Background <p>The use of digital technologies by unhealthy commodity industries (UCIs) warrants closer investigation as a potential vector of disease. Examining one such digital technology, this research analyses the use of “smart labels” by the alcohol industry (labels which have physical and digital dimensions which can sense, process, and deliver real time and immersive information and entertainment between product and consumer) to investigate if rapidly advancing technologies create a gap between policy and technological innovation in general, and examine whether smart labels in the alcohol industry present a threat to public health in particular.</p> Methods <p>This study analyses alcohol brands’ smart label use within the ten largest alcohol companies operating in Ireland since 2010. Using framing analysis to examine smart labels used by different alcohol brands, we sought to address three questions: (i) what are the technological capacities of smart labels? (ii) what justifications does the alcohol industry use to normalise smart labels? (iii) how does this technology impact health when considered through a the lens of commercial determinants of health?</p> Results <p>Smart labelling has been justified by the alcohol industry as a technology that creates a more informed consumer, enhances corporate social responsibility and regulatory compliance, assures product quality, and leads to more responsible consumption. We examine these frames by introducing the MORAL framework. To contrast, we consider the impact of smart labels on public health through a commercial determinants of health perspective, showing that smart labelling (i) habituates consumption, (ii) undermines health information presented on physical labels, (iii) drives the next revolution in the micro-targeting of consumers, and (iv) is rapidly establishing an industry norm, in order to leapfrog current regulation. We articulate this through a HARM framework.</p> Conclusions <p>Smart labelling is a novel commercial determinant of health. Through rapid innovation of traditional labelling practices, the alcohol industry has leveraged smart labels to leapfrog regulation and perpetuate patterns of harm to public health. Our findings underscore the expanded playbook capabilities of the alcohol industry to outpace policy in the digital age, and suggest that it is crucial for policy to either rapidly evolve, or to perpetually remain one step behind unhealthy commodity industries.</p>