1

 The copy test was conducted jointly by the Bureaus of Consumer Protection and

Economics. Principal participants from the Division of Advertising Practices of the Bureau of

Consumer Protection were Theodore Hoppock, Michelle Rusk, and Marianne Watts. 

Representing the Bureau of Economics were Dennis Murphy of the Division of Consumer

Protection and Pauline Ippolito of the Division of Economic Policy Analysis. Two outside

consultants participated in the project. These were David W. Stewart, Professor of Marketing at

the University of Southern California, and Kenneth L. Bernhardt, Professor of Marketing at

Georgia State University. 

 

2

 For example, a label cannot link a food's sodium level to a reduced risk of hypertension

unless that food is low in sodium (140mg per serving or less). Labels cannot relate fat content to

a heart disease benefit unless the food is low in fat (3g or less), saturated fat (1g or less), and

cholesterol (20mg or less). 

EXPLANATORY NOTE FOR ELECTRONIC VERSION OF THIS REPORT:

 All reproductions of the test advertisements are presented in Appendix A.

I. Introduction

This report presents the primary findings of a large scale copy test project that was

initiated to examine several issues relevant to the Commission's 1994 Enforcement Policy

Statement on Food Advertising ("Statement").1 That document provides guidance concerning the

manner in which the Commission’s approach to advertising relates to FDA's food labeling

regulations that implemented the Nutrition Labeling and Education Act of 1990. These

regulations define a series of standardized "nutrient content descriptors" that may be used in

labeling to characterize the absolute and relative level of common nutrients in foods. The FDA

rules also prescribe standards governing the use of health claims on labels. 

The FTC Statement generally comports with the FDA standards, but provides for certain

disclosures and qualifications that would allow advertisers to make health claims about products

and diet-health relationships that could not appear in labeling. The copy test that is the subject of

this memo was undertaken to help determine which types of disclosures and qualifications

communicate most effectively truthful and nonmisleading information concerning the nutrient

content and health attributes of food products and dietary supplements. 

A. The FDA Regulations 

As indicated, the FDA regulations define several nutrient content descriptors, such as

"high" fiber, "low" fat, or "reduced" sodium. The regulations also specify a series of requirements

that determine whether a food label may carry a health claim that links the nutrient profile of the

food to a specific health benefit, such as a reduced risk of heart disease or cancer. 

Specifically, the FDA regulations allow health claims only when (1) the labeled food does

not contain more than 20 percent of the recommended daily value for total fat, saturated fat,

sodium, or cholesterol, (2) the labeled food meets certain minimum or maximum nutrient level

requirements specific to the health claim being made,2 and (3) FDA has determined that there is

"significant scientific agreement" supporting the claimed diet-disease relationship. To date, FDA
 

3

 See Statement, pp. 22-23. Disclosure would almost certainly be necessary if the riskincreasing nutrient were closely related to the same diet-disease relationship that is the subject of

the health claim. That is, a product low in fat and cholesterol, but high in sodium, could not make

a heart health claim unless the advertisement also alerted consumers to the product's sodium

content. It might also be necessary to explain the link between high-sodium diets and

hypertension (and therefore heart disease). 

 

The Statement also advises that, depending on context, such disclosure might be necessary

even when the nutrient that is the subject of the health claim and the risk-increasing nutrient relate

to different diet-disease relationships, as would be the case for a food high in calcium (reduced

risk of osteoporosis) but also high in saturated fat (increased risk of heart disease). The

governing consideration is whether, absent qualifying disclosures, the osteoporosis health claim

would convey to reasonable consumers that the food is healthful in all respects. 

 

4

 Statement, p. 25. 

has approved health claims for eleven diet-health relationships. Claims concerning any other

health relationship (including antioxidant vitamin supplements and cancer and trans fatty acids and

heart disease) are currently prohibited. 

B. The FTC Statement

The FTC Statement advises that the Commission will apply FDA's definitions for absolute

and relative nutrient content descriptors when they are used in the same context in advertising. 

With respect to health claims, the Statement advises that advertised foods should meet the FDA

regulations for the relevant health claim if the claim contains no qualifications concerning the

extent of the benefit or the degree of scientific proof underlying the claim. The Statement does,

however, provide for certain qualified health claims that could not appear in labeling.

First, the Statement does not automatically disqualify all health claims for products that

contain more than 20 percent of the Daily Value for any of the four nutrients that can increase the

risk of a diet-related disease. Instead, the Statement advises that it may be necessary under such

circumstances for an advertisement to disclose the presence and possibly the significance of the

risk-increasing ingredient if reasonable consumers might otherwise believe that the product did

not present any health risk.3

Second, the Statement advises that, under certain limited instances, it may be possible to

craft a truthful and nonmisleading comparative health claim in advertisng for a product that does

not meet the nutrient profile prescribed by FDA for the specific nutrient-disease area in question. 

If, for example, a product were substantially lower in total fat than other foods in its product

category, but exceeded the 3-gram limit FDA stipulates for a heart health claim, an advertiser

could still claim the product was heart healthy if the advertisement made clear that the benefit

derived only from the substitution of the food for a significantly less healthful alternative.4

Third, the Statement does not necessarily limit health claims to the eleven diet-disease

relationships for which FDA has determined there is significant scientific agreement. The
 

5

 Id., p. 20. 

3

Statement allows qualified health claims for other relationships if the advertisement clearly

discloses the extent of the scientific support for the claim, and the claim is not inconsistent with

the larger body of evidence in that area.5 Thus, the Statement leaves the door open to

nonmisleading advertising about diet-disease relationships where existing evidence is very

promising, but has not yet attained the level of certainty that would constitute significant scientific

agreement. 

II. Overview of The Food Copy Test

A. Components of the Test

The consumer research project reported in this memo contained three components, each

targeted at one of the three previously discussed areas where the FTC Statement departs from the

FDA labeling regulations. In all cases, the study first probed whether additional disclosures and

qualifications were actually needed to correct misimpressions that consumers might otherwise

receive from unqualified health claims. The research also attempted to determine which of several

types of disclosures and qualifications would remedy most successfully any misimpressions that

consumers do receive from unqualified claims. 

1. Halo Effect

The first component of the consumer research, which can conveniently be referenced as

the "Halo Effect" segment, concerned food products that are high in both a clearly beneficial

nutrient (such as fiber) and a risk-increasing nutrient (such as sodium), and therefore are

disqualified from health claims on labels. One major goal of this phase of the project was to

determine whether nutrient content and, in particular, health claims about the beneficial nutrient

would cast a halo over the entire product and convey to consumers that there were no

problematic elements in the food's overall nutrient profile. The other purpose of this segment was

to determine the effectiveness of a series of increasingly detailed and explicit disclosures

concerning the level and significance of the risk-increasing ingredient in the food. 

2. Substitution Claim

The second component of the project, which will be referenced as the "Substitution

Claim" segment, concerned health products that are relatively low in a risk-increasing nutrient, but

not sufficiently low to meet the relevant FDA definition of low. Such products could not make a

claim in labeling that explained the health benefits of reducing the intake of the problem nutrient.

Specifically, this phase of the research tested advertisements for a brand of packaged

sliced turkey that claimed to have less than half of the sodium of other leading brands, but which

still did not qualify as a low sodium food. All of the ads stated that switching to the lower sodium

brand could help consumers cut back on sodium and help reduce the risk of high blood pressure. 
 

6

 The testing facilities were in Birmingham, Boston, Colorado Springs, Los Angeles, Orlando,

Philadelphia, Seattle, Springfield, St. Louis, Tampa, Toledo, and Wichita.

 

7

 The age limits for the study were 21-60, distributed approximately equally over 4 categories

(21-34, 35-44, 45-54, and 55-60). Approximately 75 percent of the respondents were female. 

 

8

 The two clutter ads were control ads from other segments of the study. 

4

All but the control ad contained disclosures specifying more precisely the levels of sodium in the

advertised brand and in other leading brands. 

The first object of the inquiry was to determine whether consumers would misinterpret the

sodium comparison and health claim in the control ad to mean that the advertised product was in

an absolute sense a low sodium food. The second goal was to determine the capacity of the

tested sodium content disclosures to correct any such misimpressions.

3. Level of Scientific Certainty

The final portion of the research involved health claims that have not yet achieved the level

of scientific support needed for FDA approval in labeling. As discussed, the Statement advises

that such claims may be allowable in advertising if the ad accurately conveys the level of scientific

support for the claim and if there is not a larger body of scientific evidence that contradicts the

claim. 

This component of the consumer research tested health claims for two diet-disease

relationships that have not been approved by FDA--antioxidant vitamins and cancer and trans

fatty acids and heart disease. Two sets of ads were tested--one for an antioxidant vitamin

supplement and one for a margarine that was free of trans fatty acids. The research attempted to

determine what level of certainty consumers would attach to unqualified health claims for these

products, and then to gauge the impact of a series of disclosures that qualified the degree of

scientific proof supporting the claims.

B. Experimental Design

The copy test project employed the same experimental design for each of the three subject

areas that were explored. Respondents were recruited in shopping malls in 12 geographically

dispersed cities across the country.6 All respondents were screened to meet age and sex quotas

and to determine whether they used products in the food category under examination.7

Consumers who passed the screening criteria were then escorted to an on-site testing

facility, where they initially were shown three print ads. Two of these were "clutter ads" and one

was the ad to be tested.8 The ads were then removed from sight and respondents were questioned

to determine whether they remembered seeing the test ad. If so, the respondents were asked the

very general open-ended question, "What do you think were the main points of the ad?" After

responding, the respondents were allowed to view the test ad again, and the full questionnaire was

administered (with the ad once more out of sight.) After the main interview concluded, all
 

9

 All but one of the ads used in the project were for a fictitious product brand. The decision

to use fictitious rather than real-world brands was driven both by logistical and research design

considerations. From a practical standpoint, we did not have sufficient resources or expertise to

produce professional ads for real products or alter existing ads convincingly. From a theoretical

standpoint, we were also concerned that consumers' prior beliefs concerning specific brands might

color the results, notwithstanding the use of control ads. Our final strategy was to use a computer

graphics program to produce ads that consumers might construe as preliminary versions of

promotional material for a new product introduction. We recognized, however, that there were

also risks to this approach, in that consumers might discount the credibility of the fictitious ads

and participate less seriously in the interview process. As a check on this possibility, we included

in the Strength of Science component one actual print ad for a real brand of vitamin supplements

to help determine whether there were systematic differences in consumer reactions to the real and

fictitious ads. 

 

10 In two cases, consumers also saw an intermediate ad with a "nutrient content" claim that

referenced high levels of fiber or calcium, but did not link the nutrient to a specific health benefit. 

5

respondents completed a questionnaire that measured their attitudes toward nutrition issues and

their nutrition knowledge. 

In general, one group of respondents in each segment of the research was shown a

"tombstone" control ad for a fictitious product brand.9 This ad contained very general claims

about such attributes as taste and/or price and made no explicit references to any health benefits

from consuming the product. Results from the control ads presumably would reflect prior beliefs

and knowledge about nutrition that consumers brought to the interviews, and therefore could

provide a point of reference in gauging the impact of the test ads. 

A second group of consumers viewed a very similar ad that contained some form of

unqualified health claim.10 Remaining groups of respondents were exposed to one of several

"remedy" ads that contained successively more detailed disclosures qualifying the overall health

benefits of the products or the extent of scientific support for the health claim. In all, 27 ads were

tested, with approximately 60 respondents exposed to each ad. A total of 1,623 respondents

participated in the project. 

As will be discussed in greater detail below, the results from the Halo Effect segment of

the study revealed that the original version of the most detailed remedy disclosure failed to

provide any additional clarification concerning the high level of risk-increasing nutrients in the two

advertised products. Since this poor performance appeared to be due to a flaw in the

experimental design, a small retest involving 120 respondents and two ads was conducted in

February of 1997 using revised wording for this remedy disclosure. Thus over 1,700 respondents

participated in either the initial or follow-up portions of the consumer research.

III. Detailed Discussion of Halo Effect Component

A. Hypotheses Tested
 

11 To economize on resources, the remedy disclosures were only applied to ads carrying a full

health claim rather than a simple nutrient content claim. Since it was hypothesized that any halo

effect from a health claim would be stronger than that associated with a simple nutrient content

claim, a disclosure that proved effective in a health claim ad presumably would also have remedied

misleading inferences from a nutrient content claim. 

 

12 Our test disclosures referenced FDA's "Daily Value" as the "Maximum Daily Value," since

FTC orders in food advertising cases have specified this variation on the FDA term in an attempt

(continued...)

6

There were two broad objectives in the Halo Effect segment. The first was to determine

whether a health claim (or, to a lesser extent, a simple nutrient content claim) for a food that

contains high levels of a beneficial and a risk-increasing nutrient will imply to consumers that there

are no problematic elements in the advertised product’s nutrient profile. More formally, the first

portion of the Halo Effect research was designed to test one primary and one secondary

hypothesis:

Hypothesis I: A health claim relating a nutrient level to a reduction in the risk of a diet-related

disease will imply to a substantial number of consumers that the product contains no other

nutrient at levels that will increase the risk of a diet-related disease.

Secondary Hypothesis Ia: The implication that a food is free of any risk-increasing nutrients will

be stronger for a health claim than for a nutrient content claim. 

The second major objective of this phase of the research was to determine what types of

disclosures would succeed in alerting consumers to the amount and health significance of the riskincreasing nutrient, assuming any such disclosures were needed.11

As discussed, the FDA labeling regulations prohibit health claims for the types of food

products we would be testing. Nutrient content claims are, however, allowed in labeling if the

claim is accompanied by a disclosure referring consumers to the nutrition facts panel for

information on the risk-increasing nutrient and other nutrients. For example, a complying

nutrient content claim on the label of a frozen dinner that was low in fat but high in sodium might

appear as follows: "Low in Fat. See back panel for information about sodium and other

nutrients."

We did not consider the FDA disclosure appropriate for advertising, since, among other

reasons, consumers viewing an ad could not conveniently consult the nutrition facts panel to

determine the nutrient profile of the product. We therefore based most of our test disclosures on

the information that consumers would find if they could in fact view the nutrition facts panel in

conjunction with the advertisement. Our disclosures generally conformed to metrics and

abbreviations specified by FDA. The first disclosure tested was simply the absolute amount of the

problem nutrient stated in grams or milligrams ("absolute disclosure"). The second test disclosure

added a statement of the absolute amount of the problem nutrient expressed as a percentage of

the Daily Value that FDA specifies for that nutrient ("relative disclosure").12 
 

12(...continued)

to communicate more clearly that the Daily Value for risk-increasing nutrients is the upper limit

on the desired daily intake. 

 

13 Statement, p. 22.

 

14 Had sufficient resources been available, we also would have tested a truncated version of

the strong disclosure that deleted the dietary warning concerning heart disease. This

experimental design would have allowed us to isolate how much of the superior performance of

the revised strong disclosure was due to a clearer communication of the level of sodium and

saturated fat in the advertised products, and how much was attributable to the explanation of the

health significance of the problem nutrients. The decision to devote the limited funds to a test of

the complete revised disclosure was driven by our negative experience with the original remedy

disclosures. Given that all of the initial attempts to find an effective remedy had failed, we wanted

to concentrate the follow-up research on the remedy that appeared most likely to succeed.

 

15 The three malls were located in Boston, St. Louis, and Los Angeles. 

7

The final disclosure (the "strong disclosure") initially was designed to test whether

consumers would be better able to interpret the absolute and relative nutrient content information

if additional information (not found on the Nutrition Facts Panel) were provided on the health

significance of high levels of the problem ingredient. The Statement advises that such a disclosure

may frequently be needed to prevent deceptive inferences when health claims are made for

products with high levels of a risk-increasing nutrient.13 We therefore added a health advisory to

the relative disclosure of the form: "Diets high in (the problem nutrient) may increase the risk of

(the associated disease).

As indicated, this disclosure performed no better than the absolute or relative disclosures

in alerting consumers to the high levels of risk-increasing nutrients in the test products and, in

some instances, increased the number of consumers responding that the advertised products were

low in these nutrients. After further analysis of the results and a reassessment of the experimental

design, we realized that consumers were likely to understand the significance of the tested health

advisory only if they also interpreted the absolute and relative nutrient content disclosures

correctly in the first instance and already knew that the tested foods were high in a problem

nutrient. If consumers did not realize from the nutrient content metrics that the test food was

high in the relevant ingredient, a statement that warned about diets high in that ingredient could

be--and was--interpreted to mean that the advertised food was particularly healthy because it did

not contribute to an unhealthy diet. 

To correct this design flaw, the absolute and relative nutrient content disclosures were

removed from the strong disclosure and replaced with a simple statement warning that the

advertised food was high in the risk-increasing ingredient. This direct alert was followed by the

original advisory concerning the health risks of diets high in the problem nutrient.14 The revamped

strong disclosure was then retested in three of the original twelve shopping malls under conditions

that replicated the initial research.15
8

In summary, the remedy section of the halo effect segment of our research tested four

subordinate hypotheses:

Hypothesis II: If a health claim is advertised for a food with a high level of a risk-increasing

nutrient:

a. Disclosing the absolute amount of the risk-increasing nutrient in conjunction with the

health claim will on net increase the number of consumers who understand that the 

product is high in a risk-increasing nutrient. 

b: An additional disclosure that expresses the amount of the risk-increasing nutrient as a

percentage of the Maximum Daily Value will on net increase the number of consumers

who understand that the advertised product is high in a risk-increasing nutrient. 

c: An additional disclosure that explains the health significance of the risk-increasing

nutrient will on net increase the number of consumers who understand that the advertised

product is high in a risk-increasing nutrient. 

d: Consumers will be most likely to understand that the advertised product is high in a

risk-increasing nutrient if the quantitative disclosures used to test hypothesis II(c) above

are replaced with an express warning that the advertised product is high in the riskincreasing nutrient. 

B. Food Products and Advertisements Tested

Two fictitious food products were chosen as subjects for the Halo Effect component. The

first was a canned minestrone soup ("Rich and Hearty") that was high in fiber and sodium. The

specific sodium level was 840 mg, which is 35 percent of the maximum suggested daily value and

therefore well over the risk-increasing threshold of 20 percent. The tested health claim for this

soup linked diets high in fiber to a reduction in the risk of some forms of cancer. The strongest

remedy disclosure that was tested connected diets high in sodium to an increased risk of high

blood pressure and heart disease.

The second test was for packaged swiss cheese slices ("Matterhorn") that were high in

calcium, but contained 7 grams of saturated fat (which also is 35 percent of the daily value). The

claimed health benefit was a reduced risk of osteoporosis, while the strongest remedy disclosure

was for an increased risk of heart disease.

Six ads--1 control ad and 5 test ads--were developed for both the soup and cheese

products. These ads are reproduced in Appendix A. Tables I and II present, respectively, the

differences in the main text portion of each of the soup and cheese ads designed to test the

hypotheses described above. In most cases, successive quotations in the tables include only

additional information not found in the previous ad. 
 

16 Statement, p. 20, note 82.

9

The disclosures in the three remedy ads were designed to meet the criteria the Statement

specifies for clarity and prominence.16 The disclosures appear in a box immediately below the

health claim in a font size approximately half that of the main text. 

C. Questionnaire Design

The questionnaires administered to viewers of the soup and cheese ads were virtually identical and

conformed to the "funneling" format customary in consumer survey research of this type. The

questioning began in a very general, completely open ended manner and gradually focused more narrowly

on the perceived healthiness of the products and, finally, on the perceived sodium or saturated fat

content.

The questionnaire ended with demographic questions concerning income and education level. 

The ads and survey instruments for the halo effect component of the research were pre-tested twice--

once in Baltimore and, following revisions, a second time in Philadelphia. The full questionnaire for the

soup respondents is presented in Appendix B.
10

 Table I

Principal Differences in Text of Soup Ads

____________________________________________________________________________________

 Nutrient Content Claim 

And Rich and Hearty is High in Fiber, Too!

 Health Claim Absolute Disclosure 

 That's Good News! Eating Diets Sodium Per Serving: 840 mg

 That Are Low in Fat and High in 

 Fiber May Reduce the Risk of

 Some Forms of Cancer.

 Relative Disclosure Strong Disclosure

 Sodium Per Serving: 840 mg Sodium Per Serving: 840 mg

 % of Maximum Daily Value: 35% % of Maximum Daily Value:35%

 Diets high in sodium may

 increase the risk of high

 blood pressure and heart disease

 

 Revised Strong Disclosure

 Rich and Hearty is high in sodium.

 Diets high in sodium may increase 

 the risk of high blood pressure and

 heart disease. 

____________________________________________________________________________________
11

Table II

Principal Differences in Text of Cheese Ads

____________________________________________________________________________________

 

 Nutrient Content Claim

 

 And Matterhorn is High in Calcium, Too!

 Health Claim Absolute Disclosure

 That's Good News! Eating Foods Saturated Fat Per Serving: 7g

 That Are High in Calcium May 

 Reduce the Risk of Osteoporosis.

 Relative Disclosure Strong Disclosure

 Saturated Fat Per Serving: 7g Saturated Fat Per Serving: 7g

 % of Maximum Daily Value: 35% % of Maximum Daily Value: 35%

 Diets high in saturated fat may increase 

 the risk of heart disease.

 Revised Strong Disclosure

 Matterhorn is high in saturated fat.

 Diets high in saturated fat may increase 

 the risk of heart disease.

____________________________________________________________________________________
 

17 A complete question-by-question analysis of the results is available from the principal

author. The discussion that follows generally omits or treats in cursory fashion questions that

failed to yield new insights concerning the principal issues under investigation.

12

D. Copy Test Results

1. Overview

Stated succinctly, the results from both the soup and cheese test advertisements failed to

support most of the hypothesized outcomes. Little evidence developed that was consistent with

the primary halo effect theory. The positive nutrient content and health claims concerning fiber

had only a small impact on respondents' perception of the overall healthiness of the advertised

soup, and the calcium information had no effect in the corresponding cheese cells. More

important, these positive messages did not appear to alter respondents' perception of the level of

sodium or saturated fat in the advertised products, although low response rates in key test cells

prevented firm conclusions on this issue. 

Further, the three remedy disclosures originally tested were misinterpreted by many

consumers, and, on net, did not increase the number of respondents who understood the high

level of sodium or saturated fat present in the advertised soup or cheese. Respondents were

particularly confused by the dietary advisory in the original strong disclosure. Many viewers

apparently misconstrued the warning about the health risks of diets high in sodium or saturated fat

as a positive indication that the advertised products were low in these nutrients and therefore did

not present the described dietary risk. Taken together, the results from these original remedy cells

indicate that, at the time of our test, consumers had a poor understanding of metric nutrient

content measures, and that, when in doubt, consumers will tend to attach a positive connotation

to information disclosures in advertising. 

The revised strong disclosure provided an exception to the otherwise poor performance of

the remedies. Virtually all respondents in the cheese cell understood the more direct verbal

message, and the corresponding sodium warning avoided most (though not all) of the confusion

associated with the original quantitative strong sodium disclosure. Due to resource constraints, it

was not possible to determine how much of the effectiveness of the revised disclosure could have

been achieved without the heart disease warning contained in the second sentence. Future

research might explore productively whether a shorter and less burdensome alert to high levels of

a problem nutrient would prove as successful as the more complete warning tested here.

2. Results in Detail

Given that the ad format and questionnaires for the soup and cheese products were

essentially identical, the two sets of results will be discussed together.17 Results for the original

strong disclosure cells are provided only for the key close-ended question, since the revised

disclosure was conceptually superior and clearly outperformed the initial disclosure in the field. 
 

18 Most cheese respondents recalled correctly that the warning concerned saturated fat rather

than total fat. 

13

a. Main Points of the Ad, First Exposure

The unaided responses to the first open-ended question, which was asked after the first

exposure to the test ad (and the clutter ads), give an initial read on what respondents found to be

the primary messages. The most interesting issues promised to be the proportion of respondents

that mentioned nutrient content or health messages, and whether respondents in the remedy cells

noticed and interpreted correctly the various sodium or saturated fat disclosures.

 With the exception of the tombstone control ads, which contained no nutrient

information, approximately half of the respondents seeing the various soup or cheese ads

mentioned nutrients, usually fiber or calcium. With respect to risk-increasing nutrients, 17 percent

of respondents in the absolute and relative disclosure cells, and 38 percent in the strong disclosure

cell, made some reference to sodium. For cheese, about one-third of the respondents in the first

two remedy cells mentioned fat or saturated fat. This figure rose to 45 percent in the strong

disclosure cell. 

A closer examination of the sodium and saturated fat responses yields early indications

that the absolute and relative remedy disclosures did not perform as hypothesized. No

respondents seeing the absolute disclosure cheese ad reported that the cheese was high in fat or

saturated fat, and only 5 percent in the relative disclosure cell reported such a message. The

outcome was virtually identical in the corresponding soup cells. Results for the strong disclosure

ads were much more encouraging, however. Almost one third of the soup respondents recalled

high sodium as a main message, and over 40 percent of the cheese respondents recalled as a main

point that the advertised product was high in fat or saturated fat.18

 

Finally, from 40-50 percent of respondents seeing the health claim and remedy disclosure

ads for soup and cheese reported some form of health message as a main point. (The

corresponding figures for the control and nutrient content ads were 15 and 8 percent,

respectively.) These health responses tended to be very general, such as the soup "is good for

you" or "is healthy." 

b. Main Points, Second Exposure

After respondents had given their first impressions of the soup and cheese ads, they were

allowed to read the ads again, after which they were asked: "Now what do you think the main

points are." With one exception discussed below, the pattern of responses to this second query

changed very little over the first, although, not surprisingly, there was an across-the-board

increase in the proportion of consumers reporting a given point. For example, from 63 percent

(health claim) to 78 percent (relative disclosure) of respondents listed calcium content has a main

point of the cheese ads, vs. 39-53 percent after the first exposure. 
 

19 The relatively high playback of negative characterizations of sodium and saturated fat in the

strong disclosure cells raises the issue of whether the stern warnings in these ads interfered in any

way with communication of the positive messages concerning fiber, calcium, and their associated

health benefits. There is no evidence that the strong disclosure ads were any less successful than

the simple health claim ads in communicating positive nutrient content information. There were

slightly more mentions of fiber and calcium in the soup and cheese strong disclosure cells than in

the corresponding health claim cells. 

There was, however, a modest falloff in the number of positive health messages reported

by respondents seeing the strong disclosure ads. About half of the respondents in the soup health

claim cell mentioned cancer reduction benefits as a main point of the ad. This proportion fell to

40% in the strong disclosure cell, although roughly equal reductions occurred in the other soup

remedy cells. Similarly, the incidence of osteoporosis messages reported in the cheese health

claim cell (57%) was 12 percentage points higher than in the strong disclosure cell. Again,

however, the absolute and relative disclosure ads also produced fewer mentions of osteoporosis

(51% and 34.4%), even though very few respondents in these cells cast the remedy disclosures in

a negative light in the verbatims. Thus, it may simply be the greater quantity of information in the

remedy ads, rather than their negative content, that is responsible for the decreased playback of

specific health claims.

14

There were similar increases in the proportion of respondents mentioning a health claim

after viewing the health claim and remedy disclosure ads a second time. Unlike the first exposure,

however, most of these responses made specific reference to lowered risk of cancer or

osteoporosis. 

The second exposure did not change the pattern of responses to the three remedy

disclosures appreciably. No respondents in the cheese absolute disclosure cell, and only 3 percent

in the corresponding soup cell, volunteered as a main point that the products were high in any

type of fat or in sodium. For cheese, 7 percent of respondents seeing the relative disclosure

mentioned fat or cholesterol in a negative light. This figure rose substantially to 42 percent in the

strong disclosure cell. For soup, negative mentions of sodium in the relative and strong disclosure

cells were, respectively, 10 percent and 33 percent.19

 

c. Purchase Interest

The next question in the interview was intended to give a summary measure of

respondent's overall evaluation of the advertised product. The question read:

Q3. "Based on the information in the ad, how interested would you be in buying the 

product?" 

Respondents were shown a card with five possible answers, ranging from "not at all interested" to

"extremely interested." 
15

If the healthiness of a product were important to respondents, and if the ads successfully

communicated nutrient and health information that respondents did not already know, we would

expect the mean purchase interest rating for the nutrient content cell to be higher than for the

control, and the rating for the health claim cell to increase over that of the nutrient content cell. 

The ratings should then decline steadily as greater detail is added to the remedy disclosures. We

cannot predict a priori whether the ratings for the remedy cells would be lower than for the

control. This would depend in part upon how respondents weighted the positive and negative

nutrient attributes of the soup and cheese products. 

The results did not fit the predicted pattern very well. For soup, the highest purchase

interest was expressed by viewers of the control ad, which contained no health or nutrient

information. Although the lowest purchase ratings were registered in the remedy cells, none was

significantly below the health claim cell which, a priori, should have produced the highest rating. 

For cheese, all of the purchase interest ratings were statistically indistinguishable except,

marginally, the revised strong disclosure rating, which was lower than the health claim rating at a

.15 level of significance. Overall, the mean purchase interest ratings ranged from 2.19 (where 2.0

represents "not very interested") in the cheese revised disclosure cell to 3.13 (slightly above

"somewhat interested") in the soup control cell.

 Following the purchase interest question, respondents were asked two very general

questions that were intended to direct attention to the nutrient profile health attributes of the

featured foods. These questions were:

Q4. Did the ad say or imply anything about what is in the soup (swiss cheese)? What?

Q5. Did the ad say or imply that the soup (swiss cheese) would have any effect on your 

health? What?

Neither of these questions generated any new information that was not already provided by the

responses to the initial open-ended questions concerning the perceived main points of the ads. 

d. Ad Believability

Question 6 asked respondents, "How believable is the ad?" Such an inquiry is pro forma

in consumer research of this type, and serves as a check on possible glitches in the wording and

appearance of the test ads. In this case, the question also tested whether adding increasingly

detailed and explicit nutrient content and health information would increase the credibility of an

ad. Respondents were instructed to select one of 5 possible ratings, ranging from "not at all

believable" to "extremely believable."

There were no large differences in the believability ratings for any of the ads. Although

the control scored highest of any of the soup ads, the control cheese ad was the poorest

performer. In any event, there are no statistically significant differences between any of the ads. 

Overall, respondents found the cheese ads slightly more believable than the soup ads. In

all cases, however, respondents scored the ads above the midpoint "somewhat believable" rating. 
 

20 There were virtually no mentions of low sodium or fat in any of the other test or control

cells.

16

The mean score for all of the soup ads was 3.21; the corresponding cheese score was 3.36. 

Considering that the ads were computer mock-ups and that the products were fictitious, this is a

fairly strong result. There were not very many derogatory comments about the appearance of the

ads in any of the verbatims for any of the questions.

e. Overall Healthiness

Question 7 measured how the test ads affected respondents' appraisal of the overall healthiness of

the soup and cheese products. The question asked:

Q7. Based on what the ad says or implies, how healthy would you rate this product? 

Why?

The five response choices ranged from "very unhealthy" to "very healthy." Figures 3 and 4

illustrate the results.

Although there is not a great deal of variation in outcomes among the soup ads, the

overall pattern does at least conform to a priori predictions. The highest rating of 4.05 is obtained

in the health claim cell, after which the scores decline as more explicit remedies are disclosed

about the problem nutrients. The final rating of 3.48 for the revised strong disclosure is below the

health claim score by an amount that just misses statistical significance at the .10 level (p=.11),

and is also the lowest recorded in any of the cells. This neat pattern all but collapses in the

cheese results. The distribution of scores among the first five cells appears purely random. 

Again, however, the revised strong disclosure does perform as predicted, lowering the healthiness

score by about a full point in comparison with most of the other cells. Even the smallest

difference--that between the strong disclosure score of 2.76 and the control score of 3.57--is

significant at the .05 level.

In their responses to the follow-up probe in Question 7, about 10% of participants openly

misinterpreted the absolute and relative remedy disclosures in the soup and cheese ads, stating

that the advertised foods were low in the problem nutrient. This proportion fell to 7% in the soup

revised strong disclosure cell, and 3% in the equivalent cheese cell.20

A higher proportion of respondents, however, volunteered explanations that contained

correct interpretations of these remedies. For soup, 13% (relative) to 33% (revised strong) cited

high sodium levels as a basis for their rating. Negative mentions were considerably higher among

the cheese justifications. The advertised cheese was identified as high in saturated or total fat by

21% of respondents in the relative cell, 39% in the absolute cell, and 60% in the 
17

5: extremely healthy

4: very healthy

3: somewhat healthy

2: not very healthy

1: not at all healthy

3.83

3.60 3.70

4.05 4.02

3.75

3.48

0

1

2

3

4

5

Total Control Nutrient

Content

Health Claim Absolute

Disclosure

Relative

Disclosure

Strong

Disclosure

VERSION

MEAN RESPONSE

FIGURE 3

HEALTHINESS OF ADVERTISED SOUP
18

5: extremely healthy

4: very healthy

3: somewhat healthy

2: not very healthy

1: not at all healthy

3.73

3.57

3.80 3.71

3.86

3.68

2.76

0

1

2

3

4

5

Total Control Nutrient

Content

Health Claim Absolute

Disclosure

Relative

Disclosure

Strong

Disclosure

VERSION

MEAN RESPONSE

FIGURE 4

HEALTHINESS OF ADVERTISED CHEESE
 

21 The control and health claim ads also elicited an appreciable number of mentions of high fat

or saturated fat in the probe to Question 7. Thirteen percent of respondents in these cells

commented negatively on the fat content of the advertised cheese. 

19

strong cell.21

 f. Sodium and Saturated Fat Content

Question 8 provides the most focused inquiry into respondents' perceptions concerning the

risk-increasing nutrients in the advertised products, and is therefore the most direct test of the

hypothesized halo effect and hypotheses IIa-IId, which relate to the predicted efficacy of the

alternative remedy disclosures. This question asked respondents to rate the sodium or saturated

fat content of the foods along a 5-point scale labeled, "low," "somewhat low," "neither high nor

low," "somewhat high," and "high." The average ratings for the various cells are reported in

Figures 5 and 6.

These tables include results for the original strong remedy disclosure, which coupled the

relative disclosure with a warning concerning risks of diets high in sodium or saturated fat. The

revised strong disclosure, it will be recalled, replaced the quantitative information in the relative

disclosure component with a simple statement that the food was high in the relevant problem

nutrient.

The results for the first three cells in Figures 5 and 6--control, nutrient content, and health

claim--provide evidence on the hypothesized halo effect. The results would support this theory if

the mean sodium and saturated fat ratings were highest in the control cell, and then fell

progressively in the nutrient content and health claim cells.

In the case of soup, the mean sodium rating for the control ad, which contained no health

or nutrient content messages, is quite low at 2.43. Over 60% of respondents, however, stated

that the ad did not say anything about sodium or that they did not know. The mean sodium rating

then rises unexpectedly in the nutrient content cell. Again, however, only a minority of

respondents estimated sodium content, and the difference is not statistically significant. The

results for the health claim cell must also be interpreted with caution, since the ratings reflect the

opinion of only about half of the respondents. The rating of 2.27 is lower than the control, and

therefore consistent with Hypothesis I (halo effect), but the difference is not significant.

Figure 6 reveals much less variation in the cheese saturated fat ratings over the first three

cells. The mean scores in the control, nutrient content, and health claim cells are within .06 points

of each other. It should be noted, however, that response rates were even lower than in the

equivalent soup cells, ranging from 45 percent in the control cell to only 33 percent in the health

claim cell. 

Taken together, the soup and cheese results provide no evidence of a halo effect from the

health claims. The analysis is, however, clouded by low response rates, which greatly reduces the

power of the test. It is possible that a significant difference in perceived sodium or saturated fat
 

22 One alternative would have been to phrase the sodium probe as a belief question rather than

as a strict ad communication question. That is, the introduction to Question 8 might have read

"Do you think the advertised product is..." rather than "Based on what the ad says or implies...." 

We can only speculate as to whether this approach would have yielded useful information, or

whether instead the shift to a beliefs perspective would have introduced biases or ambiguities that

would have made the results difficult to interpret.

20

levels between the control and health claim ads might have emerged if a method had been found

to elicit a rating by a majority of respondents in the control cells.22 It is not likely, however, that

any such effect would have proven substantial, since the responses to Question 7 revealed no

significant difference between the perceived healthiness of the advertised products in the control

and health claim cells. 

 

The results for the last four cells reported in Figures 5 and 6 reveal the impact of the

remedy disclosures on consumer perceptions of the level of problem nutrients in the advertised

products. For soup, the performance of the absolute disclosure is consistent with Hypothesis IIa,

which predicted that disclosing the absolute quantity of a risk-increasing ingredient would

improve consumer understanding of the amount of that nutrient in the advertised food. The mean

sodium rating for the absolute cell is higher than that of the health claim, although the difference is

significant only at the .14 level. The subsequent results for the relative disclosure cell and the

original strong disclosure cell fail to support Hypotheses IIb and IIc, which predicted

progressively higher sodium ratings for increasingly detailed and explicit disclosures. Consumer

perception of sodium actually falls to 2.88 in the relative disclosure cell, and again to 2.68 in the

original strong disclosure cell. (These differences are not significant.) 

The final result reported in Figure 5 provides support for hypothesis II(d), which predicted

that a verbal warning concerning the high level of sodium in the soup would prove more effective

than the quantitative measures contained in the original strong disclosure. The mean sodium

rating for the revised strong disclosure (3.75) is higher than any other cell, and is significantly

higher than the rating recorded in the health claim cell (p=.004) and the nutrient content cell

(p=.04). This disclosure cannot, however, be considered a complete success, since the mean

rating of 3.75 (slightly below "somewhat high") indicates that respondents on average still

underestimated the true sodium content of the soup.

 Figure 6 reveals clearly that the absolute disclosure failed to communicate any additional

information on the quantity of saturated fat in the advertised cheese. As with soup, the relative

disclosure performed even more poorly than the absolute disclosure, although no statistical

significance can be attached to the difference in saturated fat ratings (2.91 for the absolute vs.

2.61 for the relative). The rating of 2.86 for the original strong disclosure indicates that adding a

dietary warning to the relative disclosure was on net of little or no value. The revised strong

disclosure provides a striking exception to these disappointing results. The direct verbal warning

succeeded almost completely in alerting consumers to the high level of saturated fat in the

advertised cheese. The mean rating of 4.59 is significantly higher than any other cell (p<.001). 
21

5: high

4: somewhat high

3: neither high nor low

2: somewhat low

1: low

2.78

2.43

2.74

2.27

3.31

2.88

2.68

3.75

0

1

2

3

4

5

Total Control Nutrient

Content

Health

Claim

Absolute

Disclosure

Relative

Disclosure

Original

Strong

Disclosure

Revised

Strong

Disclosure

VERSION

MEAN RESPONSE

 

FIGURE 5

SODIUM CONTENT OF ADVERTISED SOUP
22

5: high

4: somewhat high

3: neither high nor low

2: somewhat low

1: low

2.84 2.89 2.95 2.90 2.91

2.61

2.86

4.59

0

1

2

3

4

5

Total Control Nutrient

Content

Health

Claim

Absolute

Disclosure

Relative

Disclosure

Original

Strong

Disclosure

Revised

Strong

Disclosure

VERSION

MEAN RESPONSE

FIGURE 6

SATURATED FAT CONTENT OF ADVERTISED CHEESE
23

The mean ratings for the remedy cells in Figures 5 and 6 obscure important underlying

patterns in respondents' perceptions of sodium and saturated fat content that develop as the

various remedy disclosures are added to the positive health claims. Figures 7 and 8 show the

movement across cells in four categories of responses to Question 8: "Don’t Know--Ad Doesn’t

Say," "Low, Somewhat Low," "Neither High nor Low," and "High, Somewhat High." 

Both graphs reveal that the proportion of respondents who answered "don’t know" or "ad

doesn’t say" falls precipitously as the remedies are introduced. This demonstrates that most

respondents at least noticed the references to sodium or saturated fat content. Figures 7 and 8

also document that very few respondents interpreted the disclosures in a neutral fashion. In all

but one cell (the cheese absolute disclosure), fewer than 10% of the respondents selected the

"neither high nor low" option. 

The dashed line graphs in Figures 7 and 8 show that, as hypothesized, many respondents

interpreted the remedies correctly to indicate that the soup and cheese products were somewhat

high or high in sodium or saturated fat. The proportion of responses in this category jumps to

about 40% in the soup absolute disclosure cell and to about 25% in the corresponding cheese cell. 

The soup percentages fall slightly in the next two cells, but the proportion of "high, somewhat

high" responses increases again to about 65% in the revised strong disclosure cell. For cheese,

the percentage of "high, somewhat high" responses does not change in the relative disclosure, and

increases to 45% in the original strong disclosure. This percentage then practically doubles when

respondents are shown the revised strong disclosure. 

The most surprising and troubling pattern in Figures 7 and 8 is the impact of the original

remedies on the proportion of respondents answering "low, somewhat low." As is charted by the

solid black line in these graphs, this proportion increases steadily as more detail is provided on the

quantity and health significance of the sodium or saturated fat in the advertised products. Further,

with the sole exception of the soup absolute disclosure, more respondents misconstrue the

original disclosures as positive information than correctly understand the negative message that

was intended. Thus, Figures 7 and 8 demonstrate even more clearly than the mean ratings in

Figures 5 and 6 that the metric disclosures and the hybrid original strong disclosure essentially

backfired, and that the extent of their perverse impact varied directly with the amount of

information provided.

These results suggest more generally that many Americans are apparently not sufficiently

familiar with metric measurements as applied to nutrient levels or sufficiently comfortable with

percentage measurements and the concept of a Daily Value to interpret such disclosures correctly. 

Consumers may also assume that the disclosures are intended to be construed in a positive manner

simply because they are presented in the context of an advertisement promoting the health benefits

of a product. 
24

0

10

20

30

40

50

60

70

80

90

100

Control Nutrient

Content

Health

Claim

Absolute

Disclosure

Relative

Disclosure

Original

Strong

Disclosure

Revised

Strong

Disclosure

VERSION OF AD

% of All 

Respondents in 

Cell

0

10

20

30

40

50

60

70

80

90

100

high, somewhat high

neither high nor low

low, somewhat low

don't know, ad doesn't say

FIGURE 7

SODIUM LEVEL RATINGS BY CATEGORY

SOUP
25

0

10

20

30

40

50

60

70

80

90

100

Control Nutrient

Content

Health Claim Absolute

Disclosure

Relative

Disclosure

Original

Strong

Disclosure

Revised

Strong

Disclosure

VERSION OF AD

% of All 

Respondents in Cell

0

10

20

30

40

50

60

70

80

90

100

high, somewhat high

neither high nor low

low, somewhat low

don't know, ad doesn't say

FIGURE 8

SATURATED FAT RATINGS BY CATEGORY

CHEESE
 

23 We can only conjecture as to why the revised strong disclosure in the cheese ad

communicated so much more effectively than the same format in the soup ad. One possibility is

that consumers are more concerned about fat and saturated fat than sodium, and therefore

focused more attention on the warning in the cheese ad. It is certainly true that the link between

sodium and hypertension has received much less attention in the press and health community

during the last decade than has the relationship between saturated fat and heart disease. 

It may also be important that the positive health message in the soup ad was somewhat

more complex than the equivalent portion of the cheese ad. The soup health claim was worded to

track the FDA language for fiber-cancer claims in labeling. Because of the suspected link

between certain kinds of cancer and high fat intake, this language places the fiber claim in the

context of a diet that is low in fat. (It will be recalled that our version of the FDA fiber claim was: 

"Eating foods that are low in fat and high in fiber may reduce the risk of some forms of cancer.") 

Thus, the soup ad contained references to three nutrients--fiber, fat, and sodium--while the cheese

ad mentioned only calcium and saturated fat. This may partially explain why the saturated fat

advisory received greater attention than the sodium advisory.

26

In addition, the particularly poor performance of the original strong disclosure seems to

suggest that any consumer confusion concerning absolute or relative nutrient content disclosures

will be exacerbated by an additional disclosure that explains the health significance of the problem

nutrient in the context of the overall diet. It seems clear that those consumers who fail to

understand the numerical disclosures will tend to misinterpret the dietary warning as a positive

statement about the healthiness of the advertised product. Such consumers will assume that the

products will help them reduce the quantity of sodium or saturated fat in their diets and therefore

avoid the health risks mentioned in the warning. 

Figures 7 and 8 also reveal that much, though not all, of the confusion caused by the

original strong disclosure can be avoided by substituting for the numerical information a simple

verbal statement warning that the product is high in the relevant risk increasing nutrient. In the

case of cheese, this approach reduced the percentage of respondents taking a low or somewhat

low saturated fat claim from 44 percent to only 7 percent. 

The improvement is less dramatic though still appreciable for soup. The revised strong

disclosure cut the proportion of seriously confused or misled respondents approximately in half,

with the percentage of low or somewhat low responses falling from 48 percent to 27 percent. 

This is considerably below the corresponding figure for the relative disclosure (40%), and exactly

equal to the absolute disclosure fraction. It should be noted, however, that on an overall basis the

revised strong disclosure outperformed the absolute disclosure. Sixty-three percent of

respondents in the new strong disclosure cell replied that the soup was high or somewhat high in

sodium, whereas 40% of the absolute respondents gave this answer.23
 

24

 Before Question 10 was posed, respondents were asked a question intended to clarify the

responses of consumers who thought the advertised products were low in a problem nutrient. In

such cases, we wanted to know whether the respondents meant that the product was low enough

to meet a formal nutrient content standard, or whether they were attaching a less rigorous

interpretation, perhaps thinking that the food was relatively low for products of that type.

Given that the two foods in the halo effect test were unambiguously high in risk-increasing

nutrients, and that any rating of low or somewhat low was incorrect however interpreted, this

question was of less interest than an equivalent question asked in the Substitution Claim test,

where the advertised product was in fact relatively low in sodium when compared with other

packaged turkey slices. In any event, there are signs that the logistics involved in asking the

question overwhelmed many of the interviewers and/or respondents, and the results are of

insufficient reliability and interest to warrant discussion here. 

27

g. Recall of Nutrient Information

Question 10 tested the degree to which respondents noticed the various nutrient content

disclosures presented in the ads. Of particular interest was the proportion of respondents in the

remedy cells that remembered seeing information about sodium or saturated fat.24 For the cheese

ads, respondents were asked whether they remembered seeing any information about fat,

saturated fat, and sodium. Sodium was included to measure yea-saying bias, since this nutrient

was never mentioned in any of the ads. Questions about both fat and total fat were included to

determine how many respondents had noticed that the remedy disclosure concerned saturated fat

rather than total fat. 

Soup respondents were asked about fiber, sodium, and fat. The question about fat

functioned as a check on yea-saying bias only in the control and nutrient content cells, since fat

was mentioned peripherally in the health claim linking diets high in fiber and low in fat to a

reduction in the risk of some forms of cancer. 

For some unexplained reason, interviewers asked question 10 to only a small minority of

respondents in the cheese control, nutrient content, and health claim cells, and to only 24

respondents in the soup control cell. These results are therefore of little value. In the remedy

cells, most cheese respondents said they recalled information about both fat and saturated fat. 

Recall levels were lowest for the relative disclosure, where 78% mentioned total fat and 63%

mentioned saturated fat. Corresponding recall levels in the absolute cell were 10 percentage

points higher. Fully 90% of respondents in the revised strong cell recalled seeing information

about saturated fat. Even when corrected for yea-saying bias, which ran from 7% to 19%, recall

of the disclosures about fat or saturated was high enough to conclude that the cheese quantitative

remedy disclosures did not perform poorly simply because they were overlooked. 

Recall levels in the soup remedy cells were very similar. From 73% (absolute) to 88%

(revised strong) remembered seeing sodium information of some kind. Recall of the positive fiber

information was even higher, ranging from 92 to 98 percent.
28

h. Demographic Questions

The last two questions in the interview asked about respondent education and income

level. The demographic results are summarized in Figures 9 and 10. The average education level

of the cheese respondents as a group was slightly above a high school degree, and significantly

higher than the soup respondents (p=.09). The average family income of the viewers of the

cheese ads was also higher than that of the soup respondents ($32,750 vs $30,000), but this

difference is not statistically significant. Across cells, there are no significant differences in

income or education for either the soup or cheese respondents. 

These data allow a test of whether the previously discussed bifurcation in respondents'

interpretation of the various remedy disclosures (Q7) could be explained in part by differences in

education level. Subsequent analysis, however, did not support this conjecture. A variety of

cross tabulations and regressions failed to find any overall relationship between education and

perceived sodium or saturated fat content in the remedy cells.

E. Conclusion

The results from the first segment of the food health claims copy test suggest three

primary conclusions. First, judging from the responses to the purchase interest question, our

respondents did not consider the positive health information presented in the nutrient content and

health claim advertisements very important. 

Second, and perhaps related, the results provide little or no support for the existence of a

strong halo effect from an unqualified health claim. This is particularly true if the effect is

construed very generally as an increase in the perceived healthiness of a product. Low response

rates in certain test cells prevent firm conclusions on the more focused question of whether or not

a health claim will lower consumer perceptions of the level of specific problem nutrients in a food. 

Third, there is no support for the hypothesized capacity of either the sodium or saturated

fat numeric nutrient content disclosures to improve respondents' overall understanding of the

nutrient profile of the advertised products (Hypotheses IIa and IIb). These metric disclosures,

whether expressed in absolute or relative terms, generally confused or misled about as many

respondents as they helped. Coupling the quantitative measures with a dietary warning actually

furthered the confusion. Based on the superior performance of the verbal approach tested in the

revised strong disclosure, consumers apparently require nutrient content information to be

presented directly in plain English. 

 
29

1: some high school

2: high school graduate

3: some college or technical school

4: college gradute

5: post graduate

3.0

3.3

3.2

2.9

3.3

3.4

3.0

3.1 3.1

2.8

3.2 3.2

0

1

2

3

4

5

Control Nutrient

Content

Health

Claim

Absolute

Disclosure

Relative

Disclosure

Strong

Disclosure

VERSION

EDUCATION 

LEVEL

cheese

soup

FIGURE 9

AVERAGE EDUCATION LEVEL

CHEESE & SOUP RESPONDENTS
30

1: under $25,000

2: $25,000 - $49,999

3: $50,000 - $74,000

4: $75,000 or more

2.2

2.1

2.4 2.4

2.3

2.5

2.0

2.3

2.5

2.3

2.2 2.2

0

1

2

3

4

Control Nutrient

Content

Health Claim Absolute

Disclosure

Relative

Disclosure

Strong

Disclosure

VERSION

INCOME LEVEL

cheese

soup

FIGURE 10

AVERAGE INCOME LEVEL

CHEESE & SOUP RESPONDENTS
 

25 Statement, p. 25.

31

IV. Detailed Discussion of Substitution Claim Component

As summarized earlier, the FDA labeling regulations prescribe strict minimum and

maximum nutrient content requirements that are specific to each of the eleven health claims

currently authorized. By way of illustration, no food product can relate its sodium content to a

reduced risk of hypertension unless that food is "low" in sodium (140 mg of sodium or less per

serving.) Calcium-osteoporosis claims are allowed only for foods that contain 180mg or more of

calcium per serving, which is the standard for "high" calcium. In short, FDA generally reserves

health claims for products that are among the very best in the relevant nutrient domain. 

In the FTC Statement’s less restrictive treatment of this subject, health claims may appear

in advertising for products that are substantially "better" in a given nutrient characteristic, though

not necessarily among the "best" in the food category. The governing considerations are (1)

whether the ad describes a dietary substitution that will in fact appreciably reduce or increase

intake of the nutrient(s) at issue, and (2) whether readers of the ad will understand the limited

scope of the brand’s nutrient superiority. The Statement cautions advertisers that "it may be

necessary to disclose the actual level of the nutrient that is the basis for the claim and its

significance to prevent deception...."25 

A. Hypotheses Tested

The first task of the Substitution Claim component was to determine whether consumers

exposed to health claims for the type of product at issue would, in fact, overestimate the relative

attractiveness of the food’s nutrient profile when no information is provided concerning the

absolute level of nutrients in the advertised or compared foods. 

In principle, the Statement’s treatment of substitution claims applies both to foods that are

relatively low in a problem nutrient or relatively high in a beneficial nutrient. In practice,

however, claims concerning reduced levels of risk-increasing nutrients such as fat or sodium might

be more prevalent, since they would appeal to consumers who, for taste reasons, are unwilling to

purchase products that are truly low in these nutrients, but who might still be seeking healthier

alternatives to their current choices. 

We therefore specified the first hypothesis to be tested as follows:

Hypothesis I: If an advertisement states that a food product contains less of a risincreasing nutrient than other identified products, and if the advertisement relates

this comparative advantage to a specific health benefit, the advertisement will

convey to a substantial number of consumers that the advantaged product is low in

the risk-increasing nutrient whether or not the product meets the relevant FDA

definition of low. 
32

The second objective of this phase of the food copy test was to determine which types of

nutrient disclosures or explanations would best correct any misimpressions that consumers

received from the advertisement used to test the first hypothesis. Four remedy disclosures were

tested. The first, identical to the absolute disclosure in the halo effect component, tested whether

a simple statement of the absolute quantity of the risk-increasing nutrient in the advertised product

and in the compared products would correct any impressions that the advertised product was low

in the problem nutrient.

The remaining remedies implemented in varying formats the Statement’s advisory that

advertisers might have to disclose both the level of the relevant nutrient and its significance in

order to prevent deception. The first attempt to indicate the significance of the nutrient level

replicated the format of the relative disclosure in the halo effect segment. This remedy disclosed

the level of the risk increasing nutrient terms both in absolute terms and as a percentage of the

Maximum Daily Value. 

The last two remedies tested more explicit disclosures. In one approach, an advisory was

appended to the relative disclosure stating that the advertised product was not low in the relevant

risk-increasing nutrient. The other approach tested whether a purely verbal advisory placed in the

main body of the text would prove more effective than the separate quantitative or hybrid

quantitative-verbal disclosures employed in the first three remedies. 

The four tested hypotheses may be summarized as follows:

Hypothesis II: For the advertisement used to test Hypothesis I: 

a. Disclosing the absolute amount of the risk-increasing nutrient will on net increase the

number of consumers who understand that the advertised product is not low in this

nutrient.

b. An additional disclosure that expresses the amount of the risk-increasing nutrient as a

percentage of the Maximum Daily Value will on net increase the number of consumers

who understand that the advertised product is not low in this nutrient.

c. An additional disclosure stating that the advertised product is not low in the riskincreasing nutrient will on net increase the number of consumers who understand that the

product is not low in this nutrient.

d. In lieu of IIa-IIc, a separate disclosure in the main body of the text stating that the

advertised product is not low in the risk-increasing nutrient will on net increase the

number of consumers who understand that the product is not low in this nutrient. 

B. Food Product and Advertisements Tested

The food chosen for the test ads was a fictitious brand of packaged sliced turkey ("Bradley

Right Slices"). The test focused on sodium as the risk-increasing nutrient of interest. The

absolute level of sodium in the product was chosen to be 240mg per serving, which is slightly less
 

26 This ad was not a true tombstone control, since it contained the same sodium comparison

and health claim that appeared in the remedy ads. Thus, the results from this cell cannot reveal

definitively whether any misimpressions concerning the sodium content of Right Slices arose from

the sodium information in the ad, or whether they were formed by prior beliefs. Although it

would have been preferable to test a true tombstone control that did not reference sodium in any

way, it was decided that resources would better be devoted to an additional remedy ad than to

testing the hypothesis that a large number of consumers believe that packaged poultry slices are

low in sodium. 

33

than half the sodium content of regular turkey slices (about 600mg) but 100mg higher than the

FDA upper limit of 140mg per serving for a low sodium claim. 

All versions of the tested ads began with the following comparative nutrient content claim: 

New Bradley Right Slices deliver the taste of oven roasted turkey with less than 1⁄2

the sodium of other leading brands!

This comparative nutrient content claim was followed by an explanation of the health significance

of the lowered sodium content:

And that’s important news. Because diets high in sodium can increase the risk of

high blood pressure and heart disease!

The control ad, which is shown in Figure 1, provided no other information concerning the specific

sodium content of Right Slices. Results from this cell were intended to provide a baseline for

determining the proportion of consumers who would interpret the comparative nutrient

information and the health claim to mean that Right Slices was in an absolute sense low in

sodium.26

The four remedy ads constructed to test Hypotheses IIa-IId are presented in Figures 2-5. 

The first remedy ("absolute disclosure") presented the sodium content of Right Slices (240 mg)

and the corresponding figure for "most leading brands." The average figure for "most leading

brands" was set at 600 mg, which is realistic for the most popular brands of packaged turkey

slices currently on the market. The comparative sodium content information was presented in a

large box immediately below the text discussion of the link between high-sodium diets and high

blood pressure.

The second remedy ("relative disclosure") expressed the sodium content of Right Slices

and the average for other leading brands both in milligrams and as percentage of the Maximum

Daily Value (10% and 25% respectively). The third remedy ("strong disclosure") was identical to

the relative disclosure, except that the following advisory was added in close proximity to the

numerical disclosures: "Right Slices is not a low sodium food." 
34

As is evident from Figures 2-5, the boxed remedy disclosures were even more prominent

than the sodium or saturated fat advisories in the halo effect segment. Thus, these ads provided a

best-case opportunity for quantitative nutrient content information to reveal its corrective

potential.

The last remedy cell ("verbal disclosure") replaced the boxed sodium content information

with a statement in the main body of the text that attempted in purely verbal terms to place the

nutrient benefit of Right Slices in proper perspective:

Although Right Slices is not a low sodium food, switching to Right Slices can help

you cut back on sodium.

C. Questionnaire Design

In general, the Substitution Claim questionnaire was identical to that used in the Halo

Effect segment. In Questions 7-10, however, the substitution claim instrument asked respondents

to compare the healthiness or sodium content of Right Slices both with foods in general, as had

been the case in the Halo Effect survey, and also more specifically with other leading brands of

turkey slices. The objective was to see whether respondents would rank Right Slices more

favorably in the limited comparison with high-sodium competitors than in the broad comparison

with all other food products. The full questionnaire for the substitution claim segment is

presented in Appendix C.

D. Copy Test Results 

1. Overview

The results from the Substitution Claim segment of our research indicate that, for the type

of food product tested, a substantial minority of consumers will interpret a comparative "less

than" claim for a problem nutrient to mean that the advertised product is absolutely low in that

nutrient. Consistent with the findings in Halo Effect research, metric disclosures that expressed

the level of the problem nutrient in milligrams and as a percentage of the Daily Value had little or

no impact on such misimpressions. In contrast to the Halo Effect outcome, however, disclosures

that characterized the level of sodium in simple verbal terms proved no more effective a remedy

than the metric disclosures. These disparate results may indicate that even stronger or more

prominent disclosures are necessary when the information being provided requires consumers to

reconcile positive and negative messages about the same nutrient. 

2. Results in Detail

a. Main Points of the Ad, First and Second Exposure

The first question was a completely open-ended inquiry into what respondents perceived

as the main points of the ad. It was asked twice, once after the initial showing with the two

clutter ads, and again after respondents reread the ad in isolation. 
35

Although it was anticipated (and confirmed) that respondents would report a sodium

content claim of some kind as the primary message, there were two major areas of interest

concerning the pattern of these responses. The first was the proportion of respondents in the

control cell that would express the sodium advantage of Right Slices in relative terms (e.g."lower"

or "less" sodium) rather than absolute ("low" sodium). The second important issue was the

impact of the various remedy disclosures on this split between relative and absolute

characterizations.

Figures 6 and 7 summarize, respectively, the results obtained from the initial exposure

(with clutter ads) and the second showing of the ad. The percentages reported are the combined

total of all response codings that reasonably could be considered a relative or an absolute sodium

content message, and are therefore subject to some interpretational judgment calls. Still, certain

patterns seem clear. 

First, irrespective of cell, the plurality of respondents took away an absolute low sodium

claim from their first cursory examination of the turkey ads. From 40% to almost 50% of 

respondents mentioned a low sodium claim of some kind; the corresponding range for lower or

less sodium interpretations was 24-35 percent. Second, the pattern across cells appears

somewhat perverse. The highest playback of low sodium claims generally occurred in the remedy

cells, while the second-lowest incidence of such claims occurred in the control cell. It should be

noted, however, that the control cell also posted the second-highest incidence of lower sodium

claims.

Third, these response patterns essentially reverse after respondents had a chance to read

the turkey ads a second time without the distraction of clutter ads. Figure 6 shows that the

plurality of respondents now express the main point of the ad in relative rather than absolute

terms. Further, with the exception of the strong disclosure cell, the proportion of relative

characterizations increases steadily from a low of 40.3% in the control cell to a high of 51% for

the verbal remedy. 

The pattern for absolute low sodium characterizations, however, appears completely

random after the second viewing. The proportion of respondents reporting such absolute

messages seesaws back and forth across cells, with the greatest disparity occurring between the

strong disclosure (40.7%) and the verbal disclosure (29%). 
36

45.2%

41.9% 40.3%

45.8%

49.1% 49.2%

30.1%

35.4%

23.8%

35.7%

30.5%

24.5%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Total Control Absolute

Disclosure

Relative

Disclosure

Strong

Disclosure

Verbal

Disclosure

VERSION

PERCENT low sodium

less, lower sodium

FIGURE 6

MAIN POINTS, FIRST EXPOSURE

TURKEY

 
37

33.7%

30.6%

37.7%

30.6%

40.7%

28.8%

47.9%

40.3%

45.7%

48.4%

44.4%

51.0%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Total Control Absolute

Disclosure

Relative

Disclosure

Strong

Disclosure

Verbal

Disclosure

VERSION

PERCENT

low sodium

less, lower sodium

Figure 7

MAIN POINTS. SECOND EXPOSURE

TURKEY
38

As a whole, the second exposure results suggest that the verbal disclosure was most

successful in communicating the true nutrient profile of the advertised turkey, since the greatest

number of consumers viewed the sodium advantage in relative terms and the smallest number

volunteered an absolute low sodium response. For no apparent reason, however, the worst

performing remedy based on these same criteria appears to be the strong disclosure, which

contained an explicit advisory that Right Slices was not low in sodium. About the only

generalization possible from the initial open-ended results is that none of the remedies prevented

at least a significant minority of respondents from reporting a low sodium message as a major

point of the ad. 

b. Purchase Interest

The first close-ended question in the survey explored the general appeal of the turkey

slices as presented in the various ads. The question asked respondents to use a five-point scale to

indicate how interested they would be in purchasing the advertised product. The pattern across

cells would be very difficult to predict even if we assumed that respondents saw and understood

the remedy disclosures. If respondents primarily were concerned about the health benefits of

reduced sodium intake and were seeking a truly low sodium product, purchase interest might

decrease in the remedy cells as it became increasingly clear that Right Slices did not meet this

criterion. Conversely, purchase interest might increase in the remedy cells if participants were

more concerned about the possibly bland taste of a low sodium food.

The actual results revealed essentially no patterns of any kind. As a group, the remedy

cells registered a slightly higher rating than the control, but the differences are quite small and

statistically insignificant. Within remedies, the strong and verbal disclosures scored lower than the

absolute or relative, but again the differences are too small to deserve serious attention. The

overall purchase interest rating of 3.04 was somewhat higher than that observed in the Halo

Effect segment for soup and cheese (2.87 and 2.69 respectively).

c. Contents of Advertised Food

Question 4 was what proved to be a failed attempt to focus the respondents on the

nutrient profile of the product in question. Its very general wording was as follows:

Q4. Did the ad say or imply anything about what is in the turkey slices?

The question perplexed about two-thirds of the respondents, who answered either "no" or

"don’t know." Of the minority giving an affirmative response, most referenced sodium in some

manner, and of these a larger fraction expressed sodium content in comparative rather than in

absolute terms. Mentions of "low sodium" ranged from 5%-10% of all respondents, while

relative characterizations ranged from 6 to 17 percent. No clear patterns emerged across cells,

and the response rate was, in any event, too low to justify detailed analysis.
39

 

d. Effect on Health

Question 5 asked respondents whether the ad stated or implied that the turkey slices

would have any effect on their health; a follow-up probe asked respondents to identify any such

effects. The results failed to provide any significant new insights and will not be discussed here. 

Two additional questions asked respondents to rate the general healthiness of Right Slices in

relation to other sliced turkey products and to foods in general. Again, the results were not of

sufficient interest to warrant presentation. 

e. Ad Believability

In all components of the food copy test, respondents were asked to rank the believability

of the tested ads on a 5-point scale. The purpose was to check for any extreme negative

reactions respondents may have had to some aspect of the test ads’ layout or wording. It was

also of interest to see whether the various disclosures and advisories in the remedy cells would

have any impact on credibility, although we had no strong conjectures as to the direction of any

such effect. 

This question generated fairly high believability ratings for the turkey ads. The mean score

was 3.38, which is between "somewhat believable" and "very believable."). This rating is equal

to or higher than the corresponding figures for the soup and cheese ads (3.21 and 3.36

respectively), and equal to the rating given the real vitamin supplement ad that was tested in the

Strength of Science component. There were no significant variations across cells.

f. Sodium Content

The next two questions in the survey focused specifically on respondent perceptions of the

sodium content of Right Slices. Respondents first rated the sodium content of Right Slices in

relation to other leading brands of turkey, and then were asked to broaden the comparative

context to foods in general. If respondents realized that foods in general tended to be lower in

sodium than the leading brands of turkey referenced in the ads, the sodium ratings for Right Slices

should rise when the basis for comparison is broadened.

Questions 9 read as follows:

Q9. Based on what the ad says or implies, compared to other leading brands

of packaged sliced turkey, is the advertised product:

 1 2 3 4 5

 Low Somewhat Neither Somewhat High

 in low in high nor high in in

 sodium sodium low in sodium sodium sodium

Question 10 replaced the reference to other turkey brands with a comparison to "other foods."

 
40

The format of these questions was less than ideal, in that the response categories were

absolute measurements, while the question was strictly comparative. It would have been more

consistent to have phrased the response choices in relative terms, such as "much lower in

sodium," "somewhat lower," etc. This would, however, have generated responses that could not

be compared directly with the absolute nutrient content descriptor "low sodium" that was of

primary interest. In any event, there were no signs in the pretests or in the verbatims that

consumers were confused by this nonparallel construction. The results for Questions 9 and 10 are

shown in Figures 8 and 9

As hypothesized, respondents as a whole rated Right Slices lower in sodium when the

frame of reference was other brands of turkey rather than foods in general. The mean response to

Question 9 was 1.48, vs. 1.65 for the broader Question 10 (p=.008). This pattern was uniform

across cells except for the verbal disclosure, where the scores for the two questions were

identical. 

In both Questions 9 and 10, respondents seeing the absolute disclosure remedy gave Right

Slices the lowest sodium rating (1.34 and 1.51 respectively). In Question 9, the scores generated

by the other three remedies were virtually identical to the control rating of 1.50. In Question 10,

only the relative disclosure produced a higher sodium rating than the control, and the difference is

clearly inconsequential and insignificant. Indeed, there are no significant differences between any

of the cells in either Question 9 or 10.

Among those respondents who replied "low" or "somewhat low," the most common

justification offered in the follow-up probe was "it says so" or "that’s what it said or implied." 

Interestingly, this explanation was most common for the strong disclosure ad, which included the

"not a low sodium food" advisory. Fully half of the relevant subgroup of strong disclosure

respondents offered this justification, although some of these explanations may have related to a

"somewhat low" response and therefore may not have been inconsistent with the advisory. 

The mean scores reported in Figures 8 and 9 do not permit a direct test of Hypothesis I or

Hypotheses IIa-IId, which all turn more narrowly on the proportion of respondents that rated

Right Slices explicitly as a low sodium food. Figure 10 breaks out from the Question 10 results

the percentage of respondents in the various cells that rated Right Slices as "low in sodium"

compared with other foods (which is the frame of reference embodied in the FDA nutrient

content descriptors).
41

5 = high

4 = somewhat high

3 = neither high nor low

2 = somewhat low

1 = low

1.48 1.50

1.34

1.50 1.51 1.57

0

1

2

3

4

5

Total Control Absolute

Disclosure

Relative

Disclosure

Strong

Disclosure

Verbal

Disclosure

VERSION

MEAN RESPONSE

FIGURE 8

SODIUM CONTENT COMPARED TO OTHER BRANDS

TURKEY
42

5 = high

4 = somewhat high

3 = neither high nor low

2 = somewhat low

1 = low

1.65 1.73

1.51

1.75 1.66 1.57

0

1

2

3

4

5

Total Control Absolute

Disclosure

Relative

Disclosure

Strong

Disclosure

Verbal

Disclosure

VERSION

MEAN 

RESPONSE

FIGURE 9

SODIUM CONTENT COMPARED TO OTHER FOODS

TURKEY

 
43

38.6%

40.3%

44.3%

35.5%

33.9%

39.0%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Total Control Absolute

Disclosure

Relative

Disclosure

Strong

Disclosure

Verbal

Disclosure

VERSION

MEAN RESPONSE

FIGURE 10

SODIUM CONTENT COMPARED TO OTHER FOODS

% RESPONDING LOW

TURKEY
44

Hypothesis I predicted that the control ad would convey a low sodium claim to a

substantial number of respondents. Figure 10 confirms this prediction. Approximately 40% of

the viewers of the control ad reported the claim. This represents the upper bound on the

proportion of respondents misled by the ad, since there was no tombstone control for prior

beliefs, and, in any event, we have no firm basis for concluding that these respondents thought

that Right Slices was low enough in sodium to meet a formal definition of "low sodium."

Hypotheses IIa-IId predicted that the proportion of low sodium responses would

continuously decline across the four remedy cells arrayed in Figure 10. The results reveal a more

complex pattern. There is clearly no support for Hypothesis IIa, which predicted that the absolute

disclosure would generate fewer low sodium responses than the control. The opposite occurred,

although the difference is not significant. 

The percentages for the relative and strong disclosures, on the other hand, are at least

below the 40% figure for the control and therefore not inconsistent with Hypotheses IIb and IIc. 

These differences do not even approach significance, however. Finally, there is no support for

Hypothesis IId, which predicted that a clear "not a low sodium food" advisory in the main text

would prove the most effective remedy. The verbal disclosure generated essentially the same

impressions among respondents as did the control ad. 

The poor performance of the verbal disclosure is perhaps the most surprising element in

these results. It is difficult to explain why virtually no readers of that ad saw (or at least attached

any significance to) the very prominent and explicit statement in the text that Right Slices was not

a low sodium food. A review of the explanations accompanying the follow-up probe to Question

10 reveals only one mention of the statement from respondents in the verbal disclosure cell. 

In general, the unimpressive showing of the remedy disclosures was unaffected by

educational or gender status, nutrition knowledge (as reflected in responses to the selfadministered quiz), or interest in nutrition issues (as measured by responses to the 10 selfadministered nutrition attitude questions.) A variety of probit regressions showed that the 

probability of a respondent rating Right Slices as low in sodium was not related in any of the cells

to the respondent’s quiz score or to the response for the most relevant single quiz question (which

asked respondents to choose the correct Maximum Daily Value for sodium). Similarly, this

probability showed no relationship to the combined score on the attitude questions or to the

question that asked specifically whether a respondent was concerned about the amount of sodium

in his or her diet. The only association that emerged from these regressions was a slightly higher

tendency for females in the control cell to rate Right Slices low in sodium.

g. Comparison With Low Sodium Product

The questionnaires for both the Halo Effect and Substitution Claim components

introduced at this point a comparative exercise intended to determine more definitively whether a

substantial proportion of respondents in any of the cells thought the advertised food met a formal

definition of "low sodium" or, for the sliced cheese product, "low saturated fat." In all cases,

respondents were asked how they thought the level of the risk-increasing nutrient in the

advertised product compared with that of a second fictitious product, a picture of which was
45

shown prior to questioning. The labeling for this product stated explicitly that the brand was

"low" in the problem nutrient. 

For the Substitution Claim component, the fictitious comparison product was

"Ridgefield’s Low Sodium Turkey Slices." It was hoped that respondents would interpret the

nutrient content claim in the title as a reference to an official descriptor for low, and then assess

whether they thought that Right Slices also qualified for this descriptor. Question 11 asked:

Q11. Please look at this picture I have just handed you. Compared to the brand in the 

picture you just looked at, would you say the advertised product we talked about first

has....(Respondents selected one of 5 response categories ranging from "much less

sodium" to "much more sodium.")

Since Right Slices exceeded the upper limit for a low sodium food by 100 mg, the most

correct answer would have been response category 4--"somewhat more sodium." Although we

had no reason to believe that respondents knew the specifics of FDA’s "low sodium" descriptor

requirements, it was nevertheless of interest to determine whether viewers of the strong and

verbal disclosures, which explicitly disclaimed a "low sodium" designation for Right Slices, would

rate the sodium content of the advertised product higher than the "Ridgefield’s" slices. 

Question 11 was worded to ensure as best we could that respondents would rate Right

Slices in relation to Ridgefield’s, and not vice versa. It was readily apparent from an inspection of

the verbatims to Question 11, however, that many respondents had compared the sodium content

of Ridgefield’s with that of Right Slices. This meant that, in many cases, a response of "much

less" or "somewhat less" should have been recorded as "much more" or "somewhat more." 

Despite our best efforts to identify the reversed comparisons from the verbatims and to adjust the

responses accordingly, we no doubt failed to rectify the problem fully. The adjusted results,

which are displayed in Figure 11, should therefore be interpreted with caution. 

 

Taken at face value, the results indicate that respondents regarded Right Slices as

exceedingly low in sodium. In most cells, including the verbal disclosure, the average score for

Right Slices was between "somewhat less" and "about the same" sodium as the "low sodium"

Ridgefield’s turkey slices. Only in the strong disclosure does the mean rating even equal that of

the low sodium reference product. Although we cannot be certain that respondents took the

desired descriptor connotation from the Ridgefield’s label, these results at the very least provide

no support for the theory that consumers understood that Right Slices was relatively, but not

absolutely, low in sodium. 

h. Demographic Analysis

The Substitution Claim survey closed with the customary questions about respondent

education and income level. The demographic profile of these respondents closely resembled that

of the Halo Effect participants. On average, respondents scored 3.03 on the 5-point 
46

5 = much more

4 = somewhat more

3 = about the same

2 = somewhat less

1 = much less

2.63

2.47 2.45

2.54

3.03

2.71

0

1

2

3

4

5

Total Control Absolute

Disclosure

Relative

Disclosure

Strong

Disclosure

Verbal

Disclosure

VERSION

MEAN RESPONSE

FIGURE 11

COMPARISON WITH LOW SODIUM PRODUCT

TURKEY
47

education scale (some college or technical school training), which is virtually identical to the

educational status of the Halo Effect participants. Across-cell differences were not significant.

The average income of the Substitution Claim respondents was about $29,000, which is

slightly below the soup ($30,000) and cheese ($33,000) respondents. Again, there were no

significant differences in income across cells.

E. Conclusion

The results from the Substitution Claim component provide fairly strong support for

Hypothesis I, which predicted that a substantial number of respondents would take a low sodium

claim from the control ad’s sodium comparison between Right Slices and other leading brands of

packaged turkey slices. About 30% of the control cell respondents volunteered a low sodium

interpretation of the ad in answering the first open-ended question (although a higher fraction

expressed the sodium claim in relative terms). This figure rose to 40% in the relevant close-ended

question. 

Although logistical difficulties compromised our efforts to explore the precise meaning

respondents attached to the phrase "low sodium," the results are consistent with the view that the

participants who described Right Slices in these terms really meant that the product was in an

absolute sense a low sodium food. All of these conclusions are subject to the caveat that the

Substitution Claim segment did not employ a true tombstone, and we therefore cannot determine

the extent to which the responses were shaped by prior beliefs rather than claims conveyed in the

test ad. 

Results from the remedy cells are consistent with some, but not all, of the findings of the

Halo Effect segment. One result seems quite robust. Most consumers did not know how to

interpret a disclosure of the absolute amount of a nutrient expressed in grams or milligrams. The

absolute disclosure consistently performed poorly, and even perversely, in both the Halo Effect

and Substitution Claim components. Although the relative disclosure at times appeared to

communicate more effectively than the absolute disclosure in the turkey ads, the differences were

insignificant either from a practical or statistical standpoint. Thus, both the Halo Effect and

Substitution Claim results point strongly to the conclusion that, in the context of advertising,

metric disclosures such as those found on food product labels are ineffective vehicles for

correcting misimpressions consumers may have concerning saturated fat or sodium content. 

In other respects, results from the remedy cells appear inconsistent with corresponding

findings in the Halo Effect segment. It will be recalled that by far the most effective sodium or

saturated fat disclosure for the soup and cheese ads was a verbal statement warning that the

advertised food was high in the problem nutrient (followed by an explanation of associated health

risks). In the substitution claim segment, however, the performance of the closest analogues to

these remedies--the strong and verbal disclosures--was statistically indistinguishable from that of

the absolute or relative disclosures. 

The principal difference between the verbal advisories in the two segments was that the

Halo Effect statements warned of the presence and significance of high levels of a bad nutrient,

whereas the substitution claim disclosures merely advised that the turkey slices were not low in
48

sodium. Further, the disclosures in the Substitution Claim segment were imbedded in ads that

otherwise promoted the healthiness of the product’s sodium profile. In the Halo Effect ads, the

warnings concerned nutrients that were not the subject of the positive health claims. Thus, one

possible explanation for the seemingly disparate results is that the prominent and highly positive

discussion of the lower sodium content of the turkey slices dominated perceptions and distracted

respondents from what may have seemed unimportant or contradictory messages. 
 

27 Trans fatty acids are found most commonly in commercial baked products and margarines

that contain "partially hydrogenated vegetable oil." This substance is formed by bubbling

hydrogen through vegetable oil, which adds enough hydrogen atoms to straighten the carbon

chains that form the fatty acids in the oil. The new configuration forms a solid crystal at room

temperature.

 

28 This literature included a long record of animal tests with positive results for antioxidant

vitamin supplementation, numerous epidemiologic studies showing an inverse relationship

between dietary intake of carotenoids and cancer risk, and matched case studies and serum level

studies supporting a protective effect of beta carotene intake for lung cancer and oral cavity

cancers. Epidemiologic evidence and serum level studies also pointed to the efficacy of Vitamin

(continued...)

49

V. Detailed Discussion of Strength of Science Component

A. Introduction

The Strength of Science segment tested consumer responses to a series of advertisements

containing qualified and unqualified health claims for two disease relationships that have not yet

met FDA’s "Significant Scientific Agreement" standard of proof, and therefore have not been

sanctioned for labeling. As explained earlier, the Statement allows advertisers to discuss

unapproved diet-disease relationships, provided that such ads are carefully qualified to convey the

actual level of scientific support for the relationship, and there is no larger body of scientific

evidence that contradicts the claim. 

The two nutrient-disease relationships for our research were (1) antioxidant vitamin

supplements and a reduction in the risk of cancer, and (2) trans fatty acids and an increase in the

risk of heart disease.27 Print ads for a fictitious vitamin supplement product ("ACE Vitamins")

provided the vehicle for testing health claims concerning the cancer reduction benefits of

antioxidants. The possible heart risks of trans fatty acids were presented in ads for an imaginary

new margarine ("Better Blend") that claimed to be free of trans fatty acids.

These nutrient subject areas were selected in part for their topicality, but more principally

because we believed the level of scientific support in the two areas had advanced to the point

where it might be possible to craft qualified health claims that could provide a meaningful test of

the guidance provided in the Statement. In both cases, the hypothesized relationships were

supported by a level of scientific evidence that could not be characterized as purely speculative or

even preliminary. At the same time, limitations in the types or sheer quantity of research

prevented firm conclusions on the efficacy of antioxidant vitamin supplementation or the

importance of the heart disease risks of trans fatty acids.

More specifically, at the time our research was conducted, an extensive scientific literature

had developed suggesting a positive relationship between dietary intake of certain antioxidant

vitamins (principally beta carotene and vitamins C and E) and a reduction in the risk of several

cancers.28 There were, however, no completed long-term, placebo-controlled clinical trials using
 

28(...continued)

C in reducing the risk of oral cancers and cancers of the esophagus and stomach. The results of

studies investigating Vitamin E were less consistent. For a review of the scientific literature on

antioxidant vitamins and cancer risk, see J. Dorgan and A. Schatzkin: Antioxidant Micronutrients

in Cancer Prevention, Hematology Clinics of N. America: 5: Feb., l991.

 

29 O.P. Heinoonen, J.K. Huttunen, et al.(N Engl J Med 1994;330:1029-35). The seemingly

anomalous results were viewed with some skepticism when the Finnish study first appeared. 

Recently, however, a clinical study of over 18,000 U.S. smokers and workers exposed to asbestos

was terminated before completion due to preliminary results that also found an increased

incidence of lung cancer among recipients of beta carotene supplements. (See Omen GS,

Goodman GE, et al. N Engl J Med 1996;334:114-9.) 

 

30 The most important clinical intervention trial was conducted by researchers at the

Department of Agriculture (Judd, et al., 1993.) This study found a rise in serum cholesterol when

trans fatty acids were consumed at levels typical of the American diet. Several contemporaneous

trials reported similar results (Wood, R. et al., 1993; Lichtenstein, et al., 1993; Mensink, et al.,

1992). A major epidemiologic study found that U.S. nurses who reported consuming about 6

grams of trans fatty acids per day had a 50% higher risk of coronary heart disease than nurses

who reported consuming about 2.5 grams per day (Willett, et al., 1993). 

50

vitamins C or E, and only one such clinical using beta carotene. That study, involving 29,000

male smokers in Finland, reported a higher incidence of lung cancer for smokers in the beta

carotene treatment group, and no reductions in the risk of any other forms of cancer.29 Thus,

absent additional clinical evidence, scientists could not reject the possibility that the cancer

reduction benefits reported in non-clinical studies were attributable to some other unidentified

element in foods that contained high levels of antioxidant vitamins. 

Although the literature on trans fatty acids and heart disease was more limited, it did

include several well conducted clinical studies indicating that diets high in trans fatty acids could

increase serum cholesterol levels, and thus the risk of heart disease. The principal scientific

controversy concerned the magnitude of this adverse serum cholesterol impact, rather than its

existence per se.30

As detailed below, the remedy test ads used in the Strength of Science component

contained qualifying language that attempted to describe in varying degree the extent and nature

of the scientific debate concerning the health effects of antioxidant vitamins and trans fatty acids. 

For comparative purposes, our research also employed an unqualified version of these ads that

claimed cancer or heart benefits had been proven for the advertised products.

B. Experimental Design

This section of the food copy test posed by far the most difficult analytical challenges and

required compromises in the precision of the tested hypotheses and the analytical rigor with which

they were developed. The most fundamental challenge was determining the level of certainty that

consumers should attach to a health claim about antioxidant vitamins or trans fatty acids. 
51

Reasonably intelligent but lay readers of the literature on antioxidant vitamins and cancer might

take away widely varying impressions of the current level of scientific certainty in this field. 

Although the perceived range of probabilities would be narrower for the existence of a positive

link between trans fatty acids intake and serum cholesterol levels, this range would widen

considerably if the issue were posed in terms of the practical importance of the relationship,

particularly in comparison with the proven link between saturated fat intake and cholesterol levels.

One approach to the problem would have been to ask leading researchers in these areas to

rate their own certainty of the relevant nutrient-disease relationship on a scale of 1-100. We

might then have asked respondents viewing our test ads to indicate on the same scale how certain

they thought scientists were about the relationship. This would have anchored the analysis in a

manner that would have allowed a meaningful test of the success with which a given

advertisement conveyed the proper level of scientific uncertainty. 

We did not pursue this polling of medical researchers due to resource constraints and a

concern that these individuals would be reluctant to engage in such a speculative exercise,

particularly for a government agency. We did, however, retain the basic construct of the exercise

in formulating the key close-ended interview question, which asked viewers of the various ads to

indicate on a five-level scale "how sure" they thought "scientists" were about the nutrient-disease

relationship at issue.

Since we lacked a concrete reference point for assessing the absolute accuracy of

respondents’ evaluations of qualified and unqualified health claims, our research attempted only to

test for differences in the level of certainty that respondents would attach to health claims with

varying degrees of qualification. Our basic objectives were to determine (1) whether consumers

would in fact distinguish between qualified and unqualified health claims, and, if so, (2) what

minimum level of qualification was needed to achieve a significant difference in the certainty

scores that respondents assigned to the two types of claims.

The range of possible qualification levels was constrained by a need to portray the existing

state of scientific evidence in a truthful manner, without exaggerating the extent of controversy or

impeaching the significance of valid research. For reasons of both public policy and law, the

Commission would never require advertisers to include disclaimers that were not truthful in their

own right. Further, to the maximum extent possible, we wished to test qualifications that did not

undermine the positive messages advertisers might validly convey. Our objective was to

determine whether the guidance in the Statement could be implemented in a manner that did not

constitute an effective ban on advertising claims concerning diet-disease levels that have not yet

achieved significant scientific agreement. 

An analysis of the relevant scientific literature suggested two levels of qualifications that

would be appropriate for both the antioxidant vitamin supplement and margarine ads, and a third

qualification level specifically appropriate for the vitamin supplement product. The first level

represented what we considered to be the least intrusive disclaimer that might reasonably alert

consumers to the lack of scientific certainty in the two areas of interest. The ads incorporating

this disclaimer maintained a positive overall tone, and should be regarded as a very lenient

implementation of the Statement’s guidance. 
 

31 The complement of ads lacked a true tombstone control that did not describe the vitamin or

nutrient composition of the advertised products in any manner. Although such a control was not

needed to measure the marginal impact of the various qualified and unqualified health claims, its

absence did prevent us from gauging the effect of the simple "no trans fatty acids" claim on

respondents’ perceptions concerning the general healthiness of Better Blend or, more specifically,

the total fat content of the product. 

52

For the vitamin product, the first level of qualifying language was limited to a simple

advisory that scientists would not be sure about the cancer benefits of antioxidant vitamin

supplements until "longer term research" was completed. The margarine disclosure stated that

scientists would not know "how big a problem" trans fatty acids were until further research was

conducted. 

The second qualification level provided additional detail concerning the extent and nature

of current scientific uncertainty and represents a strict, though reasonable, implementation of the

Statement’s call for advertisers to "carefully qualify" the level of scientific support for health

claims of this type. Specifically, the antioxidant vitamin qualification disclosed that some recent

studies had failed to find a cancer benefit for supplements. This was an oblique reference to the

Finnish study’s negative findings for beta carotene and to other research that has not always

reported cancer reduction benefits for one or more antioxidant vitamins. The corresponding

margarine ad disclosed that there was an ongoing scientific debate concerning the amount by

which trans fatty acids raise serum cholesterol. In addition, the second level of qualification

emphasized the incomplete status of research in both fields by cautioning readers that "It’s too

early to tell for sure." 

The third and strongest qualification, limited to antioxidant vitamin supplements, disclosed

the Finnish study’s finding that high doses of an antioxidant may actually have increased the risk

of cancer among smokers. Although this statement arguably went beyond mere qualification to

include disclosure of a negative material fact, and might also prove unpalatable to advertisers of

these vitamin products, we included the warning to determine whether disclosures of this severity

are needed to affect consumers’ perception of scientific certainty. 

Two other variants of the vitamin supplement and margarine ads completed the

experimental design for the Strength of Science component of our research. To control for prior

beliefs concerning antioxidant vitamin supplements or trans fatty acids, one group of respondents

was shown an ad that described the composition of the vitamin supplements or the margarine

without making an explicit health claim.31 Finally, another test cell was devoted to an

advertisement that presented the health benefits of the vitamin supplement or margarine as

established scientific fact. This unqualified "proof claim" served as the frame of reference for

gauging the impact of the various levels of qualifications in the remaining ads. 

As will be even clearer shortly, there were too many differences in the wording of most of

the ads to permit testing of narrowly drawn hypotheses. Had sufficient resources been available,

it would have been preferable to test a long series of ads, each one of which differed only in the
53

addition of or change in a single key phrase. With the exception of the most highly qualified

vitamin ad, which did test the impact of a specific negative disclosure, the ads that finally emerged

allow only a much rougher analysis of what (if any) degree of qualification is needed to convey

scientific uncertainty about a health claim that FDA has not approved for labeling. 

C. Complete Description of Test Ads

The vitamin supplement and margarine ads developed for the Strength of Science

component are displayed in Figures 1-10. The two control ads--Figures 1 and 7--are basically

nutrient content claims with additional references to convenience, taste, and/or cost. No

information is provided on the health significance of antioxidant vitamins or trans fatty acids. 

The test ads with health claims all adhere to the same format. The ads begin with the

banner and headline that appeared in the controls. Below this point, the text is presented in two

subsections.

The first of these, which is introduced with the headline "What We Know About

Antioxidants and Cancer" or "What We Know About Trans Fatty Acids and Heart Disease",

contains brief background information concerning antioxidant vitamins or trans fatty acids, and

closes with an explicit health claim. In the unqualified vitamin ad, for example, the health claim

states that "scientists have now proven" that antioxidant supplements reduce the risk of cancer. 

This ad, and the corresponding margarine ad, will be referenced hereafter as the "proof claim,"

and are shown in Figures 2 and 8. The corresponding health claims in the various qualified ads

state that medical studies "report" or "suggest" the relevant diet-disease relationship. 

The second subsection, which appears under the heading "What This Means To You,"

showcases the varying levels of qualifications concerning the certainty of the scientific evidence

for the health claim. The ads with the mildest disclaimers--hereafter referenced as the "qualified

claim"-- are shown in Figures 3 and 9. As discussed earlier, a deliberate attempt was made to cast

these ads in a positive light in order to determine whether a strong sales message could still

convey a significant degree of qualification. Accordingly, this section of the vitamin ad is

introduced withe the phrase "it looks promising," followed by the caution that longer term

research is still needed. The corresponding opening for the margarine qualification is "It looks

like you should try to avoid foods with trans fatty acids."

Figures 4 and 10 present the ads with the next level of qualification. These "highly

qualified claims" are much more emphatic about the degree of scientific uncertainty or

controversy and, at least for trans fatty acids and heart disease, are near the limit of what

reasonably could be expected of advertisers given the state of scientific knowledge at the time of

the test. 

The strictest qualifying language, specific to antioxidant vitamin supplements, is shown in

Figure 5. This "very highly qualified claim" adds the previously discussed reference to the 

Finnish study results that showed a positive relationship between beta carotene supplementation

and the risk of lung cancer among smokers. 
54

Finally, Figure 6 presents an actual print ad for "Nature Made Antioxidant Formula" that

functioned as a kind of reality check in our study. This ad allowed us to compare consumer

interpretations of and reactions to the fictitious and somewhat rough test ads with those obtained

using a professionally produced commercial advertisement that made similar kinds of claims for

antioxidant vitamins. 

At the time of the test, very few advertisers of vitamin supplements were making explicit

health claims. The few such ads that did exist all employed lengthy small-print texts that did not

promise to hold the dedicated attention of respondents intercepted in shopping malls. Of this

limited group, the Nature Made ad was considered the most appropriate for our purposes, since it

tracked the general message presented in our ACE vitamin ads (albeit in far more detailed

fashion). 

Fortuitously, the ad specifically references the opinions of "scientists," which provided a

convenient premise for our close-ended question that asked respondents to rate how sure

scientists were about the health benefits of antioxidant supplements. Like our ads, the Nature

Made ad also cites the benefits of foods rich in antioxidants, and cautions that "studies haven’t

proven that vitamin supplements offer the same protection as foods rich in antioxidants." The

principal difference between our qualified ads and the real Nature Made selection is the latter’s

explanation of the hypothesized role free radicals play in cell damage and the development of

heart disease and cancer, and the beneficial role antioxidants may play in helping to neutralize free

radicals. 

 

D. Questionnaire Design

The survey instrument employed in the Strength of Science segment was very similar to

the questionnaire in the other two components. The first portion of the interview gathered

information on general ad recall after the first and second exposure, purchase interest, perceived

healthiness of the advertised products, and ad believability. These inquiries led to the principal

close-ended question that asked respondents to rate how sure they thought scientists were about

the cancer reduction benefits of antioxidant vitamin supplements or the cholesterol-raising impact

of trans fatty acids. 

The vitamin supplement and margarine surveys both contained questions that tested

whether viewers of any of the ads took away an exaggerated impression of the overall healthiness

of the products. For vitamins, the issue was whether respondents would tend to view the

supplements as "magic pills" that could, at least in part, replace fruits and vegetables and greatly

reduce the risk of cancer. Respondents were asked to rate the healthiness of the advertised

vitamin supplement in comparison with fruits and vegetables, and were also asked to indicate the

amount by which they thought the supplements would reduce the risk of cancer. 

In the case of margarine, the concern was that respondents would interpret the "no trans

fatty acids" claim as an indication that Better Blend was also free of or low in total fat. Although

some soft "tub" margarines may in fact be low fat or even fat free, the pictured product was in

stick form and therefore should not necessarily have been construed as markedly different in total

fat content than other stick margarines. This issue was probed by asking respondents to rate the
55

healthiness of Better Blend in relation to other margarines and in relation to other foods in

general, and to indicate the level of fat contained in the advertised margarine.

E. Copy Test Results

1. Overview

The Strength of Science component of our research generated clear evidence that the

types of disclosures included in the Highly Qualified vitamin and margarine ads can alter

respondents’ perceptions of the level of support for a health claim that has not yet attained

significant scientific agreement. Respondents in these cells gave significantly lower ratings of

scientific certainty than did viewers of the unqualified health claims. Although mean certainty

ratings among respondents exposed to the milder disclaimers in the Qualified ads also were lower

than in the corresponding Proof cells, these differences did not achieve statistical significance. 

In absolute terms, the results revealed that relatively few consumers in any of the qualified

cells took away a clearly deceptive impression of the level of scientific agreement concerning the

relevant health claim. For example, only about 12% of the vitamin respondents exposed to the

qualified claim (which was still fairly positive in tone) interpreted the ad to mean that scientists

were highly certain about the ability of antioxidant vitamin supplements to lower the risk of

cancer. 

Our research did not find that the vitamin or the margarine ads had a significant impact on

actual consumer beliefs concerning the health benefits of antioxidant vitamin supplements or

products that are free of trans fatty acids. Nor could we find any evidence that demographic

factors or nutrition knowledge affected respondents’ reactions to the test ads. 

2. Results in Detail

Due to the close correspondence between the vitamin and margarine questionnaires,

results for the two sets of ads will be presented simultaneously for each question. 

a. Main Points of the Ad, First Exposure

All respondents in the Food Copy Test were given two opportunities to report what they

considered to be the main points of the test ads--once after an initial exposure with two clutter

ads, and a second time after respondents read the ad again in isolation. For the Strength of

Science ads, the key issues at this early point in the test were the proportion of respondents that

would recall a health claim, and, more important, the number of respondents within this group

that would describe the claim in qualified terms rather than as an established fact. For the

margarine ads, an additional issue was whether readers would correctly recall the specific term

"trans fatty acids," or whether they would misconstrue the ads as referencing fat in general.

Responses to the first exposure should be approached with lowered expectations, since

most of the test ads contained fairly complex messages and respondents were unlikely to focus

intently on all three of the ads they were initially shown. Nevertheless, a considerable majority of
 

32 Since the major codings of the verbatim responses for all of the open-ended and follow-up

questions in the Food Copy Test were performed by the project contractor, it was not possible to

determine the authorship of the verbatims in any of the coding categories, and therefore not

possible to tell whether the same respondent had played back multiple messages that appeared in

separate categories. 

56

the vitamin respondents appear to have volunteered some form of health claim as a major ad

message of all but the control ad. The precise percentages cannot be easily determined, since

individual respondents may very well have identified more than one health message.32 At the

upper limit, however, from 85% (Proof claim) to 98% (Extremely Qualified claim) of the vitamin

respondents mentioned a health claim, and of these most tied the health benefit specifically to

cancer. Half of the viewers of the real Nature Made ad reported a health claim, but only one-fifth

of these referenced cancer in any way. There is, in fact, only one explicit mention of cancer in

that ad, and it occupies a very small fraction of the lengthy text. 

 

 Health claims were reported less frequently by initial readers of the margarine ads. With

the exception of the control ad, which generated only very general references to health from about

13% of respondents, from 40% to 50% of the margarine respondents cited health in some

manner; about half of the mentions were specific references to the adverse impact of trans fatty

acids on cholesterol. 

Most of the margarine respondents (from 53% to 70%) merely cited the absence of trans

fatty acids or some other fat as the main point of the margarine ads. Slightly more than half of

these respondents identified trans fatty acids correctly by name. The remaining mentions were

evenly split between "fat" and "fatty acids." About 12 percent of respondents stated explicitly

that Better Blend was low in fat or contained no fat. 

Figures 11 and 12 provide a preliminary indication of the impact of the various levels of

qualifying language on respondents’ perception of the level of proof supporting the vitamin and

margarine health claims. To generate these bar charts, coding categories relating to all but the

most general health claims were classified as either unqualified or qualified. A response category

was classified as unqualified if it pertained to definite statements such as trans fatty acids "raise"

cholesterol, "cause" heart disease, or, more generally, "are unhealthy." A response category was

considered qualified if it related to indefinite statements, such as antioxidant vitamins "may" or

"might" fight cancer, or to explicitly negative characterization of the evidence, such as "studies

are contradictory," or "nothing is proven yet." 
57

6.8%5.1%

32.3%

28.9%

36.7%

31.8%

0%

34.0% 35.7%

26.7% 25.2%

0%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Control Proof Qualified Highly

Qualified

Very

Highly

Qualified

Real

Nature

VERSION Made

PERCENT

unqualified health message

qualified health message

FIGURE 11

MAIN POINTS, FIRST EXPOSURE

VITAMINS
58

8.5% 6.7%

22.4%

0%

13.3%

6.7%

0% 1.7%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Control Proof Qualified Highly Qualified

VERSION

PERCENT

unqualified health message

qualified health message

FIGURE 12

MAIN POINTS, FIRST EXPOSURE

MARGARINE
59

The base for the percentage calculations is the entire cell (approximately 60 respondents). 

Thus, the percentages vary across cells both because of differences in the distribution of qualified

vs. unqualified claims, and because of differences in the proportion of respondents that

volunteered a health claim as a main ad message. Note that the percentages for the Nature Made

Vitamins cell and the control ads are dramatically lower than any of the other cells, since so few

readers of these ads mentioned a specific health claim after the initial exposure. 

The only pattern in Figure 11 (vitamins) that is consistent with the expected impact of the

qualifiers is a general rise in the percentage of qualified claims as the level of qualification in the

ads increases. There is, however, no corresponding fall in the percentage of unqualified claims. 

Figure 12 (margarine) is more consistent with expectations. Although the absolute

number of reported health claims is lower than in vitamins, there is a large and steady decline in

the incidence of unqualified claims as we move from the proof claim to the qualified and highly

qualified claims. Interestingly, no respondents reported a qualified health message in the proof

claim cell; these claims become slightly more evident in the two qualified cells.

b. Main Points of the Ad, Second Exposure

 Not surprisingly, health claim messages figure even more prominently in the verbatims

that followed the second reading of the vitamin and margarine ads. With no adjustment for

double counting due to multiple responses, the percentage of respondents reporting a health claim

for the ACE vitamin test ads varied from 90% to 100%. (This percentage was 18% in the ACE

control cell.) Specific references to cancer ranged from 65% in the qualified cell to 77% in the

proof cell. Seventy-five percent of respondents viewing the real Nature Made ad a second time

cited a health claim as a main message, although once again the claims were very general and

almost never cited cancer specifically. 

Unlike the initial verbatims, more margarine respondents reported a health claim after the

second reading than offered a simple ingredients claim, such as "no trans fatty acids." Health

claims ranged from 72% - 80% in the three test cells. (The control cell figure was 15 percent.) 

Within the category of ingredients claims, the plurality of respondents--41%--referenced the

complete phrase "trans fatty acids," rather than "fatty acids"(24%), or "fat" (only 8%).

Figures 13 and 14 illustrate cell-to-cell variations in the incidence of qualified vs.

unqualified expressions of the health benefits of the vitamin and margarine products after a second

exposure. Two elements stand out in the vitamin results. First, as would be predicted, Figure 13

shows that the highest proportion of unqualified claims--about 37%--occurs in the Proof cell. 

Although the occurrence of these claims does not fall steadily thereafter as the level of

qualification increases, the lowest proportion of unqualified claims does occur in the most

qualified cell (17%). 

Second, again as predicted, the incidence of qualified claims for vitamins is, by a

considerable margin, highest in the very highly qualified cell. Almost half of the viewers of this ad

tempered their remarks with some form of qualification. An examination of the codings for this

group shows that most of the increase in qualified statements occurs in the sub category 
60

1.7%

5.1%

17.0%

27.2%

20.0%

36.7%

0%

49.3%

28.4% 26.8% 27.2%

0%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Control Proof Qualified Highly

Qualified

Very

Highly

Qualified

Real

Nature

Made

VERSION

PERCENT

unqualified health message

qualified health message

FIGURE 13

MAIN POINTS, SECOND EXPOSURE

VITAMINS
61

58.5%

48.4%

68.5%

11.8%

30.0%

20.0%

3.4% 1.7%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Control Proof Qualified Highly Qualified

VERSION

PERCENT

unqualified health message

qualified health message

FIGURE 14

MAIN POINTS, SECOND EXPOSURE

MARGARINE
62

"studies are contradictory." This is probably a reference to the perverse result for Finnish

smokers that was mentioned only in the very highly qualified ad. There is no clear pattern in the

percentage of qualified claims across the proof, qualified, and highly qualified cells.

The pattern of qualified and unqualified statements is quite similar in the margarine

verbatims (Figure 14). Again, the highest playback of unqualified claims occurs in the Proof cell. 

Anomalously, however, more viewers of the highly qualified ad gave unqualified responses than

did respondents in the qualified cell. The pattern of qualified claims conforms completely to

expectations. Almost no one in the Proof cell qualified their response. The incidence of qualified

claims then increases to 20% in the qualified cell and to 30% in the highly qualified cell.

c. Purchase Interest

This close-ended question, which appeared in all of the Food Copy Test questionnaires,

provides a convenient summary measure of the overall impression, either positive or negative, that 

respondents received from the various ads. The question asked respondents to rate their degree

of interest in purchasing the advertised product on a 5-point scale. Presumably, the strongly

worded proof claim that promised established health benefits for ACE Vitamins and Better Blend

Margarine would increase purchase interest when compared with the ratings generated by the

control ads, which contained no health claims. Mean purchase interest should then decline across

the remaining cells as the claimed benefits appear less and less certain. 

Figures 15 and 16 reveal that this pattern did in fact materialize, although most of the

differences between cells are not statistically significant. For vitamins, only the difference

between the proof rating of 2.92 and the very highly qualified score of 2.38 comes close to

significance (p=.16). The results are stronger for the margarine ads, where the difference between

the proof and highly qualified scores is significant at the .02 level, and the corresponding

difference between the control and highly qualified scores verges on significance (p=.11).

One interesting outcome, common to both sets of ads, is the slight decline in purchase

interest between the control and qualified cells. This suggests that consumers may be at best

indifferent between products presented in an ad that provides no specific health information and

one that is more informative but raises even an element of doubt about the underlying evidence. 

Considering that both the vitamin and margarine qualified ads were intended to strike a positive

tone, this result raises questions about the incentives advertisers have to provide qualified health

claims. 
63

 5: extremely interested 

 4: very interested 

 3: somewhat interested 

 2: not very interested 

 1: not at all interested 

2.72 2.75

2.92

2.73 2.67

2.38

2.84

0

1

2

3

4

5

Total Control Proof Qualified Highly

Qualified

Very Highly

Qualified

Real Nature

Made

VERSION

MEAN RESPONSE

FIGURE 15

PURCHASE INTEREST

VITAMINS
64

 5: extremely interested 

 4: very interested 

 3: somewhat interested 

 2: not very interested 

 1: not at all interested 

2.87

3.00

3.13

2.79

2.57

0

1

2

3

4

5

Total Control Proof Qualified Highly

Qualified VERSION

 MEAN RESPONSE

FIGURE 16

PURCHASE INTEREST

MARGARINE
65

In terms of the absolute level of purchase interest displayed by respondents in general, it is

clear from Figure 15 that viewers of the vitamin ads were less than enthusiastic about ACE. The

overall mean rating of 2.69 tied with Matterhorn Swiss Cheese Slices for the lowest rating

accorded any of the products in the Copy test. This does not appear to be due to any glitch in the

name or presentation of ACE Vitamins, since the real Nature Made ad generated a rating of only

2.84 (half way between the Proof and Qualified ratings for ACE). One explanation for the

lackluster showing, cited in 13 percent of the verbatims, is that respondents were already satisfied

with the antioxidant vitamins they were taking. 

Respondents were more interested in sampling Better Blend Margarine. Its overall

purchase interest score of 2.87 equaled the rating for Rich and Hearty Soup, although it was still

lower than the 3.04 registered for Right Slices Turkey. 

d. Effect on Health

The fourth question, which asked respondents whether the advertisement stated or implied

that the vitamins or margarine would have any effect on health, was intended to focus attention on

the health claims and qualifications in the test ads. The primary item of interest was the response

to the follow-up probe, which asked respondents to explain what effect the product would have

on health. The verbatims supporting the affirmative responses revealed a pattern of qualified and

unqualified characterizations very similar to that portrayed previously in Figures 13 and 14, and

will not be discussed further here.

e. Ad Believability

Respondents in all of the Food Copy test segments were asked to rate the believability of

the test ads on a 5-point scale that ran from "not at all believable" to "extremely believable." This

question served two very specific purposes in the Strength of Science segment. As indicated, one

of the vitamin test ads was a real ad for an actual vitamin supplement. The results of the

believability question therefore allowed us to determine whether respondents would consider a

professionally produced ad for a possibly familiar product significantly more credible than the

cruder computer mock-ups and fictitious products used in the remainder of the study. This

question also allowed a test of the hypothesis that consumers would find qualified claims more

credible than an absolute proof claim. 

The results are presented in Figures 17 and 18. There is a rather remarkable lack of

variation across cells within either the margarine or vitamin groupings. This uniformity is

sufficient to reject the hypothesis that qualification per se will lend credibility to an ad. In

addition, the similarity between the believability scores of the fictitious vitamin ads and the real

Nature Made ad indicates (reassuringly) that respondents saw nothing particularly problematic in

the format or content of the our computer mock-ups.

For reasons that are not readily apparent, respondents as a group found the vitamin ads

more believable than the margarine ads. The mean vitamin score of 3.35 essentially replicated the

ratings recorded for the Matterhorn Swiss Cheese and Right Slices Turkey ads, and exceeded the

3.21 score for Rich and Hearty Soup. The overall score of 3.09 for Better Blend Margarine 
66

 5: extremely believable 

 4: very believable 

 3: somewhat believable 

 2: not very believable 

 1: not at all believable 

3.35 3.32

3.52

3.27 3.28 3.30

3.40

0

1

2

3

4

5

Total Control Proof Qualified Highly

Qualified

Very

Highly

Qualified

Real

Nature

Made

VERSION

MEAN RESPONSE

FIGURE 17

AD BELIEVABILITY

VITAMINS
67

 5: extremely believable

 4: very believable 

 3: somewhat believable 

 2: not very believable 

 1: not at all believable 

3.09 3.12 3.05

3.16

3.04

0

1

2

3

4

5

Total Control Proof Qualified Highly

Qualified

VERSION

 MEAN RESPONSE

FIGURE 18

AD BELIEVABILITY

MARGARINE
68

was the lowest in the food Copy test. The verbatims explaining respondents’ responses do not

point to any particular deficiency in the presentation of the Better Blend ads.

f. Healthiness of Advertised Products

The next section of the vitamin and margarine questionnaires contained a series of

questions that asked respondents to rate the healthiness of the advertised products in a variety of

comparative contexts. The vitamin respondents first rated the absolute healthiness of ACE on a

5-point scale with no frame of reference specified. This question was intended to reveal whatever

impact the varying levels of qualification had on respondents’ perceptions of the overall

healthiness of ACE.

Respondents were then asked to evaluate the healthiness of ACE in relation to fruits and

vegetables using a 5-point comparative scale (ranging from "much less healthy" to "much more

healthy"). As discussed earlier, this question was an attempt to determine whether the ads were

leading respondents to regard ACE as a "magic pill" that could allow a substantial reduction in the

dietary intake of fruits and vegetables.

The corresponding margarine sequence began by asking viewers of the Better Blend ads

to rate the product’s healthiness in relation to other brands of margarine, which was the frame of

reference presented in the ads. This question explored the impact of the differing levels of

qualification on respondents’ appraisal of the healthiness of Better Blend as a margarine product. 

Respondents were next asked to rate the healthiness of Better Blend in relation to other foods. If

viewers of the ads thought that Better Blend contained appreciable levels of total fat, the ratings

obtained from the previous question should now be displaced downward to reflect the broader

comparative framework. 

 

The first set of healthiness questions produced a very similar patter of responses for

vitamins and margarine. When respondents were asked to rate the overall healthiness of ACE or

the healthiness of Better Blend in relation to other margarines, the healthiness ratings were

highest in the proof cell, and then declined slightly (and insignificantly) in the qualified and again

in the highly qualified cells. The principal distinction was the additional and more precipitous

decline that occurred in the very highly qualified vitamin cell. The difference between the

healthiness rating for that ad (3.06) and the rating in the proof cell (3.69) is highly significant

(p=.003). The results for the vitamin ads are illustrated in Figure 19.

The next question in the vitamin sequence did not find strong support for the theory that

respondents would regard ACE as a magic pill. When asked to compare the healthiness of the

vitamin supplement and fruits and vegetables, respondents on average placed ACE midway

between "less healthy" and "about as healthy." 

Results from the second healthiness question in the margarine sequence showed that

Better Blend was not considered as healthy in relation to foods in general as it was in relation to

other brands of margarine. The mean rating fell from 3.64 to 3.21. This score still places Blend

as above average in healthiness, which might indicate that respondents did not think that the

product was very high in total fat. This conjecture was confirmed in a later question that asked 
69

 5: extremely healthy 

 4: very healthy 

 3: somewhat healthy 

 2: not very healthy 

 1: not at all healthy 

3.46 3.48

3.69

3.44 3.40

3.06

3.65

0

1

2

3

4

5

Total Control Proof Qualified Highly

Qualified

Very

Highly

Qualified

Real

Nature

Made

VERSION

MEAN RESPONSE

FIGURE 19

HEALTHINESS OF ADVERTISED VITAMINS
70

respondents to rate the fat content of Better Blend on a 5-point scale, ranging from "fat free" to

"high." The mean response to that question was 2.56, which is half way between "somewhat

low" and "neither high nor low." Although it is plausible, and even likely, that the "no trans fatty

acids" claim influenced this outcome, the absence of a true tombstone control that contained no

ingredient claims prevents a definitive conclusion on this point.

g. Certainty of the Science

Following the queries concerning the perceived healthiness of the advertised products,

Question 8 in the vitamin and margarine questionnaires focused on the primary issue in the

Strength of Science segment. The specific wording of this question was as follows: 

Q8(Vitamins): Based on what the ad says or implies, how sure are scientists that

taking antioxidant vitamin supplements will reduce the risk of certain kinds of

cancer?

Q8(Margarine): Based on what the ad says or implies, how sure are scientists

about whether eating foods that contain trans fatty acids will increase the risk of

heart disease?

The 5-point response scale ranged from "very unsure" to "very sure."

The results of the two key questions are displayed in Figures 20 and 21. The pattern of

responses among the vitamin and margarine respondents is virtually identical across the 4

common cells. For both products, the certainty ratings are highest in the Proof cell, and then fall

continuously in the Qualified and Highly Qualified cells. For vitamins, the differences between the

ratings in the Highly Qualified and Proof cells and the Very Highly Qualified and Proof cells are

highly significant (p=.002 and .006, respectively). There are, however, no other significant

differences between any of the four scores. 

In the case of margarine, the difference between the ratings in the Proof and Highly

Qualified cells is also highly significant (p=.003). The corresponding difference between the

Proof and Qualified cells just misses significance at the 10% level (p=.13). There are no other

significant differences between any of the margarine cells. 

A comparison of the mean ratings for the two control ads, which did not contain explicit

health claims, suggests that the margarine respondents were more confident about the relationship

between trans fatty acids and heart disease (mean = 3.67) than the vitamin respondents were

about the power of antioxidant vitamin supplements to reduce cancer risks (mean = 3.17.) Only

about half of the respondents in these cells gave certainty ratings, however, and the difference is

not statistically significant. Still, the ratings for all of the margarine cells are consistently higher

than the corresponding vitamin ratings, which suggests that respondents found the claimed health

benefits for Better Blend somewhat more plausible than the claimed 
71

 5: very sure 

 4: somewhat sure 

 3: neither sure nor unsure

 2: somewhat unsure 

 1: very unsure 

3.32

3.17

3.85

3.39

2.88 2.96

3.64

0

1

2

3

4

5

Total Control Proof Qualified Highly

Qualified

Very Highly

Qualified

Real Nature

Made

VERSION

MEAN RESPONSE

FIGURE 20

HOW SURE ARE SCIENTISTS?

VITAMINS
72

 5: very sure 

 4: somewhat sure 

 3: neither sure nor unsure

 2: somewhat unsure 

 1: very unsure 

3.50

3.67

3.94

3.41

3.11

0

1

2

3

4

5

Total Control Proof Qualified Highly

Qualified

VERSION

 MEAN RESPONSE

FIGURE 21

HOW SURE ARE SCIENTISTS?

MARGARINE
73

cancer benefits for ACE. This was an unanticipated result, given the considerable attention that

antioxidant vitamins have received in the popular press

Another interesting result is the relative reluctance of respondents in either of the proof

cells to assign very high levels of certainty to the science supporting the antioxidant-cancer or

trans fatty acids-heart disease relationships. In both cases, the mean rating is slightly below

"somewhat sure," which suggests that many respondents either did not believe the strongly

worded establishment claims, or perhaps were merely exhibiting an aversion to choosing the most

extreme options in the provided ratings menu. Only 27% of the vitamin respondents and 31% of

the margarine participants chose the "very sure" rating. 

The verbatims for the respondents in the vitamin Proof cell suggest that general skepticism

about advertising claims explains at least part of the observed outcome. About 20% of the

vitamin participants complained that the ad offered no proof or stated that they do not believe

everything they read in ads. Practically none of the margarine respondents, on the other hand,

volunteered negative comments of this type.

With respect to the verbatims supporting the ratings in the Qualified and Highly Qualified

vitamin and margarine cells, the most frequently volunteered remark was some form of reference

to the need for more research. Thirty percent of the respondents in the Qualified vitamin and

margarine cells and Highly Qualified vitamin cell offered such an explanation for their rating. This

figure rose to 39% in the highly qualified vitamin cell.

Figure 20 reveals interesting outcomes for the two vitamin cells that were not included in

the margarine sequence--the Very Highly Qualified ad and the real ad for Nature Made Vitamins. 

Although the Very Highly Qualified ad had scored lowest of all the vitamin ads in the purchase

interest and overall healthiness ratings, it registered an (insignificantly) higher scientific certainty

score than the Highly Qualified ad. This suggests that respondents did not interpret the advisory

concerning the Finnish smokers’ higher cancer rates as a caveat about the state of scientific

agreement, but rather as a warning about a specific subgroup that might wish to avoid antioxidant

vitamins. 

Finally, the relatively high certainty rating accorded the real Nature Made ad suggests that

the qualifiers in this ad were overwhelmed by the extensive discussion of free radicals and the

mechanism by which antioxidants are thought to help fight cancer. The score of 3.64 is

significantly higher than the 2.88 rating for the Highly Qualified ACE ad (p=.05) and half way

between the scores for the Proof and Qualified ACE cells. 

The results in Figures 20 and 21 do not lend themselves to definitive conclusions. If the

object of our experiment is viewed strictly as determining what degree of qualification is needed

to lower consumers’ perception of scientific certainty below the level generated by an

establishment claim, our results from the vitamin ads indicate that the degree of qualification

would have to be quite high. The margarine results suggest that somewhat less strict qualification

might be needed in the area of trans fatty acids health claims, although the lower certainty score in

the Qualified cell did not quite achieve statistical significance. 
74

If, on the other hand, the goal of our research is viewed as determining what degree of

qualification is needed to avoid consumer deception, the results point to much less strict remedies. 

In the Qualified vitamin cell, only about 12 percent of respondents stated that scientists were very

sure that taking antioxidant vitamins would reduce the risk of cancer. Only one respondent in the

Highly Qualified cell gave this response. The mean score in the Qualified cell is only about onethird of the way between "neither sure nor unsure" and "somewhat sure," a rating that does not

appear to have seriously overstated the actual level of confidence of scientists in this health area at

the time the interviews were conducted. 

The potential for consumer deception is even less evident in the margarine results. 

Although the ratings are as a group higher than in vitamins, the actual level of agreement among

researchers in the field of trans fatty acids is at least correspondingly higher. Although, as

discussed, these scientists may not agree on the magnitude of the problem, there is relatively little

doubt that dietary intake of trans fatty acids can increase serum cholesterol significantly. Thus,

the mean rating of 3.41 in the Qualified cell does not appear problematic. The upper limit on the

incidence of deception in this group would appear to be the 18% of respondents who rated

scientists as "very sure." 

h. Impact on Beliefs

Although all of the interview questions in the Food Copy test were phrased to measure

what respondents thought was said or implied in the ads ("ad conveyance"), a self-administered

questionnaire given to all of the respondents following the interview allowed a unique opportunity

to determine whether the health claims in the Strength of Science component had altered

respondents’ beliefs about the diet-disease relationships at issue. Specifically, all respondents

were asked to indicate on a 7-point scale how strongly they agreed with the statements, "I believe

that taking antioxidant vitamin supplements will reduce the risk of cancer," and "I believe that

eating foods that contain trans fatty acids increases the risk of heart disease." If any of the ads in

the vitamin or margarine sequence changed respondents’ opinions about these health

relationships, the average belief ratings of the respondents in these cells should diverge from the

average ratings of all of the remaining respondents who were not exposed to a health claim

concerning antioxidant vitamins or trans fatty acids. 

Figure 22 displays for each of the vitamin cells the average agreement rating for the

statement concerning antioxidant vitamins and a reduced cancer risk. Also presented is the

average agreement rate for all of the remaining non-vitamin respondents in the Copy test. The

results show that the vitamin respondents as a group indicated slightly higher agreement with the

antioxidants-cancer statement than did respondents not seeing these ads (4.72 vs. 4.60,

respectively). The highest degree of agreement was, as would be expected, recorded by the proof

cell participants. Even this rating, however, indicates that respondents only "somewhat agreed"

with the statement. The ratings then fall in the various qualified cells, though not continuously. 

Interestingly, none of these ratings falls below the rating of 4.6 recorded by the remaining

participants in the Food Copy test. 
75

The mean score of 4.47 for the real Nature Made score is puzzling. Although the explicit

reference to cancer is not very prominent, it is not evident why viewers of this ad would be less

likely to believe in the cancer benefits of antioxidant vitamins than respondents who saw no claims

of any kind about these substances.

The margarine results are, at best, anomalous. As shown in Figure 23, none of the

agreement ratings, with the exception of the highly qualified cell, conforms to reasonable prior

expectations. Most curiously, the proof claim rating of 5.17 is lower than the mean rating of 5.55

recorded by all other Copy test respondents. 

The subsequent rise in agreement among respondents in the Qualified cell is also a bit

curious, particularly since this first level of qualification barely missed statistical significance in

reducing the scientific certainty ratings from those of the Proof ad. Finally, the fall in agreement

in the Highly Qualified cell is of the expected direction, but its magnitude seems large given the

more modest cell-to-cell variations in the other vitamin and margarine scores. 

i. Demographic Analysis

There was relatively little variation across cells in the mean education and income levels of

either the vitamin or margarine respondents. On an overall basis, the mean education levels of the

vitamin and margarine participants were all but identical (slightly above some college or technical

school training), as were the corresponding income levels (about $30,000.)

In addition to the demographic data on education and income, all of the data sets for the

Food Copy test also contain information concerning respondents’ knowledge and interest in

nutrition issues as measured by the self-administered nutrition quiz and attitudes questionnaire

that respondents completed following the main interview. The demographic and questionnaire

information allowed a test of whether the answers to the key interview question concerning the

relative certainty of scientists (Question 8) were related to respondent demographics or nutrition

knowledge and interest. 

Specifically, a series of ordered logit regressions were run using--both individually and

collectively--sex, income, education, and scores on the nutrition quiz and attitudes survey to

predict the level of certainty that respondents chose in response to Question 8. In theory, we

would expect that more educated, knowledgeable, and interested consumers would be more likely

to recognize and understand the various qualifications in the remedy ads. We should therefore

observe a negative correlation between the certainty ratings and education, knowledge, and

perhaps income and nutrition interest, in the various qualified cells. The results showed no

significant relationships of any kind, other than one negative correlation between education and

the certainty ratings for the qualified margarine ad. 
76

4.72 4.77

5.02

4.67 4.76 4.66 4.47 4.60

0

1

2

3

4

5

6

7

Total Control Proof Qualified Highly

Qualified

Very

Highly

Qualified

Real

Nature

Made

All Other

Cells

VERSION

MEAN RESPONSE

7: strongly agree

6: agree

5: somewhat agree

4: neither agree nor disagree

3: somewhat disagree

2: disagree

1: strongly disagree

FIGURE 22

ANTIOXIDANT VITAMINS REDUCE CANCER RISK

AGREEMENT RATES

FIGURE 23

TRANS FATTY ACIDS INCREASE HEART 

 DISEASE RISK

AGREEMENT RATES
77

4.97 5.00

5.17 5.23

4.48

5.55

0

1

2

3

4

5

6

7

Total Control Proof Qualified Highly

Qualified

All Other

Cells VERSION

MEAN RESPONSE

7: strongly agree

6: agree

5: somewhat agree

4: neither agree nor disagree

3: somewhat disagree

2: disagree

1: strongly disagree

F. Conclusion

The results of the Strength of Science component demonstrate that advertising disclosures

can have a significant impact on consumer perceptions of the degree of certainty underlying health

claims that have not yet attained a high level of scientific agreement. If we use as a baseline the
78

mean certainty rating that consumers accord a "proof" or "establishment" claim for a nutrientdisease relationship, our results reveal that these ratings will be reduced significantly by explicit

qualifications concerning inconsistencies in study results and the existence of ongoing scientific

debate.

The performance of the tested qualifications appears even stronger when viewed within a

more traditional deception framework that focuses on the proportion of consumers that receives a

deceptive message concerning the degree of scientific agreement for an advertised health claim. 

In the case of antioxidant vitamin supplements and cancer, only about 12% of respondents

viewing ads with the mildest level of qualification rated scientists as "very sure" about the

relationship (compared with about 27% in the proof cell). This percentage fell to only 2% in the

highly qualified cell. For the trans fatty acids-heart disease relationship (about which scientists are

fairly confident), the percentage of respondents reporting a "very sure" rating fell from 31% in the

proof cell to 18% in the qualified cell, and then to 10% in the highly qualified cell. 

Although our research confirmed the feasibility of qualifying health claims to conform with

the guidance provided in the Commission’s Policy Statement on Food Advertising, we did not

find strong indications that such qualifying language, even in its mildest form, would have

significant sales appeal. Viewers of the control ads, which contained no explicit health claims,

registered a purchase interest that was at least as high as that recorded in any of the qualified cells.

Finally, the impact of the qualifying disclosures did not appear to depend upon the

demographic characteristics of respondents. We found almost no evidence that education,

income, sex, interest in nutrition issues, or knowledge of nutrition facts affected respondents’

ratings of the degree of scientific certainty supporting the various health claims.