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An advertisement on YouTube for Peroni 0.0 featured a group of friends in a train station who set up a table at the station bar to have a drink while waiting for their train.
Complaint
The complainant objected to the advertisement being served to their account as they were streaming various historical content from YouTube on their phone to their television during the afternoon for their children. The complainant advised that they were logged into their account as an over 18’s user. They objected on the grounds that they considered that alcohol advertising was not permitted on broadcast media at that time, and by streaming content onto their television from YouTube, they considered the serving of an alcohol advertisement was circumventing the rules and was targeting them and their children.
Response
The advertisers stated that the only advertising placed on YouTube was for the non-alcoholic product variant, Peroni 0.0.
They stated that all advertisements for Peroni Nastro Azzurro placed on YouTube were age-gated and targeted exclusively to adult audiences.
They said that from a targeting perspective, they implemented 100% of available safeguards to prevent underage exposure by the following:
• In-house technology ensured ads were only served to adults.
• Third-party technology, including Google/YouTube, restricted advertising to adult audiences where
alcohol promotion was permitted.
• Content exclusion: All alcohol-marked adverts were automatically excluded from children’s content
categories, and category-level targeting further ensured that content primarily aimed at minors was not
served.
The advertisers said that they categorically excluded children’s content for all advertisements marked as alcohol; they also excluded children’s content through their category targeting options within Google’s platform. For context, they said that they had an exclusion list of approx. 10,000 channels which had been excluded for all their campaigns. For the example used, they said that Google’s categorisation was done automatically in almost all cases as there were hundreds of thousands (or more) of videos uploaded each day.
They said that they complied fully with Google’s policies for YouTube alcohol advertising by the following:
• Age-Gating and Targeting: Google’s advertising policies restricted alcohol ads to countries where it was
permitted and required advertisers to target only adult audiences
• Content Restrictions: Ads promoting alcohol and alcohol-like beverages that don’t meet Google’s policies
are not allowed
• Prohibited Content: YouTube prohibits content that shows minors drinking alcohol.
They said that their campaigns were designed to meet all relevant sections of the ASA Code, including:
• General Advertising Rules: Ads were prepared responsibly and communicated alcohol content
appropriately.
• Alcoholic Beverages Advertising Rules: No marketing was directed at children or likely to encourage
underage drinking.
• Digital Media Rules: Age verification and platform-targeting systems were implemented in line with best
practice and regulatory guidance.
They said that their media agency held IAB Gold Standard accreditation in digital media buying, demonstrating adherence to the highest standards for programmatic advertising, brand safety, and audience verification, and the agency had confirmed that all procedures complied fully with these standards.
Finally, they provided a screenshot showing that the advertisement was targeted to over 18’s.
Conclusion
Complaint Not Upheld.
The Complaints Council considered the detail of the complaint and the advertisers’ response.
The Council noted that while the complainant had stated that alcohol advertising had been served to them, the advertisement aired was for the non-alcoholic product variant and that the complainant had been logged into their over 18’s account when streaming the content. The Council noted the evidence provided showing that the advertising had been targeted at over 18’s only and that the advertising was not served to users who were not logged into an account, nor was it placed in children’s content categories. In the circumstances, the Council did not consider that the serving of the advertising was in breach of the Code.
Action Required
No further action required.
