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Submission to the ACMA review of alcohol advertising rules in the Free TV Code

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A young child watching television

Australians should be able to enjoy sport and entertainment in environments that are safe and free from harm caused by alcohol. Commercial free-to-air television continues to play a significant role in the lives of Australians, and in shaping community norms and behaviours. More than half of Australian adults are watching broadcast television each week, according to the latest data from ACMA.

The harms of alcohol, which are exacerbated by exposure to advertising, are serious and well understood. They include individual health impacts, broader social and economic impacts, and disproportionate impacts on specific groups such as women and children.

The current regulatory framework governing alcohol advertising on commercial television (Part 6.2 of the Code) is fundamentally inadequate and fails to provide appropriate safeguards for the community.

As well as being generally lax in its permitting of alcohol advertising, the Code also allows extensive exemptions for various types of sport programming on weekends and public holidays. The Code’s rules narrowly define alcohol advertising and fail to capture the full range of contemporary alcohol product promotions. The Code also fails to apply to the broadcasters’ video on demand services.

The result is that alcohol advertising is pervasive and unavoidable on commercial broadcast television for large segments of the community.

The existing Code relies on classification‑based time restrictions that do not meaningfully protect children, nor does it address the harms experienced by adults, including people with alcohol dependence and women and children experiencing domestic, family and sexual violence.

The sports programming exemption is particularly harmful. It disproportionately exposes communities to alcohol promotion during times of high audience engagement and at times of heightened risk of alcohol related harms such as domestic and family violence. It regularly exposes children to alcohol advertising. This exemption remains despite evidence that alcohol advertising during sport contributes only a relatively small proportion of broadcasters’ revenue.

The Code’s shortcomings are structural and unlikely to be remedied through industry-led revisions. The industry has weakened the Code over successive revisions and in 2024 sought to weaken protections for alcohol advertising even further. The industry has an inherent commercial conflict of interest that undermines its ability to fulfil the obligation to safeguard the community.

There is strong public support for regulatory action to be taken by ACMA. Recent community polling, together with multiple government strategies and action plans – such as the Federal Government’s National Alcohol Strategy and the Rapid Review of Prevention approaches – demonstrate a clear understanding of the harm caused by alcohol and alcohol advertising, and an expectation of meaningful actions to protect the community.

In summary: the existing Code does not provide appropriate community safeguards and in fact facilitates extensive exposure to alcohol advertising, including to children, which contributes to the serious alcohol-related harm within the community. The Code has failed. ACMA should replace the existing industry code with a robust program standard that prioritises public health and community wellbeing over commercial interests.

Recommendations

Recommendation 1. ACMA exercise its power under s125 of the Broadcasting Services Act 1992 to make a program standard to apply to the commercial television broadcasting industry in relation to alcohol advertising. This program standard would replace the current Code in respect of alcohol advertising because the Code has failed in delivering appropriate community safeguards.

Recommendation 2. The program standard should be framed to provide strong community safeguards that recognise the role that alcohol advertising plays in driving alcohol consumption and the harms that flow from such consumption. The standard should specify its object is to protect the public’s health and safety through reducing the community’s exposure to alcohol advertising. As a minimum the program standard should also:

  • further restrict the permitted alcohol advertising hours
  • remove any exemption for alcohol advertising during sports programming
  • capture all forms of alcohol marketing seen on broadcast television (including sponsorship and zero/no alcohol products).

Recommendation 3. The program standard should be extended to all aspects of the commercial broadcasters’ services, including broadcast video on demand (BVOD) (eg. Channels 7Plus, 9Now).

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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