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Joint submission on the ACCC Digital Platforms Inquiry


Vulnerable groups, including children, are the object of direct alcohol marketing in the booming digital ecosystem, and the dire lack of regulation and transparency of digital platforms makes this a lucrative space for alcohol companies to recruit drinkers.

Alcohol is one of the most heavily promoted products in the world. Yet it is also one of the most harmful, contributing to more than 200 disease and injury conditions and causing nearly 6,000 deaths in Australia every year.[i], [ii]

The point of alcohol advertising is to increase sales, thereby increasing the amount of alcohol consumed either by more people or in greater amounts among drinkers.[iii] However, the current self-regulatory advertising framework is clearly not protecting vulnerable groups and is failing all consumers.

In February 2019, FARE released a joint submission on the ACCC’s inquiry into digital platforms. The submission is based on protecting children from marketing for unhealthy commodities – alcohol, gambling and unhealthy food.

The submission from the coalition of public health organisations urges the ACCC to ensure that all recommendations consider the rights of children to safely use and enjoy the online spaces created by digital platforms.


The lack of regulation and the insufficient protections for children against the collection and use of their personal data for unconscionable behaviour, such as targeted marketing by unhealthy commodity industries, requires immediate and decisive action.

The submission states, “While we are supportive of a comprehensive review of the media regulatory framework (recommendation six), it is paramount that this does not halt measures to protect children in the meantime, by extending regulation, increasing transparency or other methods”.

The submission has six recommendations for the ACCC:

  1. Acknowledge that in regulating digital platforms consideration must be given to the protection of children and their ability to safely use digital platforms.
  2. Recommend that regulations designed to protect children from unhealthy marketing, including unhealthy food, alcohol and gambling, are applied to all media formats, including digital platforms.
  3. Recommend that all minors are automatically opted out of targeted advertising and prohibit the use of children’s personal data for tracking, targeted advertising and other marketing strategies.
  4. Recommend increasing data collection on targeted advertising used by unhealthy commodity industries to promote transparency and accountability and ensure compliance, potentially through an expanded role for digital platforms’ regulatory authorities.
  5. Impose sanctions and monetary penalties for regulatory breaches involving the marketing of unhealthy products to children and the use of children’s personal data.
  6. Consider international cross-border strategies to protect the integrity of Australia’s regulatory system. We wish to see a stronger focus given to the rights of the child and their experiences in interacting with digital platforms. It is the responsibility of our government to ensure that children are able to participate in the digital world without being targeted by marketers of alcohol, unhealthy food, gambling and other products potentially harmful to their health. After all, Australia has always been a strong supporter of the United Nations Convention on the Rights of the Child, where the interests of the child are paramount.

[i] Lensvelt, E., et. al. (2018). Estimated alcohol-attributable deaths and hospitalisations in Australia 2004 to 2015. National Alcohol Indicators, Bulletin 16. Perth: National Drug Research Institute, Curtin University. Retr

[ii] World Health Organization. (2018). Global status report on alcohol and health 2018. Geneva: WHO.

[iii] Pan American Health Organization. (2017). Technical note: Background on alcohol marketing regulation and monitoring for the protection of public health. Washington, D.C.: PAHO & WHO.

FARE supports policy reforms that contribute to a reduction in alcohol-related harms in Australia. Our policy work is informed by the evidence of what is most effective in reducing alcohol-related harms. We support the progression of population-based health measures, which take into consideration the far reaching and complex impacts of alcohol-related harms.

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