Alcohol ad complaints highlight issues on social media placements

Source: Vinicius “amnx” Amano via Unsplash

The Alcohol Beverages Advertising Code (ABAC) has seen a significant reduction in complaints in the second quarter of 2022.

The first quarterly ABAC report saw a sharp fall in consumer complaints about alcohol marketing with around half the complaints and a quarter of the determinations of the previous quarter.

This was the lowest number in a quarter since 2019.

In the latest quarterly report, this decrease in complaints has continued with only 21 complaints and 8 determinations.

Despite this reduction, complaints continue to raise new issues, including the ambiguity of social media placements, the following determinations provide further clarity.

social media tagging

The ABAC received its first complaint about a third-party post that tagged a beer brand and therefore appeared on the brand’s own Instagram account (40/20 Beer Company) under tagged posts.


Source: ABAC

The third-party post shows alcohol use in a swimming pool, and the complaint said: “This post demonstrates drinking alcohol during the high-risk behavior of swimming.”

While the panel noted that the post was created by a third-party, there are no precise rules as to the moderation responsibilities of alcohol companies and social media accounts, so the gray area for alcohol brands on social media is murky.

ABAC said it would not be reasonable to expect tagged posts that offend the ABAC standards to be removed within say a few hours or even a day or two of the post being made (a “no-fault breach” might be suitable in such cases) .

On the other hand, a company should be keeping a regular eye on its own social media accounts and inappropriate user generated comments or tagged posts should not remain for weeks.

ABAC Chair Harry Jenkins AO said: “This decision highlights the importance of an alcohol marketer moderating user generated comments or tags on its social media accounts and removing any that do not meet responsible alcohol marketing standards within a reasonable period of time.

“Moderation is not only an ABAC requirement with the ACCC advising that ‘businesses using social media channels like Facebook, Twitter and Youtube have a responsibility to ensure content on their pages is accurate, irrespective of who put it there'”.

YouTube ad placements

A complaint was raised about the placement of a Carlton Draft advert within a YouTube video called “How I Cured Years of Depression Within Days (Do These 4 Things)”.

Link to Carlton Draft Advertisement on YouTube

Contending that the placement of an alcohol ad within a video about depression means that the ad will be seen by people struggling with depression and could encourage the use of alcohol to cope with the condition and even alcoholism.

This complaint highlights the issues of placement in online content which relies on the correct tagging of content and exclusionary practices by the advertiser.

The nature of the complaint raises the question of how the ABAC deals with alcohol marketing and vulnerable people – since the ABAC Placement Rules are aimed to limit the exposure of minors to alcohol marketing and the rules do not protect other potentially at-risk groups or individuals .

Carlton Draft advised that it applies exclusions to campaigns running on YouTube so that advertisements are not shown during videos tagged as being in the mental health and depression categories.

The effectiveness of the exclusions depends on the categorization of YouTube content by the platform, in this case, the Company suggests the content was miscategorized.

In any event, the placement of the ad with the Corsetti video is not a breach of the ABAC Placement Rules.

These two ads show the responsibility marketers have to operate consistently with their formal regulatory requirements and be aware of their social license to adopt practices that minimize the risk of harm from alcohol misuse.

ABAC encourages all alcohol marketing staff, ad agency staff, alcohol packaging designers and other media partners to undertake the online training course and now also use these checklists as an important compliance and self-audit tool.

The ABAC pre-vetting service guide has recently been updated, with the inclusion of new guidance on the submission of social media marketing material.

Following the excellent uptake of the free online training course developed last year, ABAC continues to focus on alcohol education and awareness by publishing a range of useful compliance checklists.

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