Health Committee - The Government's Alcohol StrategyWritten evidence from the Advertising Standards Authority (GAS 25)
1. Introduction
1.1 This evidence is provided on behalf of the Advertising Standards Authority (ASA) and Committees of Advertising Practice, CAP and BCAP (the ASA system).
1.2 The ASA is the UK s independent regulator for ensuring that advertising in all media is legal, decent, honest and truthful, for the benefit of consumers, business and society. The system is both self-regulatory and co-regulatory.
1.3 The ASA administers the UK Advertising Codes which are written and maintained by two industry bodies, the Committee of Advertising Practice (CAP) and the Broadcast Committee of Advertising Practice (BCAP).1
1.4 The ASA system recognises the important role that advertising regulation has to play in ensuring that advertisements are responsible and do not encourage or condone irresponsible drinking. We have consistently worked hard to achieve this, as we will demonstrate through this submission.
1.5 This submission provides:
Our initial view on the Alcohol Strategy.
A brief overview of the UK advertising regulatory system and how the rules are developed.
An outline of the rules governing alcohol advertising, and recent examples of where these rules have been applied.
An analysis of the evidence base underpinning the alcohol advertising rules.
A summary of recent developments in alcohol advertising regulation.
1.6 The ASA would be prepared to give oral evidence to the Committee or provide further written information on request.
2. The Alcohol Strategy
2.1 As this submission will show, the UK s alcohol advertising rules are extremely robust, having been subject to significant regulatory scrutiny in recent years in response to societal concerns about irresponsible and harmful drinking.
2.2 The Government s latest Alcohol Strategy includes three commitments that are directly relevant to our work:
We will work with the ASA and Ofcom to examine ways to ensure that adverts promoting alcohol are not shown during programmes of high appeal to young people.
We will work with the ASA to ensure the full and vigorous application of ASA powers to online and social media.
We will also work with the ASA and other relevant bodies to look at the rules and incentives that might inhibit the promotion of lower strength alcohol products and the encouragement of responsible drinking behaviours.
2.3 Two of these recommendations could have significant policy implications on the way alcohol ads are regulated. Our consideration of these recommendations will be undertaken in line with widely accepted better regulation principles.
2.4 We welcome the opportunity to explore these matters with Government. Whilst it is too early to provide the Committee with detailed responses at this time, this submission will, where relevant, outline some initial thoughts.
3. Overview of the ASA System
3.1 The Advertising Codes are written and maintained by two industry committees, CAP and BCAP. The ASA is the independent body responsible for administering the Codes.
3.2 As well as handling complaints, the ASA also pro-actively monitors ads on TV, radio and on the internet, across both national and local media, to make sure standards are being maintained.
3.3 March 2011 marked a major step forward for advertising regulation when the advertising industry significantly extended the ASA s remit to cover companies own marketing communications on their own websites and social media.
3.4 A year on, the remit extension has been, to date, successful and has already had some notable successes in removing inappropriate alcohol advertising (Cell Drinks, see 4.11).
3.5 The ASA is 50 years old this year, and is widely viewed as an example of a best-practice self-regulator:
“The Government recognises the ASA as a highly successful model of both self and co-regulation; and that the UK s advertising regulatory system is well respected and seen as a gold standard worldwide.”2
3.6 The ASA is an integral part of the alcohol regulatory system. Our role is distinct from that of The Portman Group,3 which regulates the naming, packaging and promotion of alcoholic drinks, as well as drinks sponsorship.
3.7 More comprehensive information about the ASA system can be found in Annex A and on our website at www.asa.org.uk.
3.8 How the Advertising Codes are developed
3.8.1
3.8.2
3.8.3
3.8.4
3.8.5
4. Regulation of Alcohol Advertising
4.1 The ASA system shares the Government s commitment to protect society from irresponsible alcohol advertisements.
4.2 The Codes contain robust alcohol rules that sit on top of other Code provisions that require ads not to mislead, harm or cause serious or widespread offence. The rules are designed to protect society by ensuring that only responsible drinking behaviours and outcomes are seen in ads. The rules protect young people by both reducing the likelihood that they will see alcohol ads and, if they do, by ensuring the ads will not appeal strongly or particularly to them.4
4.3 The alcohol rules are comprehensive, proportionate, and based upon detailed assessments of the best available evidence of the effect of alcohol advertising on drinking behaviour (see section 5).
4.4 In summary, the rules state that alcohol ads must not:
link alcohol with daring, antisocial, aggressive or irresponsible behaviour;
link alcohol with seduction, sex or social success;
show alcohol being handled or served irresponsibly; and
show people drinking or behaving in an adolescent or juvenile way or reflecting the culture of people under 18 years of age.
4.5 In non-broadcast media (including online and in the cinema) alcoholic drinks cannot be advertised if more than 25% of the audience is under 18 years of age. On television, alcohol ads cannot be shown around programmes of particular appeal to under 18s (see 4.6).
4.5.1
4.6 TV scheduling rules for alcohol
4.6.1
commissioned for;
principally directed at, or
likely to appeal particularly to those under 18 years of age.
4.6.2
4.6.3
4.7 Low-alcohol
4.7.1
4.7.2
4.7.3
4.7.4
4.7.5
4.7.6
4.8 Compliance with the Codes
4.8.1
4.9 Pre-clearance
4.9.1
4.9.2
4.10 Complaints
The ASA receives relatively few complaints about alcohol advertising. In 2011 the ASA received 336 complaints (out of a total of 31,458) about 179 alcohol ads (out of a total of 22,397). So alcohol ads comprised just 0.8% of all those complained about.
4.11 Examples of ASA action
4.11.1
AB InBev UK Ltd (Apr 2012)—The ASA concluded that a radio ad for Budweiser beer linked alcohol to sexual success and therefore breached the Code.
Cell Drinks (Aug 2011)—In a social media first, the ASA decided that these YouTube ads, featuring a free-runner jumping around and over buildings, would appeal particularly to young people and that the ad was in breach of the Code.
WM Magners Ltd (Feb 2009)—The ASA concluded that the ad breached the Code by suggesting alcohol would boost confidence and lead to the success of a social occasion.
4.12 Sanctions
4.12.1
4.12.2
4.12.3
5. The Evidence Base
5.1 The UK s relationship with alcohol is widely acknowledged to stem from a complex range of factors—including but not limited to socio-economic group, family influences and peer pressure.
5.2 In March 2004 the Government s Alcohol Harm Reduction Strategy concluded, “There is no clear case of the effect of advertising on behaviour”. However, the strategy did highlight a possible link between young people s awareness and appreciation of alcohol advertising and their propensity to drink.
5.3 The Strategy recommended that Ofcom (who was at the time directly responsible for TV advertising regulation) should oversee a review of the TV alcohol advertising rules. In parallel with Ofcom s consultation, CAP reviewed its own non-broadcast alcohol rules.
5.4 Consequently, in 2005 the broadcast and non-broadcast alcohol advertising rules were significantly tightened, in recognition of the evidence of a possible link between young people s awareness of alcohol advertising and their attitudes to drinking. Any robust evidence that we have seen published since that date simply endorses that existing evidence base, but does not point to a stronger link to that which had been identified in 2004.
5.5 The alcohol rules were reviewed again in 2009, taking account of the latest Department of Health commissioned evidence (the ScHARR Review) and subject to a full public consultation. In so far as the ScHARR review related to advertisements, it did not offer persuasive evidence to support proposals to restrict alcohol advertising further. CAP and BCAP s assessments of the ScHARR Review evidence are available on CAP s website.13
5.6 Other studies considered by CAP and BCAP as part of the 2009 Code Review, including that by the European Alcohol & Health Forum s Science Group (SGEAHF),14had common methodological problems.15 CAP and BCAP s evidence-based approach requires it to look objectively at the balance of the evidence. None of these studies provided persuasive evidence that alcohol ads contribute to alcohol-related harms (beyond the possible link identified in 2004) or that further restrictions, on top of those already in place, would lead to a reduction in alcohol-related harm.
5.7 Further restrictions on alcohol ads must be proportionate and evidenced-based. If evidence is presented to CAP and BCAP that demonstrates a compelling case for a reconsideration of the rules, CAP and BCAP will act accordingly, as it has done in the past.
6. Current/Future Activities
6.1 Perhaps the biggest challenge facing the ASA today is the pace at which media is changing; ads are reaching consumers on new platforms and in different ways. The Government s alcohol strategy recognises this development, and calls on the ASA to ensure the advertising rules are applied robustly online and to social media. The ASA is alive to this challenge, and is determined to ensure that online marketing material is regulated with the same sense of social responsibility as that in traditional media.
6.2 The ASA s new online remit is subject to a two-year review. The review will consider the applicability of the UK Code of Non-broadcast Advertising, Sales Promotion and Direct Marketing, including its alcohol rules, to online marketing communications, to ensure they are effective and provide adequate protection.
6.3 Separately, CAP is preparing to undertake a project researching young people s experience of advertising on social media. This research will help provide a clear understanding of the types of ads young people see on social networking sites, and will enable the ASA system to identify where and whether regulatory action is required.
7. Summary
7.1 The alcohol advertising rules administered by the ASA are comprehensive and robust.
7.2 Complaints by the public about alcohol advertising are few (despite high public awareness of the advertising regulator) and advertiser compliance with the rules is high.
7.3 Having recently taken on the regulation of websites and social media, the ASA and CAP continue to work to identify emerging regulatory issues (particularly in new media).
7.4 The rules must remain evidence-based and proportionate. If policy makers have concerns about the strength of the rules in place, we are open to receiving and considering representations supported with appropriate evidence.
May 2012
Annex A
ABOUT THE ASA ONE-STOP SHOP
1. The ASA is the UK self-/co-regulatory body for ensuring that advertising in all media is legal, decent, honest and truthful, for the benefit of consumers, business and society. It does this by administering the UK Advertising Codes.
2. The Committee of Advertising Practice (CAP) and the Broadcast Committee of Advertising Practice (BCAP) are the industry bodies responsible for writing and maintaining the UK Advertising Codes. CAP writes and maintains the UK Code of Non-Broadcast Advertising, Sales Promotion and Direct Marketing and BCAP writes and maintains the UK Code of Broadcast Advertising.16
3. The system is both self-regulatory (for non-broadcast advertising eg press, poster, cinema, online, video-on-demand (VOD) services and direct mail) and co-regulatory (for TV and radio advertising). For non-broadcast advertising this means that advertisers, agencies and media have come together to write the UK Code of Non-broadcast Advertising, Sales Promotion and Direct Marketing (the CAP Code) and have set up the ASA as an independent body to judge whether ads breach the Code. There is no formal Government involvement in the system. On the rare occasions we are unable to secure compliance with the rules on unfair, aggressive and misleading advertising in non-broadcast media we can refer advertisers to the OFT for further regulatory action under B2C and B2B laws.
4. For broadcast advertising we operate under a co-regulatory partnership with Ofcom. This means that we have a contract with Ofcom which gives us day-to-day responsibility for maintaining standards and for acting on complaints about TV and radio ads. Broadcasters are obliged to comply with the BCAP Code under their broadcast licences. Non-compliant broadcast advertisers can be referred to Ofcom. The Government’s proposals do not impact upon this arrangement.17
5. The Advertising Codes sit within a legal framework, which means that, where appropriate, they reflect the standards required in law, eg misleading and unfair advertising. However, they may also contain rules that go beyond legal requirements, such as those relating to harm, offence and social responsibility.
6. The ASA deals with more than 25,000 complaints per year and operates at no cost to the tax payer. In fact the system is entirely funded, voluntarily, by the advertising industry, by a levy on paid-for advertising.
7. The ASA is committed to upholding high standards in advertising. The system takes a 360° approach to regulation, which includes pro-active monitoring, comprehensively enforced rules and training and advice for advertisers on the requirements of the Codes.
8. The system is entirely funded by industry, through a levy of 0.1% on display advertising space and airtime and 0.2% on Royal Mail Mailsort contracts. The levies are collected by two arm-length funding bodies, the Advertising Standards Board of Finance (Asbof) and the Broadcast Advertising Standards Board of Finance (Basbof).18 Last year the ASA was awarded £8 million to run the system.
9. The ASA “one-stop shop” advertising regulatory system brings great benefits for consumers and for business:
Easier for consumers—The establishment of a single complaints body has made it easier for consumers to complain.
Free to the taxpayer—Because it is funded by industry.
Simpler regulatory structure for advertisers—and cheaper for business than seeking resolution through the courts.
Harmonious decision making—Cross media adjudications are made by a single organisation.
Corporate Social Responsibility—Effective self-regulation works because the advertising industry has a strong interest in maintaining a level playing field for business and consumer trust in advertising.
10. Further information about the ASA and the work we do can be found at www.asa.org.uk. The website also contains a searchable database of all our adjudications from the past five years.
Annex B
THE ALCOHOL RULES
To note: As well as adhering to the alcohol specific rules, alcohol advertisers must also adhere to the general Code provisions, that all ads must not mislead, harm or offend. The full Advertising Codes can be accessed on the CAP website at www.cap.org.uk.
The UK Code of Non-broadcast Advertising, Sales Promotion and Direct Marketing (CAP Code)
Principle
Marketing communications for alcoholic drinks should not be targeted at people under 18 and should not imply, condone or encourage immoderate, irresponsible or anti-social drinking.
The spirit as well as the letter of the rules applies.
Definition
The rules in this section apply to marketing communications for alcoholic drinks and marketing communications that feature or refer to alcoholic drinks. Alcoholic drinks are defined as drinks containing at least 0.5% alcohol; for the purposes of this Code low-alcohol drinks are defined as drinks containing between 0.5% and 1.2% alcohol.
Where stated, exceptions are made for low-alcohol drinks. But, if a marketing communication for a low-alcohol drink could be considered to promote a stronger alcoholic drink or if the drink’s low-alcohol content is not stated clearly in the marketing communications, all the rules in this section apply.
If a soft drink is promoted as a mixer, the rules in this section apply in full.
These rules are not intended to inhibit responsible marketing communications that are intended to counter problem drinking or tell consumers about alcohol-related health or safety themes. Those marketing communications should not be likely to promote an alcohol product or brand.
Rules
18.1 Marketing communications must be socially responsible and must contain nothing that is likely to lead people to adopt styles of drinking that are unwise. For example, they should not encourage excessive drinking. Care should be taken not to exploit the young, the immature or those who are mentally or socially vulnerable.
18.2 Marketing communications must not claim or imply that alcohol can enhance confidence or popularity.
18.3 Marketing communications must not imply that drinking alcohol is a key component of the success of a personal relationship or social event. The consumption of alcohol may be portrayed as sociable or thirst-quenching.
18.4 Drinking alcohol must not be portrayed as a challenge. Marketing communications must neither show, imply, encourage or refer to aggression or unruly, irresponsible or anti-social behaviour nor link alcohol with brave, tough or daring people or behaviour.
18.5 Marketing communications must neither link alcohol with seduction, sexual activity or sexual success nor imply that alcohol can enhance attractiveness.
18.6 Marketing communications must not imply that alcohol might be indispensable or take priority in life or that drinking alcohol can overcome boredom, loneliness or other problems.
18.7 Marketing communications must not imply that alcohol has therapeutic qualities. Alcohol must not be portrayed as capable of changing mood, physical condition or behaviour or as a source of nourishment. Marketing communications must not imply that alcohol can enhance mental or physical capabilities; for example, by contributing to professional or sporting achievements.
18.8 Marketing communications must not link alcohol to illicit drugs.
18.9 Marketing communications may give factual information about the alcoholic strength of a drink. They may also make a factual alcohol strength comparison with another product, but only when the comparison is with a higher strength product of a similar beverage.
Marketing communications must not imply that a drink may be preferred because of its alcohol content or intoxicating effect. There is an exception for low-alcohol drinks, which may be presented as preferable because of their low alcoholic strength. In the case of a drink with relatively high alcoholic strength in relation to its category, the factual information should not be given undue emphasis.
18.10 Marketing communications that include a sales promotion must not imply, condone or encourage excessive consumption of alcohol.
18.11 Marketing communications must not feature alcohol being handled or served irresponsibly.
18.12 Marketing communications must not link alcohol with activities or locations in which drinking would be unsafe or unwise.
Marketing communications must not link alcohol with the use of potentially dangerous machinery or driving. Marketing communications may feature sporting and other physical activities (subject to other rules in this section; for example, appeal to under-18s or link with daring or aggression) but must not imply that those activities have been undertaken after the consumption of alcohol.
18.13 Only in exceptional circumstances may marketing communications feature alcohol being drunk by anyone in their working environment.
18.14 Marketing communications must not be likely to appeal particularly to people under 18, especially by reflecting or being associated with youth culture. They should not feature or portray real or fictitious characters who are likely to appeal particularly to people under 18 in a way that might encourage the young to drink. People shown drinking or playing a significant role (see rule 18.16) should not be shown behaving in an adolescent or juvenile manner.
18.15 Marketing communications must not be directed at people under 18 through the selection of media or the context in which they appear. No medium should be used to advertise alcoholic drinks if more than 25% of its audience is under 18 years of age.
18.16 People shown drinking or playing a significant role must neither be nor seem to be under 25. People under 25 may be shown in marketing communications, for example, in the context of family celebrations, but must be obviously not drinking.
18.17 Marketing communications may give factual information about product contents, including comparisons, but must not make any health, fitness or weight-control claims.
The only permitted nutrition claims are “low-alcohol”, “reduced alcohol” and “reduced energy” and any claim likely to have the same meaning for the consumer.
The UK Code of Broadcast Advertising (BCAP Code)
Principle
Advertisements for alcoholic drinks should not be targeted at people under 18 years of age and should not imply, condone or encourage immoderate, irresponsible or anti-social drinking.
The spirit as well as the letter of the rules in this section applies.
Definitions
The rules in this section apply to advertisements for alcoholic drinks and advertisements that feature or refer to alcoholic drinks. Alcoholic drinks are defined as those containing at least 0.5% alcohol; for the purposes of this Code low-alcohol drinks are defined as drinks containing between 0.5% and
1.2% alcohol.
Where stated, exceptions are made for low-alcohol drinks. But, if an advertisement for a low-alcohol drink could be considered to promote a stronger alcoholic drink or if the low-alcohol content of a drink is not stated clearly in the advertisement, all the rules in this section apply.
If a soft drink is promoted as a mixer, the rules in this section apply in full.
The rules are not intended to inhibit responsible advertisements that are intended to counter problem drinking or tell consumers about alcohol-related health or safety themes. Those advertisements should not be likely to promote an alcohol product or brand.
Rules
19.1 Radio Central Copy Clearance—Radio broadcasters must ensure advertisements for alcoholic drinks are centrally cleared.
Rules that apply to all advertisements
19.2 Advertisements must not feature, imply, condone or encourage irresponsible or immoderate drinking. That applies to both the amount of drink and the way drinking is portrayed.
References to, or suggestions of, buying repeat rounds of alcoholic drinks are not acceptable. That does not prevent, for example, someone buying a drink for each member of a group. It does, however, prevent any suggestion that other members of the group will buy a round.
19.3 Advertisements must neither imply that alcohol can contribute to an individual’s popularity or confidence nor imply that alcohol can enhance personal qualities.
19.4 Advertisements must not imply that drinking alcohol is a key component of social success or acceptance or that refusal is a sign of weakness. Advertisements must not imply that the success of a social occasion depends on the presence or consumption of alcohol.
19.5 Advertisements must not link alcohol with daring, toughness, aggression or unruly, irresponsible or antisocial behaviour.
19.6 Advertisements must not link alcohol with sexual activity, sexual success or seduction or imply that alcohol can enhance attractiveness. That does not preclude linking alcohol with romance or flirtation.
19.7 Advertisements must not portray alcohol as indispensable or as taking priority in life.
Advertisements must not imply that drinking can overcome problems or that regular solitary drinking is acceptable.
19.8 Advertisements must not imply that alcohol has therapeutic qualities. Alcohol must not be portrayed as capable of changing mood, physical condition or behaviour or as a source of nourishment. Although they may refer to refreshment, advertisements must not imply that alcohol can improve any type of performance.
19.9 Advertisements must not link alcohol to illicit drugs.
19.10 Advertisements may give factual information about the alcoholic strength of a drink. They may also make a factual alcohol strength comparison with another product, but only when the comparison is with a higher strength product of a similar beverage.
Advertisements must not imply that a drink may be preferred because of its alcohol content or intoxicating effect. There is an exception for low-alcohol drinks, which may be presented as preferable because of their low alcoholic strength.
In the case of a drink with relatively high alcoholic strength in relation to its category, the factual information should not be given undue emphasis.
19.11 Advertisements may include alcohol sales promotions but must not imply, condone or encourage immoderate drinking.
19.12 Advertisements must not feature alcohol being handled or served irresponsibly.
19.13 Advertisements must not link alcohol with the use of potentially dangerous machinery or driving.
Advertisements may feature sporting and other physical activities (subject to other rules in this section) but must not imply that those activities have been undertaken after the consumption of alcohol.
19.14 Advertisements must not normally show alcohol being drunk by anyone in their working environment.
Rules that apply to alcohol advertisements
19.15 Television only—Alcohol advertisements must not:
19.15.1
19.15.2
19.16 Radio only—Alcohol advertisements must not:
19.16.1
19.16.2
19.17 Alcohol advertisements must not feature in a significant role anyone who is, or seems to be, under 25 and must not feature children.
An exception is made for advertisements that feature families socialising responsibly. Here, children may be included but they should have an incidental role only and anyone who seems to be under the age of 25 must be obviously not drinking alcohol.
19.18 Advertisements for alcoholic drinks may give factual statements about product contents, including comparisons, but must not make any health claims, which include fitness or weight-control claims.
The only permitted nutrition claims are “low alcohol”, “reduced alcohol” and “reduced energy” and any claim likely to have the same meaning for the audience.
Scheduling of Television and Radio Advertisements
32.1 Broadcasters must exercise responsible judgement on the scheduling of advertisements and operate internal systems capable of identifying and avoiding unsuitable juxtapositions between advertising material and programmes, especially those that could distress or offend viewers or listeners.
Under-18s
32.2 These may not be advertised in or adjacent to programmes commissioned for, principally directed at or likely to appeal particularly to audiences below the age of 18:
32.2.1
Audience Indexing
How does Ofcom define “of particular appeal to under-18s”?
The term “of particular appeal” is an approach that has been used for many years to ensure broadcasting regulation is appropriately targeted. This is the same approach used in restricting the scheduling of alcohol advertising.
Whether a programme is “of particular appeal” to the under 18s is assessed using a statistical approach called indexing and the end result is what is often referred to as a programme’s Conversion Index.
If the proportion of children aged 10–15 watching a programme is more than 20% higher than the proportion of the UK television population watching the programme (or in other words, a programme achieves a Conversion Index of 120 or higher), the programme is defined as one which attracts a significantly higher than average proportion of viewers in that age group.
Calculation
A Conversion Index is based on audience viewing figures measured by BARB (Broadcasters’ Audience Research Board Ltd).
Each programme achieves a TVR (Television Rating).The TVR measures the popularity of a programme by comparing its audience to the TV population as a whole.19
One TVR is numerically equivalent to one% of a target audience. So for example, if Programme X achieves a rating of 10TVRs based on children aged 10–15, this would mean the average child audience of the programme is equal to 10% of all children aged 10–15 in television households.
A Conversion Index is calculated by comparing a programme’s TVR based on one audience (in this case children aged 10–15 years) with that of the base audience (all viewers).20 This comparison demonstrates the extent to which children aged 10–15 are attracted to a particular programme.
Example 1
Programme A achieves a Child (aged 10–15) rating of 5TVRs and an All Viewer rating of 3TVR. The following calculation would provide us with the Conversion Index:
Conversion Index of Programme A= 14
Formula: |
Child TVR x 100 = Conversion Index |
All Viewer TVR |
|
Example: |
5 TVRs x 100 = 167 |
3 TVRs |
The proportion of Children aged 10–15 watching Programme A is 67% higher than the proportion of the UK television population watching the programme (a Conversion Index of 167). This programme is therefore defined as one which is of particular appeal to under 18s.
Example 2
Programme B achieves a 10–15 rating of 10TVRs and an All Viewer rating of 14TVRs. The following calculation would provide us with the Conversion Index:
Conversion Index of Programme B=
Formula: |
Child TVR x 100 = Conversion Index |
All Viewer TVR |
|
Example: |
10 TVRs x 100 = 71 |
14 TVRs |
The proportion of Children aged 10–15 watching Programme A is 29% lower than the proportion of the UK television population watching the programme (a Conversion Index of 71). This programme does not attract a significantly higher than average proportion of Child viewers, and therefore is not said to be of particular appeal to this audience.
May 2012
1 www.cap.org.uk
2 Rt Hon Jeremy Hunt MP, Secretary of State for Culture, Media and Sport, in a letter to Rt Hon Chris Smith of Finsbury, ASA Chairman, 2 March 2012
3 http://www.portmangroup.org.uk/?pid=1&level=1
4 e.g. through prohibiting juvenile humour and behaviour, the use cartoon-like techniques and endorsements by people who might particularly appeal to U-18s.
5 http://www.cap.org.uk/CAP-and-BCAP-Consultations/Closed-consultations/~/media/Files/CAP/Consultations/BCAPConsultationdocumentandAnnex1.ashx
6 CAP Code rule 18.9. BCAP Code rule 19.10.
7 Alcohol Advertising Survey 2009
8 The result was an improvement on the compliance rate of 98.9% from the 2008 survey and 97.4% from the 2007 survey.
9 http://www.clearcast.co.uk/
10 http://www.racc.co.uk/racc/showCategories.aspx?catID=1
11 http://www.cinemaadvertisingassociation.co.uk/ Among other things, the CAA ensures that alcohol ads do not appear before films with an under 18 audience 25% or more of the total audience.
12 http://www.asa.org.uk/ASA-action/Adjudications.aspx
13 http://www.cap.org.uk/CAP-and-BCAP-Consultations/Closed-consultations/BCAP-Code-Review-consultation/~/media/Files/CAP/New%20Codes%20Evaluation%20Tables/BCAP%20Evaluation%20Section%2019%20Alcohol.ashx
14 http://www.tekry.fi/web/pdf/misc/Eptv_Scientific-opinion-on-marketing-communication.pdf
15 Most referred to evidence previously included in the ScHARR review, rather than offering anything new. Sometimes such evidence cherry-picked those studies that supported a particular hypothesis, but ignored the wider balance of evidence. Many were conducted in the US where the regulatory environment for alcohol advertising is very different from that in the UK. Not all of the studies reviewed looked at the relationship between advertising and consumption, but instead considered other types of influences on young people, such as film, music and videos.
16 The Advertising Codes can be found at: http://www.cap.org.uk/cap/codes/
17 Agreed through a formal Memorandum of Understanding (MOU), with the Deregulation and Contracting Out Act 1994 (DCOA) as the legal function that enables the partnership
18 www.asbof.co.uk
19 BARB figures are based on TV homes. If the programme in question is broadcast on the terrestrial channels, the TVR would be based on the Network, or the number of viewers living in TV households in the UK. If the programme is broadcast on a non-terrestrial channel, the TVR would be calculated based on the Multichannel Network, or the number of viewers living in multichannel television households in the UK.
20 The BARB definition of all viewers is Individuals aged 4 or over. As per footnote 4, if the programme is broadcast on the terrestrial channel, the index would be based on the TVR figures for Children and All Viewers living in TV households in the UK. If the programme is broadcast on a non-terrestrial channel, the index would be based on the TVR figures for Children and All Viewers living in multichannel TV households in the UK