The government is concerned about the health and crime implications of heavy drinking. If these proposals see the light of day, advertising, marketing and labelling of alcoholic drinks will all be affected.
Who: The Prime Minister's Strategy Unit
When: March 2004
With a foreword from the Prime Minster himself the UK Government's cabinet office has published a paper entitled "Alcohol Harm Reduction Strategy for England". Citing antisocial behaviour and harm to health as the two major problems which alcohol misuse causes, the document sets out a strategy for tackling the problem. The proposals have four strands. These are the improvement of health and treatment services, combating alcohol related crime and disorder, better education and communication and working with the alcohol industry. These last two have a significant advertising, promotion and labelling relating element.
Better education and communication
A strong theme here is the formulation and communication of a "revised sensible drinking message". The paper acknowledges the work of the Portman Group, set up in 1989 by the UK's leading alcohol producers to promote sensible drinking, but it clearly feels that more needs to be done.
Health warnings on labels?
Health warning labels on alcoholic beverage containers are mentioned as having been introduced on a statutory basis in a number of countries worldwide including the US. Here there is currently no health warning label legislation, but the paper mentions the current review by the European Commission of existing EU nutrition labelling legislation. As part of this process it is considering the case for compulsory nutrition labelling on all pre-packaged foods and drinks, which may well include alcoholic beverages.
Having said this, the paper goes on to report that "further extensive research conducted in the US reports no significant change in drinking behaviour as a result of [health warning labels]". The paper continues, however, "labels provide an excellent way of disseminating information and – depending on their content – may play a useful role in raising awareness and in educating drinkers about the risks associated with alcohol misuse".
Sensible drinking messages on labels
The alcohol industry will therefore be "strongly encouraged," the paper goes on, to add messages encouraging sensible consumption to product labels. A statutory approach to labelling here would need to be cleared under EU legislation, so it is suggested that for the moment there should be voluntary arrangements under the aegis of the "Social Responsibility Charter for Drinks Producers" which the paper proposes as part of the "Working with the alcohol industry" strand of its proposals.
The Social Responsibility Scheme will also encourage alcohol retailers, both on and off licence, to display information setting out the sensible drinking message and explaining what a unit is and how it translates in practical terms to the drinks sold.
The Social Responsibility Scheme will also urge the industry to display a reminder about responsible drinking on its advertisements.
The paper reports that the UK alcoholic drinks industry spends over £200 million per year on direct alcohol advertising. "With this commercial right" the paper goes on, "comes the responsibility to ensure that advertising does not glamourise or condone harmful drinking behaviour".
Consultation on the strategy in the paper revealed widespread concern that some alcohol advertisements breach the spirit, if not the letter, of the TV advertising code for alcohol.
There is a clear case, the paper goes on, for tightening existing rules on the content of advertising. To work well:
the existing codes need to set out unequivocally the issues which the rules are designed to address but be flexible enough to allow the regulator to pursue the public interest whatever new creative techniques may emerge;
the code needs to be systematically and rigorously enforced by the Broadcast Advertising Clearance Centre, where TV advertisements are pre-cleared, focusing not just on causing offence but more broadly on potential to condone or encourage misuse, taking account of all available relevant research; and
the industry itself has to take a more responsible attitude to prove that self regulation can be made to work effectively.
Concluding this section, the paper requires Ofcom to conduct a "fundamental review" of the code rules on alcohol advertising and their enforcement. The review will focus in particular on:
ensuring that ads do not target under 18s;
ensuring that ads do not encourage or celebrate irresponsible behaviour;
the potential of ads to encourage alcohol misuse as well as the simple potential to cause offence; and
ensuring that as part of its wider duty to publicise its remit, Ofcom ensures publicity for the regulator's role.
The paper says that the alcohol industry has a vital role in helping to prevent and tackle the harms caused by alcohol misuse, but whilst there are many excellent initiatives, corporate social responsibility in the alcohol industry is currently patchy and not well coordinated. To deal with this, the Government proposes to work with alcohol producers at a national level to set up a scheme to reduce harmful drinking. It will involve responsible producers seeking accreditation. Accreditation criteria might include:
agreement not to manufacture irresponsibly – for example products apparently targeting underage drinkers or encouraging drinkers to drink well over recommended limits;
agreement to observe advertising codes;
conforming to the Portman Group's existing code on packaging;
an agreement to put the sensible drinking message on bottles alongside information about unit content; and
moving towards packaging products in safer materials.
The plan is to establish the scheme by Q1 2005 and to review the success of the voluntary approach early in the next parliament. If industry actions are not beginning to make an impact in reducing harm, the government will assess the case for additional steps, including possibly legislation.
Why this matters:
Overall the paper is crisp, purposeful and laden with action points. But there is some sloppy thinking. For instance the required Ofcom review of alcohol advertising seems to overlook the fact that Ofcom is not responsible for the regulation of non broadcast alcohol advertising, and there is also an uncomfortable overlap and blurring of the edges between the initiative quoted by this paper and the separate, parallel "Choosing health?" consultation which will apparently lead to specific proposals by Q4 2004, proposals which will again, by all accounts, relate in part to advertising marketing promotion of alcoholic drinks.
Nevertheless, the Government clearly means business and to ward off the threat of tighter code controls and legislation, alcohol advertisers should be taking steps now to reduce still further the instances of upheld complaints over alcohol advertising and promotion.