About the Pre-Vetting Service
The AAPS Service began in 1992. It provides a valuable, confidential user-pays service to alcohol companies by assessing proposed marketing communications, including product names and packaging against the ABAC Responsible Alcohol Marketing Code ("ABAC") at an early stage of development.
This provides some level of assurance, but no guarantee, against the possibility (and costs) of products or marketing being later ordered out of the marketplace – via the independent ABAC complaint processes. The assessment of proposed material against any standards, including the ABAC will necessarily involve a subjective judgment by an individual pre-vetter and as such the ABAC Adjudication Panel may occasionally have a different view and uphold a complaint against material which has been pre-vetted.
To encourage the frank exchange of views within the Service, any opinion expressed by a pre-vetter in respect to a matter which is submitted for pre-vetting is confidential to the advertising agency/advertiser, the pre-vetters, ABAC executive officer and the representative of their respective industry association (if any).
Annual briefing sessions are held for alcohol companies and their agencies to become more familiar with The ABAC Scheme. In addition, both ABAC and The Communications Council Limited (the Council) offer small group workshops tailored to alcohol advertisers.
Guidance notes have been prepared to assist alcohol companies and agencies in interpreting the Code and its intentions. The Guidance Notes are available for download here.
It is also useful for new users of the scheme to spend some time reading through the Adjudications to see how some of the issues raised by past marketing have been dealt with by the independent Adjudication Panel.
General statement by the Management Committee on the relationship between:
- The ABAC Code which sets out the standards for alcohol marketing, including product names and packaging
- Determinations by the ABAC Adjudication Panel, which define the Code
- The Guidance Notes, which have no status other than to assist alcohol companies and their agencies (and other stakeholders including pre-vetters) to understand the Code
Where conflict exists between the Code and the Guidance Notes, the Code must prevail. The Code is defined by written Determinations issued by the Adjudication Panel. Consequently both pre-vetting ‘convention’ and the Guidance Notes themselves will periodically need to be adjusted to ensure they accurately reflect the Determinations issued by the Adjudication Panel.
How to Use the Service
Alcohol companies must be familiar with their industry’s pre-vetting requirements in relation to different media and different Codes (refer ABAC Rules and Procedures) and must brief their advertising agencies on these matters.
Advertising agencies conducting work for alcohol advertisers must ensure their employees understand AAPS processes and requirements.
Contacting the AAPS Service
All new AAPS applications must be completed via the following link: Online Pre-vetting Application Lodgement.
On lodging a new AAPS application you will automatically be sent a copy of your application and pre-vetter contact details via email and you will then need to send the material you wish to have considered to your allocated pre-vetter via email. Your allocated pre-vetter becomes the ‘lead’ pre-vetter for the application and will manage it though the pre-vetting process until the material is finally approved or rejected.
Ongoing work in relation to a campaign should not be submitted via a new online application but is to be sent to the pre-vetter already handling your campaign direct. It is important that you keep a record of your application form so that you can quote your application number and contact your allocated pre-vetter if you wish to have further pre-vetting work undertaken in relation to other material in the same campaign. If you are unable to recall your application number or allocated pre-vetter for an ongoing campaign, please direct your query via firstname.lastname@example.org supplying as much information as possible about previous pre-vetting work undertaken for that campaign.
If you are not a signatory to the ABAC Scheme you will need to complete an AAPS Registration form and email it to your allocated pre-vetter before the work will be completed.
If an application is rejected or given interim approval the outcome will be communicated by email from the pre-vetter handling the application. If an application receives final approval an automatically generated approval document will be emailed direct to you.
Telephone your allocated pre-vetter to discuss timing issues and submission of materials (either via email or inclusion of a URL on the application form). Whilst pre-vetters endeavour to have applications completed in less than 4 working days, sometimes this may not be possible. Meetings can be arranged to present materials.
The AAPS Service operates during normal business hours. We understand that occasionally pre-vetting may be required outside these hours but we ask that contact outside business hours is kept to a minimum. If it is anticipated that out of hours contact is necessary we ask that this is discussed prior with the relevant pre-vetter.
Submission of materials
Agencies are encouraged to send material at an early stage of development to identify possible problems before significant expense is incurred. So, whilst a pre-vetter has a right to withhold approval for a marketing communication, including packaging until they are satisfied that it complies, an alcohol company can expect that goodwill and commonsense will be applied to the task. For example, a TVC would not change in content from the ‘offline final’, to the ‘online final’ version except for brightness of colours, clarity etc.
AAPS is a user pays service. Pre-vetting services are charged at $135 per half hour for signatories and $180 per half hour for non-signatories (increasing to $200 per half hour from 1 July 2019) exclusive of GST plus disbursements at cost.
If a pre-vetting application (or part of an application) is approved, the marketer will be provided with an AAPS approval number.
Approval is only given for material to appear in the particular media nominated by the marketer on the AAPS application form. If subsequently the material is to appear in different media, it must be re-submitted for approval for the new media.
Approval is given on the basis of the material submitted and it is the responsibility of the agency to re-submit if there are material alterations. Any proposed revisions to existing approved marketing, including packaging, must be discussed with the lead pre-vetter as to whether it needs to be re-submitted for approval as the revisions can materially change the marketing communication . These revisions include, but are not limited to, editing a TV or radio ad to a longer or shorter version of the ad or changing a headline or image in a print or outdoor advertisement.
If a marketing communication is rejected the pre-vetter will advise the applicant and provide their reasons for rejecting the material. If a marketer is dissatisfied with a pre-vetting decision they are encouraged to initially discuss the decision with the pre-vetter. An advertiser may request a review of a pre-vetting decision and/or choose to revise and resubmit the material.
Review of an AAPS decision
If a marketer wishes to seek a review of a pre-vetting decision they must complete an AAPS Review Application and email it to the ABAC executive officer at email@example.com together with a copy of the pre-vetter's decision, the marketing material that resulted in that decision and any other relevant material provided to the original pre-vetter.
The ABAC executive officer will provide the application and material received from the advertiser to two pre-vetters that did not make the decision that is to be reviewed (AAPS Review Panel). The AAPS Review Panel will consider the materials in consultation with one another but independently of the original pre-vetter .
If the AAPS Review Panel:
- unanimously agrees with the decision, the original pre-vetter is directed to maintain the rejection;
- unanimously disagrees with the decision, the original pre-vetter is directed to issue an approval;
- makes a split decision, the original pre-vetter is directed to maintain the rejection.
The cost of a review will be a flat fee of $500.00. If the decision to be reviewed is complex or involves a large amount of advertising material an additional fee may be charged, however this will be discussed with the marketer after receipt of the request for review and prior to the review being conducted.