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product placement. These recommendations seem sensible and the committee encourages the industry to implement them. At a minimum, product placements should be explicitly disclosed.

Code Enforcement

Among the most important recommendations in the FTC’s 1999 report was its call for the industry to create independent external review boards with responsibility and authority to address complaints from the public or other industry members regarding alleged violations of the codes. In support of this recommendation, the FTC reported favorably on the experience of the National Advertising Division of the Council of Better Business Bureaus (CBBB), which receives and investigates complaints about the truthfulness of advertising, and the National Advertising Review Board, which receives advertiser appeals, and whose members are drawn from both inside and outside the advertising industry. Since the FTC’s 1999 report, Coors is the only company to establish such a review mechanism. The company’s “Advertising Complaint Evaluation” process opens company advertising and marketing materials to review by CBBB’s Advertising Pledge program.


What should be done if the industry codes are not strengthened and the nation’s young people continue to be exposed to such a large volume of messages portraying alcohol use in a favorable light? In the absence of external review mechanisms and in light of constitutional constraints on direct restrictions of advertising, the committee believes that the most fruitful governmental response would be to facilitate public awareness of industry advertising practices and thereby to promote industry accountability through the marketplace.

Recommendation 7-4: Congress should appropriate the necessary funding for the U.S. Department of Health and Human Services to monitor underage exposure to alcohol advertising on a continuing basis and to report periodically to Congress and the public. The report should include information on the underage percentage of the exposed audience and estimated number of underage viewers for print and broadcasting alcohol advertising in national markets and, for television and radio broadcasting, in a selection of large local or regional markets.

In Chapter 12, the committee recommends that a market surveillance mechanism be established to monitor underage use of alcohol according to

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