Toward a public health approach to the protection of vulnerable populations from the harmful effects of alcohol marketing

In the Introduction to this Supplement 1 three compelling themes were identified from this collection of systematic reviews, original research, commentaries, editorial statements and debate pieces. The first theme is that the regulation of alcohol marketing can be justified on the grounds of public health, public safety and human rights 2, 3, given the evidence 4 that exposure to alcohol marketing is associated longitudinally with the initiation of drinking and alcohol-related problems in adolescents and other vulnerable groups. The second theme is that current national responses are insufficient in fulfilling the public health mission for which they were designed; that is, to prevent the harmful use of alcohol 5-8. The third theme is that there are several promising options that governments and civil society organizations can consider to address these issues 9. In this concluding statement we describe the implications of these findings for public health and public policy. Despite attempts by the alcohol industry to promote self-regulation programs throughout the world, evidence from Latin America and the Caribbean indicates how regions with self-regulatory marketing codes continue to have high rates of youth exposure to alcohol marketing and code violations within multiple media 6. There is no effective system for removing non-compliant advertisements 5, 10. Clear precedents exist for the use of international codes to protect children and vulnerable populations through global action 9, especially in cases where human rights considerations apply to children 3. The World Health Organization (WHO) Framework Convention on Tobacco Control (FCTC) is a prime example of this. There are also examples of regulatory systems that can be instituted to govern any alcohol marketing codes that are recommended. Despite these promising tools, the challenges to effective protection of vulnerable populations are increasing as traditional media are supplemented by the use of digital media 10 and even Corporate Social Responsibility activities (a) for marketing purposes. Governments are responsible for the health of their populations. They are particularly responsible for protecting children and adolescents from pressures to consume products such as alcohol that can cause ill health and other negative consequences. Early initiation of alcohol use endangers the development of human capital, and is likely to affect social and economic development as well. Vulnerable populations—such as young people, people genetically susceptible to alcohol dependence and people in recovery—have the right to be supported in decisions not to drink. As noted in the paper by Chapman et al. 3, the United Nations Convention on the Rights of the Child encourages the development of appropriate guidelines to protect children from information and material injurious to their wellbeing. In this context, young people have the right to grow up without being pressured by commercial inducements to drink alcohol, as they are now protected from commercial inducements to use tobacco. Global and regional efforts to implement comprehensive restrictions on alcohol marketing are an essential part of a global public health mission that includes population-level protections from the marketing of tobacco, breast milk substitute, and foods high in saturated fats, transfatty acids, free sugars or salt. How can we protect young people and other vulnerable populations effectively? Global action on alcohol marketing is needed now to prevent continued exposure to vulnerable populations. Based on the evidence described above, it seems appropriate for governments and policymakers to give serious consideration to the five key messages emerging from the Pan American Health Organization (PAHO) Expert Meeting on Alcohol Marketing Regulation 11, which are consistent with the well-documented premise that alcohol is not an ordinary commodity 12 and should not be marketed as such. First, the most effective response to alcohol marketing is likely to be a comprehensive ban on alcohol advertising, promotion and sponsorship, in accordance with each country's constitution or constitutional principles. If a complete ban is not currently feasible, the French Loi Evin 13 offers an alternative model by beginning with a ban, and then in that context specifying within reasonable commercial boundaries the specific marketing activities that may be safely permitted. In countries where the promotion of alcohol cannot be banned entirely, messages and images should refer only to the characteristics of the product, such as its origin, composition, strength and means of production, and efforts should be made to keep messages from venues and channels likely to reach young people. The use of life-style images of drinkers, celebrities, sponsorships, endorsements or scenes depicting a normalized or idealized drinking context should be prohibited. Secondly, regulation of alcohol advertising and promotion should be statutory, with enforcement responsibility delegated to an appropriate public health agency of the local or national government, rather than regulated by the alcohol industry. Regulation should include print and digital media (including television and the Internet) as well as radio, point-of-purchase, product placements in television and movies and sponsorship of sports and other activities. The French model of incentivizing civil society engagement in enforcement is also worth replicating. To the extent that the alcohol industry self-regulation programs are likely to continue until statutory bans are implemented, monitoring and enforcement of self-regulatory codes should be transferred to well-resourced civil society or governmental bodies, designated by public health authorities and independent of the alcohol industry, with the ability to levy meaningful sanctions for violations. Governments should require, collect regularly from the alcohol industry and report to the public, information regarding alcohol advertising, promotion and sponsorship activities, including expenditures and fields of activity. Thirdly, regulation should be independent of the alcohol industry, whose primary interest is growing its markets and maximizing profits. Given the conflict between commercial interests and a government's public health responsibility to protect vulnerable populations, alcohol producers should have no role in formulating information or policy relating to the safe use of their products. Media campaigns and messages about the low-risk use of alcohol should be formulated by a body independent of the industry, and should be factual in nature and avoid ambiguous concepts such as ‘responsible drinking’. Fourthly, in recognition of the global nature of alcohol marketing and the limitations of national regulation, a global agreement on the marketing of alcoholic beverages is needed to support country efforts to move towards a comprehensive ban on alcohol advertising, promotion and sponsorship. Such an agreement should be developed and disseminated by an international public health agency in accordance with each country's constitution or constitutional principles. Moreover, global trade agreements should not compromise the ability of national governments to regulate and restrict the marketing of alcoholic beverages, and should be balanced by global health agreements prioritizing government action to protect health. Fifthly, given the role of alcohol as a major contributing factor to non-communicable diseases, collaboration with other population-level efforts to restrict marketing of potentially harmful products, such as ultra-processed food, sugary beverages, tobacco and breast milk substitutes, should be encouraged and supported. WHO and its regional offices should develop a common code for alcohol marketing regulation and practice to assist countries in the formulation of appropriate legislation or other mechanisms to implement and monitor regulatory controls on alcohol marketing. In conclusion, the dramatic growth of alcohol marketing and its insinuation into every possible communication medium available to children and adolescents has created the conditions for unhealthy life-style choices that will burden individuals, families, communities and governments for years to come. As the papers in this Supplement have shown, there are reasonable measures to address the problem. The way forward is clear. None. This is one of a series of papers published in a Supplement to Addiction entitled: ‘The Regulation of Alcohol Marketing: From Research to Public Health Policy’. Funding for the publication of the Supplement was provided by Alcohol Research UK and the Institute of Alcohol Studies. The authors are grateful to Dr Maristela Monteiro, Senior Advisor, Alcohol and Substance Abuse, Pan American Health Organization, for convening the PAHO meeting on alcohol marketing regulation, which brought together public health experts and researchers from around the globe, and stimulated the preparation of many of the papers included in this Supplement.