Use of Consumer-Generated Content and Sharing in Online Services

• Prohibited Advertising: It''s illegal to use or encourage the sharing of consumer-generated content (words or images) in alcohol advertising. This includes using consumers'' photos or videos of drinking in ads, sharing such content on the restaurant''s website or social media, and producing promotional films for consumers to share.

• Guidelines from Valvira:

  • Advertisers should not encourage consumers to share content that can be considered as alcohol advertising.
  • Consumers can "like" content without creating it themselves, and advertisers do not need to remove or block these likes.

• Allowed Activities:

  • Advertising mild alcoholic beverages on traditional websites.
  • Advertising mild alcoholic beverages on social media, as long as sharing functions are restricted, and consumers cannot post comments that could be seen as alcohol advertising.
  • Using consumer-generated content and sharing options in non-alcohol product advertising is allowed, as long as the main message is not about alcohol.

• Prohibited Activities:

  • Encouraging the sharing of alcohol advertising content.
  • Using social media sharing buttons or links to social media on traditional websites controlled by the advertiser, if related to alcohol advertising.
  • Purchasing paid alcohol advertising meant for sharing on social media (like news feed ads).

Combined Offers and Event Packages

• Allowed Offers:

  • A single mild alcoholic drink can be sold as part of a meal deal, as long as there is also a non-alcoholic option available. The drink should not be advertised as free or complimentary.
  • Including one mild alcoholic drink in the price of an event ticket, with the option of a non-alcoholic alternative. The drink must not be advertised as free.
  • For events in licensed premises, it is allowed to include one mild alcoholic drink as a welcome drink or a limited amount of mild alcohol with a meal in the ticket price, provided a non-alcoholic option is available. Strong alcoholic drinks should not be included in the ticket price to avoid illegal marketing.

• Restrictions:

  • Only the license holder can sell packages that include food, alcohol, and entertainment. No third party can buy and resell these packages, as it is illegal to act as an intermediary in alcohol transactions.

Loyalty Events

• Hosting Events: A restaurant or bar can occasionally host time-limited events for loyalty customers, where mild alcoholic beverages are served for free. Guests must have an existing customer relationship, and invitations must be sent in advance and be personal. Only a moderate amount of alcohol should be served at these events. While strong alcoholic drinks can be served, they cannot be advertised or mentioned in the event invitation due to marketing restrictions.

• Private Events: During a private loyalty event, the restaurant or section hosting the event must be closed to the general public. After the event ends, the restaurant can resume normal operations and be open to everyone.

Product Demonstrations

• Alcohol at Events: During events like trade shows, alcoholic beverages can be showcased within the serving area. However, at public events, the showcased alcohol cannot be served for free or at a very low price. Any consumption of alcohol related to the demonstration must comply with alcohol laws.

• Serving Arrangements: Alcohol industry exhibitors must coordinate with the license holder to arrange the delivery and serving of the showcased beverages. Only legally supplied alcohol can be served and consumed in the licensed premises.

Alcohol Advertising in Public Places

• General Rule: Advertising alcoholic beverages in public places is generally prohibited.

• Exceptions:

  • A restaurant can display information about the availability and prices of mild alcoholic drinks on its windows or outside the premises in a factual manner.
  • Advertisements should not be overly large or attention-grabbing outside of sales locations, and descriptions should not be clearly promotional (e.g., detailed descriptions of the product''s quality or taste are not allowed). The ad must be placed close to the sales location unless there is a valid reason, like difficulty in finding the location.
  • Customers should be able to understand the connection between the ad and the sales location. For example, a general lightboard outside a shopping center is not considered advertising by the license holder.

• Outdoor Serving Areas: Advertising on items like umbrellas or furniture in outdoor serving areas should not be so noticeable or directed outside the area that it could be seen as circumventing the public advertising ban.

• Permitted Advertising: Mild alcoholic beverages can be advertised in terms of availability and price through:

  • Window displays with text or symbols.
  • A-stands placed near the establishment.
  • Awnings of the establishment.
  • Advertising umbrellas in outdoor serving areas.

Key Advertising Principles

The alcohol advertising rules can be summarized around a few core principles:

• Strong alcoholic beverages may only be advertised inside the licensed premises, in a neutral and professional manner. No highlighting of individual products, no samples, no outdoor visibility.

• Mild alcoholic beverages may be advertised more broadly — including outside the premises and on social media — but promotions must be factual, not encourage excessive consumption, and must not use consumer-generated sharing.

• Consumer-generated content (photos, videos, comments, shares) may not be used in or encouraged for alcohol advertising in any medium.

• Bundled offers including alcohol are allowed only when a non-alcoholic alternative is available and the alcohol is not the principal message. Only the license holder may sell such packages.

• Games, contests, and prize draws may not involve alcoholic beverages in any way — not as prizes, not as the theme, and not indirectly through product families.

• Loyalty events for existing customers are permitted if closed, time-limited, and personally invited. Strong alcohol may be served but not mentioned in invitations.

• Outdoor public advertising is prohibited except for small, factual signs about mild alcohol availability and pricing, placed close to the premises.