Alcohol advertising and promotion consultation: stakeholder engagement summary – 2 February 2023

Minutes from the ministerial roundtable with alcohol retailers and hospitality stakeholders on 2 February 2023 to discuss the consultation on potential restrictions to alcohol advertising and promotion.

Attendees and apologies

  • Maree Todd MSP, Minister for Public Health, Women’s Health and Sport
  • Richard Foggo, Director of Population Health, Scottish Government
  • Aidan Grisewood, Interim Director of Economic Strategy, Scottish Government
  • Karen Macnee, Deputy Director, Health Improvement, Scottish Government (remote)
  • Scottish Government officials
  • Aldi
  • ASDA
  • Association of Convenience Stores
  • Federation of Independent Retailers    
  • Lidl
  • Majestic Wine
  • Marks and Spencer
  • Sainsburys
  • Scotland Food and Drink
  • Scottish Beer and Pub Association
  • Scottish Grocers Federation
  • Scottish Licensed Trade Association
  • Scottish Retail Consortium
  • Scottish Wholesale Association
  • Star Pubs and Bars 
  • Tesco
  • UK Hospitality
  • Whyte and Mackay
  • Wine and Spirts Trade Association  
  • Punch Pubs (remote) 
  • Society of Independent Brewers (remote) 
  • The Cooperative (remote)   
  • Waitrose (remote) 

Items and actions

The Minister thanked attendees for their time and opened the meeting with an explanation of the purpose of the roundtable. Officials then provided an overview of the consultation. 

Concerns were raised by attendees that the Scottish Government (SG) did not work with business ahead of the consultation launch and that the consultation development had not followed the Better Regulation Agenda.

The Minister set out that the consultation had been committed to in the Alcohol Framework 2018 and in two Programmes for Government. 

The Minister also noted that the consultation is an early first step prior to any proposals for potential restrictions.

Concerns were expressed by attendees around the strength of evidence and lack of a causal link between exposure to advertising and consumption.

The Minister set out international evidence around the impact alcohol advertising and promotion can have on children and young people as well as those in recovery.

There were also concerns raised by attendees about being asked to declare any interests with the alcohol industry and asked why this had been included in the consultation. 

The Minister provided reassurance that this question was for analytical purposes and that responses would not be treated differently and all responses are treated equally.

Concerns were noted around the impact placement proposals might have on smaller retailers where space is already at a premium. Attendees noted that there could be adverse reaction to idea of having to change layout due to the deposit return scheme, regulation for high fat, sugar and salt products and then again for potential alcohol restrictions. Attendees stressed that this comes at a high cost for retailers.

The Minister acknowledged that impact on business will be considered but highlighted the problem Scotland continues to have with alcohol harm, which includes an economic cost, and the imperative to take action to tackle this. 

Attendees discussed the disproportionate economic impact proposals could have and that this economic impact was not set out in consultation document.

The Minister stated that the SG has no intention of harming the alcohol industry and that the purpose of the consultation was to draw out all views to better understand any potential impacts of the proposals.

The Minister said that economic data from attendees would help to better understand potential economic impacts of proposals but understood the issues around commercial sensitivities.

The value and importance of hospitality in Scotland and how branded merchandise forms part of this were highlighted by attendees.

It was also raised by attendees that retailers and hospitality take their responsibilities in selling alcohol seriously and adhere to the regulation (both statutory and self-regulation) currently in place.

Practical issues around restricting alcohol advertising and promotion in public spaces were raised by attendees including how some licensed premises contain open frontage or outdoor areas within streets.

The Minister stressed the early stage of this consultation and that evidence of this nature is helpful within responses.

Questions were raised about the limited evidence included in the consultation around the impact on alcohol harms when other countries have restricted alcohol advertising.

The Minister noted this but set out that restricting alcohol advertising and promotion is one of the World Health Organization’s three best buy policies to prevent and tackle alcohol related harms. There is international evidence that alcohol marketing has an impact at an individual level – particularly on children and young people and those in recovery.

Attendees mentioned the impact that proposals could have on the supply chain including distribution to public sector premises.

The Minister acknowledged the potential economic impact and repeated calls for as much evidence as possible to allow full consideration to take place as part of consultation.

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