    (1.3%)     (.3%)    (.3%)    (2.7%)
Structure/ function      30         7         3       18         1
  claim                (4.5%)    (1.0%)     (.4%)   (2.7%)     (.1%)
Health claim             14         5         0        7         1
                       (2.1%)     (.7%)    (0%)     (1.0%)     (.1%)
Total HNR claims        170        68        98       61        85
                      (25.2%)   (10.0%)   (14.5%)   (9.0%)   (12.5%)
Total ads               277       152       300       78       123
                      (21.0%)   (11.5%)   (22.7%)   (5.9%)    (9.3%)

                      Dairy    Vege-    Other    Total
                      foods    tables   foods

Nutrient content         58      13        61        445
  claim                (8.6/)  (1.9%)    (9.0%)    (65.9%)
General nutrition        10       1         3         53
  claim                (1.5%)   (.1%)     (.4%)     (7.7%)
Healthy claim             5       1         5         53
                        (.7%)   (.1%)     (.7%)     (8.0%)
Structure/ function      12       3        15         89
  claim                (1.8%)   (.4%)    (2.2%)    (13.1%)
Health claim              3       1         1         32
                        (.4%)   (.1%)     (.1%)     (4.5%)
Total HNR claims         88      19        85        674
                      (13.0%)  (2.6%)   (12.4%)    (99.2% *)
Total ads               111      53       226      1,320
                       (8.4%)  (4.0%)   (17.1%)    (99.9% *)

                      [chi square] **

Nutrient content         35.972
  claim
General nutrition        33.14
  claim
Healthy claim            47.703

Structure/ function      67.199
  claim
Health claim             -- ***

Total HNR claims

Total ads

Note: HNR = health and nutrition related.

* Totals do not equal 100% due to rounding.

** df = 7; p < .0001.

*** More than 25% of cells have expected count less than 5.

Funding for this study was provided by a grant from the Faculty Research and Creative Activities Fund at Western Michigan University. Additional assistance was provided by the John W. Hartman Center for Sales, Advertising, and Marketing History at Duke University. The author thanks Professor Ron Faber and the reviewers for their helpful comments. Thanks are also due to Jingcai Chen, for her assistance in data collection and coding, and the author's colleagues in the Haworth College of Business for their suggestions on earlier versions of the article.

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Centers for Disease Control (1994), "Daily Dietary Fat and Total Food-Energy Intakes: Third National Health and Nutrition Examination Survey," Morbidity and Mortality Weekly Report, 23 (February 25), 116-125.

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Betty J. Parker (Ph.D., University of Missouri) is an associate professor of marketing and advertising, Department of Marketing, Western Michigan University.