Alcohol advertising debates need to move beyond content

Ahead of the launch of a report on alcohol marketing on Facebook tonight Sven Brodmerkel and Nicholas Carah urge the ad industry to embrace a more open conversation about the effects targeting will have on this form of advertising. 

A few weeks ago The Australian National Preventive Health Agency (ANPHA) recommended in a draft report that the Alcohol Beverages Advertising Code (ABAC) should include all forms of marketing within its self-regulatory scope.

This position has been met with opposition not only by the Australian Association of National Advertisers (AANA) some creative industries and the alcohol industry. Mike O’Rourke from Bloke argues that culture in general, and parents’ behaviour at home in particular is much more important in shaping children’s attitude towards alcohol than advertising. He also makes the point that tighter regulation will only lead to agencies finding even more creative ways to advertise alcohol.



In that he might be right. But should we then draw the conclusion that attempts to regulate alcohol advertising are futile? As a first step we need to address whether the existing regulatory codes are based on principles that enable them to easily adapt to advertising innovation over time.

Let’s for example take the case of alcohol advertising on Facebook. Alcohol brand activity on Facebook is extensive. The alcohol industry has been especially innovative in the development of participatory and data-driven mode of branding on Facebook. Alcohol brands are also developing innovative uses of Instagram that integrate consumer participation and real-world promotions with social and mobile media. These activities challenge a regulatory framework based on making judgments about the content of advertisements.

There has been some public debate about the activity of alcohol brands on Facebook. Much of this discussion has focussed on the content of brand messages. It is easy to locate on Facebook examples of brand content promoting or celebrating excessive consumption of alcohol, and expressing views that many in the community would find offensive or inappropriate. Focussing only on the content of brand messages however diverts attention from the necessary examination of how alcohol brands operate in a participatory and interactive media environment.

Participation and transparency in particular need to be considered as part of the larger debate between industry and the public about the practices, and regulation of, alcohol marketing.

By the end of 2012 the most popular twenty alcohol brands had 2.5 million followers on their Australian Facebook pages. During the year they posted more than 4,500 items of content. Their followers interacted with that content – liking, sharing and commenting on it – over 2.3 million times. Each of those interactions increases the reach of the brand into the news feeds of users and the affinity between brands and users within the network.



Brands use Facebook to encourage the participation of users on Facebook. That’s fine. Consumers ought to be free to say just about whatever they like on Facebook. Consumers ought to be able to incorporate brands into the stories they tell about themselves on their social media profiles if they want to. The challenge comes when brands get consumers to say things the brand itself could never say under the current regulatory framework. Consider two scenarios:

1. An alcohol brand posts content every Friday afternoon that asks consumers to share their drinking rituals and practices. The brand routinely elicits from consumers celebrations of excessive consumption.

2. An alcohol brand regularly asks its predominantly male audience to express sentiments about women. For instance, by asking them what they are buying their wife for Valentines Day. The responses from consumers are regularly of a sexist and even misogynistic nature.

In each case, it is the consumers who say things that fall outside the alcohol marketers’ self-regulatory code. But, consumers say those things after being prompted by a brand. And, as observations over time show, the responses of consumers are fairly predictable.

The ASB and ABAC have made it clear these consumers expressions are part of the brand content. But, under the current provisions they would only be considered by the ASB if someone complained about each and every instance.

Alcohol brands’ ‘real-world’ promotional activities raise similar issues. Themed social spaces in nightlife precincts, music festivals and sporting events that embody the brand’s identity and mythology have become popular with alcohol brands. For example XXXX Gold created XXXX Island, asking fans to contribute to its mythology on their Facebook page. Several brands sponsor music festivals where they build large themed bars. In addition to serving alcohol and having exclusive performances at the festival, they use these spaces to generate extensive Facebook content via both their own profiles, and by encouraging fans to upload content to their individual profiles.

These activations are central to embedding the brand within the cultural experiences and memories of consumers. They are used to generate content and engagement on their Facebook pages. As brands and consumers generate updates and images and circulate them online they become ‘authentic’ peer-to-peer advertisements that embed the brands within the identities and cultural world of consumers. Current regulatory approaches however do not cover these culturally embedded marketing activities, even if they appear to be celebrating the excessive consumption of alcohol.

In each of these cases brand content is co-created via interaction with consumers. How should a regulatory framework take account of these participatory forms of brand creation?


We have until now relied on forms of marketing regulation that mostly work at the level of content, that is what brands can and cannot say, when and where they say it and who they can say it to. Regulating alcohol brands depends to a large extent on brand activity being subject to public scrutiny – ABAC itself has recently launched a TV ad reminding consumers about their right to complain about alcohol ads.

We need to be able to see what they say, who to, and in what context for regulation to work. However, on Facebook – as branding activities go ‘below the line’ – it is not possible for regulators, researchers, policy makers and the public to observe and scrutinise the activities of brands. Yet at the same time Facebook dramatically increases the ‘visibility’ of users and consumers to brands. Brands know much more about consumers’ identities, cultural practices and social networks, but the public knows far less about what brands are doing.

Increasingly, brands will use targeted messages and forms of content that are shaped to be visible to specific kinds of users. More and more of these activities are invisible to regulators and researchers, because the Facebook pages and news feeds of particular users are not publicly accessible. Brand activity is ‘hidden’ in micro-level exchanges in niche peer groups.

The trajectory of media like Facebook is toward increasingly customised flows of content. Remember Google CEO Eric Schmidt’s prediction that soon ‘the technology will be so good it will be very hard for people to watch or consume something that has not in some sense been tailored for them’. Customised forms of media like Facebook are going to further undermine forms of regulation based on public scrutiny.

For example, Facebook may soon offer the capacity of brands to ‘gate’ content in increasingly refined ways. At present alcohol brands age gate content on Facebook to prevent under-18s from viewing it. These technologies could be extended to enable brands to gate content so that only people of a certain age, gender, or with specific demographic characteristics can see it. These tools may increase the capacity of brands to ensure their activities are not scrutinised by people outside of the target market. These activities and technologies significantly diminish the role that public scrutiny plays in regulating alcohol brands.

Does anyone remember Vance Packard’s highly influential Hidden Persuaders and its impact on the industry’s reputation?

It should be in the advertising industry’s own best interest to enter into a robust debate about the limits of these forms of data-driven, yet at the same time, culturally embedded (alcohol) advertising. If there ever was a distinction between ‘advertising’ on one side and ‘culture’ on the other, it surely does not exist anymore in today’s participatory media environment.

Thus any attempt by the advertising industry to retreat to a position of “it’s the culture at home, not the advertising” appears ignorant at best. It is true, responsibility begins at home – and the industry should do its homework.

Dr Nic Carah is a  lecturer at the University of Queensland, and Sven Brodmerkel is an assistant professor at Bond University. Carah’s  latest research report Like, Comment, Share: Alcohol brand activity on Facebook will be launched at the Drink Tank Forum on Thursday May 1 at the Australian National University, Canberra. To find out more about the event and read the full report visit www.fare.org.au.



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