The ASA have released advice on the advertising of alcohol over the festive season through their site:
Christmas comes but once a year, but the advertising rules apply all year round so it’s important that you ensure your alcohol ads are responsible this festive season. Here’s the gift of advice for your stocking.
Ads featuring alcohol have to be socially responsible and mustn’t contain anything likely to lead people to adopt styles of drinking that are excessive or unwise.
Showing alcohol is not problematic in itself but the ASA is likely to take a dim view of ads that show people drinking to excess or in an irresponsible manner. When making decisions the ASA will usually consider the number of people that the ad suggests might consume the quantity of alcohol shown, over what period and why.
An ad that showed six people drinking from bottles with their heads tilted far back was viewed as being associated with the culture of “downing drinks” and therefore considered irresponsible. Similarly a promotion for unlimited alcohol that made prominent references to partying and “bottomless” and “free flowing prosecco” was banned for creating the impression that an excessive amount of alcohol was intended to be consumed as part of the offer.
For more advice on depicting consumption, see our guidance.
Avoid exaggerating its importance
Ads must not imply that drinking alcohol is a key component of the success of a social event, so avoid any suggestion that alcohol is needed to have a good festive party.
This doesn’t mean marketers can’t play on traditional associations between particular alcohol products and the Christmas season to some extent – provided they take care with the execution.
An ad that featured the claim “IT’S NOT CHRISTMAS WITHOUT YOU … BAILEYS” was judged not to have broken the rules because the claim, in context, was likely to be interpreted as referring to getting together with friends over the festive period. The drink was also traditionally associated with the Christmas period. The women in the ad also appeared to be laughing and enjoying each other’s company from the beginning, before they had been served any Baileys, helping to highlight that the alcohol was not the key component of the success of their social gathering.
Mind the children
Marketers must avoid using themes or imagery likely to appeal particularly to people under 18 years old.
Take care when using cartoon-like images, particularly of Santa Claus or other festive icons; these might be acceptable if the style is more likely to appeal to adults, but you’ll run the risk of appealing particularly to under-18s if images are too childish in their execution.
An ad that used an illustration from the ‘Where’s Wally?’ series of picture-books, into which a bottle of gin had been digitally added, was found to break the rules as it featured a fictitious character who was likely to appeal particularly to people under 18.