“The IT rules already have measures to establish age appropriateness of online curated content, and our survey shows that there’s a high degree of user awareness in this regard…we found that there’s likely to be minimal to no impact of tobacco depiction on a person’s smoking behavior. Several studies that show that OTT serves as a way of leisure and as a way for people to de-stress. So, it’s actually a positive thing for most viewers,” highlighted Tamanna Sharma, from Koan Advisory Group.
Sharma was presenting the study ‘The Effectiveness of Tobacco Disclaimers on OTT Content Service’ conducted by Koan Advisory Group in collaboration with Youth Ki Awaaz—at MediaNama’s virtual panel discussion on ‘OTT & Health Warnings’ on June 28. The discussion was hosted with support from Koan Advisory Group, and MediaNama’s community partner, the Internet Freedom Foundation.
Here are some of the key takeaways from Koan’s study:
1. Timeline of the rules: Before delving into the tobacco rules for OTT platforms, Sharma gave a quick overview of the major developments in the Cigarettes and Other Tobacco Products Act and Amendment Rules (COTPA Rules) for films and television in the past decade.
(Timeline of Tobacco Regulation. Source: Presentation slide shared by Tamanna Sharma, Koan Advisory Group)
2. On lack of industry consultation: Sharma pointed out that with the growing popularity of OTT content in the past decade, calls for regulation of tobacco depiction in online curated content by members of civil society and public health organizations have also increased. While reviewing such calls for regulation and subsequent reports, researchers found that most of these regulations were largely based on interactions of civil society groups with the health ministry, and industry feedback was absent, as well as consumer input.
3. Gaps in existing studies:
Sharma highlighted the following gaps in existing literature and surveys (mainly done by the Ministry) calling for expanding the ambit of COTPA Rules to OTT content:
- Absence of any direct investigation of the relationship between tobacco consumption and OTT content.
- Existing literature fails to capture consumer feedback.
- Content regulation of digital media is largely targeted towards the younger cohorts but fails to take into account their habits or viewpoints, an aspect essential for effective implementation of these rules.
Article continues below. You might also want to read: How Will the OTT Tobacco Rules Affect the Content Viewing Experience
4. Regulation in other countries: Koan’s study also refers to countries where content regulation is also linked with tobacco depiction. They found:
- Majority of these countries have deployed age verification mechanisms to target their interventions for young population.
- India’s regulation of Online Curated Content Providers (OCCPs) under the IT Rules of 2021 also calls for a higher degree of age classification of such content.
- India’s regulatory measure is already in line with what other countries are doing and there’s high degree of user awareness in this regard.
5. Koan’s survey: Koan Advisory Group conducted a survey of about 2000 OTT viewers in collaboration with Youth Ki Awaaz in 350 different locations across the country. Here’s what they found:
- Two out of every three respondents said that they are already aware of the existing age rating and content descriptors on OTT content.
- Two out of every three respondents said that depiction of tobacco on OTT would not influence their behavior or how they look towards smoking in any way. There’s likely to be minimal to no impact of tobacco depiction on a person’s smoking behavior.
- At least 53 percent of the respondents agreed that additional disclaimers would impact their viewing experience.
- At least 52 percent of the respondents questioned the need for adding additional disclaimers, given that there are existing content descriptors and age ratings in place as per the IT rules.
- Depiction of tobacco on TV, OTT will have no impact on encouraging smoking uptake. Influence of peers, friends, and mental stress are some of the key factors that encourage a person to uptake smoking.
6. Recommendations from Koan’s study:
- Strengthening the enforcement of IT rules: Sharma informed that out of the 50 OTT services that are currently registered under the Ministry of Information and Broadcasting, not all are associated with the existing Self-Regulating Bodies – Digital Publishers, Content Grievances Council under the Internet and Mobile Association of India (IAMAI), and the Digital Media Content Regulatory Council under the Indian Broadcasting and Digital Foundation (IBDF). She added that it is important that all OTT content services operating in India are affiliated with either of these two existing self-regulating bodies (SRBs) to ensure a uniform user experience across different OCCPs, which is currently not the case.
- Strengthening age-verification mechanisms: “OCCPs can leverage technology to introduce automated systems of age verification and it is important to ensure high standards of age gating and age verification and moving beyond the minimal level of compliance,” Sharma explained. This must be done while ensuring an individual’s privacy and data security. But largely, she underlines the need for ensuring a high standard of age verification and age gating.
Notable points from the Q & A session:
Are there international studies similar to Koan’s? Sharma states that so far, there is no other study that directly looks at the relationship between OTTs and tobacco, as this is a fairly new development and that OTTs have only gained popularity in the last decade or so. However, some studies look at the relationship between television programs and alcohol consumption and how tobacco warnings impact a user’s experience.
Is drug consumption in content also studied, regulated? Koan’s study singularly focuses on smoking and tobacco consumption. Sharma informs that the group has not seen any targeted intervention for drug consumption specifically.
Internationally, has there been any public consultation on tobacco regulations for OTT? Sharma said no, stating that countries have done industry consultation, have taken a user-centric approach, and are not paternalistic in approach. This is not true for India’s latest OTT tobacco rules though.
Are there studies on effectiveness of point-of-sale warnings vs warnings on TV, OTT? Sharma responded stating that advertisements at point-of-sale, imagery on cigarette packs are discouraging factors – as per what respondents have indicated. But, whether or not there is a direct comparison between the two, we have not come across any such studies.
What are the behavioural insights from the study? “People who are watching OTT content are extremely aware of what they’re watching, there is awareness about age-appropriateness of content. Most of the respondents in our survey said that watching tobacco depiction of OTT is really not going to impact their smoking behavior or how they already look at smoking. So, in terms of behavioral impact, I would say the results say that it’s not going to impact in any way tobacco depiction,” Sharma responded.
Are user surveys a good measure to study cause and effect? Sharma highlights that it is important to take into account a consumer’s experience when a regulation is brought out on their behalf and a user survey is needed for that reason. “Whether there would be a bias. Yes, there might be a bias, but any sort of survey and analysis does factor those biases into account. So, whatever results we come up with, the methods that we use for our analysis already factor these biases into account,” she stated.
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Also Read:
- Why Discussion On Public Versus Private Viewing Is Key To Framing Rules For OTT Content?
- Health Ministry Must Revisit The Tobacco Guidelines For OTT Content: Wishlist At Discussion On ‘OTT & Health Warnings’
- Can OTT Tobacco Rules Be Challenged In The Court? Experts Explore At ‘OTT & Health Warnings’ Discussion
