Alcohol advertising regulation that balances commercial and public interest

Transcription

1 Alcohol advertising regulation that balances commercial and public interest Alcohol Concern Making Sense of Alcohol

2 Contents Stick to the Facts: Alcohol advertising regulation that balances commercial and public interest Executive summary 1 Policy recommendations 3 Alcohol marketing and young people 4 The shape of contemporary marketing 5 The regulation 6 Alcohol advertising and youth perspectives: the work of YAAC 7 Rebalancing regulation 11 Conclusion 14 Policy recommendations 15 References 16

3 Executive summary Changes to the contemporary media and communications landscape have dramatically impacted on the extent and nature of marketing. With the growth of digital technologies, advertisers today harness social media, online video channels and mobile phones as well as traditional channels such as television, cinema and billboards to promote products. The alcohol industry spends more than 800 million annually in the UK on promotion 1 and is fully tapped into new opportunities to engage consumers. Sophisticated and multi-dimensional alcohol marketing strategies increasingly integrate online and off-line promotions, reaching right across people s lives. As advertising has expanded across new technologies such as the Internet, so the volume and speed of marketing communication pose increasingly challenging questions of regulatory control. High levels of alcohol brand recognition amongst children illustrate the weaknesses of the current regulation both in terms of the volume of young people s exposure and the appeal of advertising content 2,3. Young people tell us that they regularly view alcohol advertising which, despite the controls, makes strong associations with prohibited themes; they also assert that digital advertising, which moves quickly and in high volumes, regularly breaches the rules. Since August 2011, the Youth Alcohol Advertising Council (YAAC) a group of young people coordinated by Alcohol Concern has been reviewing selected alcohol advertising against the regulatory codes. As a result of the review YAAC has made complaints about advertising content, where appropriate, to the regulator, the Advertising Standards Authority (ASA). However, the whole review process raises serious concerns about the current framework of control and balanced application of the rules governing alcohol advertising. The alcohol industry spends more than 800 million annually in the UK on promotion and is fully tapped into new opportunities to engage consumers. 1

4 The Government s 2012 Alcohol Strategy acknowledged the link between advertising and consumption, particularly in young people under-18-years-old 4. The World Health Organisation recognises the dose-response relationship between young people s exposure to alcohol marketing and the likelihood that they will start drinking; the greater the exposure, the greater the impact 5. Evidence appears to suggest that limiting the amount and type of alcohol marketing would reduce drinking initiation and heavy drinking, particularly among young people 6. Alcohol Concern is calling for change in order to prioritise the protection of children and young people under-18-years-old. It is likely that as the weight of evidence grows, so too will calls for a total ban on alcohol advertising; however, there is an immediate need for a revised framework of regulation. The Loi Evin introduced in France in 1991 is a partial ban on alcohol advertising which places restrictions on where and how alcohol is promoted. In our Stick to the Facts initiative we are calling for the introduction of measures that capture the spirit of the Loi Evin, adapted to the UK s social and cultural context. It is an approach that balances commercial freedoms with genuinely robust protection for children and young people. Without a total ban it is impossible to entirely prevent children and young people from being exposed to alcohol promotion. Instead, in the absence of such a ban, to reduce the appeal to minors we are advocating that alcohol should be marketed on product facts alone, such as strength, origin, composition and means of production as has been successfully achieved via the Loi Evin in France. A move away from stipulating what advertisers cannot say about alcohol to what they can reduces the scope to make associations with prohibited themes. Marketing that inserts alcohol brands directly into people s enjoyment of leisure activities for example, sponsorship of sporting, cultural and music events, and branded merchandise should be prevented. Other forms of advertising that do not appeal to or target under-18s or associate alcohol with lifestyle characteristics may be permitted. New controls should be overseen by an independent, statutoryenabled regulatory body with the power to levy meaningful deterrents such as fines. Given the evidence, responsible alcohol advertising regulation provides adequate protection to vulnerable groups. The Stick to the Facts approach draws on the legally road-tested principles of the Loi Evin to ensure greater protection for those who are underage, within a framework of statutory regulation that is fully functioning. The approach seeks greater balance between commercial and public interest.... an approach that balances commercial freedoms with genuinely robust protection for children and young people. 2

5 Policy recommendations Only advertise product characteristics Statutory and independent regulation Meaningful sanctions Prohibit sponsorship Where advertising is permitted, messages and images should only refer to the characteristics of the product s strength, origin, composition, and means of production. Promotion of lifestyle images of drinkers or scenes depicting a drinking atmosphere should be prohibited. Regulation of alcohol promotion should be statutory and independent of alcohol and advertising industries. Regulation of digital and online content in particular is challenging, and experience from within the UK and abroad has demonstrated that self-regulation is failing to adequately protect children and young people. Meaningful sanctions such as fines for serious non-compliance with marketing regulations should be introduced in line with the size of marketing budget and estimated children s exposure. This would have a deterrent effect. Sponsorship of sporting, cultural and music events by alcohol companies and brands should be prohibited. Such sponsorship should be phased out, and organisations assisted to source alternative funding. Branded merchandise should also be prohibited. 5 Restrict cinema advertising Alcohol advertising at cinemas should be prohibited for all films without an 18 classification. Whilst not all adult films have the highest certificate, this is the only way to ensure that children are not part of the audience. 3

6 Alcohol marketing and young people Alcohol consumption among children and young people in the UK is of widespread concern. Although the numbers of young people choosing not to drink have increased in very recent years, the amount consumed by those who do is high 7. Young people are particularly vulnerable to the effects of alcohol, and misuse contributes to a range of immediate and longer term risks. Heavy drinking in youth can affect executive functioning of developing brains and is linked to the decreasing age of liver disease onset 8. Alcohol-related deaths account for around 25% of all deaths in young men aged between 15 and Crucially, the early onset of drinking is also linked to the likelihood of dependence in later life 10. Alcohol advertising is one of a range of factors that increases the likelihood of starting to drink 11. The exact level of influence in percentage terms is difficult to define, but the Government has accepted the academic evidence that alcohol advertising is linked to consumption, particularly in under-18s 12. Clearly advertising is effective, or the industry would not spend 800 million in the UK each year promoting its products a figure likely to have increased in the period since it was calculated. Alcohol advertising commonly draws on themes of humour, sociability, physical attractiveness, success, adventure, fun activities, celebrity and music 13 ; content that is likely to appeal to young audiences 14. Subversion is noted as a growing theme, and alcohol ads often also emphasise sexual and social stereotyping. It is no surprise that a study of the impact of alcohol advertising on teenagers in Ireland found that alcohol advertisements were identified as their favourites, compared with other ads, by the majority of those surveyed 15. Alcohol advertising is linked to consumption, particularly in under 18s. The high volume of alcohol promotion in the UK may serve to normalise drinking, particularly amongst younger viewers. Compared to adults, children and young people in the UK are exposed to significantly more alcohol adverts than would be presumed, given their viewership patterns. Young people aged years are exposed to 11% more alcohol advertising than adults aged 25 years and older, and to 51% more advertising for ready-mixed drinks (generally high in sugar content and popularly referred to as alcopops) 16. A 2012 study in Wales of primary school children aged 10 and 11 found that 95% of participants recognised the Fosters and Stella Artois logos as being for alcoholic drinks a greater percentage than those who recognised Ben and Jerry s ice-cream or Mr Kipling cakes 17. 4

7 The shape of contemporary marketing In recent years the landscape of contemporary marketing has changed, marked by a rapid diversification of communication channels. Marketing expenditure has shifted away from traditional forms of direct advertising, broadcast or published to mass audiences through print, radio and television (known as above-the-line marketing), towards activities such as sponsorship, competitions and special promotions (known as below-the-line marketing). New technologies and the Internet in particular have helped reshape the extent and nature of marketing across our lives. Interactive digital communications that use the Internet, such as social networking sites, podcasts, blogs, tweets, video sharing and mobile phone devices (often referred to as new media ), offer innovative ways to recruit, engage and build relationships with consumers. In 2009 the UK became the first major economy in which advertisers spent more on the Internet than they did on television 18. Online social networking, through sites such as Facebook, is hugely popular particularly with younger people: 86% of year-olds in the UK say they have used the Internet for social networking 19. Such sites offer numerous different ways for marketers to promote their products, from paid-for banner advertising to brand profiles for people to like. Online video sharing sites such as YouTube allow access to enormous quantities of video content that can be embedded into social networking sites or forwarded, allowing them to go viral. With the growth of digital mobile technology, consumers increasingly carry the source of advertising communication around with them in their pockets. The vast majority of social networking sites have mobile-friendly versions, and 20% of the time spent by younger adults on social networking is actually via a mobile device 20. Bluetooth marketing that involves a device receiving an advertising message, often upon entering a particular vicinity, is increasing. Reflecting this movement, the volume of online alcohol adverts in the UK almost doubled between 2007 and Alcohol features prominently on online video sharing sites through user-generated clips and official video clips, and is widely marketed both formally and informally through social media. Today, almost all alcohol products have a dedicated website that often uses interactive features to grow the brand. Contemporary marketing contexts pose new and emerging challenges. New forms of marketing reach right across people s lives, integrating social and marketing activity, and are blurring the boundaries of what is traditionally considered advertising content. In a recent survey almost half of young people aged under 18 did not recognise alcohol product Facebook pages as marketing 22, potentially increasing their vulnerability to marketing messages. There is concern that below-theline and new media activity, particularly viewed by young audiences, is largely invisible to older groups and policymakers, with implications for the appropriateness of current policies intended to protect vulnerable populations 23. For example, the regulation of alcohol advertising on YouTube is not subject to the same regulatory oversight as televised broadcast and many banned adverts are available to be viewed on the site. 5

8 The regulation In the UK the regulation of advertising is a combination of self-regulation and co-regulation. The Advertising Standards Authority (ASA) is the UK s independent regulator, funded by advertisers through a levy on advertising spending. It applies the Advertising Codes written by the Committee of Advertising Practice (CAP). There are separate codes for broadcast and non-broadcast media, governing placement and content: the UK Code of Broadcast Advertising (BCAP Code); and the UK Code of Non-broadcast Advertising, Sales Promotion and Direct Marketing (CAP Code). Non-broadcast advertising, which includes digital and online marketing, is self-regulated, whilst the ASA regulates broadcast advertising under a contract from Ofcom. The main difference is that television advertising has to be cleared prior to transmission; with this exception, the system is primarily reliant on the public making complaints to the ASA. The ASA may conduct an investigation where it deems appropriate, and content found to contravene the codes may be requested to be withdrawn or amended. The ASA has the power to refer broadcasters to Ofcom for further action if needed, but instances of this are extremely rare. In the UK the regulation of advertising is a combination of self-regulation and co-regulation. 6

9 Alcohol advertising and youth perspectives: the work of YAAC The Youth Alcohol Advertising Council (YAAC) is a group of young people aged between 16 and 19 years, coordinated by Alcohol Concern, with the remit to scrutinise alcohol advertising against the BCAP and CAP codes from a younger person s perspective. After reviewing selected advertising, it is the group s task to decide whether to make a complaint to the ASA. YAAC was set up to give young people a voice in the debates about alcohol advertising policy, and to explore whether children and young people view the appeal of advertising content differently from the regulator. Since August 2011 the YAAC group has made 13 complaints about advertising content; three of which have been upheld by the ASA Council, leading to the withdrawal of content. Seven complaints have been rejected, one article was found not to fall under UK jurisdiction and two investigations are pending. The process has highlighted important weaknesses in the regulatory controls of alcohol marketing, as follows. 1. Reliant on public engagement With the exception of pre-vetted television adverts, regulatory controls are overly reliant on the public being familiar with the rules the majority is not and knowing how and where to complain about perceived infringements. In an increasingly fragmented media, marketing strategies that reach young audiences may be increasingly invisible to parents. Few parents are fully aware of the social media that their children access or the apps they have on their phones, which makes negative feedback unlikely, as young people may be less willing to engage in a formal complaints process. Public apathy or parental ignorance may be interpreted as a lack of concern, or worse implicit approval of the status quo. 2. Retrospective and slow Again, with the exception of pre-vetted television adverts, investigation is largely retrospective, taking place after a complaint has been made. Reactive regulation means that high numbers of young people can be exposed to inappropriate advertising before action is taken. One of the videos on the Frosty Jack s cider YouTube channel adjudged by the ASA to be particularly likely to appeal to children and young people under-18-years-old had been viewed by over 360,000 people by the time it was removed. The slow nature of the regulatory investigative process, which can take several months, compounds the problem. 3. Lack of meaningful penalties or deterrents The regulation lacks meaningful penalties and therefore sufficient deterrent threat to prevent advertisers from breaching the rules controlling content. The stated aim of the regulator is to work with advertisers to ensure compliance with the codes through a system powered and driven by a sense of corporate social responsibility amongst the advertising industry 24. The removal of offending content and the risk of negative publicity, cited as a key driver of compliance, may be insufficient deterrent. After several YAAC complaints, the early removal of offending content satisfied the ASA such that it did not investigate at all, and the advertiser avoided any negative publicity. 7

10 4. Weak control of Internet advertising Controls have failed to keep pace with the practices of digital and Internet advertising and are not designed to respond to the volume and real-time nature of alcohol marketing in the 21st century. In recent years significant marketing spend has moved online, in particular to social media where content on Facebook and Twitter is uploaded on a minute-by-minute basis. Internet and digital advertising, including fastmoving social media, appears seriously underregulated in comparison with broadcast advertising, which is largely pre-vetted. Recent brand posts on the Fireball Whisky Facebook page Non-broadcast advertising controls have a limited remit that leaves certain content beyond the code s reach. The CAP Code covering online alcohol advertising only addresses marketing communication that is directly connected with the supply or transfer of goods and services 25. This leaves content that is editorial by nature, such as some blogs and uploads, outside the CAP Code remit. A YAAC complaint about pop music videos and viral video clips posted on the Sourz website with the sign-off Sourz Team xx was rejected by the ASA. Despite young people saying the content appeared designed to appeal to them, the video uploads, complete with brand sign-off, were deemed not to be directly connected with the supply or transfer of goods, and therefore judged to fall outside the CAP Code remit (see top of opposite page). 8

11 Video upload and brand sign-off on the Sourz website The ASA limits its investigations to content on social media that was uploaded in the previous three months. At the time of writing, inappropriate content that is still viewable on social media but was posted more than three months ago effectively sits beyond regulation. Young people complained that the content posted on the Foster s Facebook page suggested that drinking Foster s would enhance social success and promoted the use of alcohol for relaxation. The ASA refused to investigate the complaint as the content was posted more than three months ago (see below). 5. The spirit of the codes is rarely applied The first rule of compliance in the BCAP and CAP codes is that advertising must reflect the spirit, not merely the letter, of the rules. YAAC found various instances of alcohol advertising making strong associations with themes such as social success, sexual activity and increased confidence associations that are supposed to be prohibited by the codes. The ASA s investigation of young people s complaints suggests that interpretation of the rules is narrow and at times overlooks the spirit behind the codes. Examples of brand posts on the Foster s Facebook pages 9

12 For example, in 2012 YAAC made complaints to the ASA about ads for Bulmers cider, Estrella beer and Smirnoff vodka complaints that were rejected, in part, on the basis that characters were not seen consuming alcohol. In each of the ads a character was portrayed holding a bottle or a glass of the product, yet this was interpreted as an insufficient portrayal of consumption. Such literal interpretation of the codes leaves creative space to make strong associations about alcohol without actually breaching the rules. Similarly, the ASA s response to a complaint about Lambrini advertising appears to misunderstand the basic principles of marketing. The ad portrays a series of characters in dreary circumstances having an X-factor style moment of flamboyance or fame. The ASA s response suggested that the message is here are some extrovert people; if you are like them, you might like our product too, when clearly it implies if you aspire to be like these extrovert people, do what they presumably do and use our product. It may well be that spirit of the code clauses are unenforceable for practical purposes. While it is easy for the regulator to show that an advert does not say our product will make you sexy, cool, sophisticated and successful, it is more difficult to show that this message is not implied. A prescriptive system is needed which establishes what can, rather than what cannot, be said. Lambrini television advert (2012) 10

13 Rebalancing regulation The relationship between alcohol advertising and consumption, particularly amongst under-18s, is accepted by Government. The precise degree of influence advertising has on consumption is difficult if not impossible to define, but advertising is used to strengthen social norms around alcohol and to promote consumption as a normal part of, if not central to, a full life. In light of the emerging evidence, there is a strong case for a measured rebalancing of regulation. Alcohol Concern believes that, as the weight of evidence grows, so too will calls for a total ban on alcohol advertising. Regardless, there is an immediate need for a revised framework of regulation that is more effective and more proportionate to the potential harms. Despite existing controls, children are exposed to large volumes of alcohol marketing and are highly aware of alcohol brands. The YAAC group has found that alcohol marketing, contrary to the codes, often appeals to young people and makes associations with prohibited themes. Regulation is overly reliant on corporate social responsibility, lacks deterrent capacity and needs to be put on a statutory footing. Our proposals are for a partial, not a total, ban on alcohol advertising that places restrictions on where and how alcohol is promoted. The proposals draw on elements of France s Loi Evin, adapted to the UK s social and cultural context, and prioritise the protection of young people whilst allowing alcohol producers to promote their products responsibly. Implementation could be achieved through an enabling statute from Government that put responsibility on a statutory footing under the arm of an agency such as Ofcom, with expanded remit for broadcast and non-broadcast advertising; and the power to issue meaningful sanctions such as fines, enforceable through the courts. Via the Loi Evin such measures have already been legally road-tested in the highest European courts, meaning a potential obstacle to implementation has been removed. Three key elements would make up an effective and balanced regulatory framework, which would serve to protect children and young people from harmful influence whilst enabling the alcohol and advertising industries to continue to function responsibly. 1. Stick to the facts As with the Loi Evin, where alcohol marketing is permitted, it should be restricted to messages and images that refer to the characteristics of the product, such as strength, origin, composition, and means of production. It should also be accompanied by a clear health message. Characters, celebrities, lifestyle images of drinkers or scenes depicting a drinking atmosphere should not be permissible, as restricting this type of advertising content is likely to reduce the appeal to youthful audiences. In France, these sanctions have resulted in the language of alcohol advertising losing most of its seductive character, together with a complete disappearance of the drinker and drinking environments from the imagery, in favour of highlighting the product itself. In the example from France an association with sexuality has been replaced by an emphasis on the refreshing nature of the product in post-loi Evin advertising (see overleaf). 11

14 Before introduction of the Loi Evin 2. Limit channels of promotion Like other forms of marketing, sponsorship and branded merchandise give alcohol companies a platform for developing positive associations with their products, and often associate alcohol with lifestyle aspirations. It may be difficult to prevent underage exposure to alcohol sponsorship of sporting, cultural or music events, or branded merchandise, and alcohol sponsorship of sport in particular sends contradictory messages about the health benefits of participation. Alcohol sponsorship and branded merchandise should not be permitted. Successful implementation of such a ban can be managed, as the phased removal of tobacco sponsorship from sports such as Formula One motor racing has demonstrated. It is also possible to implement such a ban and still be part of pan-european sporting competition. The Heineken cup, the premier European rugby competition, is known as the H cup in France due to the restrictions on alcohol sponsorship resulting from the Loi Evin. For these same reasons, and because of the high potential of underage exposure, alcohol advertising in cinemas should only be permitted for films with an 18 certificate. All other forms of alcohol advertising that stick to the facts may be permitted. 3. Statutory and independent oversight The regulatory body, the ASA, lacks meaningful mechanisms for pro-active investigation of potential advertising breaches. Apart from the clearance of television advertising prior to transmission, the regulator is largely 12

15 After introduction of the Loi Evin dependent on complaints from the public for the identification and address of breaches of the codes. Many people remain unaware of the codes, let alone the complaints procedure. Marketing that targets niche audiences such as young people can be largely invisible to the adult population, and these groups may be less critical or inclined to go through a formal complaints process. Since August 2011 three YAAC complaints have been upheld two for content that would be likely to appeal particularly to those aged under 18. In each case the companies involved were instructed to withdraw the content in its current form. Seven other YAAC complaints were not upheld. A disparity exists between young people s perceptions of the messages and appeal of alcohol advertising content and the ASA s judgements. In 2009, according to the ASA compliance survey, alcohol advertising was 99.7% compliant with the codes 26. Do the adults responsible for regulating advertising actually know where and how children and young people are exposed to alcohol advertising content? Or indeed what appeals to them? Advertising self-regulation has proven insufficient 27. Supporters of the model claim it is better able to adapt to market conditions than statutory intervention, but the regulator has been seriously behind the curve of new practices in digital and Internet advertising. Regulation of alcohol marketing needs to be put on a statutory footing independent of alcohol or advertising industries, matching best practice in other fields. The regulator needs to be able to apply meaningful sanctions, such as fines, that deter non-compliance. 13

16 Conclusion Advertising is used to create social norms around alcohol and promotes the normalisation of drinking in society. Exposure to alcohol marketing is linked to consumption, particularly in under- 18s. Earlier onset of drinking is associated with a range of risks, including an increased likelihood of dependence later in life. In light of the growing body of evidence, a sensible policy response is a system of controls that robustly protects those who are underage. The UK currently has a system of regulatory controls that focuses primarily on the content of alcohol advertisements, with some limitations on the channels that can be used. Young people involved in YAAC have shown how minors are exposed to content which appeals to them, particularly via social media, and how advertisers continue to make associations with prohibited themes despite the controls. Advertisers exploit the weak rules to develop content that appeals to both adults and young people 28. Audience thresholds limiting the percentage of minors insufficiently shield those underage. Children and young people in the UK aged years are today exposed to significantly more alcohol adverts than adults than would be expected, given their viewership patterns 29. Alcohol Concern is calling for a better balance between public health concerns and commercial freedoms. Greater restrictions on the content and channels of alcohol promotion are likely to undermine the appeal to underage audiences and reduce volumes of underage exposure. Advertising self-regulation is insufficient. Regulation needs to be independent of interested industries and given real teeth. A model that draws on the principles of France s Loi Evin still allows for the promotion of alcohol brands, but within a framework of effective regulatory controls that balances commercial with public interest. Alcohol Concern is calling for a better balance between public health concerns and commercial freedoms. 14

17 Policy recommendations Only advertise product characteristics Statutory and independent regulation Meaningful sanctions Prohibit sponsorship Where advertising is permitted, messages and images should only refer to the characteristics of the product s strength, origin, composition, and means of production. Promotion of lifestyle images of drinkers or scenes depicting a drinking atmosphere should be prohibited. Regulation of alcohol promotion should be statutory and independent of alcohol and advertising industries. Regulation of digital and online content in particular is challenging, and experience from within the UK and abroad has demonstrated that self-regulation is failing to adequately protect children and young people. Meaningful sanctions such as fines for serious non-compliance with marketing regulations should be introduced in line with the size of marketing budget and estimated children s exposure. This would have a deterrent effect. Sponsorship of sporting, cultural and music events by alcohol companies and brands should be prohibited. Such sponsorship should be phased out, and organisations assisted to source alternative funding. Branded merchandise should also be prohibited. 5 Restrict cinema advertising Alcohol advertising at cinemas should be prohibited for all films without an 18 classification. Whilst not all adult films have the highest certificate, this is the only way to ensure that children are not part of the audience. 15

18 References 1 Cabinet Office. Strategy unit alcohol harm reduction project: 8 interim analytical report, 2003: Winpenny, E. et al, Assessment of young people s exposure to alcohol marketing in audiovisual and online media (2012), RAND Europe 3 Alcohol Concern Cymru, Making an Impression: Recognition of alcohol brands amongst primary school children (2012) 4 HM Government, The Government Alcohol Strategy (2012) 5 World Health Organisation Europe (2009), Handbook for action to reduce alcohol-related harm, Copenhagen, World Health Organisation, p.29 6 Ibid 7 NHS Information Centre, Smoking, drinking and drug use among young people in England 2011, London (2012) 8 Chief Medical Officer for England, Guidance on the consumption of alcohol by children and young people, Dept of Health (2009), p.8 9 European Commission, Public Health, available from: [accessed 11/1/13] 10 Chief Medical Officer for England, Guidance on the consumption of alcohol by children and young people, Dept of Health (2009) 11 Smith, L., Foxcroft, D, The Effect of Alcohol Advertising and Marketing on Drinking Behaviour in Young People, Alcohol Education Research Council (November 2007) 12 HM Government, The Government Alcohol Strategy (2012) 13 Babor, T. et al, Alcohol no ordinary commodity: research and public policy, Second edition (2010), p Chen, M.J. et al, Alcohol advertising: What makes it attractive to youth? Journal Health Communications 10 (2005) 15 Dring, C., Hope, A., The impact of alcohol advertising on teenagers in Ireland, Health Promotion Unit, Department of Health and Children (2001) 16 Winpenny, E. et al, Assessment of young people s exposure to alcohol marketing in audiovisual and online media (2012), RAND Europe 17 Alcohol Concern Cymru, Making an Impression: Recognition of alcohol brands by primary school children (2012) 18 Sweney, M., UK advertisers spend more on Internet than TV, Guardian, 30 September Ofcom website, available from: [accessed 11/1/13] 20 Ofcom website: [accessed ] 21 Advertising Standards Agency (2009), Alcohol drinks advertisements compliance survey 2008, online, available from: [accessed 11/1/13] 22 Alcohol Concern, Overexposed and overlooked: Young people s views on the regulation of alcohol promotion (2011) 23 Caswell, S. (2004) in Babor, T. et al, Alcohol no ordinary commodity: research and public policy, Second edition (2010), p Advertising Standards Agency, Self-regulation of non-broadcast advertising [accessed ] 25 Advertising Standards Agency The CAP Code, [accessed ] 26 Advertising Standards Agency, Compliance report: Alcohol advertising survey 2009 (2009) 27 Hastings, G., Brooks, O. et al, Alcohol advertising: the last chance saloon: Failure of self-regulation of UK alcohol advertising, British Medical Journal (BMJ) (International Ed) (2010), 340: European Centre for Monitoring of Alcohol Advertising [accessed ], alcohol-marketing?utm_source=eucam+newsletter&utm_campaign=c50415aab2- EUCAM_Newsletter_january+2013_20122_27_2012&utm_medium= #p Winpenny, E. et al, Assessment of young people s exposure to alcohol marketing in audiovisual and online media (2012), RAND Europe 16

19 Alcohol Concern Alcohol Concern is the leading national charity working on alcohol issues. Our goal is to improve people s lives through reducing the harm caused by alcohol. We have an ambitious long-term aim to change the drinking culture in this country. We want to live in a world where people can manage the risks and make sense of alcohol.

20 Alcohol advertising regulation that balances commercial and public interest Published by Alcohol Concern Suite B5, West Wing, New City Cloisters 196 Old Street, London EC1V 9FR Tel: Website: Registered Charity No Copyright: Alcohol Concern May 2013 Alcohol Concern Making Sense of Alcohol