New Rudd Center report on marketing beverages to children

Would you say Coca-Cola, the parent company for FANTA, is marketing to children here?

Would you say Coca-Cola is marketing to children in these lesson plans for elementary school students?

If you say "yes" to either question, then do you think Coca-Cola is breaking its pledge not to advertise to children?

Coca-Cola's pledge says:

We have a global Responsible Marketing Policy that covers all our beverages, and we do not market any products directly to children under 12. This means we will not buy advertising directly targeted at audiences that are more than 35% children under 12. Our policy applies to television, radio, and print, and, where data is available, to the Internet and mobile phones.

I can think of some ways that Coca-Cola could say these marketing efforts are consistent with the pledge. Perhaps one could find research showing that the FANTA cartoon characters are designed to appeal to 13-year-olds but not 11-year-olds. Perhaps the websites where these characters appear have a children's audience share under 35%.  Perhaps the lesson plans don't qualify as "marketing." Perhaps the use of the word "directly" is supposed to give the marketers some wiggle room.

Still, under any of these explanations, the detailed defense only serves to show how empty the pledge is. 

This post was provoked by reading the Rudd Center's new report on marketing sugar-sweetened beverages to children (.pdf).