Our Ref:          FOI-2990-1819

Thank you for your request received on 7 February 2019 asking for information about junk food advertisements.
 
Your request has been considered in accordance with the requirements of the Freedom of Information Act and our information access policy. I can confirm we hold some of the information you require. You asked for:
 
1. The total amount of advertising income generated by “junk food” advertisements (set to be banned on Feb 25) on the TfL network in the last three years. Please include total income then a breakdown by tube, buses, overground, bus shelters and any other means of advertising on the network.
2. The total amount of advertising income on the TfL network in the last three years generated from advertisements that don’t concern junk food i.e. different from that mentioned in (1) and the amount of this total that was generated from those considered to be healthy food brands/companies which would still be okay to advertise come February 25.
 
Unfortunately, to provide the information you have requested would exceed the ‘appropriate limit’ of £450 set by the Freedom of Information (Appropriate Limit and Fees) Regulations 2004.
 
Under section 12 of the FOI Act, we are not obliged to comply with a request if we estimate that the cost of determining whether we hold the information, locating and retrieving it and extracting it from other information would exceed the appropriate limit. This is calculated at £25 per hour for every hour spent on the activities described.
 
We have estimated that it would cost over £450 to provide a response to your current request. This is because it is estimated that it would take over 18 working hours to retrieve and compile the information you have requested.
 
We do not centrally record whether an advert is for “junk food”’. We would require our advertising partners (of which there are over 20), to review three years worth of food and drink campaigns and apply the Nutrient Profiling Model, to them to judge whether these campaigns would have been allowed to run on our network. Any such analysis is likely to be inaccurate as it would be difficult for our partners to find out the nutritional profile of these historic campaigns and products. Additionally, we do not know if the brands would have amended their campaigns to feature a healthier product.
 
To help bring the cost of responding to your request within the £450 limit, you may wish to consider narrowing its scope so that we can more easily locate, retrieve and extract the information you are seeking. If you want to refine your request or make a Freedom of Information Act request in future, please bear in mind that the Freedom of Information Act allows you to request recorded information held by Transport for London. You should identify the information that you want as clearly and concisely as you can, specifying the types of document that you are looking for. You might also consider limiting your request to a particular period of time, geographical area or specific departments of TfL.
 
Although your request can take the form of a question, rather than a request for specific documents, TfL does not have to answer your question if it would require the creation of new information or the provision of a judgement, explanation, advice or opinion that was not already recorded at the time of your request.
 
Please note that we will not be taking further action until we receive your revised request.
 
3. Projections in TfL advertising income once the ban comes into place for the first two years
 
We do not hold this information. It is too early to anticipate how much, if any, impact there will be on our revenue, especially as spend fluctuates between advertisers for a range of reasons. We are continuing to work with the advertising industry and brands to encourage them to choose healthy alternatives and to ensure that any revenue loss will be minimised. We know that a number of brands have a range of compliant products, which they plan to continue advertising across the TfL estate.
 
4. Number of adverts and separately brands that will have to dropped from the TfL network come February 25 due to the new rules on junk food
 
We will not be ‘dropping’ advertisements or brands from our network. We are only taking bookings past 25 February for campaigns that are compliant with our advertising policy. These changes do not preclude brands from advertising with us, as long as they provide campaigns that comply with our advertising policy.
 
5. Number of companies signed up to advertising for the first time on the TfL network from Feb 25 onwards which may help fill the void left by junk food advertising (healthy food and other brands) - since the ban was announced by the mayor of London
 
We do not hold this information, and as noted in the answer to question 3, types of adverts and brands fluctuate throughout the year. We know that a number of brands have a range of compliant products which they plan to continue advertising on the TfL estate.
 
If this is not the information you are looking for please feel free to contact me.
 
Please see the attached information sheet for details of your right to appeal.

Yours sincerely

Gemma Jacob
Senior FOI Case Officer
FOI Case Management Team
General Counsel
Transport for London

[email protected]