Letter to BATF Director Bradley Buckles on "Alcopops"
May 9, 2001
Mr. Bradley Buckles
Dear Director Buckles:
I am writing to express our strong concern about the Bureau's routine approval of labels for alcoholic beverages that appeal primarily to teenage consumers. We ask that BATF take immediate action to review existing label approvals for "alcopop" beverages (sweetened, pre-mixed malt beverages and hard lemonades) and revoke those labels pending the submission, by alcohol makers, of detailed product marketing information that convinces the Bureau and the public that the products are not aimed at and widely used by persons under the legal drinking age.
In the past several years, BATF has approved labels for new, sweetened malt beverages, packaged and labeled in bright, flashy colors and hip, youth-oriented designs. These "alcopop" drinks, including such brands as Mike's Hard Lemonade, Rick's Spiked Hard Lemonade, Hooper's Hooch, Doc Otis' Hard Lemonade, and Smirnoff Ice, (see attached list of brands) represent easy-to-drink "bridge" products that alcohol companies use to move young, "entry-level" consumers from soft drinks (such as fruit punches and sodas) toward experimentation with various types of alcoholic beverages.
Essentially, these "starter drinks" disguise with sugar and fruit flavorings the taste of alcohol and lure some consumers who might otherwise forgo or postpone alcohol use. Although "alcopop" marketers may believe the products are directed to legal-age, entry-level consumers, we have conducted survey and focus-group research that shows that younger people, including teens as young as 14 years old, are more familiar with those products -- and use them more -- than adults. This is not surprising, given their sweet, fruit-drink formulation, the distinctive brightness and attractiveness of their labeling and packaging, and government data that show the average age of initiation to drinking is 13.1 years.
During the past three months, the Center for Science in the Public Interest (CSPI) has conducted two national polls and two focus groups in New York and Massachusetts to assess the appeal of "alcopops" to underage persons in this country [copies of the survey report, quotes from the focus groups, and a video of focus group highlights are attached]. They raise serious questions about the legitimacy of a category of alcoholic beverages designed for and significantly consumed by teens and raise similar questions about the ways in which they are targeted to younger and underage consumers. Following are some of the major findings:
Based on that research, we conclude that the formulation, labeling, packaging, and marketing of "alcopop" drinks primarily target an audience of teenage consumers. In addition, we conclude that those factors mislead consumers to believe that "alcopop" products are intended for teenagers, and not solely adult consumers. Indeed, by large margins, both the adults and teens interviewed in our surveys believed that "alcopops" are more popular with teens than with adults and that they are marketed more to that group than to adults.
In addition, the labeling and packaging of "alcopops" clearly portray products that resemble non-alcoholic fruit-punch beverages and soft drinks far more than they resemble the labels and packaging for beer. Please see the attached photographs of "alcopop" drink containers contrasted with those of non-alcoholic fruit beverages and the leading brands of beer. Two-thirds of the teens interviewed in the CSPI poll thought that "alcopop" product packaging or the way the package or bottle looks are important factors in influencing younger people to at least try them.
The development and marketing to underage persons of sweet-tasting, easy-to-drink "alcopops" can have serious implications for America's youth and for alcohol-related problems throughout society. More than ten million current drinkers in the United States are between the ages of 12 and 20. A substantial body of research confirms that teens have easy access to alcohol, whether from older friends or from outlets that sell to them illegally at least 50% of the time. By any assessment, alcohol -- not marijuana, not cocaine, not heroin, not ecstasy or LSD -- is the leading drug problem among young people and adults in America. It is also the leading drug killer of our young. Alcohol kills more than six times as many teenagers as all illicit drugs combined and is a major factor in the four leading causes of teen deaths -- motor vehicle crashes, unintentional injuries, homicides, and suicides. According to estimates developed for the U.S. Department of Justice, underage drinking costs our nation $53 billion each year and contributes to violence, crime, rape, and accidental trauma of all kinds. According to the National Institute on Alcohol Abuse and Alcoholism, the current total economic cost of alcohol problems in this country tops $184 billion. More than 105,000 people die each year from alcohol-related causes.
Therefore, pursuant to 27 CFR '7.29(a)(1) and (h), relating to prohibited label practices for malt beverages, we request that the Bureau of Alcohol, Tobacco, and Firearms take the following actions to protect underage consumers from alcoholic products aimed directly at them:
(1) Immediately revoke labels for "alcopop" products, including, but not limited to the following brands: Mike's Hard Lemonade, Rick's Spiked Hard Lemonade, Doc Otis' Hard Lemonade, Jed's Hard Lemonade, and Hooper's Hooch.
(2) Require "alcopop" producers to revise the names and the design, coloring, and style of their labeling and packaging to make the products less appealing to underage consumers. "Alcopop" labels and packaging should more resemble those for traditional beers than for non-alcoholic fruit punches and soft drinks. Although the labels of some brands of "alcopops" prominently indicate the alcoholic nature of the beverages, BATF should require that all such products provide clear and conspicuous front-label statements that disclose alcohol content (as a percentage of volume and in number of standard servings per container) and identify the product as an alcoholic beverage. For example, such labeling might state: GOVERNMENT NOTICE: This is an Alcoholic Beverage Intended for Adults Only; or GOVERNMENT NOTICE: This Product Contains Alcohol And is Not a Soft Drink.
(3) Require "alcopop" producers to fully and publicly disclose their marketing plans. As a prerequisite for label approval, BATF should require "alcopop" producers to submit a detailed assessment of the potential impact of the introduction and marketing of their products on underage consumers and their consumption of alcohol. BATF should develop standards for such "alcoholism and underage-drinking impact assessments" along the lines of "environmental impact statements" required to assess the effects of new construction projects and the like. In addition to guiding the label approval process and helping BATF impose reasonable standards for product labels, this information would be valuable in assisting health providers, law enforcement agencies, and other public entities to prepare for potential increases in youth alcohol consumption and take actions to counter such increases.
Thank you for your consideration. We look forward to your reply.
George A. Hacker
To view further information on "alcopops," click here.