Responsible consumption rules collapse under volume

When 91% of wine is on promotion at once, responsible sale rules can go out of the window.

Walk into an online bottle shop in Australia and you will find nine out of ten wine products on sale at the same time.

Not some of them. Nine out of ten.

That figure comes from a 2023 study that scraped the two largest online alcohol retailers in Australia. Among all 11,184 products listed, 62% were on promotion.

Among wine, 91%. This is not a sale. This is just how alcohol is sold.
Every one of those promotions was approved. Every one met the responsible sale standard.

And then it ran inside a market where almost every other product in the category was also discounted at the same time.

Responsible sale rules exist to put a limit on how aggressively alcohol is promoted. Price. Volume. Availability. The rules are designed to create a check on promotional activity that could drive excessive purchasing.

Those rules work when they are applied to a market where promotions are the exception. They do not work when promotions are the default state of the entire category.

The rules have not changed. The market has.

When 91% of wine products are on promotion simultaneously, a discount is not a promotional event. It is the normal price. The rule designed to govern promotional activity is now governing the baseline.

At that density, responsible sale rules are still being followed. Every brand can demonstrate compliance. Every promotion has been approved. And the market is operating in a way the rules were never designed to permit.

That is the gap. Not non-compliance. A market that has moved beyond what the compliance framework was built to address.

The brands getting ahead of this are seeing
the market, not just their own campaign.

Most brands assess their promotion in isolation. Does this mechanic meet the standard? Yes. Does the pricing comply? Yes. Is it approved? Yes.

The question they are not asking is what their promotion looks like when it runs inside a market where the majority of the category is discounted at the same time.

The brands handling this well look at the full promotional environment before the brief is written. They treat the approval process as the start of the conversation, not the end of it.

After the campaign runs, they examine not just commercial results but whether the promotion executed in a way that responsible sale rules were actually designed to deliver — not just technically met.

Most brands never ask that question. The campaign ends. The results get reported. The approval gets filed. And the same process runs again next year inside the same market.

The rules are being followed. The problem is getting worse.

ABAC complaints and code breaches increased significantly in 2023. They increased again in Q4 2024.

That is not a coincidence. It is what happens when a compliance framework is applied to a market it was not designed for.

The gap between what responsible sale rules intend and what a 91% promotional density market actually delivers is not being measured by anyone.

If it is not measured, it cannot be addressed. And if it is not addressed, following the rules will keep producing the same outcome.

That is the problem. And it starts with asking a different question before the next brief is written.

Sources

¹ 62% of 11,184 products on promotion, 91% of wine — Davies T, O'Brien P, Bowden J, Petticrew M, Pettigrew S. Drug and Alcohol Review, 2024: https://onlinelibrary.wiley.com/doi/10.1111/dar.13935

² ABAC complaints and code breaches increased in 2023 and again in Q4 2024 — The Shout, January 2025: https://theshout.com.au/abac-to-begin-social-media-audit/