This new report “Digital marketing of alcohol: Challenges and policy options for better health in the WHO European Region” draws on previous WHO reports on alcohol marketing and on consultations with Member States and civil society to underline the need for urgent action to protect public health and human rights.
The United Nations Convention on the Rights of the Child (CRC) proclaims the right to health. This report makes clear that in the digital sphere, children’s right to health must include protecting children from unsolicited invasion of their digital social spaces by companies promoting alcohol consumption, normalizing alcohol culture from a very young age, placing them especially at risk of harm.
The new WHO report, developed with the support of the Government of the Netherlands, makes clear that protecting against exploitation of people’s, especially young people’s, online social lives is key in this context.
The report discusses the fast-changing digital ecosystem and the methods employed to invade online personal spaces with alcohol marketing. It provides a snapshot of regulatory contexts in a small selection of countries in the WHO European Region, as well as at international level. A range of policy options is suggested, with the overall conclusions emphasizing the urgent need for concerted action by countries and international institutions.
A global and comprehensive approach is required, with the intention of protecting children and young people, people with (or at risk of) substance use disorders and the general population by removing marketing of alcohol altogether from digital spaces.
Alcohol harm in Europe
The WHO European Region has the highest level of adult alcohol consumption in the world.
- In 2016, the regional average for adults (aged 15 years and older) was 9.8 litres of pure alcohol per capita.
- In total 10.1% of all deaths (almost 1 million people) in the European Region were caused by alcohol in 2016.
- A higher proportion of alcohol harm occurs early in the life course, compared with other major noncommunicable disease risk factors, with alcohol causing one in four deaths among people aged 20–24 years.
The dangers of digital alcohol marketing
New technologies and social media present opportunities for exploitation of children and young people, people with (or at risk of) substance use disorders and the general population for the sale of alcohol and other harmful products.
The alcohol industry exploits the digital space to develop, maintain, and nurture relationships with (yet to become) consumers. They do this on “public” social media and other digital platforms (e.g. Facebook, Instagram, TikTok, YouTube) and on “private” social media – such as the messaging services Messenger and WhatsApp. Unlike traditional advertising contexts, consumers on social media platforms interact with branded content; as a result, their personal data can be harvested and used to target them directly with highly sophisticated, personalized marketing pitches.
Increasingly, the placement of advertisements can happen in near-real time, orchestrated across different devices and applications, and with content fine-tuned according to the actions of an individual, often not consciously registered by the person.
In addition, user-generated alcohol-related videos on platforms such as TikTok have been shown overwhelmingly to promote positive associations with alcohol, including humour and camaraderie, while rarely showing negative outcomes associated with alcohol consumption.
The dynamism of the digital context creates challenges for policy makers who wish to protect people from alcohol marketing. Increasingly, networks such as Amazon, Facebook, Google, Microsoft, Snapchat, TikTok and Twitter publish digital advertisements using their own marketing technology systems: “walled-garden” businesses. As with other industrial sectors, such as food marketing, alcoholic beverage enterprises now operate sophisticated computer processing applications that ingest, analyse and make actionable information on individuals. These companies are now able to generate and place their own advertising, including on websites and online services they control, or partner with leading platforms for more effective delivery of marketing.
There is evidence that children and young people are especially at risk of harm from exposure to alcohol marketing. This exposure accelerates the onset of alcohol use, as well as frequency of alcohol use and consumption patterns, especially among young people.
There is the risk that people who consume more alcohol will be targeted for more alcohol marketing because algorithms will target them with digital promotions for alcoholic products.
Alcohol consumption patterns become digital
Accelerated by COVID-19, many people across the European Region, especially children and young people, spend more and more leisure time in online/digital spaces.
By 2025, global digital ad spend is predicted to exceed US$ 600 billion, representing 60% of total global ad spend, and mobile advertising spend will reach US$ 360 billion.
Children and young people are especially at risk from the invasion of their social spaces by communication promoting alcohol consumption, normalising alcohol in all social contexts and linked to development of adult identities.
With smartphones and tablets becoming ubiquitous, young people and others are increasingly exposed to alcohol marketing in all of their social spaces.
The vast majority of alcohol advertising online is “dark”, in the sense that it is only visible to the consumer to whom it is marketed.
Vast majority of alcohol advertising online is “dark”
Current policies across the WHO European Region are insufficient to protect people from new formats of alcohol marketing,” said Dr Carina Ferreira-Borges, Acting Director for Noncommunicable Diseases and Programme Manager for Alcohol and Illicit Drugs at WHO/Europe.
Age verification schemes, where they exist, are usually inadequate to protect minors from exposure to alcohol marketing. The fact that the vast majority of alcohol advertising online is “dark”, in the sense that it is only visible to the consumer to whom it is marketed, is challenging for policy makers thus requiring new mechanisms and a new approach.”
Dr Carina Ferreira-Borges, Acting Director for Noncommunicable Diseases and Programme Manager for Alcohol and Illicit Drugs at WHO/Europe.
Lack of protections against digital alcohol marketing
According to the new WHO report, fewer than half of the Member States of WHO European Region have indicated whether or not they have a ban on alcohol marketing on the Internet and specifically on social media platforms. Only 14 countries have informed that they have implemented such bans.
The United Nations Convention on the Rights of the Child proclaims the right to health. Much of the evidence discussed in this report frames it as a human right that children should be protected from exploitative marketing that can harm their health and well-being. Restricting marketing of alcohol is a WHO recommended “Best Buy” – a cost-effective alcohol policy to reduce alcohol consumption and attributable burden. In the digital sphere, this must include protecting children from the exploitation of their online social lives. The best way to protect children and young people, people with (or at risk of) substance use disorders and the general population from exposure to digital marketing of alcohol, with its associated risks, is to have a global and comprehensive approach that removes it, as far as possible, from all online contexts.
Just as with tobacco, a global and comprehensive approach is required to restrict digital marketing of alcohol.
How to improve country policies
Since the vast majority of alcohol advertising online is “dark” regulation of digital alcohol marketing and enforcement of those rules is difficult.
Member States of the WHO European Region have indicated their concern and also suggested the inadequacy of self-regulatory measures, including in the regional consultation on the implementation of the WHO European Action Plan to Reduce the Harmful Use of Alcohol (2012–2020). Challenges that have been described in relation to countering commercial interests include the following:
- The newly merged repertoires of marketing channels, techniques and platforms make alcohol advertising a complex, ubiquitous, constantly changing phenomenon, with many forms of expression and the overall effect of alcohol being normalized in the digital environments;
- Regulating private content/ communication platforms, where most content is shared, is extremely difficult, although recent developments in both data protection and competition policy provide potential openings;
- Adding to the complications of such oversight is the increasing role of both influencers and the major enterprises (e.g. brands and sports bodies) that provide a platform for social media and marketing.
- There has been insufficient collaboration with other sectors (e.g. gaming, gambling, and nutrition) that face similar challenges in the developing marketing environment (WHO Regional Office for Europe, 2020b).
Restricting marketing of alcohol is a WHO recommended “Best Buy” – a cost-effective policy to reduce alcohol consumption and attributable burden.
Restricting marketing of alcohol is a WHO recommended “Best Buy” – a cost-effective, high-impact alcohol policy solution to prevent and reduce harm caused by the products and practices of the alcohol industry.
In the publication, a number of policy options are discussed, including:
- Effective age verification systems for use of platforms,
- Clear labelling of advertisements in social media posts,
- Use of algorithm-based processes for alcohol-related brand names, so as to block access, and
- Sanctions for inappropriate activities, with robust enforcement.
Policy options to protect communities against digital alcohol marketing
Policy options contain several elements: international control systems, mapping and regulating the digital ecosystem, restricting access, age verification, content restrictions, fiscal strategies, and enforcement. Across these seven policy options, the new WHO Europe makes 20 concrete recommendations for policy action to better protect people and communities from digital alcohol marketing.
INTERNATIONAL CONTROL SYSTEMS
- The WHO Framework Convention on Tobacco Control (FCTC) could provide WHO and other United Nations agencies with a model for an international instrument that could strengthen the implementation of national and international alcohol control policies.
- The WHO–UNICEF–Lancet Commission has called for an optional protocol to the Convention on the Rights of the Child, in other words an additional component to the treaty that must be independently ratified, to protect children from the marketing of a range of products, including alcohol, and from potentially damaging social media and the inappropriate use of their personal data. This optional protocol could address the transnational elements of the problem and simultaneously drive national action for legal protection.
- The development of the European Union Digital Services Act (DSA) provides some opportunities to address the shortcomings with the current legislative framework as it exists in the European Union. Though alcohol is not specifically mentioned, it refers in several places to the protection of health and of minors, including “manipulative techniques and disinformation with a real and foreseeable negative impact on public health”.
- The WHO European Health Data Governance Charter could include consideration of public health requirements in relation to monitoring digital marketing of alcohol. WHO can encourage the development of new national and transnational regulatory and monitoring approaches, as well as disseminating evidence about possible technological and policy gaps and likely effective policy approaches.
MAPPING AND REGULATING THE DIGITAL ECOSYSTEM
- The interplay between the digital marketing ecosystem and global platforms needs to be mapped and understood by policy-makers at local, national and international levels, with regulatory systems being established across borders and across platforms that can move quickly to protect public health and consumer rights.
- Governments should establish and fund research to monitor developments, evaluate the impact of changes to the regulatory landscape and explore future policy options.
- Research foci should include children and young people’s exposure to and engagement with digital marketing of alcohol, as well as how data is used to optimize the targeting of messages and calls to action to consumers, in addition to analysing content, volume and placement.
- To support Member States, the WHO CLICK framework supports monitoring of digital marketing of unhealthy products, including alcohol, to children.
- Governments could ensure that the leading platform groups (including Amazon, Apple, Facebook, Google and Microsoft) develop policies and technologies which can measure, control and restrict alcohol marketing, compelling them by regulation to act where voluntary schemes have not been effective and requiring them to share relevant information, including audience data for their advertisements.
- Given the increasing dominance of these platforms in the digital marketing context, United Nations agencies, including WHO and the United Nations Children’s Fund (UNICEF) could play an important role in establishing discussions with these platforms about the prevention of exposure of children and vulnerable adults to alcohol marketing in online contexts.
- Alcohol producers and distributors could be required to supply to governments relevant marketing data, including marketing spending, media used and data on the demographics of audiences reached.
- In the event that some alcohol marketing activities continue to be permitted, any messages and images should be limited to factual content, without links to celebrities, such as influencers, for the purposes of promotion.
- Regulatory codes should state what is permitted, rather than what is not, with the legal presumption that what is not named is not allowed.
- Public health strategies that seek to regulate the commercial or public availability of alcohol through laws, policies and programmes are important ways to reduce the general level alcohol consumption and harm.
- Such strategies provide essential measures to prevent easy access to alcohol by vulnerable and high-risk groups, including children.
- Policies to limit exposure to alcohol advertising and sales in the digital space should be considered an essential component of countries’ alcohol strategies.
- All children under the age of 18 are vulnerable to the effects of digital marketing, as it operates through emotional and unconscious routes. Older children and teenagers are especially susceptible to emotional, social and identity-based advertising.
- While the situation persists that alcohol marketing is permitted in online contexts, having effective age-verification systems should be considered as an important component of strategies to restrict the exposure of minors to these activities, with action taken to make these more effective.
- Many countries have legislation to prevent minors from accessing alcohol advertising content by using age-verification systems. Where different online sites and games have different age limits, alcohol-related material and advertising should be prohibited and anyone accessing the sites should be required to use verified age-verification tools including, for example, an e-ID with a password or code.
- Legally binding regulations, accompanied by sanctions where standards are not upheld, should be implemented.
- International and national systems to verify age data more effectively, so as to restrict minors’ online exposure to alcohol marketing, also need to be developed as a priority.
- Social media platforms could voluntarily include, or be compelled by regulation to include, labels that clearly identify alcohol advertisements, including the brand name and product information in a consistent way.
- Full disclosure should enable individuals to see whether a piece of content is being paid for and, if so, by whom, and the data that have been used to target the individual.
- Health bodies should also have access to data sources indicating at scale what kinds of content are being circulated and how targeting of populations and individuals happens.
- Sanctions imposed for inappropriate activities need to be strong, with robust enforcement.
- As well as tagging of metadata, platform providers could require marketing companies to make it clear in a very obvious way when they are advertising, by displaying this in writing, and having minimum requirements in relation to size, style, placement and duration of the disclosure statement.
- Commercial content could also be required to be spatially separated from unsponsored user-generated content, or some other visual identifier, such as colour, could be used to indicate commercial content.
- Governments should consider how they can introduce and implement new taxation systems, including e-commerce taxes, that can be used to limit digital marketing of alcohol.
- Governments could also act to ensure that alcohol digital marketing activities are not considered as part of the cost of doing business, thereby reducing tax liabilities.
- It is clear that international governmental cooperation will be required to take forward any fiscal regulatory initiatives, which are likely to face opposition from the technology companies and the alcohol industry alike.
- Strategies, including legislation to restrict digital marketing online, need to be supported by effective monitoring and enforcement systems, requiring transnational cooperation by governments, with the support of international organizations and the cooperation of the platform providers.
- Geoblocking involves the blocking of content in regions in which the content is not intended to reach certain individuals for legal reasons. IP (Internet Protocol) address blocking is a modification to a network service so that requests from hosts with certain IP addresses are rejected.
- Monitoring compliance with restrictions on content and volume will certainly be easier with a complete rather than a partial approach.
- More research is required to understand how effective regulatory approaches have been.
- Lessons can be learned from other contexts, such as the experiences of three European countries, Italy, Latvia and Lithuania, which have completely banned advertising of gambling.
- Most major platforms have algorithm-based processes, often semi-automated, that browse through posts made on the platforms, searching for offensive, inappropriate, harmful or hateful content. These tools include keyword filters, spam detection tools and hash matching algorithms. The same processes could be trained to scout for alcohol-related brand names and to block access to these.
- Alcohol advertising content could also be pre-screened before publication. This would require the platform provider to set up a pre-screening service that would advise whether advertising content complies with regulations and advise the platform not to accept advertising that does not meet required standards.
Creating a WHO European Region free from alcohol harm
The WHO Europe Regional Director’s Advisory Council on Innovation for Noncommunicable Diseases (NCD Advisory Council) has the intention of inspiring action to implement the ongoing “Action Plan for the Prevention and Control of Noncommunicable Diseases in the WHO European Region 2016 – 2025”, with a view to achieving concrete results by 2025. The Council has adopted a signature initiative to prioritize actions that will protect children and young people from exposure to unhealthy commodities, including alcohol, in digital contexts.
All of this is within the framework of the European Programme of Work, 2020–2025 – “United Action for Better Health in Europe” and its flagship initiative on empowerment through digital health.
WHO Europe’s vision is of a WHO European Region where everyone has access to better health and has every opportunity to lead a fulfilling life, free from harm due to alcohol.