Introduction:

Alcohol Healthwatch is a charitable trust that works to reduce alcohol-related harm. We have been funded by the Ministry of Health since 1992 to provide expertise on alcohol-related issues at community, regional and national levels. We take a public health approach in providing services which include advocacy for healthy public policy and practice, information, support and co-ordination for professional and community groups.

We thank the Advertising Standards Authority for the opportunity to make comment on the review of liquor advertising.

Alcohol Healthwatch strongly urge the review team to ensure that the interests of public health take precedence over the commercial interests of the liquor, broadcasting and advertising industries and that the review team ensure that all submissions be judged equally on the merit of their arguments.

The Review Process:

Alcohol Healthwatch has fundamental concerns about the process of self-regulation and the review process itself. We believe it is unlikely that the current review will result in any significant restrictions in advertising given its Terms of Reference. Given that it is now over a decade since liquor brand advertising was introduced we believe a broader and more robust review is justified and necessary.

Alcohol-related harm is a national public health priority and liquor advertising contributes to this status. Therefore, liquor advertising warrants a review and decision-making process that is undertaken by an independent body that is appointed by the government.

Alcohol Healthwatch recommends that the review of alcohol advertising and future decision-making processes be undertaken by an independent government appointed body.

Alcohol advertising is a contributing factor to unacceptable levels of alcohol-related harms in New Zealand and a wide variety of strategies are required to address these. We support a strengthened legislative environment for alcohol and believe the banning of alcohol advertising will be an important ingredient in achieving success in reducing alcohol-related harms.

The Terms of Reference for the 2003 Review seeks evidence on issues that are not adequately measured in New Zealand and therefore it is very difficult for submitters to provide the requested research-based evidence. Instead Alcohol Healthwatch considers it more appropriate that alcohol advertising be considered in the context of our national goals of reducing alcohol-related harm. Numerous national legislative, policy and strategic documents call for a reduction of alcohol-related harm in their aim and/or objectives, The Sale of Liquor Act, The National Alcohol Strategy, National Drug Policy, National Road Safety Strategy, The Cancer Control Strategy to name but a few. We challenge the review team to identify how alcohol advertising contributes to the health and well-being of New Zealanders.

Alcohol Healthwatch recommends that the role of alcohol advertising in New Zealand society be reviewed in the context of our many national legislative, policy and strategic documents which include aims of reducing alcohol related harm.

The 1998 review resulted in insignificant change. The review team concluded that they could not find a sufficient link between liquor advertising and alcohol abuse to justify a total ban. In reaching this conclusion, the review team looked at the weight of evidence suggesting a significant causal link between advertising and alcohol abuse. Before increasing restrictions, concrete proof of causal relationships is demanded and this is difficult, if not impossible to supply. This is particularly frustrating in the New Zealand context when we have not had the necessary mechanisms in place to adequately identify, measure and monitor the relationships between alcohol advertising and alcohol-related harm or the impact of decisions made.

Alcohol Healthwatch recommends that, if alcohol advertising continues, more robust mechanisms are put in place to identify, measure and monitor alcohol advertising and its impacts.

The 2003 review team, again said to be an “independent review team”, is under-represented by those with a background in the health sector as was the case in the 1998 review. Only one of the current review team has clear linkage to public health, namely Dr Colin Tukuitonga.

Alcohol Healthwatch recommends that while advertising continues future reviews, pre-vetting of advertisements, adjudication of complaints and amendment of codes be undertaken by a panel that is independent of commercial interests and has a majority public health representation.

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Response to Specific Review Questions:

 •Changes in social attitudes and public policy since the Barker Report

Alcohol Healthwatch advocates a total ban on broadcast and print alcohol advertising and industry sponsorship of sport and other events. A ban is an essential part of a mix of strategies which must be collectively implemented to reduce the social and economic cost of alcohol harm in New Zealand.

We provide the following in support of this position.

There certainly have been significant changes in policy and social attitudes over recent years however, research and evaluation systems are not sophisticated enough to determine the effects and impacts of these and in many instances are not there at all. The recent report produced by the Ministry of Justice on the impact of lowering the minimum purchase age for alcohol is proof of this. The Ministry did not have sufficient information to make conclusive findings. Although we have access to research on alcohol advertising Alcohol Healthwatch does not believe it is complete enough to adequately inform policy review and decision making in New Zealand.

However, what we can say is that:
•Patterns of youth drinking are worsening:

There have been marked increases in the volume of alcohol consumed among males aged 14 – 15 and even larger increases for males 16 -17 years between the years 1995 and 2000.*
•Increases in harmful drinking patterns/Decrease in moderation drinking.
Increases have been noted in the amounts of alcohol consumed on typical drinking occasions. The proportion of 16 -17 years and women drinking enough to get drunk at least once a week has increased between 1995 and 2000. At the same time there has been a decrease in the percentage of drinkers who drank moderately i.e. those who drank two or fewer drinks on a typical drinking occasion. *
•Increases in consumption.
Increases in consumption by women, by 16 – 17 year olds and 30 -39 year olds of both genders have been found.*
•Changing attitudes:


Through our work with communities, licensees and enforcement agencies Alcohol Healthwatch believes there has been a significant shift in societal attitudes towards alcohol use in New Zealand. Desperation is evident from the public at the impact of alcohol in their communities and calls for stronger legislation and enforcement to support parents and health promotion workers are often voiced.
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Both national and local government are grappling with alcohol issues. We have a Ministerial Action Group at national level and at local level we are seeing increasing use of liquor bans in public spaces. These bans require community consultation and we have yet to hear of one that has not proceeded indicating a strong level of public support for addressing alcohol issues.

Numerous local councils in New Zealand have already or are in the process of developing comprehensive alcohol policies that are broader in scope to the traditional Sale of Liquor policies. These broader policies are endeavouring to respond to community issues and include liquor advertising bans on council property.
(See a collection of newspaper clippings in the appendix for evidence of this).

There is increasing international awareness of the pervasiveness and effects of alcohol advertising.

"Over the past 10–15 years, we have seen that the young have become an important target for marketing of alcoholic products. When large marketing resources are directed towards influencing youth behaviour, creating a balanced and healthy attitude to alcohol becomes increasingly difficult. Based on these concerns, I am calling for a concerted review by international experts of this issue of marketing and promotion of alcohol to young people."
Dr. Gro Brundtland, WHO Director-General, Stockholm 2001

Many governments are reviewing their policies around alcohol advertising and some are increasing advertising restrictions. (See appendix)

The American Academy of Paediatrics and the American Medical Association have publicly advocated a ban on alcohol advertising, especially on television.

As is evident from the many submissions to previous ASA reviews, a ban of alcohol advertising is supported by many agencies, groups and individuals in New Zealand; The Ministry of Health, New Zealand Drug Foundation and the Public Health Association to name a few agencies.

A ban on alcohol advertising is in line with a move away from an individual focus on prevention, in which a “mature society” which emphasizes parental responsibility and a “just say no” approach is advocated, towards increasing recognition by experts of the importance of environmental measures in reducing alcohol-related harms. (Kilbourne 1999). We are seeing then, an increasing trend away from liberal alcohol policies both internationally and locally.

Alcohol Healthwatch recommends that alcohol advertising is banned rather than continuing with the self-regulatory system and attempting to amend the current code.

•The relationship between broadcast advertising and long term liquor consumption trends
Per capita consumption is a crude measure that fails to reflect the hazardous patterns of use within population groups such as the alarming increase in harmful drinking patterns among the young and women.

Consumption has almost doubled in the last 50 years and has until recently, been declining from the peak reached in the 1960-70’s. However, the latest figures show consumption is beginning to rise. There is also an increase in the total alcohol available for consumption, this rose 4.6% in 2002 – (Statistics New Zealand).

Declining overall consumption has not translated into decreasing overall alcohol-related harms. Alcohol Healthwatch believes the harmful patterns of drinking inherent in our drinking culture has overridden any gains that may have been possible from declining overall consumption.

The question we ask is whether a ban on advertising could have reduced consumption levels further to where New Zealand benefited from a reduction in harm.

A declining consumption is absolutely not a licence to liberalise restriction on alcohol supply or promotion. Rather it would be more responsible to continue to strive for further reductions and capitalise on this to achieve reduced levels of harm.

A literature review conducted for the World Health Organisation (Cooke et al 2002), claims that there are many reasons why measuring consumption trends of the whole population is flawed, these include the complexity of alcohol-control policies and isolating the effects of advertising and population dynamics.

Alcohol Healthwatch recommends that the relationship between alcohol advertising and our drinking norms be considered rather than its relationship to overall consumption levels.

•Any new evidence to justify further restriction or liberalisation of codes

While the subtlety of alcohol advertising makes the effects of alcohol advertising on consumption difficult to categorically prove, evidence of the contributory effect of advertising on drinking is significant and is strengthening.

What new research has been done has served to increase understanding of the role of advertising in maintaining the norm of drinking as a socially desirable activity. A critical review of research to date conducted for the WHO (Cooke, 2002) concluded that “advertising is at least reinforcing drinking among the young. In essence, the more familiar, aware and appealing the advertisement to targeted groups, the more likely they are to drink now and in the future”.

It is well-established that advertising helps shape perceptions about alcohol. Banning alcohol advertising has the potential to strongly influence the social norms around alcohol use. A ban would assist in effectively fostering an environment that increases the likelihood that other public health policies around alcohol will be accepted and implemented. (World Health Organisation, Alcohol Policy and Public Good 1994)

Alcohol Healthwatch endorses the actions of countries where a ban on alcohol advertising is in place including France and Sweden. We believe New Zealand could be a leader in this part of the world by doing likewise. The ban must include print and other media as when only partial bans are implemented marketing in the unrestricted media takes on greater importance (Deeks 1992).
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The Alcohol Healthwatch position is further supported by the briefing paper which covers the effects of alcohol advertising and takes a critical look at some of the arguments commonly cited for continuation of the status quo regarding alcohol advertising. We recommend the review panel read this document which is available from us.

•Whether the 1998 Code needs amendment
Alcohol Healthwatch believes the current codes and associated complaint procedures do little to limit the negative impacts of alcohol advertising since the creativity and subtlety used by advertisers is unable to be restricted by these means. Although codes restrict the worst of advertising, as New Zealand researchers Hill and Casswell point out, they are largely irrelevant to the way in which alcohol advertising and promotion works. There is, for example, no need to show underage drinkers to appeal to the young, but simply show the lifestyles that young adults aspire to.

Many, if not most of the alcohol advertising campaigns of recent years push the boundaries of the current advertising code and violate the spirit of the advertising code of ethics on which it is based. The principles of this include that advertisements should not be misleading or deceptive and that advertisements should be prepared with due sense of social responsibility to the consumers and to society. Alcohol advertisements show only what is portrayed as the so called “positive” side of drinking alcohol, that it’s glamorous, sexy, strong and funny.

According to the Advertising Standards Complaints Board there is a maximum six-week turn-around period for the complaint procedure. Given that there is no requirement for the advertisement to be withheld during this time it is ample time for the public to be widely exposed to the advertisement. And in fact many advertisers are designing advertising campaigns that use a series of advertisements which change/alternate quite quickly, thus rendering any complaints process futile.

By the time the complaints procedure and sometimes the appeal procedure is undertaken, the advertisement has largely done its work. In the case of the recent “Summer’s Here” complaint and subsequent appeal by Alcohol Healthwatch, the time lapse from initial lodging of the complaint to an appeal resulting in successful removal of the advertisement was 8 months.

Alcohol Healthwatch recommends that, rather than amendment of the current codes, more stringent processes be developed to pre-vet and monitor the codes with a greater emphasis on the spirit of the codes.

We recommend that complaint processes are amended to allow for 1) quicker assessment of breaches of the codes and 2) withdrawal of advertisements whilst complaint and appeals processes are undertaken.

We recommend that a penalty system be introduced for breaches of the current codes.


•Should the ASA code be harmonised with Australia’s?

The Australian code is widely acknowledged to be ineffective and a review of alcohol advertising by Australian health ministers is currently in progress. The review of alcohol advertising by health ministers comes as drug experts express increasing alarm about binge drinking among secondary students and the strategies used by the alcohol industry to lure teenagers.
“The current system is inadequate and requires urgent re-examination. There is plenty of evidence that alcohol beverage companies are ignoring the voluntary code when they market their products.”
Victorian Health Minister, John Thwaites, July 2002:
The Australian codes are less specific compared to the New Zealand equivalent. This renders then more open to interpretation.

Alcohol Healthwatch recommends that New Zealand not harmonise with the Australian code but take the lead and set a higher standard for Australia to “harmonise” with.

•Should heroes of the young be permitted in liquor advertisements advocating moderate drinking?


Alcohol Healthwatch categorically does not support the use of heroes of the young in liquor advertisements advocating moderate drinking. We believe moderation messages are best developed and delivered by the health sector and kept separate from the liquor advertisements. We also believe that if liquor advertising continues it will always outweigh moderation messages rendering them ineffectual. With the current level of imbalance between the two the money could be better spent on more effective strategies.

Permitting the liquor industry to use heroes of the young in their advertising would make monitoring compliance of the codes considerably more difficult.

Recent incidents of our sporting and entertainment representatives behaving badly, both here and overseas, do little to inspire confidence in their ability to promote the use of alcohol in moderation.

Alcohol Healthwatch recommends that the use of heroes of the young in liquor advertising remain restricted.

•Sponsorship Provisions of Sports and other Events.


Alcohol Healthwatch believes this insidious form of advertising reinforces a link between alcohol and sporting and other achievements which is entirely unrealistic and inaccurate and should therefore be banned. Sports have a wide ranging audience and young people make up a considerable portion of this. As such, sporting events are a valuable investment for the alcohol industry in recruiting future drinkers.

Alcohol Healthwatch believes that if the status quo remains the current codes make adequate provision for broadcasting and filming to continue and help to ensure the worst of the promotion of liquor is avoided.

Alcohol Healthwatch recommends that the broadcast of alcohol-sponsored sports and other events be banned.

Alcohol Healthwatch recommends that while sponsorship continues Advertising Codes not be relaxed in any way.

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Promotion of Liquor Programme Code

The ASA seeks response as to whether the incidental promotion of liquor code reflects society’s attitudes.

From a public health perspective, changing the current attitudes and behaviours associated with alcohol is at the core of achieving reduced levels of alcohol-related harm. The question then of whether the codes reflect these attitudes is mute.

We support the current broadcasting restrictions and do not support any relaxing of these. We believe there is merit in keeping the programme and advertising codes separate. However, there would seem to be an opportunity to consider how the programme codes could be more in accord with the principles of the advertising codes.

Alcohol Healthwatch recommends that the Promotion of Liquor Programme code be more in accord with the principles of the Advertising Code.

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Summary of Recommendations:

Alcohol Healthwatch recommends that the review of alcohol advertising and future decision-making processes be undertaken by an independent government appointed body.

Alcohol Healthwatch recommends that the role of alcohol advertising in New Zealand society be reviewed in the context of our many national legislative, policy and strategic documents which include aims of reducing alcohol related harm.

Alcohol Healthwatch recommends that, if alcohol advertising continues, more robust mechanisms are put in place to identify, measure and monitor alcohol advertising and its impacts.

Alcohol Healthwatch recommends that while advertising continues future reviews, pre-vetting of advertisements, adjudication of complaints and amendment of codes be undertaken by a panel that is independent of commercial interests and has a majority public health representation.

Alcohol Healthwatch recommends that alcohol advertising is banned rather than continuing with the self-regulatory system and attempting to amend the current code.

Alcohol Healthwatch recommends that the relationship between alcohol advertising and our drinking norms be considered rather than its relationship to overall consumption levels.

Alcohol Healthwatch recommends that, rather than amendment of the current codes, more stringent processes be developed to pre-vet and monitor the codes with a greater emphasis on the spirit of the codes.

We recommend that complaint processes are amended to allow for 1) quicker assessment of breaches of the codes and 2) withdrawal of advertisements whilst complaint and appeals processes are undertaken.

We recommend that a penalty system be introduced for breaches of the current codes.

Alcohol Healthwatch recommends that New Zealand not harmonise with the Australian code but take the lead and set a higher standard for Australia to “harmonise” with.

Alcohol Healthwatch recommends that the use of heroes of the young in liquor advertising remain restricted.

Alcohol Healthwatch recommends that the broadcast of alcohol-sponsored sports and other events be banned.

Alcohol Healthwatch recommends that while sponsorship continues Advertising Codes not be relaxed in any way.

Alcohol Healthwatch recommends that the Promotion of Liquor Programme code be strengthened by closer accord with the principles of the Advertising Code.


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