New guidelines have just been introduced by the European Forum for Responsible Drinking (EFRD) governing online media. However, while the guidelines enhance the self-regulatory framework of the spirits industry, Ben Cooper writes, they do nothing to address the problems created by user-generated material.

The introduction by the European Forum for Responsible Drinking (EFRD) of new guidelines for online, digital and mobile marketing earlier this month represents a significant enhancement of the alcohol industry's self-regulatory apparatus. However, even by the EFRD's own admission, they leave a significant area of exposure in the online arena, namely social networking and other user-generated websites.

Only two weeks ago, just-drinks featured an article on twitter, just the latest in a succession of online networks revolutionising the way companies communicate with their consumers, and, of course, the way we communicate with one another. And it is the change in the latter which may be most worrying for alcohol companies.

While alcohol brands have become increasingly adept at using new media in the marketing mix, in any communication they have to be acutely aware of how alcohol consumption is portrayed, who views their messages and what reaction they will elicit. Hence, the changes announced by EFRD, which represents the major drinks corporations in Europe. Sadly, the same standards are not applied across all online media, with images of alcohol abuse commonplace.

The new EFRD guidelines form an integral part of the organisation's Common Standards for Commercial Communications, and will be implemented by member companies, which include Bacardi-Martini, Beam Global Spirits & Wine, Brown-Forman, Diageo, Moët-Hennessy and Pernod-Ricard, no later than 30 June 2009.

They cover brand and product promotion websites as well as web pages of EFRD member companies, and include stipulations such as the inclusion of age confirmation on accessing the site; the inclusion of responsible drinking messages accompanied by reference to dedicated responsible drinking websites; specific guidance on how to apply the placement provision on a 70/30-audience threshold for minors; and specific rules applying to downloadable items from brand sites.

"The key strength is that they clarify the [EFRD] common standards as to how to apply them to the new media which have developed enormously over the last few years," says EFRD's Carole Brigaudeau. "And they very much reinforce provisions to try to make sure that underage people do not access these media."

Brigaudeau stresses the importance of the stipulation ensuring that if an underage person attempts to access a website, they will be informed why they cannot, and will be directed to relevant educational information about alcohol, for example the 'Truth about Booze' website of the Drinkaware Trust in the UK. By the same token, Brigaudeau continues, adults are shown links to the main Drinkaware website.

"For adults, they will always be confronted with a web address which gives them information about alcohol, and incentives for moderate consumption. An example for the UK is, and we have more of those across Europe."

Brigaudeau also highlights the significance of the inclusion in the guidelines of information on how companies can measure audience profile for the Internet, and adds that by sharing information, the guidelines allow companies which are less acquainted with online marketing to learn best practice from those which have more experience in this area. For example, Diageo's own guidelines were a reference, along with the self-regulatory code of the US spirits trade body, DISCUS.

Brigaudeau says the long-term aspiration is for the EFRD guidelines to be adopted by the European spirits trade association, CEPS. She also has "no doubt" that self-regulation is a better way to police this area because of the fast-developing nature of the media concerned. Citing the example of how slow the Loi Evin in France was to embrace online media, Brigaudeau says legislation cannot keep pace with the speed of innovation in the online arena. "Self-regulation is much more flexible," she says.

The coverage of online media is also a long-standing feature of self-regulation of the US spirits industry, with DISCUS including online provisions in its guidelines for around ten years. Lynne Omlie, general counsel for DISCUS, says the organisation strives to remain current with technological developments, most recently adding a provision for a responsibility statement on downloadable content on websites.

Omlie says: "We are probably the first trade group in the US that put together media buying guidelines for digital and Internet ad buys, put into effect 1 January 2008.
The Internet has been part of our code for a long time and we have now added downloadable material."

However, while industry groups on both sites of the Atlantic are clearly striving to stay current with technological developments, the online arena is hard to keep pace with, and for no area is this more true than user-generated sites. Moreover, for alcohol companies, user-generated material is the hardest to police.

Frustratingly for the industry, while it is clearly going to great lengths to police itself in how it communicates through the Internet, there are countless ways in which alcohol is represented online to make drinks executives cringe, not to mention fuel the arguments of campaigners and provide excellent opportunities for the media to criticise the industry.

For example, a few searches on Youtube will produce thousands of examples of video clips of excessive, irresponsible and even dangerous, consumption of alcohol. Clips of 'chugging' of beer and spirits, in particular, appear to be very common.

For 'chugging alcohol', there were some 660 youtube clips, for 'chugging beer' there were as many as 6,230 clips available. More worryingly, there are clips of chugging of whole bottles of spirits, such as // Very often, the brand names are visible, and feature in the title of the clip.

In another clip, (// a boy, probably around 14, chugs a bottle of Smirnoff Ice. The clip concludes with the boy saying direct to camera "Smirnoff is the best, and I like it a lot." Meanwhile, the 'ultimate drunk people compilation video ever!!!' (// on youtube has received more than 11m hits.

Brigaudeau says the EFRD is to meet with its members to discuss how it can address the problem of excessive alcohol consumption being shown on such sites, saying the organisation wants to "push responsibility and self-regulation for others. We need to sensitise the server providers. This is very irresponsible and shouldn't happen."

Even though the industry has no control over this content, Brigaudeau points out that it is used as a means for campaign groups to criticise the industry, making it more important than ever to address this area.

EFRD will be pushing organisations such as Youtube to screen for material depicting excessive alcohol consumption in the same way as they do for pornographic or racist material, or clips which might aid terrorism.

Brigaudeau concludes: "If this is there, it is because no one is stopping it, and why is no one stopping it? It is because you can't stop a lot on the Internet, maybe, or it's because those who are screening at random those websites do not see it as a problem and we want to raise awareness on that."