(VIC) Extend Existing Alcohol Regulations to Zero-Alcohol Products

Author: Yin Jiang, Antonia Imeneo, Robert Guzman, Beth O’Sullivan & Kiri Bain |

Publish date: 19/11/2025

Problem Identification: 

In VIC, zero-alcohol products (ZAPs) can be sold and advertised without the same protections as alcoholic products.

Section 3 of the Liquor Control Reform Act 1998 (VIC) stipulates the definition of liquor as ‘a beverage, or other prescribed substance, intended for human consumption with an alcoholic content greater than 0.5% by volume at a temperature of 20 Celsius.’ Hence, ZAPs are not included. 

According to the Alcohol and Drug Foundation (ADF), this means there are limited restrictions on the sale or advertising of ZAPs. Holyoake, a free alcohol, drug and mental health service, has warned that ZAPs may lead to increased underage alcohol use and could act as a trigger for people recovering from alcohol addiction.

Context: 

ZAPs refer to ‘a beverage that is at or less than 0.5% alcohol by volume that: has an appearance and style commonly associated with Alcohol.’ Also known as alcohol alternatives or alcohol-mimicking products, they can use ‘brand or descriptors commonly associated with Alcohol, such as beer, wine, spirit or other.’ 

Booth et al. (2025), who are researchers from the Cancer Council and The George Institute for Global Health, found ZAPs are often associated with parent alcohol companies. Providing them sales and marketing opportunities in ‘previously inaccessible domains’, such as supermarkets, convenience stores and service stations.

They further elaborated that ‘the current regulatory environment allows minors to purchase ZAPs’ and be marketed to. The study found 80% of Australian teenagers aged 15-17 surveyed recalled seeing ZAPs for sale, with more than half (58%) citing supermarkets. Further, the majority (76%) had seen advertising for these products, including on television, social media, online and in supermarkets. In addition, the study found over half agreed ZAPs looked appealing (56%) and said the packaging was attractive (54%).

Arguments:

Booth et al. (2025) have argued the limited regulation of ZAPs may increase harm to young people due to their ‘potential gateway and alcohol-normalisation effects.’ They warned adolescents’ exposure to alcohol-like beverages could ‘potentially increas[e] the likelihood that they will engage in underage alcohol use.’ Bartram et al. (2025), researchers from Flinders University, elaborated that ZAPs are ‘typically located alongside soft drinks (a drinks category of which adolescents are the largest consumers)’, which creates ‘exposure to zero-alcohol drinks … [and] may function similarly to exposure to alcohol products and advertising.’ Holyoake emphasised that ‘early exposure of minors to alcohol-related stimuli has been consistently linked to earlier and more intense underage alcohol use, binge drinking and problematic drinking behaviour in early adulthood.’ This potential harm has been recognised by businesses. For example, 7/11 was granted an exemption by the Australian Human Rights Commission in 2023 to ‘refuse the sale of non-alcoholic, but alcohol-like, beverages to customers under the age of 18 years.’ 7/11 reportedly applied for the exemption due to the ‘potential harms’ for minors indicated by research currently available. 

It is known that the absence of regulation around how and where ZAPs are being sold or advertised can endanger people in early recovery by triggering relapse and reducing the number of safe, alcohol-free environments. Advocate and founder of alcohol addiction support group Sober in the Country, Shanna Whan, explained that ‘her experience with zero-alcohol products triggered a life-threatening relapse into alcohol addiction.’ Holyoake further argued that ‘positioning zero-alcohol products in supermarkets, convenience stores, and service stations has the additional impact of reducing the number of alcohol-free environments’ and could ‘place these individuals [recovering from an alcohol addiction] at an increased risk of a relapse being triggered.’

Advice/Solution Identification:

The VIC Minister for Casino, Gaming and Liquor Regulation should amend section 3 of the Liquor Control Reform Act 1998 (VIC) to expand the definition of liquor to include ‘a beverage containing less than 0.5% alcohol by volume (ABV) that features the branding of established alcohol companies, and/or is designed to imitate the flavour, packaging, or overall appearance of alcohol products’ to bring ZAPs under the same regulations as alcohol products. 

Alcohol and Drug Foundation (ADF), Cancer Council, Public Health Advocacy Institute and the Foundation for Alcohol Research and Education (FARE) have called for this. FARE said restricting the sale of ZAPs could ‘keep these products out of Australian supermarkets, and … prevent further normalisation of the taste and availability of alcohol.’ The ADF added that by ‘proactively placing restrictions on products mimicking alcohol … and not selling them to young people, we can help to mitigate any negative impacts.’

Precedent:

There is domestic precedent for regulating imitation products. In July 2024, VIC updated the Tobacco Act 1987 (VIC) to regulate ‘all e-cigarettes (nicotine and nicotine-free) in the same way as tobacco products.’

Download the 1-Page Brief Here - (VIC) Extend Existing Alcohol Regulations to Zero-Alcohol.

Download • 140KB

---

Public Support: 

1. Alcohol and Drug Foundation (ADF) 

2. Cancer Council                         

3. Public Health Advocacy Institute 

4. Foundation for Alcohol Research and Education (FARE) 

News Coverage:

• National Liquor News / The Shout - ‘Zero alcohol sales surge in Australia’. The article outlined the surge in sales of zero-alcohol drinks across Australia, which highlighted consumer demand and retail expansion. By: Deborah Jackson | Thu 13 March, 2025 - Read the article here.

• ABC News - ‘Zero-alcohol drinks may encourage teen drinking culture, Cancer Council warns’. The Cancer Council raised concerns that zero-alcohol products blur the lines for young people and normalise alcohol consumption. By: Eliza Berlage | Thu 25 July, 2024 - Read the article here.

• 9News - ‘Zero-alcohol drinks could be dangerous for children, study suggests’. The Cancer Council study warned that imitation alcohol products may act as a gateway for teenagers into drinking culture. By: Lara Pearce | Tue 16 July, 2024 - Read the article here.

• The Conversation - ‘Zero alcohol doesn’t mean zero risk - how marketing and blurred lines can be drinking triggers’. The article explained that marketing and branding of zero-alcohol products can act as triggers for drinking, especially among young people and those in recovery. By: Shalini Arunogiri & Anthony Hew | 21 September, 2023 - Read the article here.

• ABC News - ‘What to know before giving your teen non-alcoholic beer or wine’. The article discussed how ZAPs are unregulated for minors in many jurisdictions, and warned that these imitation drinks might normalise alcohol for young people or act as a “gateway” to drinking later. By: Kellie Scott | Sat 29 July, 2023 - Read the article here.

• ABC News - ‘Calls for zero-alcohol products to be subjected to same regulations as alcohol’. There have been calls for zero alcohol products to be governed by the same regulations as their alcoholic counterparts. By: Emma Haskin | Fri 16 Dec, 2022 - Read the article here.

Where to go to learn more: 

1. Alcohol and Drug Foundation (ADF) - Their position paper highlighted the risks of products that mimic alcohol, including zero-alcohol beers, wines, and spirits, and called for stronger regulation to protect young people. View their position paper here.

2. Holyoake - ‘Zero Alcohol Products: Helpful or Harmful?’ - The article discussed how zero-alcohol beverages mimic the look, taste and branding of alcoholic drinks, raising risks including brand extension, relapse triggers, normalising alcohol for youth, and regulatory gaps. Read the article here.

3. DrinkTank - This article explained the Public Health Advocacy Institute of WA’s Alcohol Programs Team and the Foundation for Alcohol Research and Education policy position on zero alcohol products. Read the full article here.

4. Arnold M. Washton Pd.D - ‘Does Non-Alcoholic Beer or Wine Help or Hinder Alcohol Recovery?’ - This article discussed the pros and cons of non-alcoholic beverages - it highlighted that non-alcoholic beverages may not be advisable for everyone trying to overcome an alcohol problem. Read the article here.

5. World Health Organisation (WHO) - Their global brief on zero- and low-alcohol beverages outlined concerns that marketing may mislead consumers, target minors, and provide brand spillover benefits for alcohol companies. Read the brief here.

6. Liquor Control Reform Act 1998 (VIC) - The Act that this brief proposes to modify. Read the act here.

Human Perspective: 

Content Warning: Recovering alcohol addict and addiction relapse

Sophie had just celebrated 12 months sober after a long struggle with alcohol dependence. When zero-alcohol products began to appear in local stores, she was excited by their potential benefits and how they could offer people a sense of inclusion and choice. However after trying several zero-alcohol products at a social gathering, Sophie experienced powerful memories and cravings that almost led to a relapse. Sophie had not realised how easily the zero-alcohol drinks could take her back to those old patterns. Sophie reflected that the familiar taste and rituals associated with drinking, reignited habits she thought she had left behind. Sophie has since become cautious about how zero-alcohol products are marketed. While she acknowledged they could help some people moderate their alcohol intake, she emphasised they are not universally safe. Sophie suggested stronger regulation is needed to ensure zero-alcohol products do not inadvertently cause harm to those most vulnerable.

To protect the anonymity of those involved, this is a fictionalised account drawn from an amalgamation of real-life stories, experiences and testimonials gathered during the research process for this brief. Any resemblance to actual individuals is purely coincidental.

Conflict of interest/acknowledgment statement: 

N/A

Support 

If your organisation would like to add your support to this paper or suggest amendments, please email Info@foreaustralia.com. 

Reference list: 

Alcohol and Drug Foundation. (2025). What are zero alcohol drinks? https://adf.org.au/reducing-risk/alcohol/zero-alcohol-drinks/what-zero-alcohol/ 

Alcohol and Drug Foundation. (2022, June). Products mimicking alcohol: position paper. https://cdn.adf.org.au/media/documents/ADF_PP_Products_mimicking_alcohol.pdf

Australian Human Rights Commission. (2023). Notice of Decision on Application For Temporary Exemption: 7 Holdings Pty Ltd, 7-Eleven Stores Pty Ltd And Convenience Holdings Pty Ltd. https://humanrights.gov.au/sites/default/files/notice_of_decision_on_application_for_ada_exemption_-_7-eleven_-_final_1.pdf 

Bartram, A., Mittinty, M., Ahad, M. A., Bogomolova, S., Dono, J., Brownbill, A. L., Harrison, N. J., Garcia, J., Glavinic, I., May, M., & Bowden, J. (2025). Alcohol advertising in disguise: Exposure to zero-alcohol products prompts adolescents to think of alcohol—Reaction time experimental study. International Journal of Drug Policy, 139, 104753. https://doi.org/10.1016/j.drugpo.2025.104753 

Booth, L., Keric, D., Bowden, J., Bartram, A., Sengupta, A., & Pettigrew, S. (2024). Zero alcohol products and adolescents: A tool for harm reduction or a trojan horse? Appetite, 205, 107582. https://doi.org/10.1016/j.appet.2024.107582 

Foundation for Alcohol Research and Education, & Public Health Advocacy Institute of Western Australia. (2020). Position Statement: Zero Alcohol Products. https://movendi.ngo/wp-content/uploads/2021/05/PHAIWA-FARE-Position-Statement-Zero-alcohol-products-January-2020_FINAL.pdf 

Holyoake. (2025, 14 January). Zero alcohol products: Are they helpful or harmful? https://holyoake.org.au/update/zero-alcohol-products/

https://content.legislation.vic.gov.au/sites/default/files/2024-06/98-94aa110-authorised.pdf#page=15

Liquor Control Reform Act 1998 (No. 94 of 1998) (Version 110)(VIC). https://www.legislation.vic.gov.au/in-force/acts/liquor-control-reform-act-1998/110

VIC Department of Health. E-cigarettes and vaping. (2025, July 2). https://www.health.vic.gov.au/tobacco-reform/e-cigarettes-and-vaping?%2F 

Vidler, A-C. (2020, January 29). Non-Alcoholic Alcohol: Another cynical ploy by the alcohol industry? Foundation for Alcohol Research and Education. https://fare.org.au/non-alcoholic-alcohol-another-cynical-ploy-by-the-alcohol-industry/