Submission Number: 00018
Received: 3/31/2011 2:58:59 PM
Commenter: Angela Criswell
Organization: Bluegrass Prevention
Agency: Federal Trade Commission
Initiative: Alcohol Reports: Project No. P114503
Attachments: No Attachments
The DISCUS Code of Conduct #10 regarding websites states, "Age affirmation mechanisms, utilizing month, day and year, should be employed for DISCUS member-controlled beverage alcohol advertising and marketing websites. They should also contain a reminder of the legal purchase age."
The limitation of this provision to "member-controlled" websites weakens this element of the code to the point that it is largely meaningless. For instance, when you Google Boone's Farm, the #1 site is www.boonesfarm.net, which is a "fan club" website. However, the Google search shows no alternative site that is company-run, and the Boone's Farm producers apparently defer to this site as the means to market and promote their product on the web. The site contains no age portal to enter. In addition, consumption to the point of intoxication, another violation of DISCUS Code of Conduct, is promoted heavily on the website through fan comments and pictures.
Were individual "fans" to promote this product in a way that hurt the product's sales, the company would immediately act to protect their brand. However, the fact that individuals use the web and social media to do the alcohol industry's marketing for them further removes the industry from accountability under the DISCUS Code of Conduct.
The alcohol industry should be required to take reasonable steps to ensure that their brand is not promoted by others via the web and/or Facebook and other social media in a way that violates the Code of Conduct.