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Executive summary

Background

• Ofcom (the Office of Communications) is the regulator of the UK communications industries, with responsibilities across television, radio, telecommunications and wireless communications services. Ofcom was established on 29 December 2003 and replaces the Independent Television Commission (ITC), the Radio Authority, the Broadcasting Standards Commission, Oftel and the Radio Communications Agency.
• The Advertising Standards Authority (ASA) is the UK self-regulatory body for ensuring that all advertisements are legal, decent, honest and truthful. The ASA was established in 1962 by the marketing industry in order to regulate advertisements appearing in the non-broadcast media (e.g. press, poster, cinema). Marketing communications in the non-broadcast media must comply with the British Code of Advertising, Sales Promotion and Direct Marketing (the CAP Code).
• The Communications Act 2003 requires Ofcom to review its functions and to have regard to the extent to which its duties are likely to be furthered or secured by effective self- regulation. Against this background, Ofcom decided that a self-regulatory approach to broadcast advertising regulation might be better equipped to handle the growing issues of convergence raised by the growth of digital communications than the current statutory system. It also believed that a single point of contact for consumers for advertising issues across all media might serve the public better than the fragmented approach to advertising regulation.
• Therefore, in November 2004, Ofcom delegated day-to-day responsibility for applying the broadcast advertising codes to the ASA (Advertising Standards Authority). At the same time, responsibility for the TV and Radio Advertising Standards Codes themselves was delegated to the Broadcast Committee of Advertising Practice (BCAP), the industry rule-making body, comprising advertisers, agencies and broadcast media. BCAP can only make changes to the Codes with Ofcom’s agreement and following public consultation, having consulted the independent Advertising Advisory Committee (AAC).
• Earlier, in July 2004, Ofcom had consulted on proposals to revise Section 11.8 of the Advertising Standards Code for television advertising relating to alcoholic drinks. The decision to review the rules came from a background of widespread concern about the drinking behaviour amongst teenagers and young adults, including excessive or binge drinking or anti-social behaviour associated with drinking. One of the first tasks for BCAP, following contracting-out, was to devise Notes of Guidance completing the proposed alcohol advertising regime.
• Following consultation, the new rules for television advertising came into force on 1 January 2005 with a ‘grace period’ until 30 September 2005 for advertisers who might have already committed themselves to campaigns which might not comply with the revised rules. In tandem with this process the Committee of Advertising Practice (CAP) amended the alcohol rules in the non-broadcast advertising Code. Amongst other objectives, the changes to the Codes were aimed at preventing alcohol advertising having a strong appeal to ‘under 18s’ and, in particular, being associated with youth culture. For example a new rule in the TV Code requires that alcohol advertising ’must not be likely to appeal strongly to people under 18, in particular by reflecting or being associated with youth culture’.
• The new rules have now been in place for more than two years and the research study conducted in 2005^(-1-) which provided a benchmark for understanding attitudes towards ‘alcohol advertising’ has been updated to look at any post-regulatory changes in attitudes.

Measuring the impact of regulatory change

• The main objective of this research is to measure the extent to which the changes to the alcohol advertising rules made in 2005 may have impacted on the appeal of a selection of alcohol advertisements to people under the age of 18 years. The research specifically deals with the Advertising Standards Code changes to television advertising of alcohol.
• This report contains findings of the research conducted post-regulatory change among 11-21 year olds in the UK. The study has been designed in a similar way to the benchmarking study published in 2005 and the main objective and methodology remains the same – investigating the appeal of a selection of alcohol advertisements using qualitative and quantitative research techniques.
• There are two key differences between the 2005 study and this post-wave study:
  
  
  • The benchmarking study looked in detail at drinking behaviour and general attitudes to alcohol and, due to the multi-faceted relationship between young people and alcohol, these findings are unlikely to have changed dramatically over the past two years and so have not been researched in as much depth in the post-wave research.
  • The alcohol advertisements tested between the two waves of research are different. In both the pre and post regulatory waves of research the executions were chosen as examples of advertising styles and techniques that were aimed at the younger end of the legitimate alcohol market, but which were thought likely also to appeal to ‘under 18s’, rather than because they were representative of executions within the alcohol category before and after regulatory change. It is worth noting, however, that the process of initially identifying executions which met these criteria was more difficult in 2007, indicating anecdotal evidence of a decline in the quantity of executions likely to appeal to under 18 year olds following regulatory change. As a result the commercials tested in the post wave now represent to some extent the edgier end of the market.
• Ofcom and the ASA commissioned independent research agency, Ipsos MORI, to conduct bespoke qualitative and quantitative research amongst 11-21 year olds. In addition analysis was conducted by Ofcom to look at changes in advertising trends based on Nielsen Media data.
• In seeking to understand the change in appeal of a selection of commercials, a number of areas were tested; the recall of advertising, likeability, whether the commercials were seen by young people as being aimed at them, whether they thought the commercial made the drink look appealing and whether it would encourage people to drink. Looking at whether or not the adverts are seen by young people as being aimed at them is particularly relevant in relation to the objectives of the Code changes.
• Due to the multi-faceted relationship between young people and alcohol, this research can only go so far in understanding the impact of regulatory change. The appeal of individual advertisements and the factors that drive appeal can be tested and to some extent compared. However, it is important to note that the alcohol advertising market now is different to that researched in 2005. There is considerably less exposure to alcohol advertising on television amongst young people in 2007 compared with 2005 and the types of product being advertised are markedly different – so the pre and post wave studies are not directly comparable.
• Some clear findings can be drawn from the research but due to changes in the alcohol advertising market and cultural changes which have taken place between the two waves these cannot be conclusively attributed to the changes in the Advertising Code.

Summary of changes to the Advertising Code

• Reflecting the Government’s concerns that were expressed in its Alcohol Harm Reduction Strategy, the Advertising Code was strengthened in four main ways so that the new, 2005, restrictions were stricter on:
  
  
  • the general appeal of alcohol ads to young persons, especially under-age drinkers, and references to “youth culture”;
  • linking alcohol with sex, sexual activity or sexual success;
  • linking alcohol with aggressive, anti-social or irresponsible behaviour and
  • the depiction of irresponsible handling or serving of alcohol

Research objectives

• The overarching purpose of this research is to measure the extent to which the alcohol advertising rule changes have impacted on the appeal of alcohol advertising to young people under the age of 18. In line with the 2005 study, the more specific objectives of this research were to explore:
  
  
  • Young people’s relationships with drinking and alcohol – for example when they start to drink and the amount they are drinking.
  • The extent to which a selection of alcohol advertisement, which can be described as the edgier end of the market or may be considered ‘borderline’, appeal to young people under 18 years of age.
  • If there are alcohol advertisements that do appeal to young people under 18 years of age, why they appeal.
• To meet these objectives, Ipsos MORI conducted both qualitative and quantitative research between February-June 2007. The focus of both these pieces of research was exploring young people’s reaction to alcohol advertising in the post-regulatory change culture, and what appeal adverts had at this time.
• The qualitative research consisted of 11 discussions groups across the country with young people aged 14-21 years. As in 2005, the quantitative phase followed the qualitative research as the findings of the qualitative study informed the decision making process around which commercials to test in the survey. The set up of the 2007 quantitative phase was kept as close as possible to that of the 2005 benchmarking study. Interviews were conducted among a representative sample of 1,514 young people aged 11–21 years across the UK.
• A number of advertisements were tested at both the qualitative and quantitative research stages. As with the benchmarking study the advertisements used in the post-wave study were not a random selection and, as the scope of such a project determines, are not representative of all adverts in the category. A combination of sources were used to select the commercials, including an analysis of trends in advertising activity, the findings of the 2005 research, how appealing the commercials were thought to be to young people and how appealing the actual products were thought to be to young people.

The context: young people & drinking

• The research has identified a number of changes in reported drinking behaviour between the pre and post waves of research.
  
  
  • Based on our survey the proportion of 11-13 year olds who have never drunk alcohol has increased from 31% in 2005 to 46% in 2007. This is consistent with the findings of the 2007 Government report^(-2-) which found that there has been an increase in the proportion of 11-15 year olds who claim not to drink alcohol since 2001.
  • Alcopops have declined in popularity – when asked about the brands of alcohol that they drink mentions of alcopops overall have dropped from 69% to 58%. This is particularly the case for those aged 14 or over.
  • In line with general fashions in alcohol consumption, there has been an increase in the amount of cider that young people report drinking. This is particularly the case among 14-17 and 18-21 year olds – three in ten young people from both these groups have drunk cider in the last six months (compared to 14% and 11% respectively in 2005).
  • According to this study, there has been very little change in the proportion of 11-17 year olds saying they regularly drink to get drunk between the two waves of research. The age at which it is most common for young people to report regularly drinking to get drunk is now 20 and 21 years old and there has been a significant fall in the proportion of 18-19 year olds regularly drinking to get drunk.
• These key changes appear to indicate some shifts in young people’s drinking behaviour that can potentially be seen as positive – particularly the later age at which young people start drinking.

Analysis of advertising trends

• Television remains the key advertising medium for alcohol advertisers, representing an above average share of media spend in 2006 – 49.1% of total alcohol media spend compared with 43.2% of total UK advertising spend. However, television’s share of total alcohol media spend has been in steady decline (down from 65.1% in 2002 to 49.1% in 2006) as outdoor, press and radio account for a growing proportion of spend.
• Television advertising spend within the alcoholic drinks category fell 21.1%(2005-6) , driving the overall fall in alcoholic drinks media spend (-12.0% between 2005 and 2006). Over the same period, spend on outdoor and radio advertising increased by 14.6% and 22.5% respectively.
• Lager brands continue to dominate alcohol advertising, accounting for 34.0% of total media spend in 2006. The greatest shifts in spend have been across the cider market which increased its share of total alcohol media spend from 1.3% in 2002 to 11.8% in 2006 and a fall in the proportion of total media spend represented by alcopops from 12.8% in 2002 to 4.0% in 2006.
• The proportion of television spend represented by the cider market increased from 1.8% in 2002 to 15.5% in 2006 – over the same period the proportion of alcohol television advertising spend accounted for by alcopop brands fell from 14.0% to 2.3%.
• In volume terms (commercial spots aired), alcohol television advertising increased by 7.4% between 2005 and 2006 driven in the main by increased activity across the cider market. The volume of alcopop advertising fell 67.6% between 2005-2006.
• Despite the increase in commercial spots and in line with the changes in advertising spend there has been an increase in exposure to cider advertising and brands classified by Nielsen Media under the ‘alcoholic drinks range’ sub-category and a fall in exposure to alcopop advertising.
• Overall, children and young adults are being exposed to fewer alcohol commercials on television. There was a 6.0% decline in the alcohol impacts^(-3-) delivered against 16-24 year old adults between 2005 and 2006 and a 15.5% fall in impacts amongst children aged 10-15.
• Compared with 2002, the decline in exposure to alcohol advertising on television is more marked. Between 2002-2006 there has been a decline of 31.1% and 39.0% in 16-24 and 10-15 year olds advertising impacts respectively.

Appeal of alcohol advertising

• Recall of alcohol advertising has declined between the two waves of research. There has been a significant decline in the average number of unprompted mentions of alcohol adverts from 3.95 to 3.31. Among the different sub-categories of drinks, there was a decline in recall of beer, alcopop, vodka and spirit advertising and an increase in recall of cider advertising.
• A comparison of media activity during the pre and post waves^(-4-) of research shows that total alcohol advertising spend fell by 2.9% and television advertising spend fell 26.2%. Between the two phases of research, there was a decline in spend across the beer, alcopops and spirits sub-categories and an increase in advertising spend among vodka and cider brands.
• Therefore with the exception of vodka, the downward shift in television advertising spend was matched by a downward shift in advertising recall – and for cider the increase in spend was accompanied by an increase in recall. Based on this analysis it is not possible to attribute the fall in recall of alcohol advertising to a reduction in appeal of advertising as most changes in recall are mirrored by changes in advertising spend.
• Making like for like comparisons between the adverts from the 2005 and 2007 waves of research must be approached with caution. However, based on a range of measures used to test the broad appeal of each television commercial tested in the quantitative stage, the following conclusions can be made:
  
  
  • The likeability of adverts (based on a ranking of advertisements from 1-10, 1 for ‘don’t like it at all’ and 10 for ‘like it a lot’) has not changed between the two waves of research.
  • Young people are less likely to say that they feel the adverts are aimed at them
  • However, young people are more likely to say that the adverts make the drink look appealing and that they will encourage people to drin

Conclusions

• In 2005 when the Advertising Code changes came into force it was felt necessary to provide a benchmark by which the appeal of future commercials would be measured.
• However, since the Advertising Code changes came into place in 2005 and between the two waves of research there have been considerable market and cultural changes (such as changes in licensing laws, changes in the types of drinks consumed, etc) which have meant that the two waves are not directly comparable and it would be difficult to untangle the impact of these changes on young people’s attitudes and behaviour towards both alcohol and alcohol advertising.
• The alcohol advertising market has changed significantly, particularly with regards to television advertising. Television advertising spend has declined and young people are exposed to less television advertising for alcohol products. The recall of alcohol advertising has declined since 2005 and is most probably linked to this decline in advertising spend.
• There has been no change in how much young people say they like the adverts and there has been an increase in those saying the adverts make the drink look appealing and would encourage people to drink it. Importantly, however, given the objectives of the Advertising Code changes, there has been a decline in the proportion of young people saying they feel the commercials are aimed at them.

Footnotes:

1.- Ofcom/ASA (2005) Young People and Alcohol Advertising – An investigation of alcohol advertising prior to the Advertising Code changes. http://www.asa.org.uk/NR/rdonlyres/CC8127C7-D1AE-4092-99B0-335FE2F2A221/0/alcohol_research_2005.pdf

2.- HM Government (June 2007) Safe. Sensible. Social. The next steps in the National Alcohol Strategy. http://www.homeoffice.gov.uk/documents/Alcohol-strategy.pdf?view=Binary

3.- Exposure to television advertising is measured in terms of commercial impacts. One impact is equivalent to one member of the target audience viewing one commercial spot.

4.- In order to understand the trends in recall within the context of media activity during these periods we have analysed advertising activity during December 2004-June 2005 for the benchmarking study and December 2006-June 2007 for the post-wave research.

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