Analysis of Alcohol Industry Submissions Against Marketing Regulation
Analysis of Alcohol Industry Submissions Against Marketing Regulation
Analysis of Alcohol Industry Submissions Against Marketing Regulation
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Abstract
A growing body of literature points to the role of vested interests as a barrier to the imple-
mentation of effective public health policies. Corporate political activity by the alcohol
industry is commonly used to influence policy and regulation. It is important for policy
OPEN ACCESS makers to be able to critique alcohol industry claims opposed to improved alcohol market-
Citation: Martino FP, Miller PG, Coomber K, ing regulation. The Australian National Preventive Health Agency reviewed alcohol mar-
Hancock L, Kypri K (2017) Analysis of Alcohol keting regulations in 2012 and stakeholders were invited to comment on them. In this
Industry Submissions against Marketing
study we used thematic analysis to examine submissions from the Australian alcohol
Regulation. PLoS ONE 12(1): e0170366.
doi:10.1371/journal.pone.0170366 industry, based on a system previously developed in relation to tobacco industry corpo-
rate political activity. The results show that submissions were a direct lobbying tactic,
Editor: Kent E. Vrana, Pennsylvania State
University College of Medicine, UNITED STATES making claims to government that were contrary to the evidence-base. Five main frames
were identified, in which the alcohol industry claimed that increased regulation: (1) is
Received: February 22, 2016
unnecessary; (2) is not backed up by sufficient evidence; (3) will lead to unintended nega-
Accepted: December 27, 2016
tive consequences; and (4) faces legal barriers to implementation; underpinned by the
Published: January 24, 2017 view (5) that the industry consists of socially responsible companies working toward
Copyright: © 2017 Martino et al. This is an open reducing harmful drinking. In contrast with tobacco industry submissions on public policy,
access article distributed under the terms of the which often focused on legal and economic barriers, the Australian alcohol industry
Creative Commons Attribution License, which
placed a heavier emphasis on notions of regulatory redundancy and insufficient evidence.
permits unrestricted use, distribution, and
reproduction in any medium, provided the original This may reflect differences in where these industries sit on the ‘regulatory pyramid’, alco-
author and source are credited. hol being less regulated than tobacco.
Data Availability Statement: All files are available
from the following website, Figshare: https://
figshare.com/articles/Submissions_to_the_
Alcohol_Advertising_Issues_Paper/4530581/1
(DOI: https://dx.doi.org/10.6084/m9.figshare.
4530581.v1). Introduction
Funding: This work was supported by: Australian Exposure to marketing of alcoholic beverages is associated with increased alcohol consump-
Research Council Linkage Grant (LP130100046)
tion, especially in young people, and contributes to earlier initiation of alcohol use, the devel-
PM LH KK (http://www.arc.gov.au/linkage-
projects); Foundation for Alcohol Research and
opment of positive and carefree attitudes toward drinking in the general public, and alcohol-
Education (http://www.fare.org.au/) PM LH KK; related violence [1, 2]. Similar associations have been found for tobacco; the marketing of
Victorian Cancer Council (http://www.cancervic. which increases the likelihood that adolescents start to smoke [3, 4].
org.au) PM LH KK. Peter Miller receives funding Current Alcohol Marketing Regulation
from Australian Research Council and Australian
National Health and Medical Research Council, In Australia, a quasi-regulatory framework is in place to protect against potential harmful
grants from NSW Government, National Drug Law effects of alcohol marketing on children and youth. At the centre of this is the Alcohol Bever-
Enforcement Research Fund, Foundation for ages Advertising (and Packaging) Code Scheme (ABAC), which monitors and responds to
Alcohol Research and Education, Cancer Council complaints about the content of alcohol marketing. It consists of three elements: a self-regula-
Victoria, Queensland government and Australian
tory alcohol marketing code; a pre-vetting service; and a public complaints and adjudication
Drug Foundation, travel and related costs from
Australasian Drug Strategy Conference. He has panel. These are overseen by a six-member management committee, comprised of three alco-
acted as a paid expert witness in legal proceedings hol industry representatives, an advertising industry representative, a government representa-
on behalf of a licensed venue and a security firm. tive and, as of July 2015, an Independent Chair [5]. Compliance with the scheme is voluntary,
Kypros Kypri’s contribution to this study is funded i.e., there are no legal or pecuniary sanctions for violation of the code. Other relevant codes
via a National Health & Medical Research Council
that cover some content restrictions include the Australian Association of National Advertisers
Research Fellowship. Linda Hancock has received
funding from the Australian Research Council in
(AANA) Code of Ethics and AANA’s Code for Advertising and Marketing Communications
relation to this article. She has been an unpaid to Children; the Australian Subscription Television and Radio Association (ASTRA) Code of
expert witness in relation to gambling-related Practice; and the Commercial Radio Code of Practice. The Children’s Television Standards
inquiries in Victorian and Commonwealth (CTS) and the Commercial Television Industry Code of Practice (CTICP) include some
government inquiries, the Australian Productivity restrictions regarding placement. For example, the CTS prohibits the broadcast of alcohol
Commission, the South Australian Coronial Court,
advertising during a ‘P’ program or period (suitable for pre-schoolers) and ‘C’ program or
and inquiries in New Zealand, Canada and the UK;
and she is a member of the Singapore Government period (suitable for children 14 years of age) on free-to-air television. Broadcasters are
International Advisory Panel. She was appointed by required to show P and C programs for an average of one hour per day [6]; however, in prac-
the Governor in Council as Chair of the Victorian tice this typically occurs outside of children’s peak viewing times [7].
Gambling Research Panel (2000-2004) and was a
member of the Ministerial Roundtable on
Issues Paper
Gambling. She was Director of Research for the UK
Responsible Gambling Fund and participated in In December 2012, the Australian National Preventive Health Agency (ANPHA) published an
that role on various UK committees on the ESRC, Issues Paper which reviewed current alcohol marketing regulations, focusing on children and
MRC, DCMS and the Gambling Commission. She young people’s exposure, and the effectiveness of these regulations in addressing community
has conducted independent peer review of
concerns about harmful alcohol consumption [8]. In particular, the ANPHA report examined:
bookmaker research for the UK Department of
Culture, Media and Sport (DCMS) and undertook 1) the level of exposure to alcohol advertising among children and young people, for example,
research funded by the Campaign for Fairer exposure arising from an exemption allowing alcohol advertisements to appear during live
Gambling evaluating the Responsible Gambling sport television broadcasts at times when alcohol advertising would ordinarily be banned; 2)
Trust funded research on fixed odds betting the limited scope of current regulations, including new media marketing, the focus on content
machines in bookmakers’ shops (2014 and 2016).
rather than placement, and the failure to regulate sponsorship of sporting and cultural events;
The funders had no role in study design, data
collection and analysis, decision to publish, or
3) the voluntary nature of the current regulatory system; and, therefore, 4) its inability to
preparation of the manuscript. penalise advertisers for breaches of the ABAC. Stakeholders were given the opportunity until
March 2013 to present their views of current alcohol marketing regulations in submissions to
Competing Interests: I have read the journal’s
policy and the authors of this manuscript have the
ANPHA, the content of which is the subject of the current paper.
following competing interests: Peter Miller receives
funding from Australian Research Council and Corporate Political Activity
Australian National Health and Medical Research
There is a growing body of literature identifying vested interests as barriers to the implementa-
Council, grants from NSW Government, National
Drug Law Enforcement Research Fund, Foundation tion of effective public health policies [9–11]. Corporate political activity by the alcohol indus-
for Alcohol Research and Education, Cancer try is a common strategy to influence policy in ways favourable to corporations [12, 13]. In
Council Victoria, Queensland government and Australia the alcohol industry is heavily involved in planning of public health policy; for
Australian Drug Foundation, travel and related instance, industry representatives were invited by the Inter-governmental Committee on
costs from Australasian Drug Strategy Conference.
Drugs to the development of a new National Drug Strategy [14]. However, research suggests
He has acted as a paid expert witness on behalf of
a licensed venue and a security firm. Linda
that such partnerships advance the interests of the industry rather than public health [15, 16]
Hancock has been an unpaid expert witness in because the industry merely argues the need for more research and promotes policies that fail
relation to gambling-related inquiries in Victorian to reduce alcohol sales, such as education and interventions aimed at only the riskiest drinkers
and Commonwealth government inquiries, the [11, 17]. Illustrating the possible influence of alcohol industry is the comment reiterating
Australian Productivity Commission, the South industry claims by Fiona Nash, Assistant Minister for Health, in response to the release of the
Australian Coronial Court, and inquiries in New final ANPHA report on alcohol advertising: “I do have concerns around the advertising of alco-
Zealand, Canada and the UK; and she is a member hol during sporting events, which is watched by many children. . .However the issue around it is
of the Singapore Government International
genuinely complex and more research and work is required. . .” [18].
Advisory Panel. She was appointed by the
Governor in Council as Chair of the Victorian Systematic analysis of alcohol industry framing of claims against increased marketing regu-
Gambling Research Panel (2000-2004) and was a lation has not been undertaken to date. Analysis of framing builds on notions of ‘agenda set-
member of the Ministerial Roundtable on ting’ and ‘stakeholder analysis’. These approaches describe policy processes, but often neglect
Gambling. She was Director of Research for the UK analysis of power and interests, and the strategies used to gain influence over policy, which are
Responsible Gambling Fund and participated in
our focus. Framing analysis has a long history and has been used in different disciplines, for
that role on various UK committees on the ESRC,
MRC, DCMS and the Gambling Commission. She
example, in cultural studies and communication [19, 20]; in sociology [21]; and in applied pol-
has conducted independent peer review of icy areas, such as environmental studies [22]. Its use in policy analysis of controversial policy
bookmaker research for the UK Department of issues draws on the work of Donald Schön and Martin Rein [23, 24], which has been applied
Culture, Media and Sport (DCMS) and undertook to a diverse range of policies; and drawn on by others for interpretive policy analysis [25].
research funded by the Campaign for Fairer Framing the public health debate to align with commercial interests is one important industry
Gambling evaluating the Responsible Gambling
strategy to influence policy makers and politicians [16]. This debate reflects the tension
Trust funded research on fixed odds betting
machines in bookmakers’ shops (2014). She is a between personal freedom and collective responsibility [26] and represents two opposing ethi-
Chief Investigator in an Australian Research cal frames of (1) industry actors, asserting individual responsibility and limited government
Council Linkage Grant investigating mechanisms of interference; and (2) public health actors, asserting the need for control of hazards, prevention
industry influence in the tobacco, alcohol and of harm, and burden sharing [27, 28]. Policy makers are often unaware of the framing [29], so
gambling industries. She has received no funding
there is value in providing guidance to enable critique of alcohol industry framing of claims
directly or indirectly from gambling or alcohol
industry sources for any purpose. This does not
against the implementation of effective policies.
alter our adherence to PLOS ONE policies on A recent study by Savell et al. [30] identified tactics and arguments used by the tobacco
sharing data and materials. industry to influence policy on marketing regulation. Their work builds on research that applied
corporate political analysis to wide-ranging policy applications [13]. Savell et al.’s review devel-
oped two frameworks to aid understanding of tobacco industry arguments and strategies.
Given the parallels between tobacco and alcohol industry tactics to delay development of public
health policy [31], we use the frameworks developed by Savell et al. to analyse the claims of the
Australian alcohol industry in their submissions to the 2014 ANPHA issues report [30].
Methods
Procedure
We started with the assumption to usis the reader meant to make of this? er, cite evidence to
support the claim.should be made.n of participants are likely to that corporations’ framing of
alcohol problems, scientific evidence, and government policies, is part of a strategy to influence
policies in ways likely to protect or generate profit.
We obtained all 34 submissions to the Australian National Preventative Health Taskforce
Issues report [32]. We categorised the submissions in five stakeholder groups: 1) alcohol indus-
try, including nine submissions from alcohol industry associations, major alcohol companies
and retailers; 2) media and marketing industry (n = 9); 3) public health, including eight submis-
sions from non-government organizations and academic research groups; 4) governments
(n = 3); and, 5) others (n = 5), including three anonymous submissions (see Table 1).
Inclusion criteria for the analysis of submissions were: (1) authored by (or by a representa-
tive of) an alcohol industry association, an alcohol producer (or association), an alcohol
retailer (or association), or an alcohol outlet (or association); and the content had to discuss
ANPHA’s Issues Paper. Of the nine alcohol industry submissions, one simply provided infor-
mation about the ABAC, its background, operations, services, management and coverage, and
statistics about complaints and did not discuss the Issues Paper. Therefore, eight submissions
by alcohol industry peak bodies, which broadly represent Australian manufacturers and retail-
ers, were included.
Thematic analysis of these submissions was undertaken using deductive coding [34],
according to Savell et al.’s frames and arguments (see S2 Table). As the current study concerns
a different industry than was examined by Savell et al., emergent coding (an inductive ap-
proach) was also used to adapt and develop new categories specific to the alcohol industry
[35]. Thus, an integrated approach involving inductive and deductive methods was used to
develop a categorization of frames and claims [36]. Final categories were decided on once all
the submissions were coded independently by two researchers (FM and KC). Inter-coder reli-
ability was strengthened by evolving decision rules for coding where categories were cross-
checked and amended as appropriate and the addition of new tactics where necessary. After
independently coding the data according to the (deductive) Savell et al. coding framework, the
two coders had in-depth discussion to establish consensus on appropriate frames and claims.
Results
Frames and Claims
We identified the same four frames as those in Savell et al.’s analysis of tobacco industry behav-
iour: 1) Regulatory Redundancy; 2) Insufficient Evidence; 3) Negative Unintended Consequences;
and 4) Legal. In addition, we identified 5) Corporate Social Responsibility as a frame. Within
these five frames we identified several other types of claims in addition to those identified by
Savell et al., especially under Regulatory Redundancy; and adapted other existing claims (see
Table 2 for summary of frames and claims).
Regulatory redundancy. Submissions asserted that because it is a legal product alcohol is
legitimately advertised to adults (e.g., #1, refers to exemplar quotes provided in Table 2). They
also claimed that the current system is satisfactory, that self-regulation is flexible and respon-
sive, and that social marketing is sufficiently regulated by this mechanism (eg #2a, b); that the
public complaint system is accessible; and that the adjudication panel and pre-vetting experts
are independent. Some businesses claimed to have gone further and developed their own
codes and guidelines that operate alongside the existing marketing codes (eg #3). Another type
of industry claim was that they have ongoing ‘partnerships’ with Australian governments, via
their representation on the ABAC management committee (eg #4). Some called the system
‘quasi-‘ or ‘co-regulation’ instead of self-regulation. Relatedly, different types of claims were
that ‘the vast majority of people drink responsibly’ (eg #5), and that ‘drinking alcohol can be
part of a healthy lifestyle’ (eg #6a, b).
Other submissions included assertions disputing the increasing community concern about
the link between alcohol advertising and risky drinking (eg #8a, b, 9a, b). Finally, submissions
claimed that one of the industry’s goals is to promote ‘responsible consumption of alcohol’ (eg
#9a, b).
Insufficient evidence. It was claimed within industry submissions that there was insuffi-
cient evidence to link marketing of alcohol products to increased alcohol consumption, and
therefore, that marketing regulation would have no effect (eg #10). Some specifically stated
that more research would be needed to prove this link. Submissions cited Australian govern-
ment research purporting to show a decline in alcohol consumption in minors and pregnant
women [37] and claiming “. . .there is no evidence to suggest that alcohol problems are on the rise
which could justify further regulatory constraints on the alcohol industry” (Brewers Association
of Australia and New Zealand (BAANZ)).
Biased public health advocates was a newly identified type of claim within the Insufficient
Evidence frame. Submissions asserted that the Expert Committee on Alcohol, with whom
ANPHA consulted to develop this report, was biased and anti-alcohol and that the research
referenced in the report was not scientifically valid (eg #13). For example: “Lion believes that
Table 2. Claims used by the alcohol industry attempting to influence marketing regulation using Savell et al.’s classification framework.
Frame Sub-frames (where applicable) Claims in Example quote from Assigned quote
submissions (number the submissions number‡
of submissions
presenting claim, out
of 8)
Regulatory Redundancy Industry only markets to “Alcohol is a legal 1
(8) those of legal age/is product and individual
actively opposed to producers are well
minors using product within their rights to use
(4) advertising for
commercial gain
provided the activities
do not promote misuse
and meet ABAC
requirements.” (WFA)
Current self-regulation “The independent pre- 2a
is satisfactory# (8) vetting service and the
adjudication process for
handling complaints are
particularly effective in
stopping irresponsible
marketing.” (Diageo)
“The ABAC Scheme is 2b
flexible to changing
marketing conditions
and techniques, and
can quickly respond to
new marketing
developments.”
(DSICA)
Industry adheres to “ABAC has the support 3
own self-regulatory and backing of the
codes (5) alcohol and advertising
industries, which
reduces the level of
‘gaming’ that can take
place with regulation
that relies on ‘black
letter law’ and strict
definitions.” (DSICA)
Codes are supported “It has continuous and 4
by the government* (4) substantial input from
the Australian
Government.” (DSICA)
Most consumers drink “The vast majority of 5
responsibly* (6) Australians enjoy
alcohol responsibly.”
(ALSA)
Drinking is part of a “. . .moderate 6a
healthy lifestyle* (4) consumption of alcohol,
which is a normal,
enjoyable part of life for
many adults.” (Lion)
“. . .when consumed in 6b
moderation, [alcohol]
can be part of a healthy,
balanced lifestyle.”
(WFA)
(Continued)
Table 2. (Continued)
Frame Sub-frames (where applicable) Claims in Example quote from Assigned quote
submissions (number the submissions number‡
of submissions
presenting claim, out
of 8)
Suggesting alternative “Alcohol policies that 7a
policy strategies that seek to reduce total
address harmful alcohol consumption in
consumption of minority Australia will not reduce
that misuses alcohol * misuse, but rather
(6) simply punish the
majority of consumers
who are already
drinking responsibly in
moderation.” (BAANZ)
”. . .the most effective 7b
way to reduce harmful
consumption of alcohol
is a focus on targeted
interventions as
opposed to any further
population wide
restrictions. . .”
(BAANZ)
Disputing community “. . .the complaints 8a
concern/ codes are in process and code
line with community accurately delivers
expectations* (8) against broader
community
expectations”. (Diageo)
“The small percentage 8b
of alcohol
advertisements
complained about each
year. . .reinforces the
industry view that there
is no widely held
community concern
about alcohol
advertising. . .” (WFA)
“The AHA cautions 8c
against overstating
community concern. . .”
(AHA)
Alcohol industry “Responsible drinking is 9a
encourages at the heart of our
responsible business interests.”
consumption* (4) (Diageo)
“. . .committed to 9b
working with ANPHA
and others to better
understand and
develop strategies to
address such
problems. . .” (Lion)
(Continued)
Table 2. (Continued)
Frame Sub-frames (where applicable) Claims in Example quote from Assigned quote
submissions (number the submissions number‡
of submissions
presenting claim, out
of 8)
Insufficient Evidence (8) There’s insufficient More research is “Important areas of 10
evidence that the needed, insufficient contention, such as the
proposed policy will evidence for causal link link between
work / marketing between marketing and advertising and misuse,
doesn’t increase overall increased consumption require further analysis
consumption levels levels (5) and for a clear
(marketing is used to consensus to emerge in
convince individuals the relevant research.”
switch brands and to (WFA)
sustain or increase Marketing only affects “Diageo markets its 11
company’s market market share (5) brands [. . .] to gain
share), so regulation market share by
will have no effect# (8) encouraging
consumers to switch
from other brands to
one of ours. Our
marketing is not
designed to increase
overall consumption of
alcohol.” (Diageo)
Reporting on declining “. . .in fact alcohol 12a
trends of alcohol misuse has declined in
consumption (5) Australia over the last
few decades.” (Lion)
“The case for further 12b
restrictions on alcohol
advertising is further
weakened when
looking more broadly at
per capita consumption
of alcohol as this has
been essentially static
for the past 20 years. If
advertising increases
alcohol consumption
then it does not appear
to have had any impact
in Australia.” (DSICA)
Biased public health “The present structure 13
advocates* (6) for administering the
ABAC Scheme has not
attracted criticisms
other than from
individuals or
organizations that have
taken a very public anti-
alcohol or anti-industry
position with
questionable motives.”
(ALSA)
(Continued)
Table 2. (Continued)
Frame Sub-frames (where applicable) Claims in Example quote from Assigned quote
submissions (number the submissions number‡
of submissions
presenting claim, out
of 8)
Negative Unintended Economic (6) Manufacturer (4) Regulation will cause “It would also have the 14
Consequences (6) problems maintaining potential to introduce
or increasing market significant market
share for existing distortion to the
brands# (3) competition between
responsible producers
trying to win market
share.” (WFA)
Regulation will cause “New market entrants 15
difficulties for new will find it much more
market entrants# (1) difficult to establish a
presence if advertising
is restricted, creating
significant competition
implications.” (Lion)
Associated Industries Regulation will result in “Placing further, more 16a
(4) financial or job losses onerous restrictions on
(among retailers or advertisers will have a
associated industries, serious commercial
e.g. agriculture, impact on a wide range
hospitality, tourism, of industries. . .” (Lion)
manufacturing and “. . .due to [the alcohol 16b
logistics) (4) industry’s] important
role in the agricultural,
brewing, tourism and
hospitality sectors. . .”
(BAANZ)
Public Revenue (2) Loss of direct “ACIL Tasman has 17
contribution to the estimated that the
Australian economy by direct economic
alcohol industry# (2) contribution of the
Australian brewing
industry to the
Australian economy
was approximately $4.3
billion in the 2010–11
financial year.”
(BAANZ)
Consumers* (3) Impacts on consumer “Without the ability to 18
choice* (3) be informed of their
choices, consumers
suffer a loss of welfare
as they are not aware of
new products. . .”
(DSICA)
Public Health (1) Regulation might “. . .alcohol policy 19
impact negatively on should not impact
health outcomes in moderate drinkers in its
moderate drinkers# (1) efforts to address
problem drinkers, as
this will result in
perverse health
outcomes.” (Lion)
(Continued)
Table 2. (Continued)
Frame Sub-frames (where applicable) Claims in Example quote from Assigned quote
submissions (number the submissions number‡
of submissions
presenting claim, out
of 8)
Legal (5) Regulatory Impact “Further consideration 20
Statement (RIS) needs of the potential
to be developed before increased regulatory
proposing new burden on the industry
regulation* (3) from the proposals
canvassed in the
Issues Paper also
demands a Regulatory
Impact Statement
process.” (WFA)
Body does not have the “The AHA is also 21
power to regulate/it’s surprised to see in the
beyond their jurisdiction Issues Paper a
(3) significant broadening
of scope beyond that
directed to ANPHA in
the Australian
Government Response
to the Preventative
Health Taskforce
Report. . .” (AHA)
Corporate Social Supporting efforts and “Recent examples of 22
Responsibility* (6) programs to reduce our social responsibility
harmful consumption* initiatives include. . .a
(5) social marketing
campaign, using the
strapline ‘Don’t see a
good night wasted’,
aimed at 18–25 year
olds socializing in and
around licensed venues
in Sydney.” (Diageo)
We are members of “Lion is also a founding 23a
DrinkWise *(4) member of DrinkWise
Australia. . .” (Lion)
“Woolworths fully 23b
supports the efforts and
activities of DrinkWise
that aim to affect
generational change in
the way all Australians
consume alcohol.”
(Woolworths)
Regulatory Redundancy Industry only markets to “Alcohol is a legal 1
(8) those of legal age/is product and individual
actively opposed to producers are well
minors using product within their rights to use
(4) advertising for
commercial gain
provided the activities
do not promote misuse
and meet ABAC
requirements.” (WFA)
(Continued)
Table 2. (Continued)
Frame Sub-frames (where applicable) Claims in Example quote from Assigned quote
submissions (number the submissions number‡
of submissions
presenting claim, out
of 8)
Current self-regulation “The independent pre- 2a
is satisfactory# (8) vetting service and the
adjudication process for
handling complaints are
particularly effective in
stopping irresponsible
marketing.” (Diageo)
“The ABAC Scheme is 2b
flexible to changing
marketing conditions
and techniques, and
can quickly respond to
new marketing
developments.”
(DSICA)
Industry adheres to “ABAC has the support 3
own self-regulatory and backing of the
codes (5) alcohol and advertising
industries, which
reduces the level of
‘gaming’ that can take
place with regulation
that relies on ‘black
letter law’ and strict
definitions.” (DSICA)
Codes are supported “It has continuous and 4
by the government* (4) substantial input from
the Australian
Government.” (DSICA)
Most consumers drink “The vast majority of 5
responsibly* (6) Australians enjoy
alcohol responsibly.”
(ALSA)
Drinking is part of a “. . .moderate 6a
healthy lifestyle* (4) consumption of alcohol,
which is a normal,
enjoyable part of life for
many adults.” (Lion)
“. . .when consumed in 6b
moderation, [alcohol]
can be part of a healthy,
balanced lifestyle.”
(WFA)
(Continued)
Table 2. (Continued)
Frame Sub-frames (where applicable) Claims in Example quote from Assigned quote
submissions (number the submissions number‡
of submissions
presenting claim, out
of 8)
Suggesting alternative “Alcohol policies that 7a
policy strategies that seek to reduce total
address harmful alcohol consumption in
consumption of minority Australia will not reduce
that misuses alcohol * misuse, but rather
(6) simply punish the
majority of consumers
who are already
drinking responsibly in
moderation.” (BAANZ)
”. . .the most effective 7b
way to reduce harmful
consumption of alcohol
is a focus on targeted
interventions as
opposed to any further
population wide
restrictions. . .”
(BAANZ)
Disputing community “. . .the complaints 8a
concern/ codes are in process and code
line with community accurately delivers
expectations* (8) against broader
community
expectations”. (Diageo)
“The small percentage 8b
of alcohol
advertisements
complained about each
year. . .reinforces the
industry view that there
is no widely held
community concern
about alcohol
advertising. . .” (WFA)
“The AHA cautions 8c
against overstating
community concern. . .”
(AHA)
Alcohol industry “Responsible drinking is 9a
encourages at the heart of our
responsible business interests.”
consumption* (4) (Diageo)
“. . .committed to 9b
working with ANPHA
and others to better
understand and
develop strategies to
address such
problems. . .” (Lion)
(Continued)
Table 2. (Continued)
Frame Sub-frames (where applicable) Claims in Example quote from Assigned quote
submissions (number the submissions number‡
of submissions
presenting claim, out
of 8)
Insufficient Evidence (8) There’s insufficient More research is “Important areas of 10
evidence that the needed, insufficient contention, such as the
proposed policy will evidence for causal link link between
work / marketing between marketing and advertising and misuse,
doesn’t increase overall increased consumption require further analysis
consumption levels levels (5) and for a clear
(marketing is used to consensus to emerge in
convince individuals the relevant research.”
switch brands and to (WFA)
sustain or increase Marketing only affects “Diageo markets its 11
company’s market market share (5) brands [. . .] to gain
share), so regulation market share by
will have no effect# (8) encouraging
consumers to switch
from other brands to
one of ours. Our
marketing is not
designed to increase
overall consumption of
alcohol.” (Diageo)
Reporting on declining “. . .in fact alcohol 12a
trends of alcohol misuse has declined in
consumption (5) Australia over the last
few decades.” (Lion)
“The case for further 12b
restrictions on alcohol
advertising is further
weakened when
looking more broadly at
per capita consumption
of alcohol as this has
been essentially static
for the past 20 years. If
advertising increases
alcohol consumption
then it does not appear
to have had any impact
in Australia.” (DSICA)
Biased public health “The present structure 13
advocates* (6) for administering the
ABAC Scheme has not
attracted criticisms
other than from
individuals or
organizations that have
taken a very public anti-
alcohol or anti-industry
position with
questionable motives.”
(ALSA)
(Continued)
Table 2. (Continued)
Frame Sub-frames (where applicable) Claims in Example quote from Assigned quote
submissions (number the submissions number‡
of submissions
presenting claim, out
of 8)
Negative Unintended Economic (6) Manufacturer (4) Regulation will cause “It would also have the 14
Consequences (6) problems maintaining potential to introduce
or increasing market significant market
share for existing distortion to the
brands# (3) competition between
responsible producers
trying to win market
share.” (WFA)
Regulation will cause “New market entrants 15
difficulties for new will find it much more
market entrants# (1) difficult to establish a
presence if advertising
is restricted, creating
significant competition
implications.” (Lion)
Associated Industries Regulation will result in “Placing further, more 16a
(4) financial or job losses onerous restrictions on
(among retailers or advertisers will have a
associated industries, serious commercial
e.g. agriculture, impact on a wide range
hospitality, tourism, of industries. . .” (Lion)
manufacturing and “. . .due to [the alcohol 16b
logistics) (4) industry’s] important
role in the agricultural,
brewing, tourism and
hospitality sectors. . .”
(BAANZ)
Public Revenue (2) Loss of direct “ACIL Tasman has 17
contribution to the estimated that the
Australian economy by direct economic
alcohol industry# (2) contribution of the
Australian brewing
industry to the
Australian economy
was approximately $4.3
billion in the 2010–11
financial year.”
(BAANZ)
Consumers* (3) Impacts on consumer “Without the ability to 18
choice* (3) be informed of their
choices, consumers
suffer a loss of welfare
as they are not aware of
new products. . .”
(DSICA)
Public Health (1) Regulation might “. . .alcohol policy 19
impact negatively on should not impact
health outcomes in moderate drinkers in its
moderate drinkers# (1) efforts to address
problem drinkers, as
this will result in
perverse health
outcomes.” (Lion)
(Continued)
Table 2. (Continued)
Frame Sub-frames (where applicable) Claims in Example quote from Assigned quote
submissions (number the submissions number‡
of submissions
presenting claim, out
of 8)
Legal (5) Regulatory Impact “Further consideration 20
Statement (RIS) needs of the potential
to be developed before increased regulatory
proposing new burden on the industry
regulation* (3) from the proposals
canvassed in the
Issues Paper also
demands a Regulatory
Impact Statement
process.” (WFA)
Body does not have the “The AHA is also 21
power to regulate/it’s surprised to see in the
beyond their jurisdiction Issues Paper a
(3) significant broadening
of scope beyond that
directed to ANPHA in
the Australian
Government Response
to the Preventative
Health Taskforce
Report. . .” (AHA)
Corporate Social Supporting efforts and “Recent examples of 22
Responsibility* (6) programs to reduce our social responsibility
harmful consumption* initiatives include. . .a
(5) social marketing
campaign, using the
strapline ‘Don’t see a
good night wasted’,
aimed at 18–25 year
olds socializing in and
around licensed venues
in Sydney.” (Diageo)
We are members of “Lion is also a founding 23a
DrinkWise *(4) member of DrinkWise
Australia. . .” (Lion)
“Woolworths fully 23b
supports the efforts and
activities of DrinkWise
that aim to affect
generational change in
the way all Australians
consume alcohol.”
(Woolworths)
doi:10.1371/journal.pone.0170366.t002
ANPHA should be careful to distinguish between research that is the best available, expert, peer-
reviewed research and surveys that are produced by anti-alcohol activists. . .” (Lion).
Negative unintended consequences. A set of claims was also framed around the notion
that increased regulation has negative unintended consequences. The key themes were: 1) man-
ufacturers, who would, as consequence of regulation, have trouble maintaining or increasing
market share (eg #14), or have difficulties introducing new brands (eg #15); 2) employment in
associated industries (eg #16a, b); 3) loss of public revenue from alcohol tax and the alcohol
industry’s direct contribution to the Australian economy (eg #17); and 4) loss of consumer
sovereignty (eg #18). In contrast to the tobacco industry, no submissions mentioned ‘Illicit
Trade’ and only one warned of “. . .perverse health outcomes” of increased marketing regula-
tion, without explaining what these were (eg #19).
Legal. Two claims were identified within the Legal frame. Some submissions asserted the
need for a Regulatory Impact Statement before proposing new regulation, for example “. . .any
proposals to further regulate alcohol advertising needs to clearly demonstrate that the social and
economic cost it potentially introduces are outweighed by the benefits in an environment where
rates of “at risk” consumption and harm are either stable or in decline.” (#20, Winemaker’s Fed-
eration of Australia). A number of submissions questioned why alcohol marketing regulation
was reviewed in the first place, as it was, according to them, not ANPHA’s task to do this (eg
#21). Unlike Savell et al.’s findings regarding the tobacco industry, the alcohol industry did not
refer to international trade agreements or intellectual property.
Corporate Social Responsibility. Some submitters claimed they were ‘socially responsible
companies’ by presenting involvement in efforts and programs to reduce harmful consump-
tion. For instance, “Recent examples of our social responsibility initiatives include. . .a social mar-
keting campaign, using the strapline ‘Don’t see a good night wasted’, aimed at 18–25 year olds
socializing in and around licensed venues in Sydney.” (#22; Diageo). Some emphasised their
membership of DrinkWise (eg #23a; an industry funded ‘social aspects/public relations’ orga-
nization (SAPRO)), as evidence of their commitment to Corporate Social Responsibility [11].
For example, Lion stated that it “. . .is committed to. . .funding culture change initiatives, such as
those developed by DrinkWise. . .”.
Alternative Strategies. Submissions provided recommendations for alternative strategies
that the government could use to address the small section of society that drinks heavily,
instead of “punishing the majority” of responsible drinkers (BAANZ). Proposed alternative
countermeasures focused on individual responsibility, for example, education, and more
severe drink-driving penalties.
Discussion
The Australian alcohol industry used the following five overarching frames to oppose
increased alcohol marketing regulation: 1) Regulatory Redundancy; 2) Insufficient Evidence; 3)
Negative Unintended Consequences; 4) Legal; and 5) Corporate Social Responsibility. Savell
et al.’s tobacco industry corporate political activity framework for frames and arguments was,
for the most part, applicable to the analysis of the Australian alcohol industry policy docu-
ments with one additional frame needed to characterise the submissions, namely: Corporate
Social Responsibility. The predominant alcohol industry claims were that increased marketing
regulation was unnecessary in Australia and that there is insufficient evidence to support
the proposal to regulate the promotion of alcohol. In contrast, the tobacco industry focused
more on supposed detrimental economic and legal effects of regulation [30]. These findings
reflect the different stages of government regulation applied to these two industries (i.e., their
different positions on the regulatory pyramid), where tobacco is regulated more strictly by
legislation than alcohol, where industry codes prevail [38]. Tobacco marketing in many coun-
tries is heavily regulated and evidence of the effectiveness of these comprehensive policies is
plentiful [39, 40], such that the tobacco industry focuses on the negative economic effects of
such regulation. Few governments, on the other hand, are actively considering stronger alco-
hol marketing regulation and the alcohol industry argues that current self-regulation is work-
ing well [41].
Regulatory Redundancy
We identified nine different claims within the Regulatory Redundancy frame, whereas Savell
et al. found only three used by the tobacco industry. The alcohol industry claims its marketing
targets only adults, however, research shows that young people are also exposed to this market-
ing and are negatively affected by it [1, 2]. If the industry genuinely wishes to target only adults,
the self-regulatory codes should include restrictions on sport sponsorship, outdoor media and
product placement in films and music videos.
While the ABAC scheme has a high voluntary participation rate [42], the support may
reflect the low standards of the code, the low likelihood of a finding against advertisers, and
the lack of penalties in the event of complaints being upheld [15]. The submissions cited the
low number of complaints submitted to ABAC as evidence of no community concern about
the marketing of alcohol to children. However, an alternative complaint panel, set up by the
McCusker Centre for Action on Alcohol and Youth and Cancer Council WA, the Alcohol
Advertising Review Board, received more than double the number of complaints in their first
year (2012), 68% of which were upheld, compared with only 7% of those considered by the
ABAC [42].
The alcohol industry repeats the mantras that ‘most people drink responsibly’ and that alco-
hol consumption can be ‘part of a healthy lifestyle’ [43], claiming then that the majority of the
population should therefore not be ‘punished for the sins of the few’ through policies that
reduce the promotion of alcohol [44]. In line with this, the alcohol industry promotes targeted
regulation for the ‘minority of problematic drinkers’ [45]. Research shows that alcohol market-
ing has a deleterious effect on vulnerable groups, such as ethnic minorities and problem drink-
ers [46], and these groups are specifically targeted through segment marketing [47]. Further,
alcohol marketing has implications beyond these minority groups for adults in general [48,
49], underlining the need for broad restrictions.
Insufficient Evidence
Like the tobacco industry, the alcohol industry proposed that there is insufficient evidence to
show that marketing influences consumption, asserting that it merely affects brand loyalty.
However, a recent analysis of alcohol industry documents shows that the major companies
plan to create new drinking occasions and opportunities, that is, to increase overall consump-
tion [50]. Recently, Ross et al. [51] found that, after controlling for variables known to influ-
ence drinking rates, such as parental drinking and overall market share, minors drink the
brands they see advertised most. The industry argued in the submissions that there is insuffi-
cient evidence on the effectiveness of increased regulation on consumption levels, however, a
recent extensive cross-national study showed that higher levels of regulation in Europe were
associated with lower consumption in adults [52].
submissions in this study presented few such claims. Some asserted that alcohol production
provides substantial economic benefit and employment within Australia, and that increased
marketing regulation would adversely affect the economy. While effective regulation would
undoubtedly reduce alcohol production and marketing, such impacts should be considered in
light of changes related to global market conditions and in light of the cost of alcohol harm.
For example, the recently announced merger of AB InBev and SABMiller, will result in ‘sav-
ings’ to the company of $1.4b, most of which is being achieved by exporting jobs to countries
where wages are lower [53]. On the other hand, the reductions in potential sales are compara-
tively small when compared to the huge direct societal cost of alcohol consumption to the Aus-
tralian community, estimated to be $14.352b in 2010 alone [54].
In contrast to tobacco submissions, alcohol industry submissions did not mention illicit
trade, and only one mentioned negative public health consequences (Lion). While the alcohol
industry is still defending self-regulation, the tobacco industry seems to accept that it has lost
this battle and therefore focuses on economic consequences of increased regulation.
Legal
Savell et al. [30] identified four different claims used by the tobacco industry under the Legal
frame; namely, that restrictions are infringements of legal rights (for example trademarks),
that they constitute disproportionate regulation, that the body in question does not have the
power to regulate, and that there would be an increasing number of compensation claims. We
found only two alcohol industry assertions within this frame, namely, the need for Regulation
Impact Statements and that ANPHA does not have the power to regulate. The Australian Gov-
ernment requires that a Regulation Impact Statements is prepared for significant regulatory
proposals [55], however, ANPHA’s role was to provide policy advice to the Department of
Health, not to put a proposal to Cabinet, and it was therefore not appropriate for ANPHA to
provide such a statement. Contesting the authority of key organizations or groups involved in
policy development, such as ANPHA, is common practice of ‘dangerous consumption’ indus-
tries [30]. In this case, however, Australia’s Intergovernmental Committee on Drugs underpins
ANPHA’s role legitimacy: “. . .it was decided that ANPHA’s approach to alcohol advertising
should be broadened to review the effectiveness of the alcohol industry’s voluntary code on adver-
tising and its effectiveness in addressing community concerns” [56]. The three other claims
within Savell et al.’s frame were not identified in the current study, probably because the threat
of legislation is lower than it is for the tobacco industry.
Accusations of Bias
Finally, Biased Public Health Advocates was a newly identified type of claim within the frame of
Insufficient Evidence. While actors with vested interests have often engaged in disputes with
advocates for evidence-based reform, there has rarely been a focus on public health advocates
Limitations
We sought to minimise bias in the subjectivity of thematic coding by having two researchers
(FM and KC) independently code all documents, and after discussion, reaching agreement on
all thematic classification. They discussed and decided on adaptations of existing classification
frameworks, and created new frames and claims to characterise the alcohol industry submis-
sions. A second limitation is the single country focus. Savell et al. [30] showed that the tobacco
industries worldwide use coherent strategies and claims to influence marketing regulation. It
remains unknown as to whether alcohol industry bodies in other countries adopt similar strat-
egies [62].
Conclusions
This study examined Australian alcohol industry claims regarding marketing regulation,
finding strong similarities with the frames and claims used by the tobacco industry [30].
Alcohol industry actors used multiple strategies to push their claims that increased mar-
keting regulation in Australia is unnecessary, including claims that: there is ‘insufficient
evidence for the effectiveness of increased regulation’; ‘there is insufficient evidence that
alcohol marketing contributes to drinking’; ‘current regulation is satisfactory’; ‘there is
no community concern’; and that ‘the alcohol industry markets its products in a way that
minimise harmful consumption’. These assertions, at least regarding health, stand in con-
trast to the scientific literature regarding alcohol-related harm and continuing high levels of
alcohol consumption in the community. The science reveals the poverty of industry claims
that industry actors put to public servants whose job it is to evaluate submissions. Recent
tobacco research [63] suggests that the tobacco industry seeks to ‘sow reasonable doubt’
about the science [64] among policy makers in order to resist or delay regulation. Continu-
ing to engage with industry as stakeholders in public health policies increases their opportu-
nities to present such claims [63].
Supporting Information
S1 Table. Tactics used by the Tobacco Industry when attempting to influence marketing
regulation
(DOCX)
S2 Table. Arguments used by the Tobacco Industry when attempting to influence market-
ing regulation
(DOCX)
Acknowledgments
Many thanks to Kate Maclachlan for proofreading and editing this manuscript.
Author Contributions
Conceptualization: FPM PGM KK LH.
Data curation: FPM.
Formal analysis: FPM KC.
Funding acquisition: PGM KK LH.
Methodology: FPM PGM.
Project administration: FPM.
Supervision: FPM PGM.
Validation: FPM KC.
Visualization: FPM KC.
Writing – original draft: FPM PGM.
Writing – review & editing: FPM KC KK LH PGM.
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