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

Attendees and apologies

• Maree Todd MSP, Minister for Public Health, Women’s Health and Sport
• Richard Foggo, Director of Population Health, Scottish Government
• Scottish Government officials
• Advertising Association 
• Advertising Standards Authority 
• Institute of Practitioners in Advertising
• News Scotland 
• Outsmart 
• Screen Scotland 
• STV 
• The Leith Agency 
• The Marketing Society
• British Promotional Merchandise Association (remote)
• UK Cinema Association (remote)
• Incorporated Society of British Advertisers (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.

Attendees noted that they were generally disconcerted and alarmed by the tone of the consultation, which they felt was “anti-business” and not compatible with the current Scottish economic strategy. It was also felt that the Scottish Government (SG) had already decided on the policy and that more needs to be done to understand the wider impacts of the proposals. It was noted that the proposed restrictions could lead to unintended consequences (e.g. competition issues). 

Attendees encouraged the SG to instead look at ways advertising can be used to support alcohol harm prevention.

The Minister assured attendees that this was an early consultation and no decisions had been made on the policy.

The Minister noted that recent figures show Scotland still has an unhealthy relationship with alcohol, which cannot be ignored.

The Minister said she was keen to work with stakeholders to ensure the right balance to the restrictions is struck.

Attendees agreed that more needs to be done to reduce alcohol harm across Scotland. However, they felt the proposals were a “blunt instrument”. They noted that Scotland has unique issues, which attendees could help the SG better understand. They asked if there is any evidence from other countries who have implemented restrictions on advertising.

The Minister said that it is difficult to untangle these issues and there is no linear relationship.

The Minister stated that the World Health Organization (WHO) are very clear that reducing the attractiveness of alcohol can help reduce alcohol harm.

Concerns were raised by attendees about the impact the proposals could have on business in Scotland and the knock-on effects that could have on supply chains (e.g. creative industries). Attendees also felt that the positive impact advertising could have is not reflected in the consultation. It was noted that the creative industry is fragile but the strength of Scottish brands gives an opportunity to compete at an international level. It was suggested that more impact assessment needs to be done to better understand the potential unintended consequences.

The Minister agreed that a full assessment of the impacts will be needed before any further proposals.

The Minister said that economic data from attendees would help with this process but understood the issues around commercial sensitivities.

Attendees suggested that Scotland could act as a case study around the power of the creative industry to tackle alcohol harm. It was also suggested that there are progressive and bold alternatives to the potential restrictions laid out in the consultation. Attendees were reassured that the SG were seeking early views on this issue but felt that the consultation wasn’t clear on why a whole population approach is the best option. It was suggested that the framing of the consultation only leads to an outright ban of advertising and promotion. 

It was also felt that more focus should be put on helping deprived areas and that a targeted ban of advertising was not discussed in the consultation. It was suggested that a complete ban on out of home advertising was already being prepared despite there being no clear evidence to support this measure. 

The Minister reiterated that no decision has been made. 

The Minister noted she was keen to protect children and young people and was mindful that they are not always where you expect them to be.

The Minister urged attendees to provide information on potential exemptions or alternatives in their responses to the consultation.  

Officials noted that attendees insight on behaviour change could be vital in reducing alcohol harm and would welcome any responses on this as part of consultation responses.

Attendees were concerned that the consultation provides little commentary on the current regulatory system and the role existing organisations play in world leading work in this area. They also noted that clear guidelines are already in place and industry take their responsibility in following these very seriously. It was suggested that impacts are already being felt by industry following this consultation. This, combined with an ongoing recovery from the pandemic, has meant that creative industries remain in a very fragile state.

Attendees suggested that the consultation treats industry as “bad faith actors”, which they found disappointing. They also confirmed that they would be strongly against the possibility of a separate regulator. Attendees said there was an opportunity for the SG to work with industry as they have done in the past (e.g. knife crime) and that this could act as a positive solution.

The Minister noted the points raised and confirmed that all options would be considered. 

The Minister reiterated her desire to change behaviour and avoid any unintended impacts on industry.

Attendees suggested that recent figures showed that children and young people were already drinking less without any restrictions being implemented. They felt that the information on no and low alcohol in the consultation seems to be at odds with the SG’s ambitions.

The Minister agreed that current trends look positive but noted that Scotland started in a worse position compared to other countries.

The Minister noted that people in recovery have raised concerns about the negative impacts no and low alcohol advertising can have on them and their recovery. 

Attendees were not convinced that advertising was the main issue in this area and were concerned that it was being targeted because it was a simpler to implement compared to other solutions. 

The Minister highlighted the advice from WHO which clearly states that advertising has an impact.

Concerns were raised about the nuances of media not being properly reflected within the consultation. It was suggested that the practical application of any proposals will be very complicated as things stand currently.

The Minister noted the points raised and stressed her keenness for as much detail as possible on any unintended consequences within consultation responses.

The Minister thanked all for attending and confirmed that no further decisions will be made until the consultation analysis has been completed.