This submission is based on findings from the ADM+S Australian Advertising Observatory related to unhealthy food ads on Australian social media platforms, and the work of the research team on observability of online advertising.

In this submission:

• Part 2 briefly outlines the empirical basis for the submissions - the ADM+S Australian Ad Observatory, a unique research infrastructure which allows us to observe social media ads as they are actually served to individuals on social media (not just from brands’ public websites and social media pages); and specifically a study of a subset of ads that are the type of ads that would be banned by Options 5.2.1 and 5.2.2 (‘the ADM+S Ad Observatory Unhealthy Food Ads Study’);
• Part 3 provides evidence from the ADM+S Ad Observatory Unhealthy Food Ads Study as to the likely benefits of a ban on all ‘paid for’ marketing for unhealthy foods through online media by identifying the quantity, targeting and substantive themes of unhealthy food ads online;
• Part 4 identifies what has been learned from the ADM+S Australian Ad Observatory and other research by the team generally about the ways in which online marketing could be monitored and enforced.