Consultation on Restricting Alcohol Advertising and Promotion: Analysis of responses

7 Print advertising (Q19 and Q20)

7.1 Section 10 of the consultation paper covered print advertising. It gave examples of newspaper circulation figures in Scotland and reported on research that demonstrated the exposure of children and young people to such advertising. The consultation paper suggested that restrictions on print advertising, as part of a package of marketing restrictions, would prevent the transfer of expenditure from other marketing routes and reduce the impact of alcohol marketing in Scotland.

7.2 The consultation asked two questions on this issue, inviting views on a prohibition on alcohol advertising in print media and on any exceptions to such a prohibition.

Question 19: Do you think that we should prohibit advertising of alcohol in newspapers and magazines produced in Scotland? [Yes / No / Don't know]

Question 20: What, if any, exceptions do you think there should be to prohibiting alcohol advertising in newspapers and magazines produced in Scotland?

Prohibiting advertising of alcohol in print media (Q19)

7.3 Question 19 asked for views on whether alcohol advertising in print media should be prohibited in Scotland.

7.4 Table 7.1 shows the following:

• Overall, a fifth of respondents (19%) thought that advertising of alcohol should be prohibited in newspapers and magazines produced in Scotland, while roughly four-fifths (78%) thought it should not. The remaining 3% selected 'don't know'.
• Levels of agreement with the proposition were higher for organisations (25%) than for individuals (18%), while levels of disagreement were higher for individuals (79%) than organisations (73%).
• Among organisations, almost all public health and third sector organisations (94%) agreed that advertising of alcohol in newspapers and magazines should be prohibited. By contrast, almost all alcohol producers (98%), events and sporting organisations (92%), retail and hospitality organisations (95%) and advertising and media organisations (95%) disagreed with this approach. About half of other organisation types (45%) agreed and half (50%) disagreed.

Percentages may not total 100% due to rounding.

7.5 In addition, 428 CAMRA 1 campaign respondents and 90 CAMRA 2 campaign respondents indicated that they did not support a prohibition on the advertising of alcohol in newspapers and magazines produced in Scotland.

Support for prohibiting alcohol advertising in newspapers and magazines

7.6 Those in favour of a ban on the advertising of alcohol in newspapers and magazines produced in Scotland included the vast majority of public health and third sector organisations, most academic organisations and some local authorities and public sector bodies, and around one in five individuals. These respondents argued that:

• Print advertising is a very powerful, successful and influential form of advertising with wide reach, and is key to increasing public exposure to alcohol. Respondents often presented findings from research studies to support this position.
• There is a positive association between exposure to print advertising and potentially harmful drinking behaviour. The relationship operates in two ways – both by initiating consumer habits and by reinforcing these habits once they are established. Again, evidence to this effect was presented by respondents.
• Print advertising generates a large return on investment, and is seen by consumers to be a 'trustworthy' form of advertising – more trustworthy than other, alternative forms of advertising. If restrictions are introduced in other areas, but not in print advertising, then advertisers will simply 'transfer' their advertising to print media.
• Other countries have implemented restrictions in this area, and these have been successful in reducing alcohol-related harms.

7.7 Respondents in this group also made a range of points about what would be required for a ban to be successful, or raised other issues for consideration as follows:

• The Scottish Government would have to work with the UK Government to ensure that publishers based elsewhere in the UK implemented a similar approach.
• Any restrictions would need to cover not only advertising in newspapers and magazines, but also articles and stories sponsored by the alcohol industry.

Opposition to prohibiting alcohol advertising in newspapers and magazines

7.8 Respondents who did not support a ban on advertising alcohol in print media –including advertising and media organisations, alcohol producers, music and culture organisations, retail and hospitality organisations and most individual respondents – said the costs of this approach were clear, but the benefits were not. These respondents made the following arguments, many of which have already been discussed earlier in this report:

• In a free society, individuals must be allowed to exercise free will and make their own choices.
• It sets a dangerous precedent to make the argument (as this consultation seems to do) that there is no responsible way of advertising alcoholic drinks.
• A ban on print advertising would make no difference to the extent of alcohol-related harm in Scotland. There is no evidence that print advertising is a root cause of alcohol-related harm.
• The proposed ban on print advertising would be disproportionate and would affect a wide range of publications including leaflets, tourist guides, and other information intended for tourists. Moreover, other (equally risky) products and activities – fizzy drinks, gambling, fast cars – are not subject to any such advertising ban.
• The print publishing industry is in decline, and already facing economic challenges, as consumer habits move towards more digital forms of engagement. Prohibiting alcohol advertising will make a difficult situation worse, as this revenue is vital for the economic survival of newspapers and magazines. Respondents sometimes went on to provide quantitative estimates of the revenue raised through alcohol advertising, and the impact that a ban would have on specific publications, including specialty publications, as well as more general impacts on the creative sector. Moreover, print media advertising was important to and well used by emerging Scottish brands to promote their products.
• There are codes of conduct in place which publishing staff are trained in, and which are implemented. The Advertising Standards Authority CAP code applies to all non-broadcast advertising. The Portman Group code was also mentioned. Respondents restated these rules and argued that self-regulation is successful. In particular, they emphasised that the CAP code already ensures that newspapers and magazines targeted at children and young people do not carry alcohol advertising, and so these groups are not regularly exposed to these adverts.
• A ban on alcohol advertising in newspapers and magazines produced in Scotland would 'distort markets' and disadvantage Scottish publishers in relation to other UK and international publishers. It would also mean that separate (Scottish) versions of UK-wide publications would have to be produced.
• A ban will not be effective given that so many of the newspapers and magazines in circulation originate outwith Scotland.
• There could be unintended consequences of a ban. It might prove very difficult to distinguish advertising from paid content and editorials, and this may mean that nothing about the alcohol industry can be published in newspapers and magazines.

Exceptions to a prohibition on alcohol advertising in print media (Q20)

7.9 Question 20 invited views on possible exceptions to a prohibition on alcohol advertising in print media. The consultation paper drew attention to the option of excepting specialist consumer and trade publications from any such prohibition.

7.10 There were two distinct groups of respondents identified in the analysis of the comments on exceptions to a ban as follows:

• Most respondents who answered 'yes' at Question 19 (i.e. they supported a ban on advertising in print media) said no exceptions should be allowed. A small number of these respondents argued for limited exceptions to a 'blanket ban'.
• Most respondents who answered 'no' at Question 19 (i.e. they opposed a ban on advertising in print media) wanted no further restrictions to be introduced. Rather, this group thought it would be more appropriate to explore a ban on price promotions, or on cheap alcohol. A few of these respondents did, however, go on to discuss the possibility of some limited restrictions specifically to protect children and young people, and other vulnerable groups.

7.11 These two groups are discussed separately below.

Support for exceptions in limited circumstances

7.12 The (small number of) respondents who were in favour of a 'blanket ban' but who were willing to accept the possibility of some (limited) exceptions, made a range of suggestions for what these should cover.

7.13 Respondents confirmed that, as had been suggested in the consultation paper, trade publications (also referred to as 'business-to-business' publications) and speciality publications focusing on specific alcohol products (which were bought and read by those with a commitment to or interest in a particular product or brand) should be excepted. Other potential publications and / or circumstances which might merit exceptions included:

• 'Factual' articles, news stories and features about the alcohol industry (and specifically articles which were not sponsored by the alcohol industry)
• Publications produced in Scotland but aimed at a readership outwith Scotland (this was mainly raised in relation to publications promoting Scotland as a tourist destination to those living outside Scotland).

7.14 Some of those who were willing to consider limited exceptions said that these would have to be carefully considered on a case-by-case basis, and that it would be important to ensure that they did not open the way to more widespread or general print advertising.

Support for limited restrictions to protect vulnerable groups

7.15 As stated above, most respondents who did not support a ban, (i.e. they answered 'no' at Question 19) thought that nothing should be prohibited, so no exceptions were required. However, a small number of respondents did engage with the question of what should happen (and what should be excepted) if a ban were to be introduced. Their comments were mainly concerned with introducing limited restrictions to protect children and young people, and other vulnerable groups.

7.16 Suggestions from these respondents included the following:

• Some aspects of existing codes of practice could be made statutory.
• Restrictions could potentially be applied to publications that are given away free, or to those targeted at those under the legal drinking age (although respondents also emphasised that alcohol advertising in publications targeted at those under the legal drinking age were already not permitted).

7.17 Three other substantive points were made by respondents who were opposed to a blanket ban on alcohol advertising in print media as follows:

• If a ban were to go ahead, the Scottish Government would have to seek opinion / approval from the UK Government to implement this. (Respondents highlighted the difficulties of introducing a Deposit Return Scheme in Scotland and said any decision to ban print advertising in Scotland would not necessarily be able to be implemented.)
• Consumer targeting in relation to newspapers and magazines is difficult to achieve. Advertising restrictions might therefore be more sensibly (and effectively) imposed on channels (especially digital channels) that are better able to target their advertising.
• Any advertising ban which is introduced should never apply to:
• o Trade press (newsletters for / issued by wholesalers, specialist consumer publications, industry-focused publications)
• o Publications that are distributed within a setting where alcohol is produced or served (e.g. a distillery, brewery, club, pub, etc.)
• o High-end / expensive products (which are not associated with consumption by children or young people, or with harmful drinking).