But that's exactly what happened this week. A coalition made up of the Food and Drink Federation, Food Advertising Unit, Advertising Association, the Institute of Practitioners in Advertising and ISBA has submitted the 'Better Balance' package to Ofcom. They claim it represents the views of the overwhelming majority of the advertising world.
The coalition has ruled out Ofcom's three proposals - which are all based around time restrictions on ads - and created 'package four'. It proposes to ban licensed cartoon characters and celebrities in ads targeted at children; ban all branded food and drink ads during children's programming on terrestrial TV; and limit food and drink ads on satellite and cable channels to 30 seconds an hour instead of the one in five ads that currently appear in the 12 minutes of advertising that is allowed each hour. Advertising Association director general Andrew Brown says there is no acceptable method of deciding whether foods are healthy or unhealthy, and therefore the coalition had no option but to propose an outright ban.
While some manufacturers, such as Kraft, have gone it alone with their own submissions to Ofcom, there is a virtually unanimous agreement throughout the industry that the Food Standards Agency's nutrient profiling model to score foods as either 'good' or 'bad' is fundamentally and scientifically flawed.
FDF director general Melanie Leech says: "Everybody is united in the rejection of the FSA's model."
Brown adds, however, that the coalition is not opposed to the idea of differentiation of products. "The industry is, in fact, committed to working constructively to devise a profile," he says.
The coalition, which formally describes the FSA's model as "not fit for purpose", is planning to wait and see what the European Food Safety Authority comes up with in its consideration of a Europe-wide profiling tool over the next year.
But Brown admits there are still areas that are open to interpretation in the 'Better Balance' package. For example, although TV ads aimed directly at under-tens could not be aired at all, ads aimed at over-tens could be placed in adult programming as early as 6pm. The line between children's and adult TV is not clear either, with each channel switching at different times, usually between 5pm and 6pm. "Ad agencies need to make sure that their ads are not deemed to be targeting the under-tens in any way. Kids may see the Andrex advert and like the puppy, but that doesn't mean they are being targeted," says Brown.
Gary Lineker's endorsement of Walkers is another example that springs to mind. But this is unfair, says a PepsiCo spokesman.
He maintains that the changes will not have an impact on PepsiCo's advertising strategy. "The proposed changes relate to celebrities appearing in adverts targeted directly at children under the age of ten. The Walkers adverts in which Gary Lineker appears are not targeted at children - the humour is aimed at an older audience and we do not buy airtime around children's TV programmes."
Brown admits the coalition's proposal is radical, but says Ofcom wanted any fourth option to have the same impact as its proposals.
According to the coalition's strategy, hypothetically, retailers would also be subject to the proposals, meaning ads with Jamie Oliver making his latest spinach dish for Sainsbury would be banned during children's TV.
However, brand ads not featuring products would be acceptable at any time. For example, McDonald's could appeal to viewers to go to its restaurants. But, under the package, a McDonald's ad for fruit packs would be banned.
Although ISBA - the voice of advertisers - is signed up, the BRC is not, calling retailer support of the scheme into question.
"We accept that it is illogical that you cannot advertise fresh fruit and vegetables," says Brown. "But we also say that if the model that decides what is OK is scientifically flawed, that is totally unacceptable. When an acceptable form of nutrient profile is decided upon, then the industry will look again."ncoalition proposals
The coalition of food companies and the advertising community have pledged that no more licensed cartoon characters, celebrities, the latest movie characters or collectable gifts would be used in ads directly targeted at children under ten
Under their plan, there would be no more advertising of branded foods during children's programming on terrestrial TV as there is no accurate profiling model on which to decide which food would be deemed healthy or unhealthy
Advertising of food and drink would be limited to 30 seconds per hour all day on dedicated children's channels on satellite and cable, instead of the one in five ads that currently run within the 12 minutes allotted to advertising