From Alcohol Action Ireland
Alcohol Action Ireland (AAI), the national independent advocate for reducing alcohol harm, welcomes the publication of the General Scheme of the Online Safety & Media Regulation Bill.
The AAI argued that children’s exposure to Internet alcohol marketing should be listed as ‘harmful content’
The AAI also notes that as per the Annex to the Regulatory Impact Analysis this Bill does not consider that alcohol marketing falls into the ‘harmful content’ category but rather that it may be classified as ‘inappropriate content’.
After listing several reasons why alcohol marketing is adapting to new realities faster than the current legislations across Ireland in an unregulated market, the AAI believes the Bill’s approach represents a missed opportunity to protect children from the insidious practices of corporate entities that track, profile and target young people to market harmful and addictive alcohol products.
In the report AAI underlines how the international experts’ community on children’s health and rights alleges how large companies incorporate the science of the life course approach into their marketing, to achieve the adherence and fidelity of children to capture future consumption.
The Annex to the Regulatory Impact Analysis also asserts that alcohol marketing is dealt with under the Public Health Alcohol Act, 2018 (PHAA). But while it is the case that PHAA (section 14) prohibits the advertising of alcohol within 200 meters of schools and playgrounds in public service vehicles, and at public transport stops or stations, the Act is silent on how children will be protected from online exposure to commercial exploitation by corporate alcohol interests; suggesting that online alcohol marketing is not dealt with under the PHAA.
The UN Committee on the Rights of the Child (UNCRC), that recently published the General Comment 25 on children’s rights in relation to the digital environment, also urges states to take a vigorous stance against the exposure of children to digital marketing of unhealthy products, including alcohol and junk food and recommends that state parties have appropriate independent institutions to monitor children’s rights in the digital environment.
AAI believes that the online safety commissioner must have the power to ensure that advertisers of alcohol do not advertise an alcohol product, unless, as with tobacco, all reasonable steps are taken to ensure that the advertising cannot be viewed by children10 including:
- age verification controls
- demographic targeting to ensure that the advertisement is not displayed to children
- ensuring the advertisement has been labelled or registered in a way which permits it to be blocked by parental filtering software
- ensuring the advertisement does not invite users to share it with others.
Link to the full report: https://alcoholireland.ie/download/publications/Online-Safety-Media-Reg_GeneralScheme_Obs.pdf.