SCOTGOV has issued a public consultation on new proposals to restrict the advertising and promotion of alcohol – earning a swift rebuke from the licensed trade, which is already reeling from multiple economic blows.
“If enacted, these proposals would have a devasting impact on investment and jobs across a range of sectors, while hitting small, Scottish-owned businesses the hardest,” said Emma McClarkin OBE, CEO of the Scottish Beer & Pub Association.
In the foreword to the consultation, Scottish Minister for Public Health, Women’s Health and Sport, Maree Todd MSP, referenced what she described as Scotland’s ‘deep, longstanding and troubled relationship with alcohol’.
“In 2020, Scots bought enough alcohol for everyone aged over 16 to drink 18 units of alcohol every week, 28% more than the UK Chief Medical Officers’ lower-risk guidelines of 14 units per week,” she stated.
“Alcohol-related harm is one of the most pressing public health challenges that we face in Scotland. We have taken a number of actions to prevent and reduce this, including our world-leading minimum unit pricing policy, the reduction of the drink-drive limit and the multi-buy discount ban.”
However, ScotGov wants to do more, and restrictions on alcohol marketing have been identified by the World Health Organization as amongst the most cost-effective measures to prevent and reduce alcohol-related harm.
“Many of our European neighbours have already taken action to do this including Ireland, France and Norway. This consultation sets out a potential approach for Scotland,” said Ms Todd.
The plan that ScotGov is now seeking responses to is nothing if not comprehensive, arguing that reductions in advertising and promotion must be applied equally across all possible platforms and mediums, to avoid marketing spend migrating from restricted areas into less constrained territory.
Thus the consultation asks questions of the obvious candidates like street, print and screen advertising, but also considers sports, arts and events sponsorship, online promotion, window displays, instore positioning and even indirect promotion through branded clothing and flavoured consumer products containing no alcohol, but carrying alcohol related branding.
Perhaps most surprisingly, the consultation also questions the use of alcohol-related branding on zero alcohol drinks.
SBPA’s Ms McClarkin suggested this was all so much wasted and misdirected effort, when ministerial minds might be better employed on more pressing matters: “There is already robust regulation of alcohol marketing and a recent report by Credos found ‘little evidence’ of a relationship between alcohol advertising and consumption trends and that ‘alcohol advertising spend trends are inversely correlated to alcohol-specific harms’ in Scotland.”
A new tranche of marketing restrictions would, she warned, create an ‘insurmountable barrier to growth for Scottish producers’, while ripping-out much needed funding from sports clubs, cultural events and venues, reducing jobs in creative industries.
“It would also be negative for public health goals by stifling innovation and growth in no and low alcohol products, that have a vital, recognised role in helping people moderate consumption and reduce health harms.
“Businesses in these sectors are desperate for additional funding to survive the current economic crisis. The Scottish Government should be looking at ways to support them instead of inflicting more damage on the economy.”
Ms McClarkin concluded: “We will engage constructively around these proposals but the Scottish Government and MSPs must think very carefully about the potential impact these measures might have on the economy. Now is not the time to be risking investment and jobs.”
Matt Lambert, CEO of the Portman Group, a UK-wide body for alcohol labelling, packaging and promotion, said: “These recommendations are entirely disproportionate and inhibit consumers’ ability to make informed choices, and restrict the ability to trade for producers and retailers who ensure that alcohol is sold responsibly.
“The majority of adults in Scotland are moderate or non-drinkers and it is encouraging that binge drinking, alcohol-related crime and underage drinking have all significantly declined,” he said.
The consultation is open for responses until March 2023.
