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The rapid growth of online alcohol sales, delivery services, and digital marketing has increased alcohol availability and heightened public health concerns, particularly among adolescents. However, regulatory responses remain inconsistent and vary significantly across regions. This scoping review synthesizes global regulatory approaches to online alcohol access, encompassing both established Western models and emerging Asian frameworks, and identifies key cross-national patterns and policy gaps. This scoping review followed PRISMA-ScR (preferred reporting items for systematic reviews and meta-analyses extension for scoping reviews) and Joanna Briggs Institute guidance. Searches of four electronic databases were complemented by a supplementary gray literature search targeting specific Asian jurisdictions to minimize geographic bias. The identified sources included policies and peer-reviewed studies on online alcohol sales, delivery practices, age-verification procedures, and digital marketing regulations. Data were systematically organized by regulatory domain and analyzed using a comparative socio-political framework (liberalism vs. paternalism) to interpret cross-national differences. The analysis of 34 documents across five regulatory domains revealed a distinct global divide. Western nations predominantly rely on co-regulatory models that frequently suffer from significant enforcement gaps, whereas Asian jurisdictions employ strict structural barriers. These include mandatory digital real-name authentication, “Smart Order” systems, and joint platform liability, designed to effectively restrict underage access where Western self-regulation has historically failed. To address global enforcement gaps, future policies must evolve from “soft” co-regulation to “hard” technical mandates. Integrating Asian-style digital identity systems with strict platform liability offers a viable pathway to effectively restrict underage access and reduce alcohol-related harm.
Alcohol consumption remains a major contributor to the global disease burden, accounting for 5.1% [1,2]. However, despite widespread recognition of alcohol-related risks, global consumption continues to rise, increasing from 5.9 L per capita in 1990 to 6.5 L in 2017 and projected to reach 7.6 L by 2030 [3]. Although consumption in some high-income countries, such as the United Kingdom, has declined since 2004 [4], alcohol use and binge drinking have escalated in the United States, particularly among middle-aged and older adults [5]. Emerging Asian markets are witnessing shifts in consumption patterns driven by economic growth. The United Nations emphasizes preventive and treatment measures under Sustainable Development Goal indicator 3.5.2 to address these trends. Aligned with this goal, various countries have introduced policy initiatives, including excise tax increases, advertising restrictions, minimum legal drinking age laws, and public health campaigns. Scotland adopted minimum unit pricing, leading to a 3.5% reduction in off-trade alcohol sales [6,7]; Lithuania implemented a comprehensive advertising ban [8]; and Australia and New Zealand launched public awareness campaigns to promote safer drinking behaviors [9].
The expansion of online alcohol marketing, particularly during and after the coronavirus 2019 pandemic, has increased youth exposure, binge drinking, and alcohol sales, raising significant public health concerns [10,11]. Consequently, diverse regulatory approaches have emerged globally. Jurisdictions such as the European Union (EU) and New South Wales (NSW) have strengthened age verification and delivery regulations [12,13], while distinct control mechanisms are evolving in Asian economies to manage the digital marketplace [14,15]. However, legal, logistical, and political barriers persist, hindering effective regulation and enforcement of online alcohol sales. Among these barriers, industry-driven challenges are particularly prominent, as the alcohol industry often delays regulations through litigation [16], and self-regulatory frameworks, such as those in the United Kingdom, have proven ineffective [17]. Enforcement remains limited as brands frequently bypass age-verification mechanisms and rely on indirect marketing strategies [18,19]. Recent evidence from Taiwan further illustrates these risks, showing that unregulated digital strategies—specifically influencer marketing and the promotion of nonalcoholic beer—serve as effective gateways that increase alcohol purchase intentions among adolescents [20]. Furthermore, while descriptive studies exist, there is a lack of comparative analyses examining the socio-political drivers (e.g., liberal vs. paternalistic values) that shape these regulatory differences. Given these persistent challenges and regional variations, this review examines existing regulatory frameworks encompassing both established Western models and Asian contexts and recommends strengthening global online alcohol control policies.
Methods
Consistent with PRISMA-ScR (preferred reporting items for systematic reviews and meta-analyses extension for scoping reviews) and Joanna Briggs Institute (JBI) guidance [21,22], this scoping review did not include a formal critical appraisal of the included studies or policy documents. Because scoping reviews aim to map the extent and nature of available evidence rather than assess study quality, a risk-of-bias evaluation was not conducted. This approach is consistent with established methodological standards. Ethical approval was not required for this study because it used publicly available data and did not involve human participants.
Research question
How do national regulations and policies control the online environment for alcohol access? What are the similarities and differences between them?
Eligibility criteria
Peer-reviewed articles from PubMed, Scopus, Google Scholar, and the Thai Journal Citation Index, as well as official government reports, international trade analyses, and legal texts discussing regulatory frameworks or policy evaluations, published up to March 2024.
Search strategy
A multistage search strategy was employed to ensure comprehensive coverage of both academic and gray literature. First, electronic bibliographic databases were searched up to March 2024 using a structured combination of terms such as (alcohol OR liquor) AND (access) AND (online OR internet OR electronics OR digital OR website OR social media) AND (sale OR sales OR selling OR advert OR delivery OR tradition) AND (regulation OR measures OR policy OR enforcement OR restriction OR rule OR law OR act OR control).
Second, to mitigate geographic bias and capture non-indexed regulatory frameworks in Asia, a supplementary gray literature search was conducted (updated to December 2025). We specifically targeted major Asian economies and representative jurisdictions, including Thailand, South Korea, Japan, China, Taiwan, Vietnam, and Singapore. Information sources included international databases (e.g., United States Department of Agriculture Global Agricultural Information Network [USDA GAIN], EU Access2Markets, and World Health Organization Global Information System on Alcohol and Health [WHO GISAH]) and national government portals.
Search terms for this supplementary phase were adapted to include jurisdiction-specific legal terminology, such as “Alcohol Control Act” (Thailand), “Smart Order” (South Korea), “Mailorder Liquor Retail License” (Japan), “E-Commerce Law” (China), “Tobacco and Alcohol Administration Act” (Taiwan), “Decree 24” (Vietnam), and “Liquor Control Act” (Singapore). This expanded strategy allowed for the identification of specific regulatory mechanisms, such as age-verification systems, digital licensing, and time-based delivery restrictions, which are often detailed only in government acts or trade reports rather than in academic journals.
Screening process
Inclusion
Sources (including peer-reviewed articles, government acts, and trade reports) describing regulatory measures governing online alcohol access, focusing on sales methods, location restrictions, permits, age-verification procedures, sales timeframes, advertising, and penalties.
Exclusion
Literature or documents unrelated to public policy measures addressing online alcohol access.
Screening
For academic articles, titles and abstracts were screened. For gray literature and legal texts, executive summaries or tables of content were assessed for relevance. This was followed by fulltext reviews of all potentially eligible sources, and the reasons for exclusion were documented (Figure 1).
Data extraction
Data were extracted in Table 1 [14,15,18,23-52], including source characteristics (e.g., country and type of document) and regulatory measures. To facilitate cross-jurisdictional comparisons, data from the supplementary search were synthesized into a comparative regulatory framework (Table 2). A descriptive analysis was then conducted to categorize regulatory approaches based on strictness (e.g., liberal, moderate, and strict/ban). These findings are visualized using a regulatory intensity heat map to illustrate the divergences in enforcement philosophies between Western and Asian jurisdictions (Figure 2).
Data synthesis and analysis
Data were extracted and summarized using a descriptive analytical method based on the identified regulatory domains. To interpret the divergence in regulatory approaches across jurisdictions, a comparative socio-political framework was employed. Specifically, the analysis contrasts predominant trends of “neoliberal” governance models, which emphasize individual responsibility and market self-regulation (predominant in Western contexts) [53], with “state paternalism” models, which prioritize collective social protection and strict government intervention (often observed in Asian contexts) [54]. It is important to note that these frameworks function as analytical tools rather than absolute binaries. We acknowledge that exceptions exist and that regulatory landscapes within each region can vary significantly. This theoretical lens was used to synthesize findings regarding enforcement mechanisms, compliance cultures, and the role of technology in alcohol control.
Results
Overview of selected literature and regulatory sources
Following the selection process detailed in Figure 1, 34 documents were included in this scoping review. The composition of these sources reflects the distinct geographic characteristics of the current evidence base. The academic literature (15 peer-reviewed studies) is predominantly concentrated in high-income Western jurisdictions, including Australia, the United Kingdom, the United States, and Finland, and focuses on the empirical effectiveness of existing regulations (Table 1). To address the significant gap in indexed literature on Asian markets, this review incorporates 19 legislative acts, government notifications, and trade reports (Table 2). This supplementary analysis captures the statutory frameworks of seven key Asian jurisdictions (China, Japan, South Korea, Taiwan, Vietnam, Singapore, and Thailand) and provides a balanced comparison between Western empirical data and Asian regulatory structures.
Regulatory domains and comparative patterns
As shown in the regulatory intensity heat map (Figure 2), regulatory approaches were clustered into five core domains. A distinct regional pattern emerged: Western OECD nations (e.g., United States, United Kingdom, Australia) largely exhibit “moderate” (medium blue) to “low” (light blue) regulatory intensity, relying on co-regulation and modification of existing offline laws. In contrast, Asian jurisdictions (e.g., Thailand, China, and South Korea) predominantly display “high” (dark blue) intensity, characterized by structural prohibitions and strict-liability frameworks. Notable regional exceptions include Finland (high/dark blue) due to its monopoly system and Japan (moderate/medium blue), which aligns more closely with Western models in terms of self-regulation but retains specific market protections.
Licensing and sales method control
Western jurisdictions typically regulate online alcohol sales as an extension of physical retail activities. In Australia (NSW) and the United Kingdom, online sellers must hold valid licenses and adhere to specific remote-sales protocols [24,25]. By contrast, Asian markets often implement structural barriers. Thailand imposed a complete prohibition on electronic alcohol sales through the Prime Minister’s Office Announcement [31]. Notably, South Korea adopts a unique “hybrid” restriction: while it bans home delivery of general liquor to prevent underage access, it permits the “Smart Order” system, which allows consumers to place orders via mobile applications but mandates in-store pickup for face-to-face age verification [29,30]. China mandates that licenses be prominently displayed on e-commerce homepages [33], while Japan restricts online licenses primarily to imported liquor or products from small breweries (<3,000 kL/y), effectively banning major domestic brands from the online channel to protect traditional retailers [34].
Age verification and purchaser identification
Age-verification approaches reveal clear technological divides. Western regulations often rely on “soft” verification mechanisms. In Australia, empirical data highlight significant enforcement failures, with couriers frequently bypassing age checks [45]. Similarly, cross-sectional analyses have documented widespread reliance on simple self-declarations (e.g., tick boxes) or credit card checks, rather than robust identity verification systems [51]. By contrast, Asian jurisdictions are moving toward integrated digital verification systems. Vietnam’s Decree No. 24 requires electronic age verification linked to cashless payment systems to ensure traceability [37], whereas China mandates real-name authentication for e-commerce users [15,33], and Taiwan invalidates any electronic transaction in which the purchaser’s age cannot be strictly verified [36]. South Korea eliminates uncertainty in digital verification by enforcing the physical “Smart Order” pickup requirement, ensuring that identification checks remain face-to-face despite the digital ordering process [29].
Delivery and courier responsibility
Delivery regulations represent the area of greatest divergence. In Australia and the United States, the regulatory burden is placed on the delivery driver to verify identification at the doorstep [24,26,45]. However, empirical studies confirm high noncompliance rates; for instance, Colbert et al. [45] found that couriers frequently leave alcohol unattended or fail to check identification. Singapore mitigated this issue by enforcing strict time-based delivery bans (10:30 PM–7:00 AM) [38,39]. More strictly, China’s E-Commerce Law imposes “joint liability” on platforms [33], while South Korea removes delivery-related risk for most alcohol categories by legally prohibiting the direct-to-home delivery of mass-market liquor products [14,29].
Advertising and digital marketing restrictions
As shown in Figure 2, the United States and the United Kingdom fall into the “Low” (light blue) zone, relying heavily on industry self-regulation. The literature consistently shows that this approach fails to shield youth from algorithmic targeting on social media [49,50,52], with similar compliance issues reported in Lithuania and Sweden regarding subtle product placements [18,41]. Conversely, Thailand and Vietnam enforce statutory bans on specific types of online promotions (e.g., spirits with >15% alcohol by volume in Vietnam). Finland (high/dark blue) stands out among Western nations by legally restricting user-generated content and interactive brand marketing on social media [27,44], demonstrating that strict digital controls are possible within a Western legal context.
Enforcement mechanisms
Enforcement in Western countries is often reactive, involving purchasing tests and fines for noncompliance. However, the sheer volume of online transactions makes manual monitoring difficult, leading to the enforcement gaps identified in Table 1 (e.g., lack of age verification by couriers in Australia [45] and inconsistent monitoring of digital ads in the United States [49]). Asian jurisdictions are increasingly utilizing platform-centric enforcement. China’s model forces platforms to act as regulators of their vendors under the threat of heavy penalties through “Joint Liability” laws [33]. Meanwhile, Thailand relies on broad prohibitions enforced by the police and the Office of the Alcohol Control Committee. However, restrictive laws alone do not guarantee success. For instance, Russia has faced persistent challenges with illicit and counterfeit alcohol distribution despite maintaining strict bans on online sales [48]. This highlights that statutory strictness must be paired with effective surveillance, although evidence on the practical effectiveness of Asian bans remains limited compared with the documented failure of Western self-regulation [40,52].
Discussion
Sociocultural drivers of regulatory heterogeneity (liberalism vs. paternalism)
The distinct regulatory divide identified in this review—with Western nations favoring co-regulation and Asian jurisdictions adopting structural prohibitions—cannot be attributed solely to administrative differences. Instead, it reflects a deeper divergence in sociocultural values and governance philosophies. The regulatory approaches observed predominantly in Anglo-American jurisdictions (including the United States, the United Kingdom, Australia, and New Zealand) are largely rooted in neoliberal principles and individual responsibility [23-26]. However, it is important to acknowledge that this does not represent a monolithic ‘Western’ model; notable exceptions exist, such as the alcohol monopoly systems in Nordic countries, which prioritize strict state intervention over market liberalization. In these Anglo-American contexts, alcohol consumption is viewed primarily as a commercial activity in which market freedom is paramount, leading to “soft” regulatory approaches (e.g., self-regulation) that aim to mitigate harm without stifling economic activity [49,52].
Conversely, strict regulatory frameworks in East and Southeast Asia align with paternalistic governance models. While East Asian jurisdictions (e.g., China, South Korea, and Taiwan) are often influenced by a Confucian heritage that emphasizes social harmony [29,33,36], Thailand’s regulatory context is distinctively shaped by Buddhist principles and local collectivist values [31]. In these societies, the state is expected to act as a guardian of public health and social order, prioritizing collective well-being over individual consumer convenience. This cultural context explains why stringent measures, such as South Korea’s hybrid verification system or Thailand’s total prohibition of online sales, are politically viable and socially accepted in parts of Asia [29,31], whereas similar measures would likely face significant legal and public resistance in Western liberal democracies because of perceived infringements on personal liberty.
Technological infrastructure as a regulatory enabler
The maturity of digital infrastructure is a critical determinant of how regulations are implemented. The ability of Asian jurisdictions to enforce “hard” verification is not merely a legal choice but a technological possibility enabled by integrated digital ecosystems. China and Vietnam, for instance, leverage centralized digital identification infrastructures and “super-apps” (e.g., WeChat, Zalo) to enforce real-name authentication and cashless payment tracking [15,33,37]. This framework enables a “platform liability” model in which enforcement is algorithmic and preventive.
In contrast, Western jurisdictions often grapple with fragmented digital infrastructure and heightened privacy concerns (e.g., the General Data Protection Regulation in Europe), which limit the adoption of centralized identity verification systems. Consequently, countries such as Australia and the United States rely on “manual” checkpoints (e.g., identification checks by couriers at the doorstep) [24,26]. As shown in the Result section, this reliance on human intervention creates the “compliance gap” wherein technological enforcement mechanisms are absent [45,51]. Thus, the “Smart Order” system in South Korea represents a notable synthesis: utilizing advanced digital ordering (technological convenience) while retaining physical pickup (human verification) to bridge the gap between digital efficiency and safety [14,29,30].
Balancing statutory strictness and public health outcomes
While Asian regulatory models appear more robust, statutory strictness does not automatically equate to public health outcomes. The “Prohibition Paradox” is evident in the comparison between Thailand and Russia. Thailand’s total ban creates a clear legal barrier [31,32]; however, as demonstrated by the Russian experience with online bans, excessive restrictions without effective surveillance can drive the market underground, thereby fostering illicit trade and counterfeit alcohol distribution [48].
Conversely, the Western “liberal” model, while economically efficient, has demonstrably failed to protect minors from algorithmic targeting and easy access, as evidenced by the high noncompliance rates in Australia and the United Kingdom [45,52]. This pattern suggests that the optimal path for public health may lie in a middle ground: moving away from the Western “self-regulation” toward “co-regulation with technological mandates” as observed in emerging Asian models. For policymakers, this implies that future regulations must move beyond simple “bans” or “warnings” and instead integrate application programming interface (API)-based age verification standards and platform accountability mechanisms, adapting the technological rigor observed in Eastern jurisdictions to the legal frameworks of the Western systems.
Limitations
This scoping review has certain limitations. First, although we addressed gaps in the Asian literature by incorporating legislative texts, the academic evidence base remains skewed toward English-language Western studies (Table 1), thereby limiting the availability of empirical effectiveness data for Asian jurisdictions. Second, regulatory documents in some regions are often fragmented or updated without immediate English translation, which may result in incomplete capture of the most recent amendments. Third, consistent with PRISMA-ScR and JBI guidelines, no formal critical appraisal of the included studies was conducted. Finally, the rapid evolution of “super-apps” and digital ecosystems in Asia suggests that statutory descriptions may lag behind actual technological enforcement practices. Future research should prioritize empirical evaluation of emerging Asian enforcement models to assess whether their reported strictness translates into measurable public health outcomes.
Conclusion
This scoping review highlights a fundamental global divergence in the regulation of online alcohol markets. Whereas Western nations continue to grapple with the limitations of “soft” coregulatory models and manual verification, Asian jurisdictions are pioneering “hard” regulatory approaches driven by distinct sociocultural values, paternalistic governance, and integrated digital infrastructure. This contrast suggests that the future of effective regulation lies neither in total prohibition nor in voluntary industry codes but in a hybrid model leveraging the technological rigor of Asian digital identity systems within frameworks that respect consumer rights. For policymakers, a clear implication is that statutory mandates must evolve from simple text-based rules to API-based technical standards that force platforms to assume liability for public health outcomes.
Article Information
Conflict of interest
No potential conflict of interest relevant to this article was reported.
Acknowledgments
An AI-based language assistance tool (Grammarly) was used for grammar and language correction throughout the manuscript. The authors assume full responsibility for the scientific content, interpretation, and conclusion of this manuscript.
Funding
This research project was supported by the National Research Council of Thailand (NRCT) (Contact No. N41A661152) and the Foundation for Disease Control Research Promotion, Department of Disease Control, Ministry of Public Health, Thailand.
Data availability
Data of this research are available from the corresponding author upon reasonable request.
Author contribution
Conceptualization: WS, PV. Methodology: WS, KS, CDNA, PV. Software: WS. Validation: WS, KS, CDNA. Formal analysis: WS, KS, CDNA. Investigation: WS, KS, CDNA. Resources: WS, PV, SV. Data curation: WS, KS, CDNA. Project administration: WS. Visualization: WS, PV. Supervision: PV, SV. Writing–original draft: WS, PV. Writing–review & editing: WS, PV. Final approval of the manuscript: all authors.
Figure. 1.
PRISMA-ScR (preferred reporting items for systematic reviews and meta-analyses extension for scoping reviews) flowchart delineating the systematic process of literature selection. USDA GAIN, United States Department of Agriculture Global Agricultural Information Network; WHO GISAH, World Health Organization Global Information System on Alcohol and Health; TCI, Thai-Journal Citation Index.
Figure. 2.
Heat map illustrating the intensity of online alcohol regulatory measures across representative Western and Asian jurisdictions.
Table 1.
Detailed summary of essential data extracted from the selected literature based on predefined criteria
No.
Study
Country
Source type (study/methodology or type of literature)
Code de la santé publique, Réforme 2009 (Article L.3323-2)
Advertising control
Prohibition of online alcohol advertising targeting minors
7.
Korea Legislation Research Institute [29] (2024), USDA Foreign Agricultural Service [30] (2024), European Commission [14] (2024)
South Korea
(1) Liquor License Act (Act No. 20249), (2) South Korea wine market report (report number: KS2024-0021), (3) Limitations to online sales of alcoholic beverages by South Korea
Sales method, age restrictions control
Bans home delivery (cited as an EU trade barrier) under the Liquor License Act. However, NTS notification permits “Smart Order”: mobile ordering with mandatory in-store pickup and face-to-face age verification
8.
The Prime Minister’s Office of Thailand [31] (2020), Alcoholic Beverage Control Act [32] (2008)
Thailand
(1) Prohibition on sales of alcoholic beverages by electronic means B.E. 2563, and (2) Alcoholic Beverage Control Act, B.E.2551
Sales method control
Total prohibition of direct electronic sales of alcoholic beverages
9.
Standing Committee of the National People’s Congress [33] (2018), USDA Foreign Agricultural Service [15] (2018)
China
(1) E-Commerce Law of the People’s Republic of China, and (2) China passes E-Commerce Law (GAIN Report Number: CH18063)
Licensing control, Sales method control
Mandates prominent license display on homepages (Article 15) and enforces joint platform liability for failure to verify sellers (Article 38)
10.
Manufactured Imports and Investment Promotion Organization [34] (2020), USDA Foreign Agricultural Service [35] (2023)
Japan
(1) Liquor sales business In MIPRO 2020, and (2) Japan FAIRS Annual Country Report Annual (report number: JA2023-0100)
Licensing control
Regulated under the Liquor Tax Act (Article 9). The “Mail-order Retail License” restricts online sales to imported liquor and products from small breweries (<3,000 kL/y), effectively banning major domestic brands
(1) Liquor Control (Supply and Consumption) Act 2015 (2020 Revised Edition); (2) Liquor Control (Supply and Consumption) (Exemption from Liquor Licence) Order 2015 (No. S 183/2015)
Sales timeframes, age restrictions control
Section 12 of the Liquor Control Act 2015 strictly prohibits delivery between 10:30 PM and 7:00 AM Sellers must strictly verify the recipient's age (18+) upon delivery
Research article (cross-sectional website content analysis)
Sales method, advertising control
Lack of recipient verification during alcohol delivery, availability of “buy now, pay later” services, and use of email marketing to promote online alcohol sales
Regional evidence: widespread youth exposure to ads
Regional evidence shows low enforcement
Moderate (regional average)
Moderate
Group 2: Asian jurisdictions
China
Mandatory license display on homepage; platform joint liability for unlicensed sellers
Real-name registration required; platforms must verify seller and buyer identity
Platforms held jointly liable for delivery breaches; logistics must verify goods
Subject to advertising law; minors must not be targeted
High: SAMR oversight; joint liability forces platforms to self police
High
Moderate
Japan
Restricted to imported liquor and small breweries (<3,000 kL/y); major domestic brands banned online
Age verification required at purchase; “age gate” buttons often used (self declaration)
Standard courier checks; delivery personnel expected to verify age if unsure
Industry self-regulation (warnings required); moderate controls
Moderate: NTS oversight; relying on license conditions
Moderate-high
Moderate
South Korea
“Smart Order” only (mobile order, in-store pickup); home delivery banned for general alcohol
Face-to-face verification mandatory at store pickup; digital ID integration emerging
Home delivery prohibited (except specific traditional liquors); pickup only
Strict restrictions on youth exposure; warnings required in digital ads
High: NTS monitoring; strict license revocation
High
Moderate
Taiwan
Prohibited unless payment/delivery method can strictly identify age
Strict age identification required; electronic transactions restricted if age unverifiable
Delivery restricted; transaction valid only if age is identified
Health warnings mandatory on websites/ads; bans on false claims
High: Ministry of Finance oversight; penalties for unrecognizable transactions
High
Moderate
Vietnam
Permitted with strict cashless payment systems to ensure traceability
Electronic age verification system required prior to purchase
Strict handover verification; couriers must check age upon delivery
Strict bans on advertising spirits (>15% ABV); controls on youth targeting
High: Ministry of Industry and Trade; payment trails used for monitoring
High
Moderate
Thailand
Complete prohibition on all online alcohol sales
Not applicable due to full prohibition
Not applicable
Digital advertising restrictions supported by enforcement mechanisms
Enforcement through consumer protection, communications authority, and police
High (prohibition model)
Moderate
Singapore
Online sales permitted; delivery strictly banned between 10:30 PM–7:00 AM
Mandatory verification upon delivery receipt
Couriers must verify age; no delivery to public spaces during restricted hours
General advertising regulations apply; guidelines on social
High: Police Licensing & Regulatory Department enforcement
High
Moderate
OECD, Organization for Economic Cooperation and Development; ABV, alcohol by volume; SAMR, State Administration for Market Regulation; NTS, National Tax Service.
a)OECD represents evidence synthesized from systematic reviews that reported results for multiple OECD countries collectively. These findings were retained to support comparative completeness but should not be interpreted as country-specific regulations. For Asian jurisdictions, evidence is primarily derived from legislative acts, government notifications, and international trade reports (e.g., United States Department of Agriculture Global Agricultural Information Network [USDA GAIN], European Union [EU] Access2Markets) due to the limited availability of indexed academic literature.
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Regulatory policies for online alcohol access control: a comparative scoping review of international approaches
Figure. 1. PRISMA-ScR (preferred reporting items for systematic reviews and meta-analyses extension for scoping reviews) flowchart delineating the systematic process of literature selection. USDA GAIN, United States Department of Agriculture Global Agricultural Information Network; WHO GISAH, World Health Organization Global Information System on Alcohol and Health; TCI, Thai-Journal Citation Index.
Figure. 2. Heat map illustrating the intensity of online alcohol regulatory measures across representative Western and Asian jurisdictions.
Figure. 1.
Figure. 2.
Regulatory policies for online alcohol access control: a comparative scoping review of international approaches
No.
Study
Country
Source type (study/methodology or type of literature)
Code de la santé publique, Réforme 2009 (Article L.3323-2)
Advertising control
Prohibition of online alcohol advertising targeting minors
7.
Korea Legislation Research Institute [29] (2024), USDA Foreign Agricultural Service [30] (2024), European Commission [14] (2024)
South Korea
(1) Liquor License Act (Act No. 20249), (2) South Korea wine market report (report number: KS2024-0021), (3) Limitations to online sales of alcoholic beverages by South Korea
Sales method, age restrictions control
Bans home delivery (cited as an EU trade barrier) under the Liquor License Act. However, NTS notification permits “Smart Order”: mobile ordering with mandatory in-store pickup and face-to-face age verification
8.
The Prime Minister’s Office of Thailand [31] (2020), Alcoholic Beverage Control Act [32] (2008)
Thailand
(1) Prohibition on sales of alcoholic beverages by electronic means B.E. 2563, and (2) Alcoholic Beverage Control Act, B.E.2551
Sales method control
Total prohibition of direct electronic sales of alcoholic beverages
9.
Standing Committee of the National People’s Congress [33] (2018), USDA Foreign Agricultural Service [15] (2018)
China
(1) E-Commerce Law of the People’s Republic of China, and (2) China passes E-Commerce Law (GAIN Report Number: CH18063)
Licensing control, Sales method control
Mandates prominent license display on homepages (Article 15) and enforces joint platform liability for failure to verify sellers (Article 38)
10.
Manufactured Imports and Investment Promotion Organization [34] (2020), USDA Foreign Agricultural Service [35] (2023)
Japan
(1) Liquor sales business In MIPRO 2020, and (2) Japan FAIRS Annual Country Report Annual (report number: JA2023-0100)
Licensing control
Regulated under the Liquor Tax Act (Article 9). The “Mail-order Retail License” restricts online sales to imported liquor and products from small breweries (<3,000 kL/y), effectively banning major domestic brands
(1) Liquor Control (Supply and Consumption) Act 2015 (2020 Revised Edition); (2) Liquor Control (Supply and Consumption) (Exemption from Liquor Licence) Order 2015 (No. S 183/2015)
Sales timeframes, age restrictions control
Section 12 of the Liquor Control Act 2015 strictly prohibits delivery between 10:30 PM and 7:00 AM Sellers must strictly verify the recipient's age (18+) upon delivery
Research article (cross-sectional website content analysis)
Sales method, advertising control
Lack of recipient verification during alcohol delivery, availability of “buy now, pay later” services, and use of email marketing to promote online alcohol sales
Regional evidence: widespread youth exposure to ads
Regional evidence shows low enforcement
Moderate (regional average)
Moderate
Group 2: Asian jurisdictions
China
Mandatory license display on homepage; platform joint liability for unlicensed sellers
Real-name registration required; platforms must verify seller and buyer identity
Platforms held jointly liable for delivery breaches; logistics must verify goods
Subject to advertising law; minors must not be targeted
High: SAMR oversight; joint liability forces platforms to self police
High
Moderate
Japan
Restricted to imported liquor and small breweries (<3,000 kL/y); major domestic brands banned online
Age verification required at purchase; “age gate” buttons often used (self declaration)
Standard courier checks; delivery personnel expected to verify age if unsure
Industry self-regulation (warnings required); moderate controls
Moderate: NTS oversight; relying on license conditions
Moderate-high
Moderate
South Korea
“Smart Order” only (mobile order, in-store pickup); home delivery banned for general alcohol
Face-to-face verification mandatory at store pickup; digital ID integration emerging
Home delivery prohibited (except specific traditional liquors); pickup only
Strict restrictions on youth exposure; warnings required in digital ads
High: NTS monitoring; strict license revocation
High
Moderate
Taiwan
Prohibited unless payment/delivery method can strictly identify age
Strict age identification required; electronic transactions restricted if age unverifiable
Delivery restricted; transaction valid only if age is identified
Health warnings mandatory on websites/ads; bans on false claims
High: Ministry of Finance oversight; penalties for unrecognizable transactions
High
Moderate
Vietnam
Permitted with strict cashless payment systems to ensure traceability
Electronic age verification system required prior to purchase
Strict handover verification; couriers must check age upon delivery
Strict bans on advertising spirits (>15% ABV); controls on youth targeting
High: Ministry of Industry and Trade; payment trails used for monitoring
High
Moderate
Thailand
Complete prohibition on all online alcohol sales
Not applicable due to full prohibition
Not applicable
Digital advertising restrictions supported by enforcement mechanisms
Enforcement through consumer protection, communications authority, and police
High (prohibition model)
Moderate
Singapore
Online sales permitted; delivery strictly banned between 10:30 PM–7:00 AM
Mandatory verification upon delivery receipt
Couriers must verify age; no delivery to public spaces during restricted hours
General advertising regulations apply; guidelines on social
High: Police Licensing & Regulatory Department enforcement
High
Moderate
Table 1. Detailed summary of essential data extracted from the selected literature based on predefined criteria
USDA, United States Department of Agriculture; NTS, National Tax Service.
Table 2. Comparative summary of online alcohol regulatory measures across different countries and regulatory contexts
OECD, Organization for Economic Cooperation and Development; ABV, alcohol by volume; SAMR, State Administration for Market Regulation; NTS, National Tax Service.
OECD represents evidence synthesized from systematic reviews that reported results for multiple OECD countries collectively. These findings were retained to support comparative completeness but should not be interpreted as country-specific regulations. For Asian jurisdictions, evidence is primarily derived from legislative acts, government notifications, and international trade reports (e.g., United States Department of Agriculture Global Agricultural Information Network [USDA GAIN], European Union [EU] Access2Markets) due to the limited availability of indexed academic literature.
, Kaitsuda Saiprom2
