WASHINGTON -- Last week, 20 state attorneys general sent comments to the Federal Trade Commission (FTC) urging it to examine the role alcohol marketing plays in promoting underage consumption. The comments were sent in response to the FTC's request for input into whether it should collect information from alcohol advertisers and what information should be collected regarding their sales and marketing expenditures, compliance with the alcohol industry's self-imposed regulatory codes and the status of complaint procedures about industry advertising.
The 20 [image-nocss] AGs are all members of the National Association of Attorneys General (NAAG) Youth Access to Alcohol Committee, a bipartisan body formed in July 2004. AG Steve Rowe of Maine and AG Mark Shurtleff of Utah chair the Committee. It studies youth exposure to alcohol advertising and access to alcohol, educates AGs on ways to reduce access and change social norms about underage drinking and partners with national and state entities to augment and enhance ongoing efforts to stop underage drinking. The committee has been examining the alcohol industry's marketing practices and the effectiveness of the industry's self-monitoring programs.
Alcoholism is a major pediatric disease in this nation. Young people are starting to drink at an earlier age and drinking more aggressively than ever before, said Rowe. We know that children who begin drinking before age 15 are four times more likely to develop alcoholism than those who begin drinking at 21. We also know that alcohol can cause not only addiction in young people; it can also cause brain damageoften irreversible brain damage. This drug is contributing to the loss of human potential in so many of our children. We are troubled by this growing thirst for alcohol among young people. We believe this thirst is driven by a culture of drinking created in part by alcohol industry marketing.
The AGs agreed that it is in the public interest for the FTC to collect updated data from alcohol advertisers, including data on expenditures, marketing practices and independent review procedures. They encourage the FTC to request information on actual alcohol marketing expenditures, including on expenditures for both measured (including TV, radio, print, web and outdoor) and unmeasured (branded merchandise, sports and entertainment sponsorships, point-of-purchase promotion, movie and TV product placement, college marketing and bar promotion) marketing activities. Unmeasured advertising reaches audiences for which no demographic information is available. The AGs urged the FTC to learn what steps the industry has taken to ensure compliance with industry standards in relation to these expenditures.
The alcohol industry currently operates under a series of voluntary standards, all of which require that advertising be placed only when 70% or more of the audience is 21 or older. The percent of TV viewers, radio listeners and magazine readers is determined by ratings agencies who sell demographic data to advertisers. The comments call on the FTC to not only review industry compliance with the current advertising standards, but to examine whether the current standards are adequate to protect against the overexposure of underage youth to alcohol advertisements. Overexposure occurs when youth are over-represented in the audience exposed to the advertising, relative to their presence in the general population.
Shurtleff said, We have asked the FTC to explore whether it is appropriate to change the current standard to one where advertising would be limited to media where no more than 15% of the audience is age 12 to 20. This standard takes into account two important realities: Radio and magazine demographic information is only available for listeners and readers ages 12 and over; and just over 15% of the population is between ages 12 and 20. If you're going to apply a proportional standard to a type of media in order to avoid overexposing youth to alcohol advertising, then that standard should have some real meaning in relation to the actual demographic information available for that media platform. We believe the current standard overexposes youth to alcohol advertising.
Finally, the comments call on the FTC to further review the sufficiency and efficacy of alcohol advertisers' pre-placement review and third-party complaint review procedures.
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