Surrogate Advertising in the Meta Age

While recently driving down a highway somewhere between Uttar Pradesh and Uttarakhand, I was amused by a large hoarding in the middle of nowhere screaming out to passing traffic   - ‘Sharab peena swaasthya ke liye haanikarak hai’ - ‘Drinking alcohol is injurious to health’. Under the bold letters was a big arrow pointing in the direction of the liquor store which had put up the board. It really highlighted how futile and ineffective the current raft of rules regarding advertising of alcohol are. People have found increasingly creative ways of getting their message across.

Since advertising of cigarette brands went dark in 2003, the products now feature prominent large health warnings on neutral packs, and yet sales continue and very profitably. A Euromonitor report showed that though sales started dropping from 2015, the country still sold 81 million sticks in 2019. (The lockdowns of 2020 are expected to have had a significant impact on the sales).

As products disappeared visibly, marketing efforts were also driven down to ground level with sampling, sponsorships and other such techniques, which really can’t match the mass power of above the line marketing channels like TV, Press Radio and Outdoor. Alcohol and personal consumption tobacco products like gutka and some pan masalas have been identified as causes of serious illness and even death and are ostensibly not allowed to advertise their products. But the whole eco-system is happily thriving with the phenomenon of surrogate and extension advertising evolving into an art form in the country.

Everyone is Happy
All parties seem to be happy with this state of affairs. Consumers, mostly innocent, are being bombarded with misleading names and similar looking products, getting brainwashed and confused in the process; producers are selling increasing volumes of their original products; media channels are collecting a good part of their revenues from these brands; celebrities and models are happily making millions while salving their consciences with the argument that they are not lending their voice to ‘those products’ and of course, governments are filling their coffers with revenues that they will anyway find hard to replace.

The Advertising Standards Council of India has tried to make some rules to preempt the vacuous use of alternate, often silly surrogate or extension products as we see today. A brand needs to have a minimum sale of Rs 20 lakh a month and an investment of at least Rs 10 crore in assets, to be allowed to be the extension of an existing brand name, or a surrogate for it. But you just have to observe the production values of  the advertisements and note their frequency and spread across media outlets to know that these restrictions are far from effective. The sales of many of the original products are so high that they can easily spend to meet the criteria and qualify for approval. A study showed a few years ago, that the amount spent on advertising of some masquerading brands, was more than their actual sales revenue.

Enter Social Media
As if the situation is not complicated enough, it’s going to become even more of a challenge to enforce the rules with more social media influencers in the mix. According to a report in The Economic Times,  the overall Indian Influencer market is valued at Rs 900 crore for 2021 and is expected to grow to Rs 2,200 crore in 2025, growing the share of alcohol and tobacco as well. The sheer diversity of the canvas will make it tough to monitor and control the content. On top of that will be the problem of fake content, spotting which would be tricky. And since we are on the subject, is it possible that people could market products like cannabis or other narcotics with surrogate ads? How are our agencies and laws geared up to face these challenges?

We know social media marketing is particularly adept at directly targeting audiences, a major segment of which is younger people. Addressing followers in a language and style that they identify with, an Influencer’s content can easily be shared further by followers, seriously multiplying the reach of  the communication.

This issue has been exercising authorities around the world, and according to a WHO report on alcohol marketing, Finland came up with what seemed to be some practical rules. Influencer content shared online, reviews and appraisals of products that they have written, or funny videos, pictures, puzzles, games or other user generated content cannot be reposted, or used by the brands, thus limiting the spread of the messages.

In most regulated markets, the penalties for broaching rules are levied from both the Influencer as well as the brand. And the fines can be pretty hefty. Furthermore, the rules around declaration of paid content or free products received are being enforced in many countries, leaving followers to decide if they feel the messages that they are receiving are independent and authentic. Three prominent Italian influencers, along with the giant BAT, are under investigation for posts on their timelines with tags and hashtags promoting a BAT product without indicating that they were paid posts.  

While the possible negative effects of social media on society have been the subject of much discussion and debate lately, this aspect of social media marketing has perhaps not received enough attention and needs to be regulated as well.

If we believe that these products are actually the cause for illness, bad health or even death, perhaps they should not be allowed to have advertisements – direct, extension or surrogate.

Otherwise, we need to keep creating an increasingly complicated and likely ineffective web of regulations and systems to control the phenomenon. And while the merry charade goes on,  everyone will be laughing their way to the bank.

Except the customer of course.  

The author has over 30 years’ experience managing and consulting with brands on retail, ecommerce and marketing. He has been a commentator and columnist in many leading publications.

Ajai Kumar Dayal

Guest Author The author has over 30 years’ experience in managing and consulting on big brands, retail, and ecommerce. He has been a commentator and columnist in many publications.