In an effort to protect the industry, the PMA, together with the American Advertising Federation (AAF), submitted comments on July 14 to the FTC in response to the Interagency Working Group’s (IWG) proposed guidelines on food marketed to children.   The comments highlighted several significant flaws in the proposal, such as failing to carry out the mandate from Congress requiring the IWG to “study” childhood obesity and prepare a report, and basing conclusions on an unfounded assumption of a causal connection between childhood obesity and food advertising.  In addition, because the proposal has overly broad definitions of “marketing to kids,” implementation could raise serious First Amendment issues and have far-reaching negative consequences on even those industries beyond the food industry, such as media, talent, and non-profits.  Finally, the suggested guidelines would violate the Administrative Procedure Act and would create bad precedent by allowing federal agencies to sidestep the formal rulemaking process simply by labeling the regulations as “voluntary.”  Click here to view the submitted comments.