Following months of strict lockdown, Victorian bars and restaurants were able to reopen for indoor service late last month. As many venues look to social media as a means of attracting patrons, the Victorian Commission for Gambling and Liquor Regulation (VCGLR) has sounded a note of caution, reminding venues of their responsibilities.

The Commission reminded venues that all licensees should be familiar with Victoria’s Guidelines for Responsible Liquor Advertising and Promotions, with failure to comply considered a breach of liquor licencing conditions.

“Guidelines also apply to any social media advertising or promotions, such as on Facebook and Instagram,” an update on the VCGLR’s website read.

“If you hire someone to manage your social media, it is still your responsibility to ensure they understand and follow these guidelines.”

Examples of inappropriate promotions and advertising include: rapid drinking games or competitions, extreme discounts, extended happy hours and all-inclusive deals (such as “bottomless brunches”) that have the potential to break RSA rules.

The regulator also reiterated that all promotions must be non-discriminatory in nature, and cannot, for example “highlight racial differences” or make “fun of a disability”.

This advice comes at a time when many drinkers are looking online for alcohol information in the wake of the pandemic.

Recent research from drinks data analysts, the IWSR, has found that across 10 key international markets, only the US failed to record a considerable increase of alcohol drinkers using TikTok.

Meanwhile, in Australia, search engines represent the third most consulted source for wine information, for those who have purchased wine online in the last six months.

In October, The Shout reported that the Alcohol Beverages Advertising Code (ABAC) received 51 complaints regarding separate Instagram and Facebook accounts that did not have age restrictions in place. ABAC Chair, Harry Jenkins AO, stated: “Everyone involved in alcohol marketing should audit all of their digital marketing assets, including influencer and brand partner activity to ensure that all available age restriction controls have been activated”.

“ABAC will be monitoring compliance in this area” he warned.

And during The Bloody Big Drinks Summit 2021 the Chief Adjudicator of the ABAC panel, Professor Michael Lavarch AO, noted that the last 10 to 15 years have seen an explosion in social media alcohol marketing, which the Code has had to extend to cover.

In a conversation with The Shout’s Editor, Andy Young, Lavarch used the example of an overseas Instagram promotion that would have breached the ABAC’s Responsible Alcohol Marketing Code.

The post included the tagline “some days you just want to forget”, with Lavarch indicating that this would have broken one of the ABAC’s Four Key Standards, by implying that alcohol can manage the stresses of life. Again, the regulatory attention paid to social media marketing activities is evident.

It is important for venues to remember they not only need to adhere to the standards of Australia-wide bodies such as the ABAC, and state licencing regulators like the VCGLR, but the guidelines of social media platforms themselves.

As certain social channels are now crucially important avenues of paid advertisements (Facebook Ad Manager, for instance), businesses involved in the sale of alcohol are cautioned to consider the effect that the suspension or removal of a page could have on overall marketing strategy.

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