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CODE ON RESPONSIBLE MARKETING OF FOOD AND BEVERAGES TO CHILDREN IN BRUNEI DARUSSALAM
1st Edition January 2021
A tool to protect children from irresponsible food marketing
KEMENTERIAN KESIHATANMINISTRY OF HEALTH
CODE ON RESPONSIBLE MARKETING OF FOOD AND
BEVERAGES TO CHILDREN IN BRUNEI DARUSSALAM
1st EDITIONJanuary 2021
FOREWORD
ACKNOWLEDGEMENT
GLOSSARY
1. INTRODUCTION
2. DEVELOPMENT OF THE CODE
3. AIMS AND SCOPE OF THE CODE
4. GUIDING PRINCIPLES
5. MARKETING CONTROL SYSTEM
6. APPENDICES:
APPENDIX 1: SETS OF RECOMMENDATIONS ON MARKETING OF FOODS AND NON-ALCOHOLIC BEVERAGES TO CHILDREN
APPENDIX 2: BRUNEI DARUSSALAM NATIONAL MULTISECTORAL ACTION PLAN FOR PREVENTION AND CONTROL OF NON-COMMUNICABLE DISEASE (BRUMAP-NCD) 2013-2018
APPENDIX 3: MULTI-SECTORAL TASKFORCE ON HEALTH (2017)
APPENDIX 4: TIMELINE FOR REGULATION OF MARKETING OF FOOD AND BEVERAGES TO CHILDREN IN BRUNEI DARUSSALAM
APPENDIX 5: CURRENT LEGISLATIONS ON ADVERTISEMENT
APPENDIX 6: LIST OF AGENCIES INVOLVED IN CONSULTATIVE SESSIONS
APPENDIX 7: LIST OF FOOD AND ADVERTISEMENT AGENCIES INVOLVED IN FOCUS GROUP DISCUSSION
APPENDIX 8: INTERNATIONAL CODE OF BREAST MILK SUBSTITUTE
APPENDIX 9: NATIONAL BRUNEI DIETARY GUIDELINE FOR HEALTHY EATING BRUNEI DARUSSALAM
APPENDIX 10: GUIDELINE ON MARKETING OF FOOD AND BEVERAGES TO CHILDREN IN BRUNEI DARUSSALAM
APPENDIX 11: FLOWCHART FOR APPLICATION PROCESS OF CONTENT OF ADVERTISEMENT ON OTHER PLATFORMS
APPENDIX 12: FLOWCHART FOR ACTIONS ON COMPLAINTS ON THE ADVERTISEMENT RELATED TO THE CODE OF RESPONSIBLE MARKETING OF FOOD AND BEVERAGES TO CHILDREN
APPENDIX 13: FREQUENTLY ASKED QUESTIONS
REFERENCES
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TABLE OF CONTENTS
Code On Responsible Marketing Of Food And Beverages To Chi ldren In Brunei Darussalam 1
Alhamdulillah, with the grace and blessings of allah Subhanahu Wata’ala, Brunei Darussalam has achieved another significant milestone in the development of an essential health policy for our children, especially in improving the nutritional environment where they live, learn and play.
Good nutrition during childhood and adolescence is essential for growth and development, health and well-being. Eating behaviours and food choices established during childhood tend to persist through to adulthood and contribute to long-term health outcomes. Food marketing (including beverages) influences children eating behaviours and food choices and is a significant risk factor for childhood obesity (WHO). Furthermore, as they are still maturing intellectually, children are highly vulnerable to marketing as they do not understand its persuasive intent and lack the cognitive ability needed to interpret marketing messages critically.
In Brunei Darussalam, the introduction of the control of marketing of unhealthy food and beverages to children has been identified as one of the strategic priorities in creating a more conducive food environment to provide healthier options and to practice healthy lifestyles. Thus, an initiative to develop a Code of Responsible Marketing of Food and Beverages to Children in Brunei Darussalam was undertaken in 2018 under the behest of the Multisectoral Taskforce for Health: Giving Every Child the Best Start in Life.
The Code of Responsible Marketing of Food and Beverages to Children in Brunei Darussalam serves as a guidance for food and marketing industries to be responsible on the marketing of their food and beverage products, particularly to children, for the benefit of children’s health. The Code is also a useful resource and reference guide for policymakers and relevant stakeholders including schools, in controlling the marketing of food and beverages to children in the country.
The implementation of the Code will be undertaken in phases on various platforms of advertisements and
marketing such as printed media on billboards, posters, newspapers and magazines, during exhibitions, in cinemas, news websites as well as local radio and television channels. Compliance to the Code is currently on a voluntary basis, however, relevant stakeholders as well as vendors are strongly encouraged to adhere to the Code and put this into practise. It is hoped that after a suitable period of time the Code can be mandated formally.
Lastly, I would like to take this opportunity to extend my greatest appreciation to all members of the professional and technical committees, from the Ministry of Health as well as other agencies who have been involved in and contributed to the development of this Code for their valuable inputs and time.
With the collective efforts from all relevant agencies, stakeholders, community members and individuals in our beloved country, we can help ensure that all our children will always be given the best possible environment to grow up healthily and enjoy good quality of life. May Allah SWT continue to bless us and our population, especially our children, with good health and wellbeing, Aameen.
FOREWORD BY
Yang Berhormat Dato Seri Setia Dr Hj Md Isham bin Hj Jaafar
Minister of Health Brunei Darussalam
Code On Responsible Marketing Of Food And Beverages To Chi ldren In Brunei Darussalam2
ACKNOWLEDGEMENTS
Prime Minister’s Office
Ministry of Energy
Ministry of Health
Ministry of Home Affairs
Ministry of Transport and Info-communications
Attorney General’s Chambers
Radio Television Brunei
Authority of Building Construction and Industry,
Ministry of Development
Department of Schools, Ministry of Education
Private Education Section, Ministry of Education
Department of Religious Studies, Ministry of
Religious Affairs
Sultan Haji Hassanal Bolkiah Tahfiz Institute,
Ministry of Religious Affairs
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Authority for Info-communication Technology
Industry
DST Communication Sdn. Bhd.
Women’s Council
Mosque Affairs Community
Representatives from selected schools under
Ministry of Education and Ministry of Religious
Affairs
Members of Parent-Teachers Associations from
selected schools (parents and teachers)
Darussalam Enterprise
Cityneon Display & Construction Sdn Bhd
Hoco Agency
Jollibee Brunei
A Ayam Restaurant
Project Ice-Cream
Gong Cha
The Code of Responsible Marketing of Food and Beverages to Children in Brunei Darussalam has been
developed in collaboration with the Western Pacific Region World Health Organisation in line with WHO’s
recommendation to curb childhood obesity in the region.
Warmest appreciation and gratitude goes to Dr Hj Zulaidi bin Haji Abdul Latif, Deputy Permanent Secretary
of Health (Professional) for his valuable insights and advice on the content of the Code.
Special thanks to student interns from University Brunei Darussalam for their splendid work in conducting
observational situational analyses on the advertisement of food and beverages in Brunei & Muara District
and conducting pilot surveys on the draft Code; also to colleagues from the Health Promotion Centre and
other departments under the Ministry of Health for their positive team-work in making the development
of this document a success.
Special commendations and appreciation to all agencies involved in the regulation of food and beverages
advertisements in Brunei Darussalam ; food and advertising agencies, both in the government and private
sectors; Non-Government Organisations; schools’ representatives and parents, who have given their kind
cooperation and provide valuable inputs and feedback during the consultation and development process
of the Code:
Code On Responsible Marketing Of Food And Beverages To Chi ldren In Brunei Darussalam 3
GLOSSARY
‘Adolescents’ refers to persons of age 10 – 19 years old according to WHO definition.
‘Advertisement’ refers to any message, notice or announcement on food and beverages addressed to children or likely to attract children or families with children (directly or indirectly through promotional offers of a product or service) including mascots with intention to influence the choice, opinion or behaviour of children, their parents, guardians or caregivers in any advertising medium listed in Section 3 during any events in any public places including schools. Advertisement is one type of marketing
component.
‘Child’ refers to a person who has not attained the age of 14 years (Children and Young Persons Act
(Chapter 129), revised 2012)).
‘Child-dedicated radio and television’ includes programmes on channels on both free-to-air and subscription radio and television that specifically target children.
‘Direct-response mechanisms’ are those that allow consumers to place orders without face-to-
face contact with the supplier.
‘Food and beverages products’ refers to any food and beverage products marketed in Brunei, including meals or individual menu items by restaurant owners and other food service providers.
‘Guideline on Marketing of Food and Beverages To Children in Brunei Darussalam’ refers to the common nutrition profile for food and beverage products that is endorsed by Ministry of Health, which will be adopted by all companies for food and beverage marketing communications targeted primarily at children (refer Appendix 10).
‘Marketing’ refers to any forms of commercial communication or message that is designed to, or has the effect of, increasing the recognition, appeal and/or consumption of particular products and services. It comprises anything that acts to advertise or otherwise promote a product or service. Marketing includes advertisement, sponsorship and promotion.
‘Media platforms’ refers to traditional media such as radio, television, newspapers, magazines and
billboards; and new media such as social media and online application platforms.
‘Non-media platforms’ refers to product design and packaging, vending machines, loyalty schemes, free samples, free tastings and vouchers.
‘Social Responsibility’ refers to a concept whereby parties/companies balance their profit-making activities with activities that benefit society and this involves business with a positive relationship to the society in which they operate.
‘Unhealthy Food and beverages’ refers to food and beverages that do not comply with Guideline on Marketing of Food and Beverages To Children in Brunei Darussalam (Appendix 10).
Code On Responsible Marketing Of Food And Beverages To Chi ldren In Brunei Darussalam4
I. CURRENT SITUATION IN BRUNEI
From 1997 to 2016, the obesity rate in Brunei Darussalam has more
than doubled from 12% to 28%. Obesity rate among teenage children
nears 20% and the same worrying trends are seen in younger children
with 1-point increase in the prevalence of obesity every single year
since 2009.
These figures were observed despite increased awareness of healthy
eating and healthy lifestyle amongst the population and changes in
a number of areas such as getting healthier food into our schools
and communities, the integration of healthy eating in the school
curriculum, equipping parents with cooking skills, and other similar
programs.
Nutrition during childhood and adolescence is essential for growth and development, health and well-
being. Further, eating behaviours established during childhood track into adulthood and contribute to
long-term health and chronic disease risk. Among multiple factors influencing eating behaviours and
food choices of children and adolescents, food marketing targeting these age group is recognised as
one of the potential factors. Increased connectivity and the modern communication environment provide
food marketers with almost unlimited access to market their products, in particular to children and their
caregivers. Meta-analysis of many studies published in The American Journal of Clinical Nutrition 2016
revealed that marketing through different forms of communications play a big role in the nutrition and
dietary pattern of the children as they influence children’s food preferences, purchase requests and
consumption patterns. Moreover, as with many countries, today’s food system in Brunei Darussalam is
dominated by foods and beverages high in salt, free sugar and/or fats which undermine a healthy diet.
Additionally, consumption of unhealthy food and beverages as a result of marketing is now recognized as
a significant risk factor for child obesity and for the development of Non-Communicable Disease (NCD),
which is a major public health concern. Hence, this puts children’s health at risk.
Marketing of unhealthy food and beverages is evidenced in Brunei Darussalam by the existence of
marketing activities of unhealthy foods and beverages targeting children which is quite prevalent either
within or outside school compounds. Observational studies (unpublished) conducted in Brunei & Muara
District by the Health Promotion Centre in 2014 revealed more than half of food-related advertisements
on the billboards was on cheap ‘unhealthy foods and beverages’ placed at strategic areas including
INTRODUCTION1
Code On Responsible Marketing Of Food And Beverages To Chi ldren In Brunei Darussalam 5
around shopping/restaurant areas or by traffic light junctions. Moreover, most (87%) of food-related
advertisements in mini-markets was found to be on unhealthy categories (high in salt, free sugar and/or
fats) with some incentives such as winning prizes and free gifts with purchase of their products. In another
study (2016), it was also observed that more than half of food-related advertisements in four local radio
stations aired during ‘peak hours’ were on fast foods, and the majority (73%) of the advertised beverages
were high in free sugar. The Health Promoting School Survey 2016 done to 363 schools revealed less
than a third (28.4%; n=103) of the schools (public and private) advertised food and beverages, where
majority advertised them through leaflet/flyers (41.7%; n=43) and posters (37.8%; n=39). Food products
advertised include soft drinks (28.2%; n=29), fast food (27.2%; n=28), other drinks such as plain water,
chocolate malt drinks and fruit juice (21.4%; n=22) and ice cream (5.8%; n=6). Nevertheless, 49.5% of
schools advertised information related to healthy foods and beverages.
Children form a distinct population that are especially vulnerable to marketing. As they are still maturing
intellectually, they are not yet able to discriminate at a perceptual level commercial from non-commercial
content, nor are they able to interpret advertising messages that may raise doubts on the truth or value
of an idea or belief. Each of these capabilities develops over time as a function of cognitive growth and
intellectual development.
Furthermore, as their dietary patterns and behaviours tend to persist through adolescence to adulthood,
this may lead to development of NCD. Management and treatment of NCD and its complication, as been
documented by many countries, not only incur high health cost for the country, but also produce negative
impact to the productivity of the country due to short- and long-term disability and premature death, for
example in the case of diabetes. In addition, as stated in United Nation Convention on the Rights of the
Child, children should be protected from economic exploitation and advertising organisation should not
take advantage of the gullibility of children. The convention further states that children have the right to
adequate food which should be beneficial to their health and well-being.
Protecting children from the negative impact of irresponsible marketing of food and beverages and giving
them opportunity to grow and develop in a more conducive food environment is a good investment for
health. This will contribute to reduced disease burden of NCDs and in the long run help to ensure healthy
and sustainable workforce necessary for the socioeconomic development of the country.
One of the action plans towards ending childhood obesity as recommended in WHO’s Report of The
Commission On Ending Childhood Obesity 2017, is to implement the set of recommendations on the
marketing of foods and non-alcoholic beverages to children in order to reduce the exposure of children and
adolescents to, and the power of, the marketing of unhealthy foods. Following the resolution passed by
WHO during the Sixty-third World Health Assembly (WHA 63.14) in May 2010, this set of recommendations
was endorsed in order to uphold responsibility on the marketing of foods and non-alcoholic beverages with
Code On Responsible Marketing Of Food And Beverages To Chi ldren In Brunei Darussalam6
a high content of fat, sugar or salt (Appendix 1). It was then taken as one of the recommended actions
for the objective to promote balanced and healthy diet in Brunei Darussalam National Multisectoral Action
Plan for Prevention and Control of Non-Communicable Disease (BruMAP-NCD) 2013-2018 (Appendix 2),
and was also taken up as one of the initiatives under the purview of the Multi-sectoral Taskforce on Health:
Giving every child the best start in life (Appendix 3).
Ministry of Health’s strategy to regulate marketing of foods and beverages to children will adopt a stepwise
approach in terms of the scope of the Code. The initial step will involve regulating the advertisement and
promotion of food and beverages to children voluntarily. Succeeding steps will involve the regulation of
sponsorship with consideration of eventually mandating the Code legally. Furthermore, the regulation of
advertisement and promotion will also be conducted in phases focusing on various types of platforms.
Hence, this document will be updated periodically (Appendix 4).
ii. CURRENT LAWS ON MARKETING IN BRUNEI
Currently, there are no regulations or laws with regards to marketing of food and beverages to children.
However, some advertisements in general are currently being regulated through respective legislations
as listed below:
• Halal Certificate and Halal Label Order 2005 (ammendment 2017)
• Building Control Order, 2014 Building Control (Advertisement, Billboard and Signboard)
Regulations, 2016
• Newspaper Act (Chapter 105) revised 2013
• Public Entertainment Act (Chapter 181) revised 2013
• Public Health (Food) Act (Chapter 182)
• Public Health (Food) Regulations (R1, Chapter 182)
• Second Schedule Code of Practice For Advertising (Broadcasting Act (Chapter 180)) 2000 edition
These legislations regulate the general aspects of advertisement on their corresponding platforms. Some
of the clauses identified in the above legislation are complementary to that in this Code document.
Details on relevant clauses are enlisted in Appendix 5.
Code On Responsible Marketing Of Food And Beverages To Chi ldren In Brunei Darussalam 7
In view of the current situation on advertisement of food and the absence of regulation on the
advertisement of food and beverages to children, the Ministry of Health through the Health Promotion
Centre conducted several activities towards the development of a code document on advertisement of
food and beverages to children.
Two consultative sessions with relevant agencies (listed in Appendix 6) including private sectors such as
those involved in broadcasting and other stakeholders such as parents, Non-Government Organisations
and community organisations were held in February 2018 in the Health Promotion Centre, Ministry of
Health. Following the consultations, a draft Code on Responsible Marketing Of Food And Beverages To
Children In Brunei Darussalam was drawn up. This document is complementary to and should be read in
conjunction with the current regulations and legislations pertaining advertisement in general, as above.
Following this, in collaboration with Brunei Darussalam Enterprise, a Focus Group Discussion was
conducted in the third quarter of 2019 among some food and advertising industries (Appendix 7) to get
their feedbacks on the Code. The Code was then further reviewed and refined by the current relevant
regulatory agencies.
DEVELOPMENT OF THE CODE2
Code On Responsible Marketing Of Food And Beverages To Chi ldren In Brunei Darussalam8
This Code aims to:
• reduce the impact of marketing of unhealthy food and beverages amongst children using
various media and non-media platforms or medium and in public places such as restaurants,
schools and where children gather; and
• ensure responsible marketing of food and beverages to children among business owners,
media, advertising and marketing agencies.
• To provide a useful resource and reference guide to policymakers and relevant stakeholders in
controlling the marketing of food and beverages to children in the country.
Who is the Code for?This Code is intended for food and beverages:
• business owners (including supermarkets, convenience stores, traditional markets, kiosks
and cube shops)
• retailers in supermarkets, convenience stores, traditional markets and kiosks
• food-service providers (including Quick-service and full-service restaurants)
• restaurants
• caterers
• media and marketing agencies (including advertising)
• marketing regulators and practitioners
• sale promoters and distributors
• media influencers (for example bloggers)
• trade associations and representing bodies (including Commercial Fair Organisers)
• food operators within school community and
• public Health Policy makers, practitioners and researchers.
This Code is also intended for:
• publishers
• schools
• public authorities
• billboard owners
• newsagents
• bookshops
• internet search engines including social media
AIMS AND SCOPE OF THE CODE3
Code On Responsible Marketing Of Food And Beverages To Chi ldren In Brunei Darussalam 9
Where does this Code apply to?This Code shall apply to any marketing of food and beverages directed to children in any form or medium
which are used in Brunei Darussalam that include, but is not limited to:
• advertisements in printed media and materials such as local newspapers, local magazines, posters,
brochures, leaflets, flyers, plastic cards including re-charge cards and purchase incentives (including
toys, vouchers, discounts and prizes);
• local radio and television commercials;
• local cinema commercials;
• advertisements displayed on billboards (including digital billboards), signboards, skysigns, free-
standing advertising structure;
• advertisements displayed on public transportation and delivery vehicles; and
• local digital news websites
This code shall also apply in settings where at least 50% of children gather such settings including, but
are not limited to, nurseries or child care centres, pre-schools and schools, playgrounds, maternal and
child health clinics and paediatric services and during any sporting, cultural activities and community
events.
Is there any exception?Marketing communications that constitute ordinary display in store/at point of sale are excluded
from the scope of this Code.
“Ordinary display in store/at point of sale” should be understood to mean:
• advertisements that are located within the actual premises of the store/restaurant or along its
frontage, including but not limited to, pallets and point of sale materials, the display of products on
shelves, at checkouts or in the aisles of the store; menu boards, tray mats, posters, flyers, table
stickers, hanging mobiles, standees, tent cards and TV screens.
• where the store/restaurant consists of outdoor areas or drive-throughs, “ordinary display in store/
at point of sale” shall include display of products within such outdoor area or along its frontage
and along the drive-through route.
The following should NOT be considered part of “ordinary display”:
• any retail points that are located outside the store or restaurant premises including trade fairs
(cinemas, trade show, trade exhibition or expo), pop-up stores, exhibition booths and conferences;
flyers or pamphlets distributed outside the store or restaurant premises (e.g. by staff or paid
promoters, or at third-party venues).
As an aside, the regulation of advertisement of breast milk substitute does not apply here (Appendix 8).
Code On Responsible Marketing Of Food And Beverages To Chi ldren In Brunei Darussalam10
All marketing of food and beverages that may influence children, in any media shall adhere to the
principles set out in this document as follows:
Guidelines supporting Principle 1 are as follows:
1.1 Halal certification/Halal Permit (label) from Islamic Religious Council Brunei Darussalam is
mandatory for any food and beverages produced in Brunei Darussalam. Halal certificate/Halal
Permit label is required to be displayed in the said premise (Halal Certificate and Halal Label Order
2005 (amendment 2017).
1.2 Marketing must not undermine the role of parents, guardians or caregivers in educating children
to have a balanced diet and be healthy individuals.
1.3 Marketing must not urge children to ask or pressurise their parents, guardians or caregivers to
buy particular food or beverages for them.
1.4 Words or tones or pictures adopted in marketing must not encourage or pressure either children
into frequently or excessively consume, or their parents, guardians or caregivers into buying any
food and beverages including via direct-response mechanism through various methods such as:
1.4.1 featuring prices with words such as “only” or “just”, which implies a level of affordability
that may not be true;
1.4.2 promoting a different product or service targeting directly at children which is linked to a
food product of interest to children for example, promotion of a toy together with unhealthy food;
1.4.3 portraying substitution or replacement for a main meal on a regular basis, or undermine
the National Brunei Dietary Guidelines For Healthy Eating Brunei Darussalam (Appendix 9).
1.4.4 exaggerating benefits of foods for a nutritious diet and implies single food should replace
a healthy diet or undermine the importance of consuming a variety of foods.
1.4.5 portraying products as complete meals (for example lunch or dinner set) unless they are
formulated as a nutritionally-designed meal replacement.
1.4.6 Using the word ‘halal’ or halal logo as an attraction or guarantee on the nutrient value and
safety of the food product.
1.5 Promotion or advertisement must not include non-halal products such as products that
originate from swine or animals that has not been slaughtered in accordance with ‘Halal Syara’.
1.6 The quantity of the food depicted in marketing must be appropriate for consumption by a person
or persons of the age depicted. They must not suggest that a portion intended for more than
Principle 1:
All marketing to children must be prepared with and observe a sense of social
responsibility to consumers and to society.
GUIDING PRINCIPLES OF THE CODE4
Code On Responsible Marketing Of Food And Beverages To Chi ldren In Brunei Darussalam 11
one child is to be consumed by a single individual, or that an adult’s portion may be consumed by
a small child.
1.7 Nutrient and nutrition claims must comply with the requirements of the Public Health (Food)
Regulations (R1, Chapter 182) and Guideline on Marketing Of Food and Beverages To Children In
Brunei Darussalam (refer Appendix 10). Such claims should not mislead or deceive the consumer.
1.8 Marketing for slimming products or foods sold as an aid to slimming must not be directed to
children.
1.9 Food and beverages products marketed on any local radio and television must NOT:
1.9.1 be directly accessible from programmes commissioned for, principally directed at or
likely to appeal to children 15 minutes before, during or 15 minutes after child-dedicated
radio and television programming hours;
1.9.2 be aired at 6.30 to 7.30 a.m., 11.30 a.m. to 1.30 p.m. and 4.00 to 6.00 p.m.;
1.9.3 appear on editorial pages (text or interactive) such as TV tickers and pop-up
advertisements that are likely to be of particular appeal to a significant audience of children.
1.10 Marketing must not be accessible before and after cinema movies watched by children under
14 years old (with or without adult).
1.11 Marketing must not promote inactive or unhealthy lifestyles nor should they show people who
choose a healthy active lifestyle in a negative manner.
Guidelines supporting Principle 2 are as follow:
2.1 Marketing should be clearly recognizable as such by children and separated from editorial,
programmes or other non-advertising content.
2.2 Marketing should take into account the level of knowledge, sophistication and maturity of the
intended audience.
2.3 Marketing must not suggest that consumption of the advertised food and beverages would make
children feel superior, more confident, clever, popular or successful.
2.4 Marketing must not suggest that non-consumption of the advertised food and beverages would
make children feel inferior, unpopular, lacking in courage, or loyalty.
2.5 Marketing must not mislead in relation to any nutritional value of any food and beverages. Foods
high in sugar, fat and/or salt, especially those marketed to and/or favoured by children, must not
be portrayed in any way that suggests they are beneficial to health.
Principle 2:
All marketing to children should not make use of children’s credulity, loyalty,
vulnerability or lack of knowledge and experience or without reason, use fear to
mislead or deceive them.
Code On Responsible Marketing Of Food And Beverages To Chi ldren In Brunei Darussalam12
2.6 Marketing on foods high in sugar should not claim to be “low fat” or “fat free” which could mislead
the consumer to believe the food is low in energy or beneficial to health.
2.7 Marketing on food high in fat must not claim to be “low in sugar” or “sugar-free” which could
mislead the consumer to believe the food is low in energy or beneficial to health.
2.8 Marketing must not exploit children’s susceptibility to any charitable appeals.
2.9 Marketing must not exaggerate the value of prizes or the chances of winning them.
2.10 Marketing must make clear that adult permission is required if a prize or an incentive might cause
conflict between a child’s desire and a parent’s or other adult’s authority.
Guidelines supporting Principle 3 are as follows:
3.1 Child actors must not be featured in advertisements related to the marketing of foods and
beverages to children.
3.2 Popular personalities or characters (live or animated) well-known to children must be used with
due sense of social responsibility to consumers and society.
3.3 Popular personalities or characters (live or animated) well-known to children (including mascot)
must not be used to promote or endorse unhealthy food and beverages products.
3.4 Marketing must not suggest that consumption of advertised food and beverages would enable
children to resemble an admired figure or role-model.
3.5 Marketing must not suggest that the non-consumption of the advertised food and beverages
would imply that the children are not being loyal to the figure or role-model they admire.
Principle 3:
Popular personalities or characters well-known to children including child actors should not
be used in marketing to promote food in such a manner as to undermine a healthy diet as
defined by the Guideline on Marketing Food and Beverages in Brunei Darussalam.
Code On Responsible Marketing Of Food And Beverages To Chi ldren In Brunei Darussalam 13
This Code shall be implemented and monitored by five Divisions/Departments under the Ministry of Health,
which comprise of Department of Policy and Planning; Corporate Communication Division, Department of
Policy and Planning; Health Promotion Centre; Department of Pharmaceutical Services and Community
Nutrition Division, Department of Health Services.
Roles and responsibilities of the respective departments are as follows:
Any applications to relevant regulatory agencies for putting up advertisements on food and beverages to children on any medium must adhere to the Guideline on Marketing Of Food and Beverages To Children in Brunei Darussalam as in Appendix 10. All marketing on food and beverages to children must comply with all the terms and conditions stated in this Code. Appropriate actions will be taken should any of the statements
are breached (Appendix 11)
Any concerns or complaints from the public on marketing on food and beverages in relation to the Code will be forwarded to Ministry of Health and the respective regulatory agencies. Appropriate actions will be taken accordingly if marketing breaches the Code (Appendix 12). All complaints should be submitted in writing with full postal address and contact information, accompanied by sufficient details of the complaints for the respective regulatory body to act. Such complaints will be investigated further for verification and further actions.
DEPARTMENTS INVOLVED ROLES AND RESPONSIBILITIES
Department of Policy and Planning Provide legal advice relating to the Code;
Corporate Communication Division Fosters the internal and external relations function of Ministry of Health particularly this Code;
Health Promotion Centre Monitor and evaluate the implementation of the Code, including:
• Review application for food and beverages advertisement to children
• Monitor compliance of industries to the Code• From time to time, investigate and verify reports of
violation of the Code
Department of Pharmaceutical Services Regulate the safety, quality and effectiveness of medicines/supplements related to the Code;
Community Nutrition Division Evaluate all marketing materials within the scope of the Code in particular information related to nutrition content in the advertisements and determining whether the application for advertisements is acceptable or otherwise;
MARKETING CONTROL SYSTEM5
Code On Responsible Marketing Of Food And Beverages To Chi ldren In Brunei Darussalam14
APPENDIX 1
1. The policy aim should be to reduce the impact on children of marketing of foods high in saturated
fats, trans-fatty acids, free sugar, or salt.
2. Given that the effectiveness of marketing is a function of exposure and power, the overall policy
objective should be to reduce both the exposure of children to, and power of, marketing of foods
high in saturated fats, trans-fatty acids, free sugar, or salt.
3. To achieve the policy aim and objective, Member States should consider different approaches, i.e.
stepwise or comprehensive, to reduce marketing of foods high in saturated fats, trans-fatty acids,
free sugar, or salt, to children.
4. Governments should set clear definitions for the key components of the policy, thereby allowing for
a standard implementation process. The setting of clear definitions would facilitate uniform
implementation, irrespective of the implementing body. When setting the key definitions Member
States need to identify and address any specific national challenges so as to derive the maximal
impact of the policy.
5. Settings where children gather should be free from all forms of marketing of foods high in saturated
fats, trans-fatty acids, free sugar, or salt. Such settings include, but are not limited to, nurseries,
schools, school grounds and pre-school centres, playgrounds, family and child clinics and paediatric
services and during any sporting and cultural activities that are held on these premises.
6. Governments should be the key stakeholders in the development of policy and provide leadership,
through a multi-stakeholder platform, for implementation, monitoring and evaluation. In setting
the national policy framework, governments may choose to allocate defined roles to other
stakeholders, while protecting the public interest and avoiding conflict of interest.
7. Considering resources, benefits and burdens of all stakeholders involved, Member States should
consider the most effective approach to reduce marketing to children of foods high in saturated
fats, trans-fatty acids, free sugar, or salt. Any approach selected should be set within a framework
developed to achieve the policy objective.
8. Member States should cooperate to put in place the means necessary to reduce the impact of
cross-border marketing (in-flowing and out-flowing) of foods high in saturated fats, trans-fatty
acids, free sugar, or salt to children in order to achieve the highest possible impact of any national
policy.
W.H.O SET OF RECOMMENDATIONS ON MARKETING OF FOODS AND NON-ALCOHOLIC
BEVERAGES TO CHILDREN:
APPENDICES6
(PTO)
Code On Responsible Marketing Of Food And Beverages To Chi ldren In Brunei Darussalam 15
9. The policy framework should specify enforcement mechanisms and establish systems for their
implementation. In this respect, the framework should include clear definitions of sanctions and
could include a system for reporting complaints.
10. All policy frameworks should include a monitoring system to ensure compliance with the objectives
set out in the national policy, using clearly defined indicators.
11. The policy frameworks should also include a system to evaluate the impact and effectiveness of
the policy on the overall aim, using clearly defined indicators.
12. Member States are encouraged to identify existing information on the extent, nature and effects of
food marketing to children in their country. They are also encouraged to support further research
in this area, especially research focused on implementation and evaluation of policies to reduce
the impact on children of marketing of foods high in saturated fats, trans-fatty acids, free sugar,
or salt.
Source: WHO Set Of Recommendations On The Marketing of Foods and Beverages To Children (WHO2010)
Code On Responsible Marketing Of Food And Beverages To Chi ldren In Brunei Darussalam16
APPENDIX 2
BRUNEI DARUSSALAM NATIONAL MULTISECTORAL ACTION PLAN FORPREVENTION AND CONTROL OF NON-COMMUNICABLE DISEASE
(BRUMAP-NCD) 2013-2018:OBJECTIVE 2: To promote balanced and healthy diet.
RECOMMENDED ACTIONS FOR MINISTRY OF HEALTH
1. To ensure compliance to the National Dietary Guidelines.
2. To develop and implement policies that limit salt, sugar and saturated fat and eliminate partially
hydrogenated vegetable oil (PHVO) in processed foods.
3. To develop and implement policies to reduce the impact of marketing of food and non-alcoholic
beverages high in sugar, salt and fat to children.
4. To develop and implement mandatory food labelling for all domestic and imported food products
including a consumer-friendly labelling to identify healthier food products.
5. To ensure healthier dietary options in schools, workplaces and where children gather.
6. To conduct sustained mass media campaigns to increase consumption of fruits and vegetables.
7. To develop and implement guidance to interact with food industry for implementing policies.
Source: Brunei Darussalam National Multisectoral Action Plan For Prevention And Control Of Non-Communicable Disease (Brumap-Ncd) 2013-2018
Code On Responsible Marketing Of Food And Beverages To Chi ldren In Brunei Darussalam 17
Target: No increase in childhood obesity rate for the next two years (until 2020)
Action plan:
1. Implementation of Nutrition and Physical Activity Guidelines in child care centres
2. Improving compliancy of canteen vendors to guidelines:
a. Revision of existing school canteen guidelines
b. Reviewing contracts for canteen and feeding scheme services
3. Implementation of physical activity policy in schools
4. Consolidation of SIHAT CERGAS and FIT4GOOD programme
5. Food marketing:
a. Food advertising
b. Control of vendors outside the schools
c. Control of unhealthy food promotion
6. Increasing exclusive breastfeeding rates
7. Students’ BMI profiling in school
APPENDIX 3
MULTI-SECTORAL TASKFORCE FOR HEALTH (2017)
Theme: ‘Giving every child the best start in life’
Vision: to reduce childhood obesity rate
REDUCE CHILDHOOD OBESITY
Code On Responsible Marketing Of Food And Beverages To Chi ldren In Brunei Darussalam18
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Code On Responsible Marketing Of Food And Beverages To Chi ldren In Brunei Darussalam 19
APPENDIX 5
CURRENT LEGISLATIONS ON ADVERTISEMENT:
(PTO)
A. Building Control Order, 2014 Building Control (Advertisement, Billboard and Signboard) Regulations, 2016Interpretation.
2. In these Regulations, unless the context otherwise requires –
“advertisement” means any logo, symbol, sign, notice, representation or other visual device that promotes any goods, brand of products, services or events and includes any logo, symbol, sign, notice or representation that is projected on to any external surface of a building or structure by light or any other means;
“animated billboard” means an advertisement that exhibits, at any one time, one or more advertisements consisting of visual moving pictures or that are otherwise able to move or change colours due to the use of electrical, mechanical or other sources of power;
“balloon sign” means an advertisement or signboard that is inflated, tethered to and suspended above any building or premises or open ground and is conspicuously visible against the sky from the ground;
“signboard” means any sign, notice, representation or other visual device containing all or following information relating to which it is affixed – (c) particulars of any business or occupation carried on at the place or premises, including any logo or symbol that identifies the business or occupation
“skysign” means any advertising structure that is exhibited – (a) On or above the roof, parapet or eaves of a building or extends above the roof line of a building, and is conspicuously visible against the sky from the ground; and(b) Containing only particulars, including any logo or symbol, of the name or owner of the building to which it is affixed.
Requirement for written approval
3 (1). No person shall exhibit or cause or permit to be exhibited outdoors, any advertisement, animated billboard, balloon sign, directional sign, signboard or skysign, whether on the exterior surface of any building or any part of any premises or on any free-standing advertising structure, without the prior written approval of the Authority.
3 (2). Notwithstanding sub-regulation (1), the written approval of the Authority shall not be required for the following –
(c) any advertisement in a shop unit, shopping mall or shopping arcade;
Alteration to advertisement etc.
9. The words, information and content displayed on any advertisement, animated billboard, balloon sign, directional sign, signboard or skysign approved under these Regulations shall not be altered without the prior written approval of the Authority.
Code On Responsible Marketing Of Food And Beverages To Chi ldren In Brunei Darussalam20
(PTO)
B. Children and Young Persons Act (Chapter 129), revised 2012
Interpretation.
2. (1) In this Act, unless the context otherwise requires -“child” means a person who has not attained the age of 14 years.
C. Newspaper Act (Chapter 105), revised in 2013
Interpretation.
2. In this Act –“newspaper” means any publication containing news, intelligence, reports of occurrences, or any remarks, observations or comments, in relation to such news, intelligence or occurrences, or to any other matter of public interest, or any magazine, comic or other form of periodical, printed for sale or free distribution at regular or irregular intervals and includes a supplement thereto but does not include any publication issued by or under the authority of the Government or of any public body;
D. Public Entertainment Act (Chapter 181)
Interpretation.
2. In this Act, unless the context otherwise requires – “public entertainment” includes – …
(n) trade fairs consisting in the exhibition, advertisement or sale of the products of industries or of materials
E. Public Health (Food) Act (Chapter 182)
Interpretation.
2. In this Act, unless the context otherwise requires – “advertisement” means any representation by any means whatsoever for the purpose of directly or indirectly promoting the sale or other disposal of any food;
“food” includes any substance manufactured, processed, sold or represented for use for human consumption, chewing substances, and any ingredient there of;
Code On Responsible Marketing Of Food And Beverages To Chi ldren In Brunei Darussalam 21
F. Public Health (Food) Regulations (R1,Chapter 182)
Misleading statements.
14 (1). No written, pictorial or other descriptive matter appearing on or attached to, or supplied
or displayed with any food shall include any false or misleading statement, word, brand,
picture, or mark purporting to indicate the nature, stability, quantity, strength, purity,
composition, weight, origin, age, effects, or proportion of the food or any ingredients there
of.
(3). Unless specifically permitted by these Regulations, claims for therapeutic or prophylactic
action or words of similar meaning shall not be made on any food.
(5). There shall not appear on any label any word or words implying that a food will prevent,
alleviate or cure any disease or condition affecting the human body.
(6). There shall not appear on any label any words implying that health or an improved physical
condition may be achieved by consuming any food.
(PTO)
G. Second Schedule Code of Practice For Advertising (Broadcasting Act
(Chapter 180))
Introduction:
a) This Code of Practice (hereinafter refer to as “the Code”) is issued under section 9 of the Broadcasting Act and applies to all advertisements broadcast or intended for broadcast on television and radio.
b) The provisions in this Code should be observed in the spirit as well as the letter. Broadcasters including editors and producers of television and radio programmes should ensure that advertisements which fail to meet the provisions in this Code are not broadcast.
c) All advertisements should be legal, decent and truthful. Any advertisement which is against public interest, national harmony or is offensive or against public decency should not be broadcast.
f) Consumer interest should be safe-guarded. Any advertisement broadcast should be true and accurate in terms of the information conveyed.
The following guidelines should be compiled with in any advertisement
intended for broadcast:
5. Claims and Comparisons.
a) Advertisements should not contain claim or comparisons which are misleading directly
or otherwise, or highly exaggerated.
8. Endorsements by Professionals.
Where endorsements by professionals are used in advertisement, prior approval should be
obtained from related professional bodies.
Code On Responsible Marketing Of Food And Beverages To Chi ldren In Brunei Darussalam22
APPENDIX 6
APPENDIX 7
LIST OF AGENCIES INVOLVED IN CONSULTATIVE SESSIONS:
1. Prime Minister’s Office
2. Ministry of Energy
3. Ministry of Health
4. Ministry of Home Affairs
5. Ministry of Transport and Info-communications
6. Attorney General’s Chamber
7. Radio Television Brunei
8. Authority of Building Construction and Industry, Ministry of Development
9. Department of Schools, Ministry of Education
10. Private Education Section, Ministry of Education
11. Department of Religious Studies, Ministry of Religious Affairs
12. Sultan Haji Hassanal Bolkiah Tahfiz Institute, Ministry of Religious Affairs
13. Authority for Info-communication Technology Industry
14. DST Communication Sdn. Bhd.
15. Women’s Council
16. Mosque Affairs Community
17. Headmasters/principals/administrative personnels from selected schools under Ministry of Education
and Ministry of Religious Affairs
18. Members of Parent-Teachers Associations from selected schools (parents and teachers)
LIST OF FOOD & ADVERTISING AGENCIES INVOLVED DURING
FOCUS GROUP DISCUSSION:
1. Cityneon Display & Construction Sdn Bhd,
2. Hoco Agency
3. Jollibee Brunei
4. A Ayam Restaurant
5. Project Ice-Cream
6. Gong Cha
Code On Responsible Marketing Of Food And Beverages To Chi ldren In Brunei Darussalam 23
APPENDIX 8
APPENDIX 9
INTERNATIONAL CODE OF BREAST MILK SUBSTITUTE
The World Health Assembly adopted the International Code of Marketing of Breastmilk Substitutes in 1981
to protect and promote breastfeeding, through the provision of adequate information on appropriate infant
feeding and the regulation of the marketing of breastmilk substitute, bottles and teats. In subsequent
years additional resolution have further defined and strengthened the Code.
The Code stipulated that there should be absolutely no promotion of breastmilk substitutes, bottles and
teats to the general public; that neither health facilities nor health professionals should have a role in
promoting breastmilk substitute; and that free samples should not be provided to pregnant women, new
mothers or families. All governments should adopt the Code into national legislation.
Source: International Code of Marketing of Breastmilk Substitutes
NATIONAL DIETARY GUIDELINES FOR HEALTHY EATING
BRUNEI DARUSSALAM
Key Messages:
1. Enjoy a wide variety of nutritious foods daily within the recommended amount.
2. Maintain calorie intake balanced with regular physical activity to keep body weight in healthy range.
3. Base meal on rice, bread, potatoes, pasta, noodles or other carbohydrates with at least half from
wholegrain.
4. Eat at least two servings of fruit and three servings of vegetables every day.
5. Eat fish, poultry, lean meat, legumes, nuts and other proteins in moderation.
6. Limit intake of fatty foods and use the recommended cooking oil sparingly.
7. Reduce intake of sugary foods and beverages.
8. Reduce salt and sauces in cooking and food preparations, and choose foods with less salt.
9. Practice exclusive breastfeeding for the first six months and continue breastfeeding until two years
while give nutritious, complementary foods from six months of age.
10. Ensure food and beverages are prepared hygienically, as well as clean and safe to consume.
11. Read and understand food labels to make healthier choices.
Source: National Dietary Guidelines For Healthy Eating Brunei Darussalam
Code On Responsible Marketing Of Food And Beverages To Chi ldren In Brunei Darussalam24
APPENDIX 10GUIDELINE ON MARKETING OF FOOD
AND BEVERAGES TO CHILDREN IN BRUNEI DARUSSALAM
A tool to protect children from irresponsible food marketing
Guidel ine On Food And Beverages Advertised To Chi ldren In Brunei Darussalam26
Guideline On Marketing Of Food And Beverages To Children In Brunei Darussalam is adapted from the
W.H.O (World Health Organisation) Nutrient Profile Model for the Western Pacific Region to be used
as a reference to the Policy on Responsible Marketing Of Food and Beverages To Children in Brunei
Darussalam.
Nutrient profiling has been recognized by W.H.O as critical tools for the implementation of restrictions on
the marketing of food and beverages to children in order to prevent disease and promote health. They
provide a way to differentiate between food and non-alcoholic beverages that are more likely to be part
of a healthy diet, and food that may contribute to excess consumption of energy, saturated fats, trans-
fats, sugar and salt.
This Guideline is designed for use by:
• business owners,
• media and advertising agencies,
• advertisers, advertisement regulators and practitioners,
• sale promoters and distributors,
• media influencers (for example bloggers),
• operators within school community and;
• Public Health Policy makers, practitioners and
• researchers
This Guideline aims to restrict marketing of food and non-alcoholic beverages by assisting users in
choosing the permitted type of food and beverages they want to advertise to children with respect to
sugar, fat and salt content in each category.
This Guideline consists of a total of 8 food categories, which are ranked by their nutritional composition.
In addition, nutrient thresholds are set for saturated fats, trans-fatty acids, added sugar and sodium
across the food categories.
INTRODUCTION1
Guidel ine On Food And Beverages Advertised To Chi ldren In Brunei Darussalam 27
DEFINITIONS OF TERMS USED IN THIS GUIDELINE2
Healthy diet: Healthy diet comprise of combination of right amount of essential nutrients such as
carbohydrates, protein, fat, vitamins, minerals and water. Eating a healthy, balanced diet is especially
important for young children’s development. It protects against malnutrition in all forms, as well as non-
communicable diseases.
Total fat: Total fat refers to the total fat content of the food product, which may be composed of
different levels of fatty acids from the three broad groupings: saturated fatty acids, monounsaturated
fatty acids and polyunsaturated fatty acids.
Total sugar: Total sugar content of the food product, which may be composed of intrinsic sugar
incorporated within the structure of intact fruit and vegetables; sugar from milk (lactose and galactose);
and all additional monosaccharides and disaccharides added to foods by the manufacturer, cook or
consumer, plus sugar naturally present in honey, syrups and fruit juices.
Added sugar: Added sugar is defined here as all monosaccharides and disaccharides added to food and
beverages by the manufacturer, cook or consumer during processing or preparation.
Artificial sweetener: Artificial sweetener is a type of food additives (other than a mono- or disaccharide
sugar) which impart a sweet taste to a food. The technological purposes for this functional class include
sweetener, intense sweetener and bulk sweetener. It should be noted that products such as sugar, honey
and other food ingredients that can be used to sweeten are not associated with the term “sweetener”.
Energy: Energy refers to the total chemical energy available in food and its macronutrient constituents
(carbohydrates, fats, proteins).
Salt: 1 g of sodium is equivalent to about 2.5 g of salt.
Guidel ine On Food And Beverages Advertised To Chi ldren In Brunei Darussalam28
Identify which food category the product falls under.
Once the appropriate food category has been identified, the nutritional content of the food product must
be cross-checked against the thresholds (depends on which coloured zone does the food belongs to).
Coloured zone:
= Advertisement of the food product in question is permitted.
= Advertisement of the food product in question is permitted ONLY if it complies
to the condition stated.
= Advertisement of the food product in question is not permitted.
For example, potatoes:
1. Potatoes are in fruits, vegetables, legumes and soya categories.
2. When cross-checking against the 3 coloured zones, potatoes are in the green zone, therefore,
advertisement of potatoes is permitted to children.
NOTE:
1. The food products should, where possible, be assessed as sold or as reconstituted, if necessary,
according to the manufacturer’s instructions.
2. If the marketing is for a restaurant meal, including a quick-service or takeaway meal of two or more
menu items, all items must individually meet the relevant nutrient criteria.
3 HOW TO USE THIS GUIDELINE?
Guidel ine On Food And Beverages Advertised To Chi ldren In Brunei Darussalam 29
BEVERAGES4Beverages that are permitted to be advertised:
• Mineral water
Beverages that are not permitted to be advertised:
• All energy drinks, tea and coffee including instants and premixed products
• Sugar-sweetened beverages
• Reconstituted chocolate or malted powdered drinks
• Syrups/cordials
• Any products in the above list that do not fulfill the conditions
Beverages that are permitted to be advertised with certain condition(s):
Condition I: If beverages do not contain any added sugar and/or artificial sweeteners:
• Flavoured mineral waters (including aerated)
• Unsweetened fresh coconut juice
• Powdered juices (e.g. Tang)
Condition II: If beverages contains 4 grams/100 grams or less of total fat and do not containany
added sugar and artificial sweeteners:
• Milks and sweetened milks
• Reconstituted powdered milk
• Almond, soya, rice and oat milks
• Goat milk
• Milk shakes
• Sweetened creamer
• Evaporated milk
• Condensed milk
Condition III: If beverages contain 5 grams/100 grams or less of total sugar and do not contain
any added sugar:
• 100% fruit and vegetable juice, including:
• Sugar cane juices
• Juices reconstituted from concentrate
• Smoothies
Guidel ine On Food And Beverages Advertised To Chi ldren In Brunei Darussalam30
DAIRY PRODUCTS5Dairy products that are permitted to be advertised:
• Nil
Dairy products that are not permitted to be advertised:
• Any products in the above list that do not fulfill the conditions
Dairy products that are permitted to be advertised with certain condition(s):
Condition I: If cheese products listed below contain 20 grams/100 grams or less of total fat and
0.52 gram/100 grams or less of salt (1 gram salt = 0.4 gram sodium):
• Medium-hard and hard cheeses (i.e. cheddar)
• Soft cheese (e.g. ricotta, mozzarella)
• Sliced cheese
• Cream cheese
• Spreadable cheese
• Grated or powdered cheese
• Cottage cheese
• Processed cheese
Condition II: If yoghurt, sour milk, cream listed below or other similar foods contain 4 grams/100
grams or less of total fat, 10 grams/100 grams or less of total sugar, no added artificial sweetener
at all and 0.08 gram/100 grams or less of salt (1 gram salt = 0.4 gram sodium) such as:
• Yoghurt including drinking yoghurt
• Sour milk including flavoured sour milk
• Cream
• Cheese-based and other yoghurt substitutes
• Fermented milk
• Curds
Guidel ine On Food And Beverages Advertised To Chi ldren In Brunei Darussalam 31
DESSERTS6Desserts that are permitted to be advertised:
• Nil
Desserts that are not permitted to be advertised:
• All type of cakes, sweet biscuits, pastries, other sweet bakery products and dry mixes for
making such including:
o Buns with sweet fillings
o Cookies
o Doughnuts
o Breakfast biscuits
• All type of chocolates, sugar confectionaries, energy bars, sweet toppings and desserts
including:
o Milk, dark and white chocolates
o Chocolate spreads
o Cereals, granolas and muesli bars
o Hard/chewy candies
o Soft-jellied candies
o Table sugar
o Flour-based confectionaries
o Spreads including peanut butter
o Chewing gums
o Caramels
o Marshmallows
o Puddings
o Cream desserts
• Any products in the above list that do not fulfill the conditions
Desserts that are permitted to be advertised with certain condition(s):
Condition: If edible ices listed below contain 4 grams/100 grams or less of total fat, 10 grams/100
grams or less of total sugar, no added artificial sweetener at all and 0.08 gram/100 grams or less
of salt (1 gram salt = 0.4 gram sodium) such as:
• Ice cream
• Iced lollies and sorbets
• Frozen yoghurt
Guidel ine On Food And Beverages Advertised To Chi ldren In Brunei Darussalam32
FATS AND OILS7Fats and oils that are permitted to be advertised:
• Nil
Fats and oils that are not permitted to be advertised:
• Any products in the above list that do not fulfill the conditions
Fats and oils that are permitted to be advertised with certain condition(s):
Condition: If butter and other fats and oils listed below contain 20 grams/100 grams or less of
saturated fats, no added sugar or artificial sweetener at all and 0.56 gram/100 grams or less of
salt (1 gram salt = 0.4 gram sodium):
• Butter
• Vegetable oils
• Margarine and spreads
• Dripping
• Ghee
Guidel ine On Food And Beverages Advertised To Chi ldren In Brunei Darussalam 33
FRUITS, VEGETABLES, LEGUMES AND SOYA8
Fresh and frozen fruit, vegetables, legumes and soya that are permitted to be advertised
including:
• Potatoes
• Roots crops
• Fresh coconut
Fruits, vegetables, legmes and soya that are not permitted to be advertised:
• Any products in the above list that do not fulfill the conditions
Fruits, vegetables, legumes and soya that are permitted to be advertised with certain condition(s):
Condition I: If processed fruit, vegetables and legumes listed below contain 5 grams/100 grams
or less of total fat, 10 grams/100 grams or less of total sugar, no added sugar at all and 0.4
gram/100 grams or less of salt (1 gram salt = 0.4 gram sodium):
• Dried fruit
• Dried coconut
• Coconut cream
• Canned fruits
• Vegetables and legumes
• Dried mushrooms
• Jams and marmalade
• Preserved or pickled fruits and vegetables
• Fermented vegetables
• Mango chutney
• Meat substitute made from fungus
• Seaweed
Condition II: If products made from soya listed below contain 12 grams/100 grams or less of
total fat, 10 grams/100 grams or less of total sugar, no added sugar at all and 0.4 gram/100
grams or less of salt (1 gram salt = 0.4 gram sodium):
• Tofu products
• Natto
• Tempeh
Guidel ine On Food And Beverages Advertised To Chi ldren In Brunei Darussalam34
GRAINS9Grains that are permitted to be advertised:
• Nil
Grains that are not permitted to be advertised:
• Any products in the above list that do not fulfill the conditions
Grains that are permitted to be advertised with certain condition(s):
Condition I: If bread, bread products and crisp breads listed below contain 10 grams/100 grams
or less of total fat, 10 grams/100 grams or less of total sugar and 0.48 gram/100 grams or less
of salt (1 gram salt = 0.4 gram sodium):
• Bread (i.e. white, yellow, whole wheat)
• Roti
• Wraps/tortillas
• Bread with raisins
• Buns
• Toast
• Cheese bread
• Roti canai/prata
Condition II: If fresh or dried noodles, pasta, rice and grains listed below contain 10 grams/100
grams or less of total fat, 10 grams/100 grams or less of total sugar and 0.48 gram/100 grams
or less of salt (1 gram salt = 0.4 gram sodium):
• Dried and fresh noodles
• Sago
• Quinoa
Guidel ine On Food And Beverages Advertised To Chi ldren In Brunei Darussalam 35
MEAT, POULTRY AND SEAFOOD10
Meat, poultry and seafood that are permitted to be advertised:
• Nil
Meat, poultry and seafood that are not permitted to be advertised:
• Any products in the above list that do not fulfill the conditions
Meat, poultry and seafood that are permitted to be advertised with certain condition(s):
Condition I: If fresh and frozen meat, poultry, fish and similar listed below contain 20 grams/100
grams or less of total fat:
• Turkey/chicken tails
• Lamb neck
• Mutton flap
• Eggs
• Oily fish (e.g. sardine)
Condition II: If processed meat, poultry, fish and similar as listed below contain 20 grams/100
grams or less of total fat, and 0.68 gram/100 grams or less of salt (1 gram salt = 0.4 gram
sodium):
• Sausage
• Canned meat (e.g. corned beef) and fish
• Chicken nuggets
• Fish fingers
• Fish balls
• Beef or chicken patty
• Liver paste
Guidel ine On Food And Beverages Advertised To Chi ldren In Brunei Darussalam36
MISCELLANEOUS11Miscellaneous that are permitted to be advertised:
• Nil
Miscellaneous that are permitted to be advertised with certain condition(s):
Condition I: If ready-made and convenience foods and composite dishes listed below contain 10
grams/100 grams or less of total fat, 4 grams/100 grams or less of saturated fats, 10 grams/100
grams or less of total sugar, 0.4 gram/100 grams or less of salt (1 gram salt = 0.4 gram sodium)
and 225 kcal/100 grams or less of energy:
• Pizzas
• Lasagne
• Ready-made sandwiches
• Tinned spaghetti
• Instant noodles
• Instant porridge
• Baked beans
• Cream corn
• Dumplings
• Burgers in buns
• Ready meals
• Filled pastas
• Soups
• French fries
• Buttered toasted bread
Condition II: If savory snacks listed below contain no added sugar at all and 0.04 gram/100
grams or less of salt (1 gram salt = 0.4 gram sodium) (0.1 gram of salt: to take into consideration
of naturally occurring salt):
• Popcorn and maize corn
• Nuts and mixed nuts (including with fruit content)
• Savory biscuits (PTO)
Guidel ine On Food And Beverages Advertised To Chi ldren In Brunei Darussalam 37
• Crackers
• Pretzels
• Other snacks made from rice, maize, wheat, dough or potato (i.e. chips, crisp)
• Chicken rind
Condition III: If sauces, dips and dressings listed below contain 10 grams/100 grams or less of
total fat, no added sugar at all and 0.4 gram/100 grams or less of salt (1 gram salt = 0.4 gram
sodium):
• Tomato ketchup
• Coloured ketchup
• Mayonnaise
• Salad dressing
• Soy sauce
• Fish sauce
• Sweet chili sauce
• Gravies
• Spaghetti sauce
• BBQ sauces
• Seasonings
• Reconstituted stocks
Miscellaneous that are not permitted to be advertised:
• Any products in the above list that do not fulfill the conditions
Guidel ine On Food And Beverages Advertised To Chi ldren In Brunei Darussalam38
AP
PEN
DIX
11
FLO
WC
HA
RT
FOR
AP
PLI
CA
TIO
N P
RO
CES
S O
F M
AR
KET
ING
OF
FOO
D A
ND
BEV
ERA
GES
TO
CH
ILD
REN
TO
DIF
FER
ENT
REL
EVA
NT
REG
ULA
TOR
Y P
LATF
OR
MS
Appl
icat
ion
for
appr
oval
on
cont
ent
of m
arke
ting
of fo
od &
bev
erag
es
from
*re
gula
tory
age
ncie
s/ c
lient
*Sub
- com
mitt
ee f
rom
Min
istr
y
of H
ealth
che
ck c
onte
nt o
f
mar
ketin
g ag
ains
t th
e Co
de
Appr
ove
cont
ent
of
mar
ketin
g
Cont
ents
doe
s
not
com
ply
with
the
Code
Cont
ent
com
plie
s
with
the
Cod
e
Clie
nt fo
llow
reco
mm
enda
tions
Clie
nt d
o no
t fo
llow
reco
mm
enda
tions
Dis
appr
ove
cont
ent
of m
arke
ting
Not
ify r
egul
ator
y ag
enci
es/
clie
nt
* Su
b- co
mm
ittee
mem
bers
of
Mar
ketin
g Co
ntro
l
unde
r M
inis
try
of H
ealth
:
• D
epar
tmen
t of
Pol
icy
and
Plan
ning
• Co
rpor
ate
Com
mun
icat
ion
Div
isio
n
• H
ealth
Pro
mot
ion
Cent
re
• Co
mm
unity
Nut
ritio
n D
ivis
ion
• D
epar
tmen
t of
Pha
rmac
eutic
al S
ervi
ces
# L
ist
of r
egul
ator
y ag
enci
es:
• Pr
ime
Min
iste
r O
ffice
• M
inis
try
of R
elig
ious
Affa
irs
• M
inis
try
of F
inan
ce a
nd E
cono
my
• M
inis
try
of H
ealth
• M
inis
try
of H
ome
Affa
irs
• M
inis
try
of T
rans
port
and
Inf
o-co
mm
unic
atio
n
• A
utho
rity
of B
uild
ing
Cons
truc
tion
and
Indu
stry
, Min
istr
y of
Dev
elop
men
t
• Au
thor
ity fo
r In
fo-c
omm
unic
atio
n Te
chno
logy
Ind
ustr
y
• Br
unei
Dar
ussa
lam
Foo
d Au
thor
ityDis
appr
ove
cont
ent
& p
rovi
de
reco
mm
enda
tions
to
clie
nts
to
abid
e th
e Co
de
Guidel ine On Food And Beverages Advertised To Chi ldren In Brunei Darussalam 39
* Su
b- co
mm
ittee
mem
bers
of
Mar
ketin
g Co
ntro
l
Syst
em u
nder
Min
istr
y of
Hea
lth:
• D
epar
tmen
t of
Pol
icy
and
Plan
ning
• Co
rpor
ate
Com
mun
icat
ion
Div
isio
n
• H
ealth
Pro
mot
ion
Cent
re
• Co
mm
unity
Nut
ritio
n D
ivis
ion
• D
epar
tmen
t of
Pha
rmac
eutic
al S
ervi
ces
Com
plai
nt fr
om p
ublic
on
cont
ent
of m
arke
ting
rela
ted
to
Code
123
rece
ive
com
plai
nt
123
push
em
ail
notifi
catio
n to
Min
istr
y
of H
ealth
com
mitt
ee
Com
plai
nt c
onve
yed
to
*sub
-com
mitt
ee
Sub-
com
mitt
ee m
eetin
g &
inve
stig
ate
stat
us o
f ap
plic
atio
n
of t
he m
arke
ting
Repo
rt t
o re
spec
tive
*reg
ulat
ory
agen
cies
Actio
n as
per
SO
P fr
om
resp
ectiv
e re
gula
tory
age
ncy
acco
rdin
gly
AP
PEN
DIX
12
FLO
WC
HA
RT
FOR
AC
TIO
NS
ON
CO
MP
LAIN
TS O
N T
HE
MA
RK
ETIN
G R
ELA
TED
TO
TH
E C
OD
E O
F R
ESP
ON
SIB
LE
MA
RK
ETIN
G O
F FO
OD
AN
D B
EVER
AG
ES T
O C
HIL
DR
EN I
N B
RU
NEI
DA
RU
SSA
LAM
# L
ist
of r
egul
ator
y ag
enci
es:
• Pr
ime
Min
iste
r O
ffice
• M
inis
try
of R
elig
ious
Affa
irs
• M
inis
try
of F
inan
ce a
nd E
cono
my
• M
inis
try
of H
ealth
• M
inis
try
of H
ome
Affa
irs
• M
inis
try
of T
rans
port
and
Inf
o-co
mm
unic
atio
n
• A
utho
rity
of B
uild
ing
Cons
truc
tion
and
Indu
stry
, Min
istr
y of
Dev
elop
men
t
• Au
thor
ity fo
r In
fo-c
omm
unic
atio
n Te
chno
logy
Ind
ustr
y
• Br
unei
Dar
ussa
lam
Foo
d Au
thor
ity
Guidel ine On Food And Beverages Advertised To Chi ldren In Brunei Darussalam40
AP
PEN
DIX
13
FREQ
UEN
TLY
ASK
ED Q
UES
TIO
NS
NO
QU
ESTI
ON
S
AN
SWER
S
1W
hat
is C
ode
on R
espo
nsib
le M
arke
ting
of F
ood
and
Beve
rage
s To
Chi
ldre
n?
Code
on
Resp
onsi
ble
Mar
ketin
g of
Foo
d an
d Be
vera
ges
To C
hild
ren
outli
ne d
os a
nd d
on’ts
to
guid
e us
ers
with
reg
ards
to m
arke
ting
of fo
od a
nd b
ever
ages
to c
hild
ren.
Thi
s se
ts o
ut a
s on
e
of th
e in
itiat
ives
to c
ontr
ol c
hild
hood
obe
sity
in B
rune
i Dar
ussa
lam
tow
ard
its v
isio
n “T
oget
her
Tow
ards
Hea
lthy
Nat
ion”
by
redu
cing
exp
osur
e am
ong
our c
hild
ren
to a
ny m
arke
ting
mes
sage
s
that
pro
mot
e un
heal
thy
food
s an
d be
vera
ges
to t
hem
.
2W
ho s
houl
d re
ad t
his
Code
?Ap
art
from
the
reg
ulat
ory
auth
oriti
es f
or a
dver
tisem
ent/
mar
ketin
g in
Bru
nei D
arus
sala
m a
nd
educ
atio
n se
ctor
s, a
ny fo
od in
dust
ries/
ente
rpris
es w
ho w
ants
to c
omm
erci
alis
e th
eir
food
and
beve
rage
s se
ctor
s to
chi
ldre
n.
3D
oes
this
Cod
e ap
ply
to m
arke
ting
of
food
and
bev
erag
es t
o ad
ults
too
?
No,
it d
oes
not.
How
ever
, it
is a
dvis
able
for
the
mar
ketin
g of
foo
d to
be
desi
gned
in s
uch
a
way
so
as n
ot t
o at
trac
t ch
ildre
n.
4W
here
doe
s th
is C
ode
appl
y to
? Th
is C
ode
appl
ies
to a
ll m
arke
ting
med
ium
use
d in
any
ven
ues
in B
rune
i Dar
ussa
lam
.
5Re
ferr
ing
to t
he w
ord
‘chi
ldre
n’,
to w
hat
exte
nd d
oes
the
Code
app
ly t
o?
Apar
t fr
om a
ge r
ange
, th
is C
ode
shal
l app
ly t
o m
arke
ting
on f
ood
and
beve
rage
s du
ring
any
even
t/se
ttin
gs w
here
at
leas
t 50
% o
f ch
ildre
n ga
ther
. Th
is i
nclu
de,
but
are
not
limite
d to
,
nurs
erie
s/ch
ild c
are
cent
res,
pre
-sch
ool,
scho
ols,
sch
ool g
roun
ds a
nd p
layg
roun
ds,
mat
erna
l
and
child
hea
lth c
linic
s an
d pa
edia
tric
ser
vice
s, a
nd d
urin
g an
y sp
ortin
g an
d cu
ltura
l act
iviti
es
that
are
hel
d on
the
se p
rem
ises
.
6W
e w
ant
to m
arke
t ou
r pr
oduc
t (f
ood
and
beve
rage
s) to
the
publ
ic, h
ow d
o w
e
appl
y fo
r ap
prov
al?
Appl
icat
ion
can
be m
ade
eith
er th
roug
h th
e re
spec
tive
regu
lato
ry b
odie
s co
rres
pond
ing
to th
e
prop
osed
adv
ertis
emen
t m
ediu
m o
r di
rect
ly t
hrou
gh M
inis
try
of H
ealth
.
(PTO
)
Guidel ine On Food And Beverages Advertised To Chi ldren In Brunei Darussalam 41
7W
e w
ant t
o m
arke
t our
pro
duct
(fo
od a
nd b
ever
ages
) to
the
publ
ic, d
o
we
still
nee
d to
com
ply
to th
e ru
les/
regu
latio
ns a
nd c
laus
es in
the
Acts
on a
dver
tisem
ents
pro
duce
d by
the
oth
er r
egul
ator
y bo
dies
?
Yes.
8W
e w
ant
to m
arke
t ou
r pr
oduc
t (f
ood
and
beve
rage
s) t
o th
e pu
blic
,
whi
ch fo
od a
nd b
ever
ages
are
allo
wed
to
be m
arke
ted?
Plea
se r
efer
to
the
atta
ched
Gui
delin
e O
n M
arke
ting
Of
Food
And
Beve
rage
s To
Chi
ldre
n (A
ppen
dix
10)
in t
he C
ode.
9W
hat
can
food
and
bev
erag
es b
usin
ess
owne
rs i
nclu
ding
MSM
Es
(Mic
ro,
Smal
l M
ediu
m E
nter
pris
es)
do i
n or
der
to c
ompl
y w
ith t
he
Code
?
They
are
adv
isab
le t
o re
form
ulat
e th
eir
food
pro
duct
s to
a
heal
thie
r ve
rsio
n.
10Ca
n w
e m
arke
t an
othe
r (d
iffer
ent)
pro
duct
(fo
od a
nd b
ever
ages
) th
at
is h
ealth
y in
our
adv
ertis
emen
t on
a fo
od a
nd b
ever
age
to c
hild
ren?
Yes,
you
can
, w
ith c
ondi
tion
the
adve
rtis
emen
t co
mpl
y w
ith
the
Code
.
11Ca
n w
e pr
omot
e/gi
ve a
way
gift
s or
toys
in th
e fo
rm o
f sta
tione
ry it
ems
in o
ur a
dver
tisem
ent
on fo
od a
nd b
ever
age
to c
hild
ren?
Yes,
as
long
as
the
adve
rtis
emen
t co
mpl
y w
ith t
he c
ondi
tion
and
the
item
is w
ithin
the
pre
mis
e.
12Ca
n sp
onso
rshi
p be
in
clud
ed
in
the
adve
rtis
emen
t of
fo
od
and
beve
rage
s?
This
Co
de
only
re
gula
tes
adve
rtis
emen
t an
d pr
omot
ion
of f
ood
and
beve
rage
s to
chi
ldre
n. H
owev
er,
adve
rtis
ing
spon
sors
hips
is o
nly
allo
wed
if th
e fo
od it
em b
eing
spo
nsor
ed
com
ply
with
the
Cod
e.
13Is
mas
cot
from
any
foo
d in
dust
ries/
ente
rpris
es a
llow
ed in
any
eve
nts
with
chi
ldre
n in
any
ven
ues
incl
udin
g sc
hool
s?
No.
14W
here
sho
uld
we
refe
r to
if
we
have
any
fur
ther
que
ries
rela
ted
to
mar
ketin
g of
food
and
bev
erag
es t
o ch
ildre
n?
For
furt
her
quer
ies,
ple
ase
cont
act 2
3858
00 a
nd y
our
quer
ies
will
be
addr
esse
s as
soo
n as
we
can.
Guidel ine On Food And Beverages Advertised To Chi ldren In Brunei Darussalam42
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For more information:
Health Promotion CentreMinistry of Health
Commonwealth DriveBandar Seri Begawan
Negara Brunei Darussalam BB3910Tel: +673 2385800
Email: [email protected]