Background: Concerns have been raised that health and societal causes surrounding the COVID-19 pandemic were misappropriated by companies to promote their unhealthy products to vulnerable populations during a time of increased stress and hardship (i.e., COVID-washing). Social media is a common medium for unhealthy foods and beverage marketing due to lack of regulation and low levels of monitoring. Purpose: This study aimed to investigate the timing, nature and extent of COVID-washing on public social media accounts by New Zealand's major food and drink brands in the initial stage of the pandemic after the first case was detected in New Zealand and when stay-at-home lockdown restrictions (Level 4 and 3 Alert levels) were in place. Methods: A content analysis of social media posts from February to May 2020 by the twenty largest confectionery, snacks, non-alcoholic beverages, and quick-service restaurant (fast-food) brands was undertaken. COVID-19 related posts were identified and classified to investigate the timing, themes and engagement with social media marketing campaigns, flagging those that may breach New Zealand's Advertising Standards. Results: 14 of 20 unhealthy food and drink brands referenced COVID-19 in posts during the 4-month period, peaking during nationwide lockdown restrictions. Over a quarter of all posts by the 14 brands (n = 372, 27.2%) were COVID-19 themed. Fast-food brands were most likely to use COVID-19 themed posts (n = 251/550 posts, 46%). Fast-food brands also had the highest number of posts overall during the pandemic and the highest engagement. The most commonly-used theme, present in 36% of all social media posts referring to COVID-19, was to draw on feelings of community support during this challenging time. Suggesting brand-related isolation activities was also common (23%), and the message that "consumption helps with coping" (22%). Six posts were found to potentially breach one of New Zealand's advertising standards codes by promoting excessive consumption or targeting children. Conclusion: COVID-washing was used by unhealthy food and drinks brands to increase brand loyalty and encourage consumption. The current Advertising Standards system is ineffective and must be replaced with a government-led approach to effectively regulate social media advertising to protect all New Zealanders, particularly in times of crisis.

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