Position statement - Marketing and promotion of alcohol

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Position statement - Marketing and promotion of alcohol



Key messages and recommendations

Cancer Council Australia supports measures that effectively regulate alcohol advertising and promotion. Improved regulation of alcohol advertising is an important component of an overall and comprehensive strategy aimed at dealing with and minimising alcohol-related harm in Australia, particularly relating to young people.

1) Alcohol advertising legislation:

Cancer Council Australia recommends a comprehensive legislative framework for regulating alcohol advertising in Australia that:

a) covers all forms of alcohol marketing;
b) establishes clear public policy goals for the regulation of advertising, such as protecting vulnerable groups like children and young people;
c) creates an independent regulatory body for administering the system with the powers to formally investigate and penalise breaches of the alcohol advertising rules; and
d) introduces meaningful sanctions for serious or persistent non-compliance by advertisers.

2) Restrict alcohol advertising and promotion:

Cancer Council Australia recommends introducing legislation to prohibit alcohol advertising that:

a) appeals to people under the age of 25. The age of 25 years is consistent with recommendations made by the National Preventative Heath Taskforce[1]. Cancer Council Australia defines advertising that appeals to people under the age of 25 as advertising that a reasonable person would consider appealing to people under the age of 25; or
b) is connected with content that appeals to people under the age of 25 (as recommended by the National Preventive Health Taskforce[1]). Cancer Council Australia defines content that appeals to under 25s as content for which 10% or more of the audience is under the age of 25.

Legislation should provide for the phased introduction of restrictions upon alcohol advertising that either appeals, or is connected with content that appeals, to people under 25 in all media. 'All media‘ includes but is not limited to broadcast and print media, billboards, public transport advertising, cinema and internet.

As a first step, Cancer Council Australia recommends removing the exception in the Commercial Television Industry Code of Practice that permits broadcasting alcohol advertisements during daytime live sporting broadcasts on weekends and public holidays.

3) Restricting sponsorship by alcohol companies:

Cancer Council Australia recommends introducing legislation to restrict the sponsorship of sporting and cultural events, organisations or participants (such as sports teams or athletes), by alcohol companies, where:

a) 10% or more of the attendees at the event are under the age of 25; or
b) a reasonable person would consider that an event appeals to people aged under 25.

Legislation that restricts sponsorship of events, organisations or participants by alcohol companies should take an incremental approach, permitting existing sponsorship agreements to run their course and allowing sufficient time for event organisers and sporting teams to seek alternative sources of sponsorship.

4) Research:

Cancer Council Australia recommends ongoing research on the impact and effect of alcohol marketing on young people in Australia, particularly alcohol sponsorship of music and cultural events, point of sale marketing and emerging online and social networking trends in alcohol advertising. Cancer Council Australia also recommends that changes to alcohol advertising regulation are accompanied by research into the effects of regulatory changes and restrictions.

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Background

In 2000 alcohol use was responsible for 4.0% of global disease burden, slightly less than the damage caused to society by tobacco use (4.1%) and high blood pressure (4.4%)[2]. Alcohol is a risk factor for cancer of the mouth, pharynx, larynx, oesophagus, bowel and breast[3][4]. The burden of illness associated with drinking alcohol and convincing association with cancer risk underpin Cancer Council Australia‘s concerns about the marketing and promotion of alcoholic beverages.

The marketing and promotion of alcoholic beverages is a global industry dominated by large, trans-national companies with immense resources and budgets. Marketing is crucial for alcohol beverage producers to achieve their key objectives – to gain the greatest possible market share and maximise alcohol consumption[5].

Traditionally, alcohol beverages have been marketed and promoted through a mix of television, radio and print advertisements and point-of-sale marketing. However, in recent years, marketing strategies have become increasingly complex and innovative, involving campaigns that combine multiple technologies and channels. For example, using personalised emails or texts that promote alcohol-related incentives, and viral marketing campaigns associated with social networking sites in which young people share marketing material[6][7]. The dynamic nature of the internet makes it a particularly powerful promotional medium and many alcohol marketers have created engaging online environments with content and promotions especially designed to appeal to young people[8].

Much of the current research around the effects of alcohol marketing illustrates the impact on children and young people. This is because in general, marketing is particularly important for recruiting new consumers, and, alcohol-related harm is more acute in young people than in older people.

There are conflicting claims on the link between advertising and harmful alcohol consumption patterns. The alcohol industry takes the position that advertising leaves total alcohol consumption unchanged, affecting only the market shares of various brands[9]. Their contention may be supported by some econometric studies, which analyse the relationship between overall levels of alcohol consumption from sales data and overall levels of advertising from advertising expenditure. These studies often demonstrate little or no effect of advertising on aggregate alcohol consumption[10], though some studies find an effect[11].

However, econometric studies examine total alcohol sales, which are primarily to adults. They cannot measure the effects of alcohol advertising on young people, who are unable to purchase alcohol directly. By contrast, studies that examine how drinking behaviour, attitudes and knowledge vary with exposure to alcohol advertising, consistently show a strong association between exposure to alcohol advertising in magazines, television, in-store displays and sports venues, and young people‘s early initiation to alcohol use and/or increased alcohol consumption[12][13][14][15].

Although the alcohol industry argues that it does not deliberately set out to target the youth market, the youth market is highly susceptible to advertising messages, which are frequently effective[16]. Exposure to alcohol advertising shapes young people‘s beliefs, attitudes and drinking behaviours, indeed, several studies show that youth, even 10–12 year olds, interpret the messages, images and targeting of alcohol advertisements in the same way as adults[16][17].

Of concern, there can be significant negative consequences that may flow from early initiation to alcohol consumption. Studies of the long-term impacts of adolescent alcohol use consistently show that early and frequent use of alcohol approximately doubles the risk of alcohol related problems later in life[18]. Research into lifelong alcohol consumption demonstrates that early initiation of alcohol drinking and heavy drinking in adolescence and young adulthood can have long-term adverse health impacts, including increased risks for a range of diseases[19].

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Marketing and promotion of alcohol

Regulation of alcohol advertising in Australia

Currently, regulation of the content and placement of alcohol advertising is limited. Alcohol advertising is largely self-regulated, predominantly through voluntary industry codes of practice. There are few legislative restrictions upon the content or placement of alcohol advertising and promotion in commercial or subscription media.

The Alcohol Beverages Advertising Code (ABAC) is an alcohol-specific advertising code of practice and complaints mechanism. In addition to the ABAC, which covers the content of alcohol advertising in most media, there are a number of media industry codes with alcohol advertising provisions, including:

(i) television broadcast codes of practice such as the Commercial Television Industry (CTI) Code of Practice and the Subscription Broadcast Code of Practice;
(ii) the Outdoor Media Association Code of Ethics;
(iii) the Publishers' Advertising Advisory Bureau‘s Guiding Principle for Alcohol Beverage Advertising; and
(iv) the Commercial Radio Code of Practice.

The Alcohol Beverages Advertising Code

The ABAC is a voluntary code. All members of Brewers Association of Australia and New Zealand, the Distilled Spirits Industry Council of Australia and the Winemakers‘ Federation of Australia are signatories to the scheme[20]. Accordingly, the vast majority of Australia's alcohol advertisers are committed to abide by the ABAC rules, including any decision by the independent Adjudication Panel. The ABAC scheme applies to print media, billboard, internet, cinema, television and radio advertising. It covers the content of alcohol advertising in these media and not its placement.

The ABAC requires advertisements to present "a mature, balanced and responsible approach to drinking"[21]. Specifically, alcohol advertisements are not to have strong or evident appeal to children or adolescents, depict the consumption or presence of alcohol as contributing to personal, business, social, sporting, sexual or other success, or suggest alcohol contributed to a change in mood or environment[21].

The ABAC is limited in scope, and fails to cover many kinds of marketing techniques such as point-of-sale and in-store promotions, viral and emerging media. It relies on complaints to identify and address breaches of rules and has no facilities for pro-active investigation of potential breaches.

A review commissioned by the Ministerial Council on Drug Strategy in 2003 concluded that the ABAC system was dysfunctional[22]. It found that advertisements routinely violated the ABAC; that many complaints were not investigated; and when they were investigated the process was excessively lengthy and decisions were not reported accurately[22]. Changes were implemented in 2004, including adding a public health expert to the ABAC complaints panel and extending ABAC to include internet advertising and the sponsorship of events.

Despite these changes, the ABAC remains an ineffective regulatory tool. It is a voluntary code, it cannot be enforced, and there are no penalties for breaches.

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Traditional alcohol advertising: television, print, radio and outdoor

In 2008, Australian alcohol advertisers spent over $109 million[23]. The top ten alcohol advertisers accounted for 70% of that figure, spread across television, press, radio, cinema and outdoor advertisements[23].

Television advertising

Commercial Television

The CTI Code of Practice regulates the placement of alcohol advertising on commercial television. The Australian Communications and Media Authority deal with breaches of the CTI Code of Practice through a complaints system.

The CTI Code of Practice provides that televised advertisements to children must not be for, or relate in any way to, alcoholic drinks or draw any association with companies that supply alcoholic drinks[24]. Additionally, the Code states that:

Alcohol advertising is only permitted during periods of M (mature classification), MA (mature audience classification) or AV (adult violence classification) programs[24].

However, the Code also permits alcohol advertising during the day as an accompaniment to the live broadcast of a sporting event on weekends and public holidays or if the sporting event is broadcast simultaneously across a number of licence areas or time zones[24].

Although alcohol advertisements are permitted on television after 8:30pm, the effect of this prohibition precludes only the youngest of children from exposure. A recent survey indicated that 71% of Australians supported limiting television advertising of alcohol until after 9.30pm, indicating strong public support for reforming the CTI Code of Practice and imposing stronger restrictions on placement of televised alcohol advertisements[25].

Moreover, the effect of limiting the placement of alcohol advertisements until after 8:30pm is undone by the live sport exception. The popularity of sport in Australia and the amount of sport broadcast on weekends and across time zones means that large numbers of children and young people are exposed to alcohol advertising during sport broadcasts. Research demonstrates the popularity of major sporting events among children[26] and indicates that alcohol advertisements are just as likely to be seen by children as adults[27].

Subscription television

Advertising on subscription television and radio is governed by the Australian Subscription Television and Radio Association (ASTRA) Code of Practice. This instrument requires all advertisements on subscription television and radio to comply with relevant AANA codes; and in relation to alcohol advertisements, these must comply with the ABAC.

However in relation to placement of advertising on subscription television and radio, the ASTRA Code of Practice acknowledges the ability for subscribers to entirely block out a channel or in some instance to block certain levels of classified material (through disabling devices such as parental lock-out)[28]. Therefore, there are no time restrictions on the placement of alcohol advertising; licensees are simply required to 'take into account the intellectual and emotional maturity of its intended audience when scheduling [alcohol] advertisements'[28].

Outdoor advertising

Outdoor alcohol advertising is regulated in the Outdoor Media Association‘s Code of Ethics. The Outdoor Media Association Code incorporates the ABAC[29].

In 2009, the Outdoor Media Association introduced an additional policy requiring all members to limit the advertising of alcohol products on fixed signs that are located within a 150-metre sight line of a primary or secondary school[29]. However, the policy does not apply where the school is in the vicinity of a club, pub or bottle shop or any other venue that sells alcohol products. The policy also does not apply to transit advertising on buses and taxis[29].

As yet, there is limited evidence about the effect of outdoor alcohol advertising on consumption levels. However, a US study found that exposure to outdoor alcohol advertising around schools is associated with subsequent youth intentions to use alcohol[30].

Print advertising

The Publishers' Advertising Advisory Bureau‘s "Guiding Principle for Alcohol Beverages" is a self-regulatory instrument that covers the placement and some content of alcohol advertising[31]. This principle states that, in part:

  • advertisements should only be placed where at least 70% of the audience is reasonably to be expected to be above the legal purchase age (determined by using reliable, up-to-date audience or readership data);
  • advertisements should not contain the name of, or depict Santa Claus, Easter Bunny, or any other culturally significant figure or character likely to appeal to a person below the legal purchase age;
  • the use of the word "schoolies" is banned in print advertisements;
  • alcohol products should not be advertised or marketed on the comic or youth pages of newspapers, magazines; and
  • all paid advertisements should contain a responsibility message in a manner and location that a reasonable person would be aware of its presence.

Print advertisements are also obliged to comply with the ABAC in relation to advertisement content.

Radio advertising

Radio advertisements are governed by the Commercial Radio Code of Practice, which requires simply that:

Advertisements broadcast by a licensee must:


(a) not be presented as news programs or other programs;


(b) comply with all other Codes of Practice so far as they are applicable.

Comments on traditional advertising

Television, radio, print and outdoor advertising represent a considerable segment of alcohol advertising in Australia. Much of this advertising is self-regulated or subject to voluntary codes. Evidence clearly shows that exposure to alcohol advertising significantly influences young people‘s decisions about drinking and their expectations related to alcohol use[12]. In effect, the more aware, familiar and appreciative young people are of alcohol, the more likely they are to drink both now and in the future. More research is needed about the exposure of children and young people to alcohol advertising in print and outdoor media, and on radio.

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Alcohol promotion: sponsorship and point-of-sale promotion

In addition to the traditional, measured, "above-the-line" marketing in television, radio, print and the outdoors, alcohol companies employ a broad mix of unmeasured, or "below-the-line" marketing techniques, particularly in association with sporting and cultural events, teams and players[32]. Below-the-line marketing represents a considerable segment of the market; above-the-line media is now understood to be an underestimation of the alcohol marketing effort 'by a factor of two to four'[7].

Events and team sponsorship

Sponsorship of sporting and cultural events, organisations and participants is commonplace in Australia. Event and team sponsorship offers alcohol marketers a receptive audience motivated to have a good time[12], commercial opportunities such as exclusive stocking agreements, and the chance to embed their brands in the everyday activities of current and potential consumers[33].

In 2008, the US Federal Trade Commission reported that alcohol manufacturers spent 44% of their marketing dollars on television, radio, print and outdoor marketing; the remainder was spent on point-of-sale advertising and promotions and sponsorship of sporting events, sports teams or individuals[33]. The variance between money spent on above- and below-the-line marketing can be telling: for example Diageo‘s 2005 annual report noted US$1,760 million for marketing, significantly more than the reported US$409 million spent on advertising[33].

It has been estimated that in Australia each year, $50 million of sponsorship for major sporting events comes from alcohol companies, with 80% invested by three companies—Fosters, Lion Nathan and Diageo[34].

Like regulation of above-the-line advertising, regulation of alcohol sponsorship is limited in scope. The ABAC contains standards for the promotion of alcohol at events, which acknowledges that alcohol beverage companies have "the right to promote their products at events together with the right to promote their association with events and event participation"[21]. According to the ABAC this right must be balanced with certain responsibilities, for example not promoting alcohol products at events that are designed to clearly target people under the legal drinking age[21].

Attitudes towards alcohol consumption are strongly influenced by social and cultural norms and by the specific social situation in which alcohol consumption occurs. In Australia, sport and alcohol have a particularly close association[35]. Indeed, it is difficult to have any involvement in sport in Australia, as either a participant or fan, without being exposed to a strong message that alcohol and sport are inextricably connected[36]. Excessive drinking is normalised by some elite athletes, who are role models to young people. Research indicates that alcohol industry sponsorship of sportspeople and, in particular, the provision of free or discounted alcoholic drinks in association with sporting events is associated with hazardous levels of drinking[37].

Alcohol companies also sponsor music events, festivals and other cultural events. As yet, the evidence is limited as to the effects of alcohol sponsorship of cultural events upon young people.

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Point-of-sale marketing

Point-of-sale marketing includes promotions and advertising in on- and off-licenced premises. The Publishers' Advertising Advisory Bureau‘s Guiding Principle for Alcohol Beverage Advertising covers point-of-sale marketing. In relation to licensed premises, the Principle states that alcohol advertisements should not[31]:

  • provide incentives that could lead to rapid or excessive consumption of liquor;
  • encourage the stockpiling of drinks by the consumer;
  • involve the availability of non-standard sized drinks or the availability of liquor in receptacles that encourage rapid drinking;
  • condone or encourage rapid or excessive drinking, drunkenness or anti-social behaviour;
  • suggest any association with risk taking, or with violent, aggressive, dangerous or antisocial behaviour;
  • have any association with, acceptance of, or allusion to, illicit drugs;
  • encourage breaking the law; or
  • encourage under-age drinking.

And that alcohol advertisements should[31]:

  • have reasonable limits and controls to minimise the risk of rapid, excessive or irresponsible consumption of liquor when advertising or promoting 'happy hours', free drinks or discounted drinks;
  • not place free liquor as the primary focus where limited free liquor is advertised as ancillary to a product or service;
  • be consistent with responsible serving of alcohol practices where advertising involves the inclusion of unlimited liquor within the entry price; and
  • avoid sexual, degrading, sexist or gratuitously offensive images, symbols, figures and innuendo.

The importance of point-of-sale marketing has been described in one study as to "…grab [the customer‘s] attention and make them aware that a particular brand is just what they want"[38]. A US study found that around 60% of people in bars make their decision about what to drink after they arrive at a venue[39].

There is limited evidence of the effect of point-of-sale marketing in Australia. However, a US study of off-licensed venues, showed associations between higher binge-drinking rates and:

(i) the availability of large volumes of beer;
(ii) lower average prices for cartons of beer;
(iii) interior and exterior advertising; and
(iv) promotions such as volume discounts, advertised price specials, or coupons.

Higher binge drinking rates at on-licence venues are associated with:

(i) lower prices for a single drink, pitcher or largest volume available;
(ii) weekend beer specials; and
(iii) the availability of promotions in the next 30 days[40].

A recent study also found "clear evidence of an association with adolescent drinking with weekly exposure to alcohol advertising in stores, and with ownership of alcohol promotional items"[41].

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Online, viral, experiential and surrogate marketing, and emerging media

Alcohol marketing has moved beyond traditional media and now encompasses a multitude of channels and techniques, including electronic and emerging media, product designs and product placement. The ABAC states that its standards apply to:

...internet sites primarily intended for advertising developed by or for producers or importers of alcohol products available in Australia or that are reasonably expected to be made available in Australia, and to banner advertising of such products on third party sites[21].

Viral, experiential and surrogate marketing, and marketing in emerging media is virtually unregulated. Where regulation does exist (for example, the ABAC), its scope is limited and addresses alcohol advertising content, but not placement.

Evidence of an effect of below-the-line marketing on young people‘s alcohol consumption is limited. However, as Babor et al. point out, "the extent and breadth of research [on the effects of exposure to young people to alcohol marketing] … is consistent in showing effects with young people"[7]. It is reasonable to assume that below-the-line marketing techniques that use emerging media, viral campaigns and electronic technology, target and capture young people.

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Cancer Council Australia’s position

Cancer Council Australia supports increased restrictions on where, when and how alcohol can be marketed. Cancer Council Australia recommends introducing legislation to restrict alcohol advertising and sponsorship that either appeals, or is connected with content that appeals, to people under 25 in all media, and emphasises the importance of research into the impact of advertising and restrictions.

Cancer Council Australia supports advertising restrictions to greatly reduce the impact of alcohol marketing and its harmful effects on the population, particularly young people. Evidence indicates that alcohol advertising bans decrease alcohol consumption[42] and, in the Australian context, would be more cost-effective than current practices[43].

Advertising bans also have the potential to reduce harmful social costs of alcohol consumption such as motor vehicle fatality rates. Econometric modelling suggests that, if countries with no alcohol advertising restrictions implemented partial bans, alcohol consumption could be reduced by 16% and motor vehicle fatality rates by 10%. As Australia effectively has no advertising bans, there is the potential to save up to $5,150 m in terms of total social costs from alcohol abuse if Australia implemented a full alcohol advertising ban and up to $3,210 m for a partial ban. The estimated impact on social costs of alcohol-attributed road accidents is also significant with up to $1,210 m cost savings after the implementation of a full advertising ban and up to $470 m for the implementation of a partial ban[44].

Cancer Council Australia‘s position is consistent with the recommended action (3.1) in the 2009 National Preventative Health Taskforce Strategy that states:

(iv) In a staged approach phase out alcohol promotions from times and placements which have high exposure to young people aged up to 25 years including:
  • Advertising during live sport broadcasts
  • Advertising during high adolescent/child viewing
  • Sponsorship of sport and cultural events (e.g. sponsorship of professional sporting codes; youth oriented print media; internet based promotions)
  • Consider whether there is a need for additional measures to address alcohol advertising and promotion across other media sources[1].

The Commonwealth Government has the constitutional power to regulate alcohol advertising or to impose a code of conduct on the alcohol industry under the Trade Practices Act 1975 (Cth). As yet, the Government has failed to step in and enact legislation to restrict alcohol advertising. See the Government Taskforce on Industry Self-Regulation at for more information.

Cancer Council Australia is of the view that the Government‘s position on alcohol advertising regulatory reform cannot be maintained, particularly where research concludes that:

There is no evidence to support the effectiveness of industry self-regulatory codes, either as a means of limiting advertisements deemed unacceptable, or as a way of limiting alcohol consumption[7].

Cancer Council Australia emphasises the compelling need for strong action on alcohol advertising, which has been either self-regulated or unregulated for too long.

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Definition of alcohol marketing and promotion

Cancer Council Australia adopts the definition of alcohol marketing as outlined in the WHO Global Alcohol Strategy and accordingly considers alcohol marketing and promotion to be "any form of commercial communication or message that is designed to increase, or has the effect of increasing, the recognition, appeal and/or consumption of particular products and services. It could comprise anything that acts to advertise or otherwise promote a product or service"[45].

Alcohol marketing can be roughly split into above-the-line (television, print, radio and outdoor) and below-the-line (point-of-sale and sponsorship) media, although in reality, alcohol marketing utilises a sophisticated combination of above- and below-the-line techniques, linking alcohol brands to sports and cultural activities, sponsorships and product placements, and new marketing techniques such as e-mails, SMS and podcasting, social media and other communication techniques[45].

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Position statement details

This position statement was approved by the Public Health Committee in September 2010.

This position statement is based on the Marketing and Advertising of Alcohol position statement developed by the Alcohol Policy Coalition, a coalition of health agencies consisting of Cancer Council Victoria, VicHealth, Australian Drug Foundation and Turning Point Alcohol and Drug Centre

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