On the 19th September 2019, the European Centre for Monitoring Alcohol Marketing (EUCAM)) together with the Centre for Health Communication of the University of Amsterdam and the European Alcohol Policy Alliance (Eurocare) organised a conference about digital alcohol marketing. The first goal of the conference was to present and discuss the most recent scientific information about the impact on young people of alcohol marketing via social media. The second goal was to try to find an answer to the question of how to regulate these relatively new marketing tactics effectively.
This document outlines the key conclusions of the conference.
What we know about digital alcohol marketing
The conference Digital Alcohol Marketing in the Spotlight included a comprehensive overview of alcohol marketing through digital media, ranging from established findings to emergent research on new and innovative forms of alcohol marketing.
Young people are exposed to alcohol marketing through a sophisticated
and interactive ‘digital marketing mix’.
This includes paid-for media (e.g. banner adverts, promoted posts, or adverts on video sharing platforms), brand owned media (e.g. websites, social media pages or smartphone apps), and convergent marketing which appears ‘under the radar’ (e.g. paid-partnerships with social influencers).
Alcohol marketing through digital media provides a high-profile opportunity to reach and interact with young people.
Such marketing is particularly powerful because it can be accessed and delivered almost anywhere (e.g. through smartphone and tablets), real-time data can be used to target marketing at particular audiences, making it almost impossible to track and report, and because digital media can extend the reach and influence of traditional marketing activities (e.g. sport sponsorship).
Internet users also engage in alcohol promotion, both by interacting with commercial marketing and by creating and sharing user-created promotion. Examples of user-shared promotion include the viral Neknominate-phenomenon or users posting photos documenting their own drinking experiences. Such content poses unique challenges as it often falls outside of regulated spaces, is not subject to controls or regulations of what messages can be promoted (e.g. excessive or high risk consumption), and perceived peer endorsement may enhance the message influence. It is important to consider both commercial and user-created content in tandem, because neither exist in a vacuum. They interact and overlap with each other and young people are exposed to both forms of content simultaneously.
Digital marketing consistently portrays alcohol in a highly positive and salient fashion giving the impression that alcohol consumption leads to social success.
For traditional media such as TV, linking alcohol with social success could go against EU marketing rules, however, on social media this is tolerated. This is particularly true for alcohol marketing using social influencers (e.g. through Instagram) where the products and brands are shown to be part of aspirational, desirable, social, popular and fashionable lifestyles and identities.
Effective digital promotion of lower-risk consumption or messages to discourage alcohol consumption amongst young people has considerable limitations.
Specifically, such messages are either absent altogether, positioned in a way that minimises visibility and audience attention, or present strategically ambiguous messages around ‘responsibility’.
Young people report awareness of, and participation with, a range of digital alcohol marketing.
Mid-2019, almost half of 11-19 year olds in the United Kingdom had seen alcohol marketing on social media in the past month , one in four saw it at least weekly , and over one-in-ten had participated with a form of alcohol marketing on social media . These estimates are even higher among younger adults above the legal purchasing age in the UK (e.g. 18- 25 year olds) . Because these studies are based on self-reporting, these findings are likely to be underestimates given the challenges involved in remembering what marketing has been seen or recognising it as marketing in the first place.
Exposure to digital alcohol marketing is associated with alcohol-related attitudes and consumption among young people, including higher-risk consumption.
Emergent research on digital alcohol marketing confirms the well-documented association between exposure to alcohol marketing and youth alcohol consumption behaviours. Even though many existing studies on digital media are cross-sectional, the fact that there is any association at all suggests that marketing must play a role in driving consumption (i.e. either initiating or reinforcing) and that reducing marketing exposure will have positive effects.
Key principles of effective alcohol marketing regulation
The conference Digital Alcohol Marketing in the Spotlight covered the scientific research on regulating alcohol marketing , and the national experiences of alcohol marketing regulation.
Volume restrictions are more effective than content restrictions.
The research is clear that exposure to alcohol advertising drives harmful consumption effects. Regulations restricting the volume of alcohol advertising (i.e. full or partial bans) are thereby more effective at reducing exposure than regulation seeking to limit the shape, content or form of such advertising. In addition, volume restrictions are easier and cheaper to enforce as they don’t require individual content analysis.
Comprehensive media-neutral legislation is more effective than partial or media specific rules.
Comprehensive media-neutral legislation ensures that new forms of marketing will automatically be covered by legislation. This avoids technical developments, or unforeseen loop-holes, leading to certain types of marketing becoming unregulated, such as digital media in many countries today. Comprehensive regulation avoids substitutive effects (i.e. marketing expenditure shifting rather than reducing).
The more difficult it is to monitor alcohol marketing on a platform, the stronger the need for encompassing volume restrictions (bans).
If legal compliance is difficult to monitor, which is the case with fast moving individually targeted ads on digital platforms, monitoring, upholding and enforcing content restrictions becomes difficult and expensive for the responsible authority. Bans ensure that platforms remove the possibility for advertisers to send alcohol advertising.
If used, it is more effective for content restrictions to define what is legal than what is illegal.
Loi-Évin-style legislation, defining what content that is legal to include in alcohol advertising (as opposed to what is illegal) simplifies monitoring and enforcement by avoiding grey-zones, unforeseen content or policy drift in what can and can’t be shown. It also makes the rules easier to understand for citizens, who are often relied on to report non-compliant marketing.
Warning messages & health information are more effective when developed independently from commercial vested interests.
Warning messages accompanying advertising carry less strategic ambiguity when defined by governments and independent health experts, as opposed to actors affiliated with the alcohol industry.
Self-regulation is not effective at reducing youth exposure to alcohol advertising.
There is conclusive evidence that industry self-regulation, including voluntary digital age- verification mechanisms, does not reduce youth exposure to alcohol advertising.
The closer a regulatory framework fulfils the above criteria, the better outcomes can be expected in terms of reduced alcohol-related harm. Encompassing, media-neutral, alcohol advertising bans, which have been enacted in Norway and Lithuania, are good examples. The efficiency of less comprehensive policy options can also be estimated based on these criteria: For example, alcohol advertising bans covering the whole digital sphere are more effective than if they just cover social media. Similarly, Loi Évin-style content restrictions including government mandated health warnings are more effective than content specific social media restrictions. Finland provides an example of content specific social media restrictions. Although there is evidence of declining trend in the use of restricted content, the regulation has not kept alcohol brands from creating engaging social media content and reaching young people. Almost all forms of statutory regulations combined with clear enforcement and sanctions have proven more effective than self-regulation by affected industries.