Department of Health and Human Services I 

OFFICE OF 

INSPECTORGENERAL 

YOUTH AND ALCOHOL: 

CONTROLLING ALCOHOL ADVERTISING 

THAT APPEALS TO YOUTH 

Richard P. Kusserow 

INSPECTOR GENERAL 

OET-09-91-00654 
EXECUTIVE SUMMARY -

PURPOSE 

This inspection examined (1) the Federal, State, alcohol industry, and national 

television networks’ advertising and marketing regulations and standards, (2) the 

monitoring of these regulations and standards, and (3) the application of the 

regulations and standards to five current alcohol advertisements. 

BACKGROUND 

In response to concerns about youth alcohol consumption, Surgeon General Antonia 

Novello requested that the Office of Inspector General (OIG) provide information 

about alcohol advertising practices and the current system governing them. These 

concerns mirror one of Department of Health and Human Services Secretary Louis 

Sullivan’s goals, which is to reduce the prevalence of alcohol problems among children 

and youth. 

In a national survey of junior and senior high school students, the OIG found that 

students notice alcohol advertisements and especially like those that spotlight attractive 

people, make drinking look like fun, and feature attractive or exotic settings. Other 

researchers have found that alcohol advertisements can affect youth attitudes about 

alcohol. For example, one study found that students exposed to beer commercials 

were more likely to think beer is “cool” or “macho.” Recent public opinion polls show 

that the public believes alcohol advertising adversely affects underage youth and 

influences them to drink. Because of alcohol’s potential for abuse, both public and 

private sectors have placed restrictions on its promotion and sale. 

In this study, we interviewed Federal agencies, State Alcoholic Beverage Control 

(ABC) agencies, alcohol trade associations and an industry-supported organization, an 

advertising industry organization, and the three largest national television networks. 

We asked about their regulations or standards for alcohol advertising and the 

enforcement of the regulations and standards. Using a case study approach, we 

selected five current print and television advertisements for alcoholic beverages and 

asked respondents about (1) the application of their regulations or standards to the 

ads, (2) the likelihood that they would take action to change the ads, and (3) their 

suggestions for improving the ads. We asked researchers and public interest groups 

who study alcohol and advertising for their opinions on current alcohol advertising 

practices and their specific comments about the five selected ads. 

i 
FINDINGS 

FEDERAL REGULATION 

t Federal jurisdiction is fragmented among several agencies. 

t Federal regulations do not specifically prohibit alcohol advertisements that 

appeal to youth. 

b The Bureau of Alcohol, Tobacco and Firearms’ enforcement authority is 

limited. 

STATE REGULATION 

b States have difficulty adopting legislation to control alcohol advertising. 

t State regulations are limited in their application. 

ALCOHOL INDUSTRY CONTROLS 

b Alcohol industry standards do not effectively restrict advertisements that appeal 

to youth. 

b Alcohol industry standards are unenforceable. 

TELEKWON NETWORK CONTROLS 

b Network enforcement is based on negotiation with advertisers. 

CASE STUDY 

b Regulations and standards have not deterred advertisers from using 

advertisements that appeal to youth. 

ISSUES FOR CONSIDERATION 

Based on a review of the findings in this report, the OIG developed a list of issues for 

consideration that could help eliminate alcohol advertisements that appeal to youth. 

ii 
TABLEOF CONTENTS 

INTRODUCTION.. ............................................... 1 

FINDINGS ...................................................... 6 

FEDERAL REGULATION ....................................... 6 

STATE REGULATION ......................................... 10 

ALCOHOL INDUSTRY CONTROLS ............................... 13 

TELEVISION NETWORK CONTROLS ............................. 16 

CXSESTUDY ................................................ 18 

ISSUES FOR CONSIDERATION .................................... 20 

APPENDICES 

Appendix A: Case Study Advertisements and Responses ............... A-l 

Appendix B: Respondents for the Case Study ....................... B-l 
INTRODUCTION 

PURPOSE 

This inspection examined (1) the Federal, State, alcohol industry, and national 

television networks’ advertising and marketing regulations and standards, (2) the 

monitoring of these regulations and standards, and (3) the application of the 

regulations and standards to five current alcohol advertisements. 

BACKGROUND 

In response to concerns about youth alcohol consumption, Surgeon General Antonia 

Novello requested that the Office of Inspector General (OIG) provide information 

about alcohol advertising practices and the current system governing them. These 

concerns mirror one of Department of Health and Human Services Secretary Louis 

Sullivan’s goals, which is to reduce the prevalence of alcohol problems among children 

and youth. This report is one in a series prepared by the OIG related to youth and 

alcohol. 

In a national survey of junior and senior high school students, the OIG found that 

students notice alcohol ads and especially like those that spotlight attractive people, 

make drinking look like fun, and feature attractive or exotic settings.* Other 

researchers have found that alcohol ads can affect youth attitudes about alcohol. For 

example, one study found that students exposed to beer commercials were more likely 

to think beer is “cool” or “macho.“2 

Alcohol Mark.dng’s Eflect on Youth 

The public has expressed concern about the marketing of alcoholic beverages to youth. 

The concern about alcohol marketing (which includes advertising, labeling, and 

promotions) focuses on youth-oriented advertising, promotional items, and events 

sponsored by the alcohol industry. In a recent public opinion poll conducted on behalf 

of the Century Council, an alcohol industry-supported organization, the Wirthlin 

Group found that 73 percent of respondents believe that alcohol advertising is a major 

contributor to underage drinking. Additionally, the majority of Americans think the 

alcohol industry is “on the wrong track,” one of the reasons being that alcohol “ads 

‘U.S. Department of Health and Human Services, OIG-OEI, Youth and Alcohol: A National 

Survev--Drinking Habits, Access, Attitudes, and Knowledge, OEI-09-9140552, June 1991. 

‘Lawrence Wallack, Diana Cassady,and Joel Grube, “T.V. Beer Commercials and Children: 

Exposure, Attention, Beliefs, and Expectations About Drinking as an Adult,” AAA Foundation for 

Traffic Safety, Fall 1990. 

I 
target the young.“3 In an opinion poll conducted for the Bureau of Alcohol, Tobacco 

and Firearms (BATF), more than 80 percent of respondents believe that alcohol 

advertising influences youth to drink alcoholic beverages.” 

Because of concerns about youth alcohol use and lack of knowledge about alcohol, 

Congress proposed the Sensible Advertising and Family Education Act of 1990. This 

legislation would not restrict the content of alcohol ads, but it would require a 

balanced message in the ads with health warnings and toll-free numbers for 

information about the risks associated with alcohol. 

Broadcasters acknowledge that advertising can affect youth. According to the 

National Association of Broadcasters (NAB), “the impact of advertising on radio and 

television audiences, particularly kids, cannot be overstated. Clever jingles, flashy 

lights, fast talking, and quick pacing, all contribute to the message of commercials.“’ 

While alcohol ads may not be aimed at the underage youth market, according to NAB, 

“youngsters still absorb the message.” 

Controversy remains, however, over the effects of alcohol advertising. While studies 

have not consistently shown that advertising increases adult alcohol consumption, some 

researchers believe that exposure to alcohol advertising affects youth’s attitudes about 

alcohol’s role in society. Researchers have not reached consensus on the 

interpretations of these findings. 

Concern for Certain Advertking Messages 

Concern over alcohol advertising arises because much alcohol advertising goes beyond 

describing the specific qualities of the beverage to creating a glamorous, pleasurable 

image that may attract youth. Research indicates that youth are attracted to certain 

types of alcohol ads.6 Alcohol advertising critics oppose ads that appeal to youth by 

3The Wirthlin Group, ”A National Benchmark Survey of Public Attitudes Toward Beverage 

Alcohol,” prepared for the Cenrury Council, Vol. 1, September1990,p. 13. 

40pinion Research Corporation, “Final Report of Findings of Research Study of the Public 

Opinion Concerning Warning Labels on Containers of Alcoholic Beverages,” conducted for BATF, 

Vol. 1, December 1988, p. 14. 

‘NAB, “Kidsummit Against Drugs,” November 18, 1987. 

6P.P. Aitken, et al., “Television Advertisements for Alcoholic Drinks j& Reinforce Under-age 

Drinking,” British Journal of Addiction, Vol. 83, 1958, pp. 1399-1419; Charles Atkin and Martin Block, 

“Content and Effects of Alcohol Advertising,” prepared for BATF, Pub. No. PB82-123142, Springfield, 

Va: National Technical Information Sexvice, 1981; Lisa R. Lieberman and Mario A Orlandi, “Alcohol 

Advertising and Adolescent Drinking,” Alcohol Health and Research World, Vol. 12, No. 1, 1987, 

pp. 32-33; Kimberly Neuendorf, “Alcohol Advertising and Media Portrayals,” Journal of Studies on 

Alcohol, Vol. 45, 1984, pp. 93-100. 

2 
(1) making lifestyle appeals, (2) making sexual appeals, (3) using sports figures, and 

(4) showing risky activities. 

Lifestyle appeak The aim of a lifestyle ad is to get consumers to identify with 

the image created. According to one report, young people are constantly 

seeking role models and attractive lifestyles to emulate.’ These ads associate 

wealth, success, social approval, and leisurely life with drinking. The ads are 

emotional rather than factual. An example is an ad that shows beautiful men 

and women on a tropical island with no cares in the world. 

S-Z appeals. These ads use sexuality as a direct appeal. Ads feature 

attractive models wearing lingerie or couples in an embrace.’ The ads usually 

make little or no mention of the products’ contents or taste. According to the 

Center for Science in the Public Interest (CSPI), direct sexual appeals in ads 

are more favorably received by young people than by adults.’ The CSPI 

claims that advertising with sexual appeals plays on the feelings of sexual 

inadequacy of young people. 

Sportsfigz~c~ Many alcohol advertisers concentrate ads in sports broadcasts, 

sponsor athletic events, own or sponsor professional teams, and use athletes in 

commercials. Sports figures are common youth heroes. Youth receive a 

positive message about alcohol use through sports figure promotion of alcohol 

products.” Examples of sports themes are ads featuring former professional 

athletes and ads showing friends getting together for weekend sports such as 

softball. 

Risky activities. These ads may show people shooting rapids, climbing 

mountains, boating, skiing, or driving race cars. Many ads associate alcohol 

with the exciting activity by interspersing action scenes and shots of the prcduct 

or by showing alcohol as a reward for the activity. Studies by Atkin and Block 

find that people interpret more than an association between the activity and the 

product; many believe that the actors have consumed the product, or it is 

acceptable for people to drink and do the activity.” 

7Michael Jacobson, Robert Atkins, and George Hacker, The Booze Merchants, Center for Science 

in the Public Interest, 1983, p. 104. 

‘George A Hacker, Ronald Collins, and Michael Jacobson, Marketing Booze to Blacks, Center for 

Science in the Public Interest, 1987, pp. 28-29. 

‘CSPI, “Omnibus Petition for Regulation of Unfair and Deceptive Alcoholic Beverage Advertising 

and Marketing Practices,” Submitted to the FTC, 1985, p. 11. 

‘OLieberman and Orlandi, p. 32. 

“Atkin and Block, pp. 332-334. 
Controls on Alcohol Advertising 

Because of alcohol’s potential for abuse, both public and private sectors have placed 

restrictions on its promotion and sale. As part of these efforts, some organizations 

have placed controls on alcohol advertising in an attempt to assure that alcohol ads do 

not target young people. Restrictions on alcohol advertising come primarily from 

(1) Federal regulations, (2) State regulations, (3) alcohol industry organization 

standards, and/or (4) national television network standards.” 

At the Federal level, the Federal Alcohol Administration (FAA) Act gives primary 

responsibility to the Department of Treasury’s BATF. The BATF regulates the 

permits, labels, and advertising of wine, distilled spirits, and, to some extent, malt 

beverages. The Food and Drug Administration (FDA), in the Department of Health 

and Human Services, has authority over labeling of wine beverages containing less 

than 7 percent alcohol and can affect the content of some point-of-sale advertising. 

The Federal Trade Commission (FTC) has the more general authority to regulate 

deceptive or unfair commercial practices. This authority extends to alcohol advertising 

and marketing activities, such as student spring break promotions. 

The Twenty-First Amendment to the U.S. Constitution repealed Prohibition and gave 

States the responsibility for regulating alcoholic beverages. As a result, some States 

have regulations that permit their Alcoholic Beverage Control (ABC) agencies to 

monitor and control alcohol advertising. 

The Beer Institute, the Wine Institute, and the Distilled Spirits Council of the United 

States (DISCUS) have developed separate advertising codes and standards for their 

members. An industry-supported, non-profit organization, the Century Council, has 

developed advertising standards intended to apply to all three sectors of the alcohol 

industry (beer, wine, and distilled spirits) effective October 1, 1991. 

After the dissolution of the NAB Television Code in 1982, the development and 

administration of advertising standards were left to the networks and stations-l3 

Three major national television networks (ABC, NBC, and CBS) adopted standards 

for alcohol ads, which they contend uphold their commitment to viewers for quality 

programming. 

More information about the Federal, State, alcohol industry organization, and 

television network roles is contained in the Findings section of this report. 

‘2”Alcohol industry organizations”and “industry organizations” refer to alcohol trade associations 

(the Beer Institute, the Wine Institute, and the Distilled Spirits Council of the United States) and the 

Century Council. 

13George Gerbner, ”Stories that Hurt: Tobacco, Alcohol, and Other Drugs in the Mass Media,” 

Youth and Drues: Societv’s Mixed Messages,Office of Substance Abuse Prevention Monograph-6, 

1990, p. 65. 
METHODOLOGY 

To obtain an understanding of the government regulations and voluntary standards 

that control alcohol advertising, we conducted structured in-person and telephone 

interviews with BATF, FTC, FDA, State ABC agencies, alcohol trade associations, the 

Century Council, the American Association of Advertising Agencies, and three 

national television networks (ABC, NBC, and CBS). We selected the three television 

networks because they have national advertising standards. During the interviews, we 

asked respondents about (1) the organization’s regulations or standards for alcohol 

advertising, (2) the effectiveness of these criteria, and (3) suggestions for improving 

the system of control over alcohol advertising. We also contacted researchers and 

public interest groups in the fields of alcohol abuse and advertising in order to discern 

their opinions about alcohol advertising practices.” 

We reviewed Federal laws, regulations, and rulings to determine the extent of Federal 

authority and jurisdiction. We researched State liquor laws in the Commerce 

Clearinghouse Liquor Control Law Reporter to determine the applicable State laws 

that regulate alcoholic beverage advertising. We also reviewed alcohol and media 

organization advertising standards to compare the industries’ codes and standards. 

To understand how the respondents’ regulations or standards apply to specific 

advertising practices, we selected five current television and print ads for alcohol. We 

asked that respondents respond as they would to complaints about each of the ads. 

Because we wanted to focus on how regulations and standards apply to alcohol 

advertising practices and techniques, rather than ads for specific products, respondents 

were asked to respond to all the ads, even those for which they do not have 

responsibility. We specifically stated, “If the ad is for a product the [organization] 

does not represent, please review the ad as if it were for [beer/wine/wine 

coolers/distilled spirits].” We asked respondents about: (1) the application of their 

regulations or standards to the five alcohol ads, (2) the likelihood that they would take 

any action to change these ads, and (3) suggestions for changing or improving the ads. 

We asked interest groups if any aspects of the ads might be particularly attractive or 

misleading to youth. Results of the case study incorporate both comments from 

interviews and written responses. Appendix B lists the individuals and organizations 

contacted for the case study, and Appendix A summarizes their responses. 

“‘The term “interest groups” will be used throughout the report to refer to researchers and public 

interest groups in the fields of alcohol abuse and advertising. 
FEDERALREGULATION 

FEDERAL JURISDICTION IS FRAGMENTED AMONG SEVERAL AGENCIES 

Several Federal agencies have responsibility for regulating alcoholic beverages. The 

BATF regulates the permits, labels, and advertising of wine, distilled spirits, and, to 

some extent, malt beverages. The FDA has authority over labeling of wine beverages 

containing less than 7 percent alcohol. The FIG prohibits deceptive and unfair 

advertising and marketing of all alcoholic beverages. It has concurrent jurisdiction 

with BATF, but FTC generally defers to BATF’s decisions. The following chart 

outlines how responsibility for alcoholic beverages is divided among the Federal 

agencies. 

THREE FEDERAL AGENCIES SHARE RESPONSIBILITY 

ADVERTISING LABELING ‘ROMOTION: ; 

00MALT BEVERAGES 

WINE 7% AND OVER 

!z 

WINE BEVERAGES 

UNDER 7% 

c 

DISTILLED SPIRITS 

FTC* 

0 

* The FTC has authority over all alcohol marketing practices (advertising, 

labeling, and promotions), but usually defers to agencies that have more 

specific jurisdiction (see discussion on p. 7). 

1 For malt beverages, BATF’s authority is limited in certain States. 

2 The BATF requires the Surgeon General’s health warning on all alcoholic 

beverages and the alcoholic content on all wines containing over 0.5 percent 

alcohol. 

While BATF has the specific responsibility for alcoholic beverage permits, labels, and 

advertising, it does not have complete control over all types of alcoholic beverages. 

For example, Federal law does not require malt beverage producers to hold a permit 

although permits are required for wine and distilled spirits producers and importers. 

Federal law also limits BATF’s authority over malt beverage labeling and advertising 

6 
in States that do not have enabling legislation (see detailed discussion of BATF’s 

jurisdiction on p. S). Also, wine coolers do not fall entirely under BATF’s jurisdiction 

because the FAA Act definition of wine does not include beverages, such as wine 

coolers, containing less than 7 percent alcohol by volume. The BATF’s jurisdiction 

over wine coolers is limited to requiring that the Surgeon General’s health warning 

and the alcoholic content appear on the labels. 

Since wine coolers do not meet the definition of wine, they are treated as a “food” and 

come under FDA’s jurisdiction. The FDA regulates the labeling, but not the 

advertising, of wine coolers. Although the FDA has no authority over advertising 

practices per se, it can affect the content of point-of-sale advertising, such as posters 

that accompany the product or advertising tags placed around the necks of bottles. 

Congress granted FTC general authority to prevent deceptive and unfair business 

practices, including marketing and advertising. While FTC has jurisdiction over the 

advertising, labeling, and promotion of all alcoholic beverages, it will defer in 

individual cases if BATF or FDA has specific regulations or makes specific decisions 

regarding a product. For example, if BATF approves a product label and decides it is 

not deceptive, FTC generally defers to BATF’s decision. Because BATF and FDA 

regulations do not address wine cooler advertising, FTC has sole jurisdiction. 

One alcoholic beverage illustrates the confusion among the Federal jurisdictions. A 

drink called “Passion” (available in Purple, Pink, Peach, and Tropical flavors) contains 

grain alcohol in some areas of the country and substandard wine in others.15 The 

BATF has jurisdiction over the grain alcohol version of Passion. The FDA, on the 

other hand, has jurisdiction over the labeling of the substandard wine mixture, which 

contains less than 7 percent alcohol. The FTC can consider questions that neither 

BATF nor FDA address. This could include such issues as whether the promotion of 

a plastic squeeze-bottle that accompanies 2-liter bottles of Passion is an unfair or 

deceptive practice. 

FEDERAL REGULATIONS DO NOT SPECIFICALLY PROHIBIT ALCOHOL 

ADVERTISEMENTS THAT APPEAL TO YOUTH 

The primary goal of the BATF and FTC regulations regarding advertising is to ensure 

that consumers receive truthful and accurate information about products. The FDA 

does not have regulations that specifically address alcoholic beverages or advertising 

practices. 

The BATF regulations prohibit advertising claims that are deceptive, misleading, 

disparaging of a competitor’s product, obscene, or indecent. They do not specifically 

address alcohol advertising and youth. Although one BATF ruling prohibits showing a 

“The BATF defines substandard wine in 27 C.F.R. 4.21(h)(2) as wine that fails to have the 

composition, color, and clean vinous taste and aroma of normal wines, has an excessvolatile acidity, or 

has excessadded water or sugar. 

7 
-- -- 

prominent athlete consuming a malt beverage, this ruling does not concern the issue of 

an athlete’s appeal to youth. Instead, BATF is simply concerned with misleading 

consumers about alcohol’s effect on athletic ability. The BATF regulations also do not 

address targeting youth or promoting alcohol at events. 

The FTC prohibits commercial practices that are deceptive or unfair. An example of 

a practice that would be unfair to underage youth is an offer to send away for a 

6-pack of beer without having to prove age. The FIG also addresses marketing and 

advertising that affect health and safety. Recently, FTC (in conjunction with BATF 

and FDA) investigated the Canandaigua Wine Company that produces Cisco, a wine 

with 20 percent alcohol. The marketing practices for Cisco were in question because 

several young people were hospitalized for overdoses of Cisco. In this case, the 

promotion and packaging of Cisco misled consumers to believe it was a wine cooler. 

Generally, the FTC is not concerned with alcohol ads that use emotional appeals or 

lifestyle themes because the Commission’s jurisdiction is limited to deception and 

unfairness and does not extend to issues of taste and public mores. 

THE BATF’S ENFORCEMENT AUTHORITY IS LIlHITED 

The BATF has faced several barriers in enforcing its regulations. Most importantly, 

the FAA Act limits BATF’s authority over malt beverage marketing practices, 

including labeling and advertising. Because the FAA Act does not require basic 

permits for brewers, BATF lacks an important enforcement tool. 

The Penultimate Paragraph of the FAA Acti limits BATF’s jurisdiction over malt 

beverages to States that have enacted legislation similar to BATF’s. Without State 

regulations that mirror BATF’s regulations, BATF has no ability to regulate malt 

beverage labeling or advertising. The 25 States that have adopted the FAA Act pose 

no problems for BATF. Also, some States have adopted parts of the FAA Act. On 

the other hand, BATF’s capability is extremely limited in States that have no laws 

concerning alcohol advertising. 

Because Federal law does not require malt beverage producers, i.e. brewers, to hold 

basic permits, BATF’s ability to achieve compliance from brewers is compromised. 

Brewers hold no permits for BATF to suspend or revoke in case of violations, which 

means that BATF must resort to criminal prosecution. According to a BATF official, 

“The brewers know that [BATF] can only take limited action against them.” 

The BATF is seeking ways to expedite enforcement. An enforcement action against 

the Coors Light slogan “Won’t Slow You Down” continued for 2 years before 

BATF sought alternative methods. The BATF obtained permission from the 

Department of Justice (DOJ) to seek an injunction through the civil courts. The 

BATF then threatened Coors with civil court action. Within a matter of weeks, Coors 

I627 U.S.C. 205. 

8 
. 

and BATF agreed to a settlement. The BATF plans to use similar civil proceedings in 

several cases of malt liquor ads that refer to the strength of the product. 

‘Ihe BATF has limited control of the nation’s “No. 1 strongest malt” 

If you want to see the rap singer Ice Cube, you can go to a movie about 

Los Angeles gangs, Bon N the Hood, or you can simply stay tuned and watch 

television ads for St. Ides malt liquor. The St. Ides ads contain overt 

references to street gangs, sexual conquest, and the malt liquor’s strength. 

Listen closely and you will hear: in a black can, why don’t ya grab a &pack and 

get your girl in the mood quicker and get your jimmy thicker with St. Ides malt 

liquor. 

While Federal alcohol advertising regulations forbid practices in the St. Ides ad, 

such as promoting its alcoholic strength and disparaging a competitor’s product, 

BATF’s authority over malt beverages is limited in certain States. Because 

California, for example, has no law that prohibits promoting alcoholic strength, 

BATF cannot act against the St. Ides campaign in that State. A BATF official 

expressed frustration that “when a State like California does not have enabling 

legislation, 10% of the American population is not being protected.” The 

St. Ides ads are currently under investigation by BATF in other States. . 

9 
STATE REGIJLATION 

STATES HAVE DIFFICULTY ADOPTING LEGISLATION TO CONTROL 

ALCOHOL ADVERTISING 

Each State has the authority to regulate alcoholic beverage advertising. Twenty-nine 

out of the 50 State and the District of Columbia ABC administrators believe that 

restricting alcohol ads can be effective in reducing advertising’s youth appeal. 

However, only 17 States have regulations that prohibit ads with youth appeal. 

Pressures on State legislators from vested interests can be a barrier to regulating 

alcohol advertising. According to one State official, “Passing these regulations 

[prohibiting alcohol advertising and promotions on college campuses] was a bloody 

battle.” Another State official found strong lobbyists opposing legislation that would 

have prohibited alcohol ads on television. According to the official, representatives 

from the alcohol industry threatened to discontinue the television broadcast of all 

sports programming, including the Super Bowl. In the face of this pressure, the 

legislation did not pass. 

Disagreements within a State also can inhibit an ABC’s attempt to control advertising. 

For example, the Washington State Liquor Control Board has been very active in 

attempts to restrict alcohol advertising. Early this year, however, a proposal by the 

Washington State Medical Association to restrict ads that imply “liquor enhances. . . 

professional or social achievement of any kind” failed to gain the support of the 

Board.17 Critics of this legislation claimed there was insufficient evidence of the 

effect of alcohol advertising on consumption. Additionally, the board members 

decided that the State already had taken enough precautions to prevent alcohol ads 

from appealing to youth. 

STATE REGULATIONS ARE LIMITED IN THEIR APPLICATION 

Problems with the wording of regulations and the nature of short-term, national ad 

campaigns diminish the effectiveness of State controls. Narrow definitions limit the 

application of many State regulations that attempt to prevent the appeal of alcohol 

advertising to youth. For example, Utah prohibits ads or promotional schemes that 

are “primarily or especially appealing” to underage youth. However, an ad is not in 

violation of the law if it appeals to 25year-old adults just as much as it appeals to 

13-year-old adolescents. This means alcohol ads could contain themes that appeal to 

youth (such as cartoons or youth-oriented music) as long as at least some adults also 

find the ad appealing. 

17JayMatthews, ”Washington State Rejects Ban on Alcohol Advertising,” Washington Post, January 

31. 1991. 

10 
In other States, the regulations are so unclear that it is difficult to agree on their 

interpretation. Virginia’s provision reads, “No advertising shall contain any statement, 

symbol, depiction or reference that would tend to induce minors to drink.” Little 

consensus exists on which ads violate this regulation. According to a State ABC 

official, “We have various regulations on advertising, and for the most part, they are 

completely ineffective because of difficulties with definitions.” 

Logistics can cause problems with enforcement, even if there is a clear violation of 

State law. The short duration of some advertising campaigns, combined with the time 

it takes for the State ABC to take action, can mean an ad will run despite the fact it is 

in violation. In Texas, the Anheuser-Busch “Budman” campaign violated State law 

that bars the use of contests or sweepstakes to induce purchase of alcoholic products. 

When State officials realized Anheuser-Busch had continued the “Budman” campaign 

in spite of the law, the ABC issued a cease-and-desist order and began steps to 

suspend Anheuser-Busch’s license to sell beer within the State. However, because the 

campaign was scheduled to end on Labor Day, “the matter will probably be moot 

before the [ABC] can hold a hearing.“” The campaign has now ended and 

Anheuser-Busch still holds its license to sell beer in Texas. Additionally, the wide 

scope of national campaigns often limits a State’s ability to control advertising. While 

States can regulate the content of alcohol advertising originating within their 

boundaries, they cannot restrict advertising originating in other States. 

18Marj Charlier, “Anheuser’s Budman Promotion Creates Big Brouhaha in Texas,” Wall Street 

Journal, August 19, 1991, Bl. 

11 
In some cases, a State can be more timely and eflective than the BATF 

The BATF and the New York Attorney General have had varied success in 

seeking discontinuance of the Coors Light “Won’t Slow You Down” 

campaign. While BATF spent 2 years corresponding with Coors and had to 

obtain DOJ’s permission to seek an injunction, the State Attorney General 

filed a suit and within a year was able to limit Coors’ future advertising 

practices. 

In 1983, Coors developed the slogans “Won’t Slow You Down” and “No 

Slowin’ Down” as part of an ad campaign showing active men and women 

involved in several types of athletic activities. This campaign suggests that 

Coors Light will not impede a consumer’s physical abilities, although alcohol 

is a depressant on the central nervous system. 

The New York Attorney General’s Bureau of Consumer Frauds and 

Protection office issued an Assurance of Discontinuance to Coors for the 

“Won’t Slow You Down” campaign. Coors withdrew its ads based on the 

threat of litigation, since it appeared that the ads violated the false and 

misleading provision in the State General Business Law. Coors agreed to 

phase out the slogan by October 1, 1991, and not to use the Silver Bullet jet, 

race car, or any ads portraying these items or any sports equipment in the 

State of New York. 

New York State’s action against Coors was independent of BATF’s 

involvement. Greater coordination between BATF and the States’ Attorneys 

General could improve effectiveness in the future. 

12 
ALCOHOLINDUSTRYCONTROLS 

ALCOHOL INDUSTRY STANDARDS DO NOT EFFECIWELY REXSTRICT 

ADVERTISEMENTS THAT APPEAL TO YOUTH 

Alcohol trade associations (the Beer Institute, the Wine Institute, and DISCUS) have 

developed separate alcohol advertising codes and standards for their members. The 

Century Council provides alcohol advertising standards for its members in all three 

sectors of the alcohol industry (beer, wine, and distilled spirits). Each of the 

advertising codes and standards has youth-related provisions.” The following table 

compares each organization’s provisions related to youth appeal: 

INDUSTRY ADVERTISING GUIDELINES: 

A COMPARISON OF YOUTH-RELATED PROVISIONS 

ALCOHOL ADVERTISEMENTS SHOULD NOT BEER DISCUS WINE CENTURY 

BE DIRECTED TO APPEAL TO YOUM BY: INSTITUTE INSTITUIE COUNCIL 

HAVING A PARTICULAR YOUfH APPEAL X X X 

ENCOURAGING UNDERAGE DRIN’KING X 

SHOWlNG UNDERAGE MODELS X X X 

SHOWING UNDERAGE DRINKING X 

SUGGESTING VIOLATION Of DRINKING AGE LAWS X X 

ALCOHOL ADS SHOULD NOT USE 

YOlJTH-ORIENlED SUEtJECT MATTER. INCLUDING: 

MUSIC X 

LANGUAGE X X 

GESTURES X X 

CARTOON CHARACTERS X X 

OBJECTS. e.g. TOYS X 

COMPARISON WITH YOUTH PRODUCTS, e.g. CANDY X 

ADS SHOULD NOT USE PERSONALmES 

TO APPEAL TO YOUTH. SUCH AS: I I I 

AT YOUTH-ORIENTED EVENTS. e.g. CONCERTS X 

NEAR SCHOOLS OR IN COLLEGE MEDIA X 

ON YOUTH TEUS. e.g. TOYS, GAMES X 

a DENOTES -l-HAT ME ORGANIZATION’S GUIDELINES ADDRESS THIS lTEM 

“Beer Institute, Brewine Industrv Advertising Guidelines, 1984;Wine Institute, Code of 

Advertising Standards, 1987; DISCUS, Code of Good Practice, 1987; Century Council, The Centurv 

Council Code of Responsible Marketine and Advertising Practices, draft, 1991. 

13 
While the industry advertising standards purport to guide alcohol advertisers towards 

responsible behavior, they fail to prevent advertising considered to have youth appeal. 

Several factors limit the alcohol industry standards’ effectiveness in preventing ads that 

appeal to youth. They include: 

(1) vague standards that do not specify unacceptable practices, 

(2) narrow standards that do not address many ads that may mislead or 

appeal to youth, 

(3) inconsistency in the definitions of youth appeal, and 

(4) the failure of most industry organizations to address marketing and 

promotional activities. 

Several advertising standards are worded vaguely. Because the standards do not 

specifically state what practices are unacceptable, advertisers are left with little 

guidance. The DISCUS Code of Good Practice, for example, covers youth issues with 

the broad statement that ads should not be “in any manner directed or primarily 

intended to appeal to persons below the legal drinking age.” Although DISCUS 

interprets the standard to discourage promotional activities on college campuses, this 

is not evident from reading its code. Also, the terms “directed” or “primarily intended 

to appeal” are difficult to define. 

Although some standards spell out precisely which practices are unacceptable, they are 

extremely narrow in scope. For example, one of the Century Council’s standards 

discourages advertising and marketing from making claims that “persons cannot solve 

social, physical, or personal problems without consuming the product.” This means 

ads that state alcohol is essential to solving problems are not allowed. However, ads 

that indicate alcohol can help a person solve problems, such as the Bass Ale campaign 

that “it helps you get to the bottom of things,” are not prohibited by the standards. 

Furthermore, the Century Council stipulates that advertising does not violate its 

standards if it merely portrays attractive, affluent people who appear to be having fun. 

These stipulations narrow the scope of the Century Council’s effectiveness in limiting 

ads that appeal to youth. 

Alcohol industry standards are inconsistent concerning which practices have youth 

appeal. The Wine Institute and Century Council recognize that a broader scope of 

advertising practices appeal to youth. For example, while the Wine Institute and 

Century Council standards discourage the use of cartoon characters, the Beer Institute 

and DISCUS standards do not. The Beer Institute, in fact, likens its use of cartoons 

to the use of cartoons in ads for a variety of adult products, including life insurance. 

Similarly, the Wine Institute and Century Council discourage any use of amateur or 

professional sports celebrities because of their potential appeal to youth, while the 

DISCUS and Beer Institute standards have no provisions that restrict the use of sports 

figures. 

14 
Most industry organization standards do not address promotional activities. The 

Century Council is the only industry organization that discourages promotional 

practices that primarily appeal to youth. Besides restricting alcohol companies from 

promotions at youth-oriented events, their standards also restrict product names and 

logos from appearing on toys, game equipment, or child-sized clothing. Other industry 

organizations do not address these practices specifically. Notably, the Beer Institute 

does not prevent promotional items such as Spuds MacKenzie stuffed animals or 

model race cars carrying the Miller logo. 

ALCOHOL INDUSTRY STANDARDS ARE UNENFORCEABLE 

Voluntary provisions and persuasion are the extent of the industry organizations’ 

enforcement of their advertising standards. Once an advertising practice has been 

brought to the attention of the Beer or Wine Institutes, resolution of the issue is 

limited to nonthreatening persuasion. Members have discretion over how to respond 

to concerns about irresponsible advertising. The DISCUS Code Review Board 

clarifies discrepancies over interpretation of the standards and informs the advertiser, 

leaving any action to the discretion of the advertiser. The Beer Institute simply refers 

concerns “to the party being complained about to see if they want to do anything.” In 

response to our questions about several beer ads, the Beer Institute refused to get 

involved and referred our questions to the advertisers, most of whom did not respond. 

The Century Council plans to have members perform self-evaluations of their 

advertising practices vis-a-vis the standards. A Century Council representative 

explained that while the chairman can persuade members to change their advertising, 

the Council has “gone as far as it can according to legal counsel.” 

Alcohol industry organizations believe they cannot penalize members for advertising 

code or standards violations, because of concerns about antitrust laws. In a 1978 letter 

to the Wine Institute, FTC stated that because the Wine Institute’s standards are 

strictly voluntary they present no antitrust concern. According to FTC, antitrust laws 

allow some voluntary restrictions of advertising themes considered socially undesirable, 

unless an undue restraint of trade results from the restriction. The Wine Institute is 

concerned that its standards, when enforced, would restrict competition. This concern 

was reinforced in 1982, when DOJ determined that the NAB Television Code 

appeared to limit advertising artificially, thereby restricting trade and violating antitrust 

laws. 

15 
-- 

-- 

TELEVISION NETWORK CONTROLS 

NETWORK ENFORCEMENT IS BASED ON NEGOTIATION WITH 

ADVERTISERS 

While networks maintain advertising standards to ensure quality programming for 

viewers, they also must attract advertising revenues to stay in business. Television 

networks rely solely on advertising revenues, and a great proportion approximately 

$700 million in 1989 comes from beer and wine advertisers.20 Without alcohol 

advertising, many networks would undergo financial problems and be forced to curtail 

programming, especially sports programs.21 In order to walk the thin line between 

maintaining responsible advertising and revenues, the networks: 

(1) negotiate with advertisers concerning the content of advertising; 

(2) allow their standards to be interpreted by local station managers, 

enabling them to attract more local advertising revenue; and 

(3) are gradually loosening their interpretation of responsible advertising. 

The networks negotiate with advertisers concerning the interpretation of their 

standards. Negotiation is fostered because advertisers and networks need each other 

for exposure and revenues, respectively. At least half of the ads reviewed by networks 

require further documentation or revision. CBS has found that ad agencies are very 

cooperative and responsive to suggestions for revisions. In one case, they asked an 

advertiser to move the child in an alcohol ad into the background to make any 

reference to children incidental. At times in the negotiation process, the advertisers 

convince the networks that the standards do not warrant changes in their ads. Overall, 

the networks reject only a very small percentage of alcohol ads. Even in the 

complaint process, the networks work closely with the advertisers to reach a 

compromise. The network wants to sustain good relations with its viewers and 

advertisers. It is in the best interests of the network to act as a mediator for 

resolution. 

Although networks have national standards to control the appeal of alcohol advertising 

to youth, these standards do not apply to local stations. Network standards serve as 

models for the network-owned stations, affiliates, and independent stations. These 

stations interpret the standards in light of local interests and the need to attract local 

advertisers. 

20Communicationwith NAB, January 8, 1991. 

“Statement of Edward 0. Fritts of NAB, before the Senate Subcommittee on Alcoholism and 

Drug Abuse, Committee on Labor and Human Resources, February 7, 1985. 

16 
The current trend has been to loosen network standards even further. According to 

an article in the Wall Street Journal, one network’s standards are weakening in 

response to advertiser pressure.22 The ABC network, which has lost advertising 

revenue due to the recession and to competition from independent and cable 

networks, has decided to relax its longstanding standards in order to attract more 

advertisers. So far, these revisions to the alcohol advertising standards have allowed 

advertisers to suggest off-screen drinking. According to the Wall Street Journal, it 

appears likely that the other large networks will follow ABC’s lead to loosen 

standards. 

“2JoanneLipman, “ABC to Relax Longstanding Guidelines for Ad Content,” Wall Street Journal, 

September 5, 1991, Bl. 

17 
CASE STUDY 

REGULATIONS AND STANDARDS HAVE NOT DETERRED ADVERTISERS 

FROM USING ADVERTISEMENTS THAT APPEAL TO YOUTH 

The current system fails to address the public’s concern that alcohol ads appeal to 

youth. After viewing a selection of five current ads for alcoholic beverages, interest 

groups cited several techniques and themes that appeal to youth. For the most part, 

however, government, alcohol industry, and network respondents made no reference 

to youth appeal in the ads. Their regulations and standards do not prevent these 

types of ads from reaching the public. 

Interest groups took issue with the ads because they believe the ads use 

b lifestyle appeals, 

b sex, 

b fantasy, 

b fast cars, 

t cartoons, 

b fast music, and 

b current slang 

which all appeal to youth. In most cases, interest groups believed revisions would not 

improve the ads. Whether or not the ads intentionally appeal to youth, these 

respondents suggest that these elements can be eliminated by allowing only 

“tombstone advertising.” “Tombstone advertising” restricts ads to depicting the 

product, its name, the price, and where it is available. 

Federal agencies did not comment on any issues of youth appeal in the five ads. The 

BATF cited regulations that require the depiction of an approved label and mandate 

the disclosure of the responsible advertiser and class of the product. The BATF 

refused to comment on the St. Ides ad because comments might interfere with a 

pending investigation. The FTC officials said they were unable to comment on the 

specific ads because of their law enforcement authorities and ongoing investigations. 

Representatives of the alcohol industry did not find that any of the ads appealed to 

youth or violated advertising standards. Most gave no response. The Beer Institute 

refused to respond to hypothetical complaints about ads. All of the alcohol industry 

organizations refused to comment on the ads for products not advertised by their 

members, in spite of our request that they respond as if the ads were for members’ 

products. 

The networks raised concerns about the taste, youth appeal, and hazardous activities 

in the ads, but did not say they would reject them. The networks did not reply 

formally to the survey because of alleged concerns over client confidentiality. 

18 
Appendix A contains a description of the five ads and the actual responses from 

interest groups, BATF, the alcohol industry organizations, and the national networks. 

Appendix B lists the respondents for this case study. 

19 
ISSUES FOR CONSIDERATION 

Based on a review of the findings in this report, the Office of Inspector General has 

identified some issues for consideration that could help eliminate alcohol 

advertisements that appeal to youth. While this list is not comprehensive, it should 

provide a basis for discussion of alcohol advertising controls. 

Federal Regulation 

1. Should the Federal Alcohol Administration (FAA) Act be amended to give BATF 

more authority over malt beverage producers ? For example, the FAA Act could 

be amended to require that brewers hold basic permits, or BATF’s jurisdiction 

could be extended to all States without requiring that States have enabling 

legislation. 

2. Should the FAA Act be amended to give BATF regulatory authority over wine 

beverages containing less than 7 percent alcohol by volume? 

3. Should the FDA’s ingredient labeling requirement be extended to apply to all 

alcoholic beverages? 

4. Should BATF adopt regulations that forbid alcohol advertising that appeals to 

youth including specific practices, such as the use of cartoons? 

5. Should BATF adopt regulations that restrict certain types of alcohol promotional 

activities? 

6. Should BATF consider restricting alcohol advertising to “tombstone advertising” 

(depicting only the product, its name, its price, and where it is available) to 

prevent alcohol ads that appeal to youth? 

7. Should the Federal government require that alcohol advertisers fund counteradvertising to promote public awareness of the dangers of alcohol? 

8. Can the Federal government ensure that enforcement of industry codes and 

standards does not violate First Amendment rights and antitrust laws? 

9. Can the Federal government work in cooperation with States, the alcohol industry, 

the advertising industry, national television networks, and other media to eliminate 

alcohol ads that use lifestyle appeals, sexual appeals, sports figures, and risky 

activities? 

20 
State Remlation 

1. Should the 25 States and the District of Columbia that have not yet adopted the 

FAA Act (or portions thereof) do so in order to increase BATF’s ability to 

enforce Federal malt beverage regulations? 

2. How can States use their authority to regulate intra-State advertising in a more 

timely and effective manner? 

3. What special measures must States take to regulate national broadcast advertising 

campaigns aired by stations in their States? 

4. Is there any way that States can control advertising broadcast by stations outside 

the State? 

5. Should States adopt clear regulations that forbid alcohol advertising that appeals 

to youth including specific practices, such as the use of cartoons? 

6. Should States consider restricting alcohol advertising to “tombstone advertising” 

(depicting only the product, its name, its price, and where it is available) to 

prevent alcohol ads that appeal to youth? 

Alcohol Industry 

1. 

2. 

3. 

4. 

5. 

6. 

7. 

8. 

Should alcohol industry codes and standards be more specific about what is 

unacceptable advertising? 

How can the alcohol industry avoid narrow interpretations of its standards? 

Can and should the alcohol industry develop one uniform advertising code for all 

alcoholic beverages? 

Should alcohol industry standards be expanded to include promotional activities? 

What else can the alcohol industry do to improve standards that restrict alcohol 

advertising’s appeal to youth? 

Should the alcohol industry be responsible for self-policing its advertising 

practices? 

How can the alcohol industry be held accountable to the public for its advertising 

practices? 

How can the alcohol industry make its standards enforceable? 

21 
9. Should advertising agencies be held accountable to their trade associations for 

advertising practices? 

Networks 

1. Should network-owned stations, independents, affiliates, and cable stations have 

consistent standards for all alcohol ads on television? 

2. Should the television networks consider strengthening their standards restricting 

alcohol advertising that appeals to youth? 

3. Should television networks consider restricting alcohol advertising to “tombstone 

advertising” (depicting only the product, its name, its price, and where it is 

available) to prevent alcohol ads that appeal to youth? 

4. Should networks be responsible for enforcing advertising standards? 

5. Can the television networks work in cooperation with the Federal government, 

States, the advertising industry, and other media to eliminate alcohol ads that use 

lifestyle appeals, sexual appeals, sports figures, and risky activities? 

22 
APPENDIX A 

CASE STUDY ADS AND RESPONSES 

This appendix contains examples of the five ads from the case study, and 

responses from interest groups, BATF, the alcohol industry 

organizations, and the national networks. 

We obtained the storyboards duplicated here from Radio TV Reports. 

The print ad appeared in a June 1991 publication. 

A-l 
ST. IDES MALT LIQUOR -- ICE CUBE 

RESPOhTDENT COMMIENTS 

Interest 

croups: 

b 

t 

BATF.-

DISCUS: 

Beer 

Imtitute: 

Wm 

Institute: 

Century 

Cod 

Networks: 

Interest groups point out the use of a rap celebrity: 

Ice Cube, a rap artist and movie star, uses the language and music of 

inner-city youth. 

St. Ides promotes heavy consumption with 40-ounce bottles. 

Ice Cube models public drinking, which is illegal in many urban areas. 

The BATF refused to comment on the ad due to a pending 

investigation. 

Refused to comment. 

Refused to comment. 

Refused to comment. 

Refused to comment. 

The networks might consider the use of a rapper as youth appeal. CBS 

has turned down one ad with a rap group because the members 

appeared young, yet rap music in general is not prohibited. NBC 

standards do not allow making appeals to youth or referring to the 

strength of the beverage. NBC also considers “the specific racial 

association to offend general taste and propriety.” 

A-3 
-- 

Interest 

Groupc 

b 

BAlF.-

DISCUS: 

Beer 

Institute: 

Wme 

Institute: 

Century 

coluldNetwods: 

BUDWEISER BUDMAN 4TH OF JULY 

RESPONDENT COMMENTS 

Interest groups decry Budweiser’s use of a superhero: 

As a superhero, Budman embodies strength, courage, and manhood, 

which capitalize on youths’ sense of invulnerability. 

The contest encourages consumption. If you buy more of the product, 

you increase the likelihood of winning. 

The bright comic book colors attract children’s attention. 

The context is a treasure hunt, a children’s game. 

The BATF finds the ad in compliance. As long as the ad contains 

information about the responsible advertiser and class of product and 

portrays a true reproduction of an approved label, the ad is in 

compliance with BATF regulations. 

Refused to comment. 

Refused to comment. 

Refused to comment. 

Refused to comment. 

Refused to comment. 

A-5 
MILLER GENUINE DRAFT -- RUSTY WALLACE 

RESPONDENT COMMENTS 

Interest 

Groups: Interest groups warn that the ad links drinking with hazardous driving: 

b This commercial mixes drinking, driving, and the high-risk setting of 

racing through town on wet streets. 

t Rusty Wallace, a racing celebrity, has been noticed by everyone in town 

depicting his high status and use as a role model. 

BAlF.- The BATF is concerned only about the class of the product, and this ad 

does not appear to state the class of the product as regulations require. 

DISCUS: Refused to comment. 

Beer 

Imtitule: Refused to comment. 

Wm 

Institute: ’ Refused to comment. 

Century 

CounciL- Refused to comment. 

Networks: Two networks are concerned with the use of race car drivers in alcohol 

ads. While NBC does not allow active athletes or the association of 

drinking and driving in alcohol ads, they do not consider race car drivers 

to be athletes and find it acceptable for a company to tout its 

sponsorship of a race car. Although CBS forbids ads that intersperse 

actual race footage with product shots, they aired this ad in 1990. 

A-7 
-- 

Interest 

Groups: 

t 

BATF.-

DISCUS: 

Beer 

hstitute: 

Wm 

Ikdu.te: 

Century 

Counc~ 

Nehvorkx 

MALIBU DUNCAN 

RESPONDENT COMMENTS 

Interest groups criticize the use of a cartoon and outlandish humor: 

The cartoon reflects the popular “Far Side (Gary Larson) type humor 

and drawing.” 

The characters are at the beach surfing and windsurfing, two high risk 

activities that have a youthful appeal. 

The slogan that the taste is “slightly off the map” appeals to notions of 

independence and rebellion among youth. 

The BATF finds the ad in compliance. 

DISCUS finds the ad consistent with its standards. The DISCUS Code 

Review Board notes the characters in the ad do not appear to be 

underage. It considers surfing and windsurfing to be sports enjoyed by 

persons of all ages and points out that the average age of a Nobel prize 

winner for the last 30 years is 59 years. 

Refused to comment. 

Refused to comment. 

Refused to comment. 

NBC considers animation or cartoons in ads to have youthful appeal and 

believes this ad has insufficient disclosure that Malibu is an alcoholic 

beverage. 

A-9 
-- 

Interest 

Groups: 

. 

. 

BATF: 

DISCUS: 

Beer 

Institute: 

Coors: 

wine 

Institute: 

Century 

Counc~ 

Networkx 

COORS LIGHT JOGGING MAN 

RESPONDENT COMMENTS 

Interest groups take issue with the sexual images and beach scenes: 

The ad presents women in an overly sexual and demeaning way. 

The language of the ad tells viewers that drinking is right anywhere, 

anytime. 

The setting of the ad at the beach is inappropriate since 

“30 to 50 percent of drownings are alcohol-related.“23 

The BATF finds the ad in compliance as long as the ad contains 

information about the responsible advertiser and class of product and 

portrays a true reproduction of an approved label. 

Refused to comment. 

Refused to comment. 

Coors maintains the ad is in compliance with regulations and industry 

standards. 

Refused to comment. 

Refused to comment. 

CBS considers hazardous activities to include running in the surf or 

swimming with alcohol. CBS will not allow models standing in the water 

with alcohol. 

“Source: Marin Institute interview held July 30, 1991. 

A-11 
APPENDIX B 

RESPONDENTS FOR THE CASE STUDY 

Federal Agencies 

Bureau of Alcohol Tobacco and 

Firearms (BATF) 

Federal Trade Commission (FTC) 

Food and Drug Administration (FDA) 

Alcohol Industry Organizations 

Beer Institute 

Century Council 

Distilled Spirits Council of the United 

States (DISCUS) 

National Wine Coalition 

Wine Institute 

Advertking Association 

American Association of Advertising 

Agencies (AAAA) 

Networkr 

ABC Network 

CBS Network 

NBC Network 

Interest Groups 

Advocacy Institute 

Center for Science in the Public 

Interest (CSPI) 

Dr. Jean Kilbourne 

Marin Institute 

National Council on Alcoholism and 

Drug Dependence 

National Council for Drug-Free 

Schools 

National Families in Action 

National Parent Teacher Association 

Prevention Research Center 

Dr. Lawrence Wallack 

B-l