AAI has made its submission to the European Commission’s public consultation on the evaluation and revision of the Audiovisual Media Services Directive (AVMSD), which sets out AAI’s position on the urgent need to strengthen the AVMSD’s provisions relating to alcohol advertising, with particular regard to the protection of children and young people.
Alcohol is not an ordinary commodity, it is a carcinogenic, psychoactive, dependence-producing drug whose harms are comprehensively documented across decades of research. The current regulatory framework set out by the AVMSD, with its continued reliance on self- and co-regulation, has demonstrably failed to protect minors from exposure to alcohol marketing across both traditional and digital media and falls far short of what the evidence demands.
In its submission AAI makes a series of evidence-based recommendations which we believe are necessary to strengthen the AVMSD to ensure it offers protection to children from alcohol advertising. These include:
- Alcohol advertising restrictions: Article 9 must be strengthened to ensure that audiovisual commercial communications for alcoholic products are not seen by minors and do not encourage consumption.
- Influencer marketing: The revised directive must explicitly include influencers under alcohol advertising restrictions and introduce clear disclosure requirements.
- Protection of minors: Given alcohol’s proven harms to physical health, neurological development, and its links to self-harm and suicide, Articles 6(a) and 28b must be amended to include explicit reference to alcohol.
- Video-sharing platform obligations: Article 28b must be updated to include alcohol and all regulatory codes must be underpinned by national primary legislation rather than self-regulation.
- AVMSD and the DSA: Alcohol marketing on VSPs and VLOPs must be explicitly recognised as a systemic risk under Article 34 of the DSA, and algorithmic recommender systems must be restricted to prevent alcohol advertising reaching minors.
- End self-regulation: The AVMSD must move decisively away from self-regulatory frameworks and mandate primary legislative regulatory codes.
- NoLo products: The same audiovisual commercial communications restrictions that apply to alcohol must be extended to no- and low-alcohol products.
AAI urges the European Commission to use this revision of the AVMSD as a genuine and historic opportunity to
prioritise public health over industry interests. The evidence in relation to alcohol is unambiguous; self-regulation
has repeatedly failed, children are being exposed to harmful alcohol marketing at scale, and the existing framework
is wholly inadequate to address the realities of the modern digital media environment.
AAI therefore calls for strengthened statutory provisions, explicit protections for minors from alcohol advertising across all platforms and services, and meaningful regulatory coherence between the AVMSD and the Digital Services Act.
