Restricting alcohol advertising and promotion: consultation

12. Television and Radio Advertising

“When I was going through a long period of drinking too much, seeing alcohol adverts on TV just prompted me to buy more.”

Respondent, Alcohol Health Alliance Survey

12.1 Television is a highly visible marketing channel and one which can reach high volumes of people. In 2021, television and online audiovisual advertising increased by 39.1% to £6.2bn. Television viewing combines a mix of watching live television as well as broadcaster on-demand services (e.g. All4 or ITV hub) and subscription services like Netflix and Prime Video, some of which do not currently include advertising during the programming.

12.2 On average, people in Scotland spent 3 hours 39 minutes per day watching broadcast television on the television set in 2020 (similar to 2017 levels), the most of any nation in the UK. Although older adults watch more of this, Scottish children in 2020 aged 4-15 years old watched 64 minutes per day whilst those aged 16-24 watched 72 minutes (which was consistent with 2019). Children are more likely to watch some form of on-demand content than live television. In 2020, nine in ten Scottish children aged 5-15 (94%) watched some form of on-demand content. The effects of the covid pandemic for the majority of 2020 has not changed viewing patterns when compared with 2019.

12.3 About three-quarters of adults in Scotland tune into the radio every week.

12.4 The Youth Alcohol Policy Survey asked participants to recall alcohol marketing activity they had seen in the month prior to the survey. In 2019, 69% had seen an alcohol advert on television, 46% on a catch up or streaming service whilst 24% had heard one on radio.

12.5 Television and radio advertising in the UK is regulated by the ASA through a system of co-regulation with Ofcom. The ASA enforces the UK Code of Broadcast Advertising (BCAP Code) which is drawn up, and regularly reviewed, by an industry committee.

12.6 The current regulatory system prohibits alcohol advertising around programming commissioned for or likely to appeal particularly to children. To determine whether a programme is likely to appeal particularly to children, broadcasters rely on ‘audience indexing’ in which Broadcasters Audience Research Board (BARB) data is used to determine which programmes would attract a high percentage of children compared to the total audience watching.

12.7 Despite this, we know that children watch all types of television programming, not just shows aimed directly at them. The current system of BARB audience indexing also only considers the proportion of the total audience that are children, rather than the total number of children watching. Children’s viewing time peaks between 6-9pm, a time period where the television shows most likely to be broadcast are not children’s programming, but instead ‘family’ or adult programmes. This means that some of the shows most watched by children, such as Saturday Night Takeaway, or Great British Bake Off, are not captured within the scope of current restrictions.

12.8 However, it is not just children and young people that this affects. If children and young adults are seeing regular alcohol advertising during television programming then it is not unreasonable to assume that adults in the general public will see at least as much advertising, if not more. This could be especially problematic for those in recovery.

12.9 Scottish Government may not have sufficient power to restrict advertising on television or radio in Scotland and may need to work with the UK Government to take action.

12.10 Scottish Ministers have previously written to the UK Government asking them to take action to protect children and young people from seeing alcohol advertising on television.

12.11 Children and young people in Scotland support the need to take action to further restrict alcohol advertising on television.

Young Scot Health Panel

Recommendations 3

Introduce a watershed for alcohol advertising on television.

Children’s Parliament

Recommendations 7

Make alcohol less visible (television)

Children’s Parliament Investigators called for alcohol to be omitted or blurred from television programmes designed for children or at times when children may be watching.

12.12 Other European countries have differing approaches to restricting alcohol advertising on television and on radio. Some countries prohibit this completely (Lithuania, Norway, Sweden and Russia) whilst others have time-based restrictions (e.g. Estonia and Ireland), with the aim of prohibiting advertising when children and young people are liking to be hearing or seeing this. In Ireland, for example, this prohibits alcohol advertising on TV between 3 a.m. and 9 p.m.

Question 28

Do you think we should explore prohibiting alcohol advertising on television and radio completely (e.g. like Norway or Sweden)?

Please tick one

Yes

No

Don’t Know

Please explain your answer in the text box.

Question 29

Do you think we should introduce a watershed for alcohol advertising on TV and radio (e.g. like Ireland), and if so how would this work?

Please tick one

Yes

No

Don’t Know

Please explain your answer in the text box.

13. Cinema Advertising

13.1 Children and young people are highly engaged with cinema-going; data shows that 63% of 5-10 year olds had attended the cinema in a year, moving up to 70% within the 11-15 age group. Those with children in their household are more likely to go to the cinema than those without.

13.2 Cinema provides a captive audience and an opportunity for advertising before films start. Alcohol adverts can make up to 40% of the commercials shown before feature films. Around a quarter (23%) of 11-19 year olds in the UK reported having seen an alcohol advert in the cinema in the month before being surveyed. Research carried out in the North East of England found that during five popular family films (four rated 12A and one 15 certificate) shown throughout the summer, one in four adverts were for alcohol.

13.3 The current regulatory system around cinema advertising does not restrict alcohol advertising to films certified over 18. It is covered by the CAP Code and overseen by the ASA. Alcohol advertising is restricted if 25% or more of the audience are estimated to be under 18. This is done through a pre-clearance procedure by the Cinema Advertising Association (CAA) which clears all ads.

13.4 As with TV and radio advertising, the focus of the rules on the proportion of under 18’s does not allow for consideration of the high volume of under 18’s who will still see alcohol adverts. Those in recovery, and those in the general population, are also likely to see alcohol adverts in the cinema often.

13.5 Alcohol advertising in the cinema creates a positive association between alcohol and lifestyle. However, the effects of alcohol advertising in the cinema and its effects on long-term consumption and therefore harms is complex, especially its impact on children and young people, and the general population.

13.6 For those in recovery, this is another opportunity to see alcohol advertising and another potential environment to avoid.

13.7 Following this consultation and subject to the consultation responses, we will consider possible restrictions that can be implemented. This is an area where the Scottish Government may not have the power to implement potential restrictions on cinema advertising in Scotland and where there may be a need to work with the UK Government to take action.

Question 30

Do you think alcohol advertising should be restricted in cinemas?

Please tick one

Yes

No

Don’t Know

Please explain your answer in the text box.

13.8 Some European countries, including Finland and Ireland, have introduced an approach whereby alcohol can be advertised in cinemas but only at films certified as 18+.

Question 31

If alcohol advertising was restricted in cinemas, what, if any exceptions (e.g. products in scope, times of day or specific movie ratings) do you think should be considered?

Please explain your answer in the text box.