Health Committee - The Government's Alcohol StrategyWritten evidence from the Institute of Practitioners in Advertising (GAS 51)

Introduction

1. The IPA is the professional body for advertising, media and marketing communications agencies based in the United Kingdom. In the UK, the advertising industry directly employs over 300,000 people. In 2011, advertising expenditure was £16.1 billion.

2. As a not-for-profit membership body, the IPA’s role is two-fold: to provide essential core support services to its corporate members who are key players in the industry; and to act as the industry spokesman.

3. The IPA is an active supporter of Government initiatives to promote the UK’s creative industries and it works in close collaboration with other advertising-related industry trade bodies in the UK, including the Advertising Association.

4. This submission on behalf of the IPA takes directly from that provided by the Advertising Association. Whilst the IPA supports the Advertising Association’s submission, we felt the issues covered by the inquiry important enough to merit our own response.

Alcohol Advertising Summary

5. Advertising is crucial to a competitive economy. It brings consumer benefits because it fuels brand competitiveness, thereby informing consumer choice. It also has an essential role in funding the media and creating a dynamic, competitive and pluralistic media marketplace. Alcohol advertising, like all advertising, is central to investment in original UK content and any disproportionate advertising restriction impacts on the level of investment available for such content.

6. It is not in the interests of the advertising industry to promote or condone irresponsible drinking. Companies advertise to promote their brand over competitors’ brands, to encourage brand-switching. We are not aware of any evidence demonstrating that alcohol advertisements collectively impact on total alcohol consumption.

7. There are strict and well enforced rules that ensure alcohol marketing is not targeted at those under the legal drinking age or in a way that might appeal to them.

Submission Overview

8. Our submission falls into three parts: (i) an overview of UK advertising regulation; (ii) a response to some of the key recommendations in the Alcohol Strategy; and (iii) a response to the Committee’s identified examples of international evidence of ways to reduce alcohol consumption.

Overview of Alcohol Advertising Regulation

9. The UK has one of the most respected regulatory regimes for advertising in the world, overseen by the Advertising Standards Authority (“ASA”), and some of the toughest advertising regulation which enjoys a 99% compliance rate.1 We welcome the Alcohol Strategy’s positive comments about advertising self-regulation.

10. Alcohol advertising in the UK is already subject to controls that seek to prevent advertisers targeting and appealing to young people. The controls cover broadcast, print and online advertising and are a mix of co-regulation (with Ofcom) and self-regulation administered by the Advertising Standards Authority and the Portman Group. The advertising of alcohol is regulated through the Advertising Codes of Practice (the CAP and BCAP Codes). These rules firmly dictate that alcohol marketing is not targeted at those under the legal drinking age, either in terms of the content of the advertisement or the content of the media that surrounds it.

11. The ASA regularly monitors alcohol advertising to ensure compliance with the rules. The ASA’s adjudications against advertisers are published and result in swift action to remove or to have amended those advertisements that contravene the rules; compliance is extremely high.

Content Rules

12. The CAP alcohol advertising rules were significantly tightened in 2005 in response to Government objectives set out in the 2004 Alcohol Harm Reduction Strategy. The ASA ensures that alcohol ads must never:

Target under 18s.

Be shown around programmes that especially appeal to under 18s.

Link alcohol with irresponsible, anti-social, tough or daring behaviour.

Show alcohol being served irresponsibly.

Show people drinking and behaving in an adolescent or juvenile way or reflecting the culture of people under 18 years old.

Link alcohol with seduction, sex or social success.

Show those who are or appear to be under the age of 25 drinking alcohol or clearly having consumed alcohol.

13. Following the strengthening of the CAP rules in 2005, an Ofcom study noted a decline in the proportion of young people saying they feel that alcohol commercials are aimed at young people.2

Exposure Rules

14. On television and radio, alcohol advertising is subject to scheduling restrictions to ensure that it does not appear around programmes of particular appeal to those under 18, and is subject to content rules to protect children and young people.

15. In cinemas, alcohol advertisements are also pre-cleared. The Cinema Advertising Association (CAA) has reviewed and tightened its pre-vetting procedures in relation to alcohol advertising in the last few years.

16. The CAP Code sets out the rules for non-broadcast advertising. It dictates that no medium should be used to advertise alcoholic drinks if more than 25% of its audience is under 18 years old. In March 2011, these rules were extended to cover companies’ and organisations’ marketing claims on their own websites and in other non-paid-for space online under their control, such as social network sites.

17. The advertising codes administered by the ASA supplement legislation and also ensure that advertisements are legal, decent, honest, truthful and socially responsible. The system is highly effective and considered to be gold standard in self-regulation both in the UK and internationally. As noted above, the rules on alcohol advertising are some of the strictest in the world and their effectiveness is shown by the Government’s recognition of their high quality in the Alcohol Strategy itself.

Response to Specific Proposals in the Alcohol Strategy

Proposal to examine ways to ensure that adverts promoting alcohol are not shown during programmes of high appeal to young people

18. The Alcohol Strategy recognises that the rules referred to above prevent adverts being shown in a context which will have “a particular appeal” to people aged under 18. We believe that the combination of the exposure rules and the content rules are a proportionate way for the advertising industry to address youth alcohol consumption.

19. We do not believe that there would be any demonstrable health benefit in introducing stricter exposure rules and we are not aware of any rigorous, independent research which demonstrates such a move would result in a reduction of harmful drinking. More restrictive rules would interfere with the legitimate right of drinks advertisers to advertise their products to adult audiences and on the rights of adults to receive advertisements for legitimate products in which they might be interested.

20. The BMA say that 96% of 13 year olds are aware of alcohol advertising and we do not argue against this statistic. However, the factors behind alcohol misuse are complex and vary between population groups and regions and there are many societal causes. Peer pressure is a significant factor behind binge-drinking amongst 18–24 year olds, for example.

Proposal to consult on a ban on multi-buy promotions

21. We do not believe multi-buy alcohol promotions are inherently irresponsible; consumers are used to multi-buy promotions in respect of many different goods and services. The focus should not be on banning a particular form of marketing, but rather on ensuring that all forms of alcohol marketing are undertaken in a responsible manner. We will respond to this particular consultation when launched by the Government, but in the meantime, we urge the Government to ensure that any proposals will be proportionate and evidence-based.

Proposal to work with the ASA to ensure the full and vigorous application of ASA powers to online and social media and work with industry to develop a scheme to verify people’s actual ages which will apply to alcohol company websites and associated social media

22. As noted above, social networking and digital media is a regulated space and bound by the same rules as off-line media. Marketing content cannot appeal to children and there are strict online requirements such as age gateways and parental controls for brand websites. As the proposal indicates, there is much greater opportunity for drinks companies to screen out under-18s in social media enabling them to target those of legal drinking age.

23. Various measures have been put in place to ensure that children are discouraged from looking at alcohol advertising and marketing. Drinks companies provide age affirmation requirements to access their websites. In addition, and as noted above, advertising rules require the content of an alcohol ad to be targeted at those above the legal drinking age. In other words, if a young person does access the relevant brand’s page, the content is unlikely to appeal to them. Alcohol Concern’s recent report found that just a very small minority in a focus group had seen alcohol companies advertising on Facebook, none were aware of alcohol channels on YouTube; none of the respondents admitted to being aware of or visiting alcohol brand websites—as they “did not anticipate that such websites would contain games and competitions, but instead expected them to be dry and informative, providing factual information...”.3

Proposal to continue to work through the Responsibility Deal to support the alcohol industry to market, advertise and sell their products in a responsible way and deliver the core commitment to “foster a culture of responsible drinking, which will help people to drink within guidelines”

24. The Advertising Association has participated in the Responsibility Deal process on behalf of its members (including the IPA) and signed the Pledge on advertising.

25. The Advertising Association (and the IPA) also support Government campaigns aimed at changing behaviour over the longer term. This demonstrates that advertising can be part of a wider approach to promoting behavioural change through positive messaging.

Identified Examples of International Evidence of Ways to Reduce Consumption

An alcohol advertising ban

26. The IPA welcomes the Alcohol Strategy’s recognition that there is no evidence demonstrating that an advertising ban would be a proportionate response to reducing alcohol consumption. In France, where alcohol advertising is banned on TV, cinema and more recently on the internet, an official French parliament report stated that this ban had been ineffective in reducing high-risk drinking patterns. There has been a steady decrease in annual alcohol consumption in France over the last 40 years. The decrease started long before the adoption of the Loi Evin rules banning such advertising in 1991 and even slowed down slightly following its adoption.4 Even the French anti-alcohol NGO ANPAA accepts that the effects of the law are “weak”.5

27. Alcohol advertising bans do not work: in Norway there is no advertising for alcoholic beverages, but consumption has been steadily increasing. In Italy, where alcohol advertising is permitted, consumption is decreasing.6 An advertising ban is not the solution to the complex problem of high alcohol consumption and those who press for it risk missing the real causes.

Plain packaging

28. The IPA does not recognise the relevance of the reference to plain packaging in the Health Committee’s inquiry into the Alcohol Strategy: plain packaging is not referred to in the Alcohol Strategy nor has alcohol plain packaging ever been proposed by the UK Government as far as we are aware.

29. There is no hard evidence on the impact on consumption of any product arising from a plain packaging policy, but such a policy would equate to a de facto advertising ban. Branding provides extremely important consumer, social and economic functions and we believe that any consideration that alcohol branding might be restricted would be an extreme, disproportionate, approach.

May 2012