In Dublin on 21 April 2004 , speaking at a Safefood seminar on the Brodcasting Commission of Ireland's new draft code on advertising to children , I said:

First of all, I welcome very much the publication of this draft code on Children's Advertising. As a fairly well-known marketing person, and indeed as a former president of the Marketing Institute, I might be expected to oppose any restrictions at all on an advertiser's freedom to woo his customers.

In fact, in this instance, the very reverse is the case.

It is my knowledge of and familiarity with the power of advertising that leads me to believe in the vital necessity of regulating its impact on children. Regardless of what advertising practitioners sometimes say, for tactical reasons, advertising is an extremely potent persuasive force - and I am not at all convinced that even our adult population is sufficiently educated in the ways of advertising to handle its impact appropriately.

But whatever about that, there is no doubt whatever in my mind that children - and in particular, young children from the age of 12 downwards - are not sufficiently developed intellectually to cope with the full, unrestricted force of advertising.

In this debate over the past few years, the issue of "pester power" has been mentioned again and again - the power of advertising to create demands from young children which the parents feel unable to resist, even though they may feel they are unable to afford to do so. In passing, I'd like to make the point that "pester power" is not restricted to advertising.

In my own business, we had the example of sweets at the checkouts. They were put there to tempt any children accompanying their parent who was shopping, and were a constant source of annoyance to the parents who felt they were hassled into buying something they didn't want to buy, simply to keep the child quiet.

Many years ago in my company, we decided to take sweets away from the checkouts altogether - to remove this example of pester power. It went down very well with the parents, though I am not so sure the children were equally pleased. But nevertheless, I think it was the right thing to do - to avoid undermining the influence of the parents in their relationship with the child.

Anyway, my preferred position would be to ban advertising to children completely, as is already the case in several other European countries. But I am persuaded that that approach is simply not practical in Ireland, where we are particularly exposed to television that is broadcast from outside the country, and therefore which we cannot control, at the moment at any rate.

I am particularly taken by the argument that any unilateral ban by this country would simply send the business abroad and would put at a competitive disadvantage native Irish producers of products who lacked the clout of bigger multinational competitors. That argument resonates well with me, since the ban on below-cost selling is an exact analogy: it impacts only on Irish-owned and managed companies, while allowing foreign-based competitors to get around its provisions with impunity.

But, while I accept that we must allow some advertising to children, I take the view that in doing so we are attempting to control a very powerful and pervasive phenomenon, whose full effects we can only guess at. Prudence would suggest, therefore, that we err on the side of caution in regulating this matter.

So while welcoming the draft code, and applauding most of its provisions, I would take the general view that it does not yet go far enough - and I would hope that over the coming years it will be refined and sharpened in the light of experience.

There are two areas in particular where I would like to see the code strengthened, and perhaps I could mention them briefly.

The first is the issue of repetition of advertising, which I am surprised to see has received very little attention if any in the discussions so far. Those of us who work with advertising will be fully aware of the critical importance of repetition in making advertising more effective. Some practitioners will argue that repetition is the whole key to advertising success. An individual advertisement cannot be judged only in isolation, when a very relevant issue is how often the audience will see it. It's interesting, I think, that the New Zealand code on children's advertising addresses this issue head on, with very specific restrictions on how frequently a particular commercial may be broadcast. I think we should give more attention to this issue as the debate develops.

The other issue is in regard to diet. I am one among many who consider the national trends in our eating habits as highly alarming, and believe that we need a concerted national effort to address the issue. Advertising to children is a critical central issue in this, because whether we like it or not our children's worldview is formed to a very large extent by what they see on television.

I am aware that moves are afoot at European level to regulate food advertising, but I am not sure that in deferring serious consideration of the question the Commission isn't in effect passing the buck. Certainly the wording of the present draft does not for me succeed in conveying the importance of this matter, which I consider to be one of the most important issues around the whole question of advertising to children.