Bundaberg Rum and Dora the Explorer: the reality of alcohol advertising in Australia

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A brief commercial break, then on with the show…

My 3-year old daughter loves Dora the Explorer.  She thinks that bossy little know-it-all, Dora, is really cool.  She used to be frightened of The Swiper, but that changed as she grew older.

Last night, I sat her down in front of a laptop and let her watch an episode of Dora on YouTube.  Right away an ad filled the screen for Bundaberg Rum.  Bundaberg Rum is a brand owned by Diageo Australia.  All of this happened mid-evening, before 9pm.

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This is the reality of alcohol advertising in Australia.  Liquor ads, bought and paid for by Australian drinks manufacturers, streamed online with children’s content.

It’s not unlawful.  It’s business as usual.

This is the kind of thing the Alcohol Advertising Review Board draws attention to in its latest report.

A product review by a 12 year-old for Vodka Cruiser Pineapple Passion Punch 2L, on the Dan Murphy website (owned by Woolworths). Johnny Walker and Smirnoff ads screened in cinemas  before “Minions” – an animated film, rated PG.  Alcohol ads plastered over bus stops outside schools (see p 17 of the report).  And so on.

If you don’t want your pre-schooler exposed to liquor ads while watching age-appropriate material online, what are your options?

First stop: The Alcoholic Beverages Advertising Code (ABAC).  According to ABAC, “The ABAC Scheme is the centrepiece of Australia’s quasi-regulatory system and is administered by a Management Committee which includes industry, advertising and government representatives.”

The ABAC Code and complaints scheme are not legally binding, but members of the Brewers Association of Australia and New Zealand, the Distilled Spirits Industry Council of Australia and the Winemakers’ Federation of Australia are signatories.

The ABAC Code places few real constraints on signatories, but it enables the alcohol industry to claim that alcohol advertising is regulated responsibly, at no cost to government.  Which would be great, if it were true.

The ABAC Code places no restrictions on the placement of an alcohol advertisement.

If you’re a drinks manufacturer who wants to advertise on the internet – including on websites that carry or are even devoted to children’s content – the ABAC Code has no problem with it.

For example, when Crown Lager ads appeared on a “Bratz” games website (and check out the URL to see what I mean ), the complaint was dismissed  because the ABAC Code was designed not to apply to the placement of alcohol ads.

An independent complaints scheme, the Alcohol Advertising Review Board, points out the limitations of the ABAC, and administers its own Codes, with help from a panel of lay members located around the country.

The Content Code is constructed from provisions in existing alcohol advertising codes from around the world.  The Placement Code, however, “features provisions by which the Board considers the placement of alcohol advertising should be governed”.

The Placement Code contains the following provisions:

1. Placement: General

Alcohol Advertisements should not be placed: (i) in places or at broadcast times where Young People are exposed or are likely to be exposed; or (ii) in connection with content that appeals to Young People.

8. Internet

Alcohol Advertisements shall not appear online in connection with content that appeals or is likely to appeal to Young People.

As a parent, those constraints appear entirely reasonable to me.

By the way, you have to love the “Drink Wise” logo in the second screen shot above.  You probably missed it.  After all, it was designed to be missed.

For further comment on this in the Sydney Morning Herald and Fairfax press, click here.

A Fairfax video reporting on this blogpost, containing the images included in this post, has now been added to YouTube.

AdNews has reported that Diageo has suspended all media across the YouTube platform while it investigates the matters raised above.

This incident provides an interesting opportunity to test the limits or otherwise of the ABAC Code.  Accordingly, I have submitted a complaint.

Are you interested in studying health law?  For further information on Sydney Law School’s Master of Health Law and Graduate Diploma programs, follow this link.


10 responses to “Bundaberg Rum and Dora the Explorer: the reality of alcohol advertising in Australia”

  1. Andrew Hamilton Avatar

    You can’t be serious. Is there a chance you were logged into a Google account at the time (I know your daughter wasn’t because they don’t let minors have Google account)

    Google, probably used your search history and decided that ad was probably ok.

    Given that Dora content is uploaded illegally to Youtube, you’d do better reporting it rather than letting your daughter watch it via an unmonitored source like Youtube.


    1. rogermagnusson Avatar

      Interesting ideas, but we were not logged onto anything at the time…not to email or to any other service provider. Technical people could talk more sensibly about this, but my understanding is that there are some pretty basic controls that YouTube could adopt and alcohol advertisers could adopt to ensure that alcohol ads are only streamed in connection with content for viewers 18+.


      1. Dave Avatar

        Luke is spot on. If your daughter is watching Dora on youtube then she is most likly watching an illegal (pirated) version of the show, tied to an unofficial account. My recommendation would be to legally source the content for your daughter.


      2. rogermagnusson Avatar

        Brings a smile to my face. Perhaps we could scrub out the story above and re-name it: ‘When will parents stop breaching copyright and pirating videos?’ That would certainly take the focus off Diageo…
        Pretty innocent, really, letting your child watch Dora on YouTube…I was not on an age-restricted site, and this was self-evidently children’s content. This was not an isolated incident. The ABAC Scheme has dismissed a number of complaints because their Code does not address the placement of alcohol advertising. If alcohol companies are going to advertise online, they need to ensure that they don’t stream ads in proximity to what by any definition is young children’s content. Otherwise they are advertising alcohol at children.


  2. Phil Beresford Avatar
    Phil Beresford

    I encountered a similar expereince in 2012 when my pre-school daughter was listening to Play School on Spotify. She saw and heard not only ads for Absolut Vodka but also for Carlton Dry. I reported both ads to the Advertising Standards Bureau who dismissed both complaints. I’d be more than happy to share their response with you. Let me know.


  3. rogermagnusson Avatar

    Thank you, I’d be interested to learn the reasons why the complaint was dismissed. Was it publicly reported?


    1. Phil Beresford Avatar
      Phil Beresford

      Not sure if it was publically reported, I guess it might have been, I was contacted by a journo about not long after. I’ll forward on the reports to your email listed on this blog.


  4. Holger Avatar

    Ads on the Internet almost all come through Google or one of the other few big online advertisement agencies. So when you surf the web on your browser, the ad agency can follow you around and look at what you search for and what you interact with.

    From this they get a very good idea on who you are and what your interests are, which they in turn use to specifically target their ads to you.

    So if you see ads anywhere online, then be assured: They’re not primarily targeted at people who frequent the current page / watch the current video. They’re targeted at the person who usually uses this computer with this browser.

    Basically I agree with Andrew. Even if you weren’t logged in specifically, Google would have assumed that it was you who watched the videos, not your daughter. (There are ways to obfuscate who you are, but they require more than simply ‘not logging in’. And even then, Google would not assume that the watcher is under age.)

    I assume that it would be very hard to automatically tag user-uploaded videos as ‘predominantly for minors’. (With websites like ‘Bratz’ that would be far easier, though.) I am a father myself, and while I don’t usually get ads for alcohol (apparently Google knows I’m a teatotaler), I do get ads for movies that are clearly not rated PG before the Minecraft Let’s plays that my 6 year old son likes to watch.

    I’m sorry, if you let your daughter watch Youtube, you have to stay with her. (After all, the next video might be a user-generated one where Dora does very … unchildlike things.) Or you have to go to Netflix or the like.


  5. rogermagnusson Avatar

    I am hearing that: if I was logged into a google account, then by definition I am an adult. If I wasn’t, then google assumes I am an adult.

    My point is simple: alcohol advertisers need to give children’s content a wide berth…


  6. rogermagnusson Avatar

    OK, thanks for your comments.


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