AGs File Comments on Information Collection from Alcohol Advertisers

Attorneys general (AGs) from 23 states and Guam have submitted comments to the Federal Trade Commission (FTC) in response to its proposed collection of information from alcohol advertisers. The information relates to “compliance with voluntary advertising placement provisions, sales and marketing expenditures, the status of third-party review of complaints regarding compliance with voluntary advertising codes, and alcohol industry data collection practices.”

Agreeing that the information collection is in the public interest, the AGs
recommend that FTC “seek advertising and promotional expenditure data on
an ongoing and regular basis, not just intermittently.” They also urge FTC “to
encourage the alcohol industry to move to a standard limiting advertising to
media where no more than 15% of the audience is between the ages of 12
and 20.” The April 26, 2011, comment further calls for FTC to “include a brand
analysis in its coming report,” noting that these beverages are marketed by
brand and not by company.

In light of the industry’s growing reliance on digital and social media in
marketing, the AGs suggest that the commission seek policies and data on (i)
“How bloggers or other third-party posters on internet sites may use alcohol
brand trademarked or copyrighted material”; (ii) “Pre-approval of posts on
corporate-sponsored social media sites”; (iii) “Personal information obtained
about viewers of corporate-sponsored social media sites”; (iv) “Actions taken
against posts on corporate-sponsored social media sites that violate voluntary
advertising codes”; and (v) “Marketing and promotional statements made by
company employees on corporate social media sites.”