Conferece Cross-Border Aspects in Alcohol Policy Tackling Harmful Use of Alcohol Official event in the programme of the Estonian Presidency of the Council of the European Union 30-31 October 2017, Tallinn, Estonia Cross-border marketing of alcoholic beverages Background paper The marketing of alcohol has become a dominant issue in the alcohol policy debate, both nationally and at EU level, with much attention being paid to questions such as the regulation of alcohol advertising, alcohol sports sponsorship and promotional and sales practices which might encourage unhealthy or undesirable patterns of consumption. Several studies have concluded that alcohol marketing communications have a powerful effect on young people and are independently linked with the onset, amount and continuance of their drinking. In addition, the self-regulatory codes of practice governing alcohol marketing do not provide sufficient protection to this demographic. Alcohol a heavily marketed good Marketing can be understood as a mix of sophisticated, integrated strategies, grouped around four main elements: the product, its price, its place (distribution) and its promotion. All four elements have ways of contributing to marketing, such as product design and brand name (product), pricing strategy and wholesale (pricing), distribution channels and placing within retail establishments (place) and promotional strategy, advertising, sales promotion and public relations (promotion). This mix of marketing strategies makes alcohol marketing a complex issue. When extended to an online reality, the complexity expands. Alcohol is a heavyly marketed commodity. EGTA (Association of Television and Radio Sales Houses) estimated a total alcohol advertising spending of the alcohol sector in Europe of 1755.56 million in 2005, 1677.19 million in 2006 and 1458.39 million in 2007, where TV advertising representing the major share, close to 50% in all years. The alcohol market has showed tendency of a concentration of international corporations, where the market is dominated by a few big companies. A concentrated industry results in higher levels of advertising. How Does Marketing Work?
A simple view on alcohol marketing is that advertising primarily works by changing consumer attitudes to a product or by increasing brand salience before changes in behavioural patterns occur. Public health researchers have been assessing the impact of alcohol marketing on consumers and there appears to be a consensus that traditional advertising and other forms of marketing indeed influence children Three core consequences of alcohol marketing are being confirmed from different kind of research: 1) association between exposure and drinking/alcohol use initiation, 2)increased drinking/alcohol use among young drinkers, and 3) frequency of drinking/alcohol use. and young people in the direction of increasing the likelihood of their beginning to drink, and on the amount consumed. Three core consequences of alcohol marketing are being confirmed from different kind of research: 1) association between exposure and drinking/alcohol use initiation, 2) increased drinking/alcohol use among young drinkers, and 3) frequency of drinking/alcohol use. These findings are confirmed by both individual studies and by systematic reviews of existing literature. The Science Group of the European Alcohol and Health Forum also highlight the same issues in their report from 2009, namely that commercial communications increase the likelihood that adolescents will start to use alcohol and to drink more it they are already using alcohol. 2 It is also important to pay attention to other factors when it comes to alcohol marketing, which relates to the very core issues of marketing; branding and expression of lifestyle and identity. Alcohol brands and consumption is part of an expression of lifestyle and identity among young people. This is an even more crucial point when linking it with social networks and the possibilities for viral marketing, where consumers actively take part in the marketing as part of their own identity. Traditional Marketing Traditional marketing includes TV, cinema and billboards advertisement, product placement, price changes and sponsorship. The most important issues in this section are the content and volume of marketing, which can be restricted to reduce alcohol consumption. Volume restrictions on alcohol advertisement are predominantly embedded in (national) statutory regulations. For example, the member states can establish the hours in a day during which alcohol advertising can be played on television and radio, or they can establish areas (such as around schools), where billboards advertisement is prohibited. Unfortunately, the current extent of restrictions on traditional marketing has not yielded sufficient results. Results from the AMMIE research show that alcohol producers use the same amount of money on adverts, increasing the exposure during the hours when alcohol advertising is allowed. The project suggests that in order to use the hours restriction effectively, it would need to be extended to 11pm. In contrast to volume restrictions, in most countries, the content restrictions are rarely established by the government, though France is a notable exception here. Instead, the content restrictions are often found in non-statutory regulations and selfregulatory codes. These codes are created by the alcohol advertisers themselves.
3 French exception Loi Evin regulates traditional alcohol marketing. The Loi Evin gives a clear definition of what an alcoholic drink is, and outlines the conditions for commercial communication by defining places and media where advertising is authorised: 1) No advertising should be targeted at young people; 2) No advertising is allowed on television or in cinemas; 3) No sponsorship of cultural or sport events is permitted. Advertising is permitted only in the press for adults, on billboards, on radio channels (under precise conditions), at special events or places such as wine fairs, wine museums. When advertising is permitted, its content is controlled: messages and images should refer only to the qualities of the products such as degree, origin, composition, means of production, patterns of consumption. A health message must be included on each advertisement to the effect that l abus d alcool est dangereux pour la santé ( alcohol abuse is dangerous for health ). Since 1991, a real change in alcohol advertising is observable in France as a result of the Loi Evin: the law has modified the language of advertising which has lost most of its seductive character. Digital Marketing Young Europeans (16-24 years old) spend more time on internet than watching TV. Internet is therefore an important platform for advertising and branding. In 2007, the drinks companies increased their web expenditure by 70%, while traditional forms of advertising declined. Internet is not simply replacing traditional forms of advertisement, but extends existing channels used in the traditional marketing, and introduces new techniques in marketing, such as viral and content marketing techniques. First concern with digital marketing is volume, where there is a non-stop access for exposing marketing messages. In addition, information online is available long-term and on other conditions than when broadcasted on TV, e.g. TV adverts which have been banned can be found online after being banned. Finnish example: In January 2015, new restrictions on the advertising of alcoholic beverages entered into force in Finland. The restrictions represent a novel approach as they are focused on techniques used in alcohol advertising, rather than the media used or features of the content of advertisements. The restrictions introduce a ban on games, lotteries and competitions, as well as on peer-to-peer sharing (viral advertising) and the use of consumer-generated content in the marketing of alcoholic beverages. These restrictions were intended to and they do target primarily alcohol advertising in social media The second concern is insufficient age control, both in terms of it s frequency and efficiency. Alcohol adverts on YouTube are the most popular among the age group 13-17, and the terms under which the content is available differ from those of TV. Often, commercials that have been
banned on TV could potentially be available online. On sites with age verification, the process is questionable since there is no way to prevent underage users from entering fictitious date of birth. 4 The third concern is the viral, gamefied and content marketing techniques, where consumers are used as active players in the marketing through interactive methods. The development of consumers own alcohol brand related pages and groups on social networking sites bring up many challenges on topics such as regulations, access, rights and ownership of the use of content. User-generated content, where consumers are uploading pictures etc, is an important part of this issue. Lack of monitoring opportunities is the fourth concern. In order to ensure the effectiveness of existing alcohol marketing regulations and to ensure enforcement, monitoring of alcohol marketing is needed. Cross-border nature of the internet makes concerted and actionable monitoring less likely. Self regulation and co-regulation Self-regulation and co-regulation are policy approaches where the alcohol industry and retailers promise to regulate their own business according to an agreed set of codes, to make statutory regulation unnecessary. Self-regulation in alcohol marketing addresses both the issue of content (codes of practice, e.g. on social success) and volume (e.g. not more than 30% of the audience under legal drinking age), and is used for both traditional and digital marketing. Selfregulation is most commonly adopted by the industries under threat of governmental regulation. Overwhelming evidence from decades of research has demonstrated that alcohol industry selfregulation is an inefficient way to curb alcohol consumption or alcohol-related harms. Instead, alcohol industry self-regulation is likely to increase positive, socially responsible value of alcohol brands and has been shown to delay more efficient statutory national level restrictions. Since the volume of alcohol advertisement shown to minors is not uniformly restricted in Europe, the alcohol industry has set a voluntary code, suggesting that no more than 30% of the audience of specific alcohol ads should be minors. This approach fails to reduce the exposure of alcohol marketing to minors. While the percentages might be nominally low, the number of minors exposed to the adverts is still very large. For example, during big cultural shows and sports events, the proportion of minors present in the audience at a stadium may small, but through broadcast and event advertising, many more will be exposed to the advertising messages. For an example from a cultural show in the Netherlands, the percentage of viewers ages 6-17 in a cultural show in the Netherlands was only 15.4%, but as many as 362 244 minors were exposed.
5 AudioVisual MediaServices Directive The regulation of alcohol Marketing is a shared competence in EU Member States have a right to set up their own regulations, given that these regulations are in accordance with the principles of Single Market and the regulations of the Union. At EU level, the minimum regulation is provided by the Audiovisual Media Services Directive (AVMSD). The objective of AVMSD is to create and ensure the proper functioning of a single European market for audiovisual media services, while contributing to the promotion of cultural diversity, providing an adequate level of consumer protection and safeguarding media pluralism. In May 2016, the European Commission (EC) adopted a proposal to revise the Audio Visual Media Service Directive (AVMSD). This revision of the current Directive provides an unique opportunity to tackle the adverse impact that the marketing of unhealthy food and drink products has on health behaviour of among children and young people.