Clare Whitton, Frith Klug, Alexia Bivoltsis, Catrina McStay, Georgina S.A. Trapp, and Claire E. Pulker
State, territory and local governments in Australia are taking steps to reduce exposure to unhealthy food advertising. This was seen through South Australia’s recent forward-thinking restrictions across state-owned buses, trains, and trams. The restrictions are based on the former Council of Australian Governments (COAG) Health Council Interim guide, a food category-based system from 2018.
However, it has become evident that the 2018 food category model users often reach different conclusions on the same ads. New research by Edith Cowan University (ECU) shows that even highly skilled researchers classifying foods using the 2018 interim guide food category-based model make different decisions on the same ads. This inconsistency risks undermining policy credibility, enforcement, and impact across local government authorities. As more local governments take action, it’s evident that the interim guide is more suited to single users such as state/territory governments, rather than multiple users.
The good news? A better model is possible. Researchers from ECU are now developing a refined version of the food category-based approach, which is clearer, more detailed, and better suited to multi-user application.
The challenge: same ad, different answers
Food advertising policies rely on food classification systems to decide which adverts are restricted. In Australia, the interim guide lists seven food categories not recommended for marketing to children. They include confectionery, sugar-sweetened drinks, and unhealthy meals. However, it doesn’t include detailed criteria or examples, leaving some grey areas.
In our study, three nutrition-trained researchers independently assessed 550 real-world outdoor food adverts using the interim guide. Each faced a straightforward choice for each advert: permit or restrict?
The result? Nearly 80% of advertisements were restricted by at least one researcher, but only 25% were restricted by all three. Strong agreement occurred only when the guide was specific, such as for confectionery and ice cream. Regarding more ambiguous categories including brand advertising, mixed meals, or sugar-sweetened drinks, decisions diverged sharply.
This matters. If trained researchers interpret the interim guide differently in key categories, how can local governments, street furniture companies, and advertisers be expected to apply it reliably? Inconsistency between users not only complicates enforcement, but also risks confusion among advertisers and the public and weakens the impact of the policy.
Why local governments need more clarity
South Australia is in a strong position to implement the policy restricting unhealthy food and drink advertising on state government transit. However, it is a different picture for local governments.
In South Australia, there is clear political willingness to act, a dedicated preventive health agency leading the technical work, and one government department processing decision making. In contrast, there are potentially hundreds of decision makers across the local government sector, each with multiple contractors to oversee.
Without additional guidance, two neighbouring councils could interpret the same ad differently. That variation doesn’t just undermine trust, it creates compliance headaches and opens the door to legal or political pushback.
Local governments need a tool that can work without the same level of technical support from a department of experts.
The issue isn’t the approach but the execution
It could be argued that the interim guide is “good enough” for local governments and can be improved later. However, not all policies can be tightened over time. Good policy design requires the local government policy to be fit for purpose in their setting where the mechanism of enforcement is decentralised.
With outdoor advertising, implementation is diffuse and the classification tool is ambiguous. The risk is not that the policy is too lenient but it can’t be applied at all. Without clear definitions and examples, the foundation for consistent application simply doesn’t exist.
A practical, improved model for local governments is underway
The ECU study suggests that for local governments, the solution lies not in abandoning the food category approach altogether. Nor is it in moving to complex nutrient profiling systems that require detailed food composition data.
Instead, the study proposes a refined food category-based model that:
- Maintains the simplicity and accessibility of the interim guide,
- Expands the number of food categories to better reflect outdoor advertising content,
- Provides detailed examples to guide classification decisions, and
- Clarifies grey areas, especially brand advertising, alcohol, and mixed meals.
This isn’t about reinventing the wheel. It’s about improving what already works in principle, so that it works better in practice.
Looking ahead: making local government policy that works
There’s no doubt that the interim guide was a step in the right direction. But as policies move from high-level endorsement to day-to-day implementation, they must be built for the real world. That means recognising when a model is being stretched beyond its original design and offering a better alternative.
Researchers from ECU are developing an updated classification model designed specifically to support consistent, scalable application by local governments, and their contractors. With clear examples, expanded categories, and practical usability in mind, it aims to strengthen, not sideline, the food category-based approach.
Getting a policy over the line is essential. But ensuring it works on the ground is what delivers real public health gains. Let’s make sure local governments are equipped not just to act but to succeed.
Photo courtesy: Cancer Council Western Australia.
All authors are from the Nutrition and Health Innovation Research Institute, School of Medical and Health Sciences of Edith Cowan University.
Clare Whitton and Claire E. Pulker are also affiliated with the School of Population Health at Curtin University.
Georgina S.A. Trapp is also affiliated with the Kids Research Institute Australia, and The University of Western Australia.
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