Health Committee - The Government's Alcohol StrategySupplementary note by the Advertising Association (GAS 52A)
I wanted to provide clarification on a point raised in a recent witness session by Dr Wollaston. The point related to alcohol advertising in cinemas being shown around Harry Potter movies. I can categorically state that alcohol advertising has never been shown alongside any of the Harry Potter films, and I provide you information below as an addendum to our submission as to why that is the case.
1.The Committee of Advertising Practice (CAP) Code sets out the rules for non-broadcast advertising including cinema. It dictates that no medium should be used to advertise alcoholic drinks if more than 25% of its audience is under 18 years old.
2.As is outlined above, if over 25% of a cinema audience is under 18 years-old, then a film will not carry alcohol advertising. These rules are administered by the Cinema Advertising Association who, as the content and nature of films changes every year, use independent modelling to project the likely audience profile for a film. This is based on a sample of similar films whose actual profile post release is used as the base for the modelling of future releases.
3.Further to these exposure rules based on percentages, the CAA also takes other steps to reduce the incidence of youth exposure to alcohol advertising. For example, unless the film is “18” certificate, the CAA takes the view that all releases featuring comic book characters in a central role are not permitted to carry alcohol advertising, given the potential appeal of those characters to younger audiences. This has meant that a number of highly successful films—including Marvel Avengers Assemble, which is currently making box office records, cannot carry alcohol. Similar data analysis has meant that “gross out” comedies receiving “15” certificates rarely carry alcohol advertising.
4.It is also essential to also note that many films that are popular with adults are lower certificate films, for example The Best Exotic Marigold Hotel. This film received a 12a certificate but, as the majority of its viewership was middle-aged or older, it would be wholly disproportionate to have banned alcohol advertising around this film.
5.Even when alcohol advertising is permitted with a film, its proportion does not exceed 40% of total advertising reel time, and CAA members endeavour to ensure that alcohol ads are always interspersed with non-alcohol ads.
6.The rules and self-regulatory behaviour set out above are a proportionate way to protect children from seeing alcohol advertising while at the same time ensuring that cinemas can benefit from advertising alcohol products in their cinemas in a responsible way. Cinemas, and particularly local cinemas, rely on advertising revenue. Any impact to the amount of advertising revenue that they receive could threaten their viability.
Additionally, the Committee Chairman made reference to his interest in the Loi Evin rules which heavily restrict alcohol advertising in France in the final evidence session. Our original submission makes clear that there is much independent evidence showing that this ban had been ineffective in reducing high-risk drinking patterns. We are happy to provide further evidence backing up our view that an advertising ban along the lines of Loi Evin is not an effective public policy measure to address the serious problem of irresponsible drinking.
William Blomefield
Regulatory Affairs Manager
June 2012
