Alcohol - Minimum Unit Pricing (MUP) - continuation and future pricing: consultation analysis

Analysis of responses to the public consultation on whether Minimum Unit Pricing (MUP) should be continued as part of the range of policy measures in place to address alcohol related harm, and, in the event of its continuation, the level the minimum unit price should be set going forward.

4. Opposing views

This chapter presents views expressed in Q3 against MUP or increasing the minimum unit price to 65 pence per unit. The themes cover various issues, including the financial burden of MUP, a lack of evidence that MUP works in practice, and unintended or wider negative economic consequences.

Additional financial burden

The most prevalent theme across all responses to Q3, mentioned by many respondents, was that the proposal would increase the financial burden on people, particularly those on low incomes. It was mostly unclear whether respondents were specifically referring to continuing MUP, the proposed price increase, or both.

Comments included that it was inappropriate to increase the minimum price per unit during a cost-of-living crisis, that it constituted an additional, regressive or stealth tax, that people in Scotland already pay more tax than elsewhere in the UK, and that income is squeezed due to high inflation leading to rising costs including increased prices for alcohol.

Respondents felt that MUP impacted everyone universally rather than focusing on a target group. It was therefore argued that as the price increase would be applied across the board, it would disproportionately impact those living in poverty.

“This adds to the cost of living crisis... It is punishing those who are working and have seen significant increases in the cost of living with no comparable rise in wages.” – Individual

“An unnecessary tax on everyone, and a particularly cruel burden on poor people during a cost of living crisis.” – Individual

“The summary stated: “People who drink at hazardous and harmful levels in lower socio-economic groups suffer greater harms than those who drink at these levels in higher socio-economic groups due to the impact of multiple drivers of health inequality”. This is the nub for me. There is no attempt to tackle this inequality. In fact, MUP exacerbates it by design. Lower socio-economic groups are disproportionately hit by MUP.” – Individual

Organisations expressing this view were mainly involved in the alcohol sector, such as producers or their representatives or wholesalers. However, Glasgow City Alcohol and Drug Partnership cited feedback from their recovery community that an increase in price per unit represented a tax on the poorest members of society which could lead to other unintended consequences for the families of hazardous and harmful drinkers[2]; such as increased hunger. The Health and Wellbeing Subject Committee of the Scottish Youth Parliament reported similar concerns and highlighted the potential for social exclusion among students experiencing financial hardship.

“A specific concern was raised for students who are already having to rely on SASS funding and other financial aid would suffer with this increase in unit pricing. MSYPs felt this could affect the social element of their university experience. One young person pointed out that the increase in a bottle of wine would significantly impact their budgeting for the week. Another young person also shared their personal experience of missing out on social events at university because they already cannot afford alcohol, and increasing this further would mean that they would move only further away from their peers.” – Scottish Youth Parliament

MUP does not work in practice

Respondents described multiple reasons for their views that MUP has not worked, typically noting that it is an ineffective way to reduce hazardous and harmful drinking, that there is no evidence that MUP has been effective, or general comments that MUP does not work. These themes are described below.

Will not deter people with alcohol dependence

The second most prevalent theme across all responses was that increasing the minimum unit price of alcohol would not reduce the amount consumed by people with alcohol dependence. Many respondents frequently argued that the cost of alcohol was not a consideration for such individuals, who would always find money to pay for it. Consequently, they would have less money available for food, clothing or to pay bills for themselves and other family members, potentially increasing household tensions. It was common for individual respondents to draw on their personal experiences to support their views. The recovery community consulted for Glasgow City Council’s response felt the policy had been written by those who did not understand the nature of addiction.

“Having worked in areas where I came into contact with alcoholics, it will not matter what the cost is; they will buy alcohol to the detriment of other areas of their lives or that of their families.” – Individual

MUP punishes the family and dependants of the alcoholic drinker without helping them in any way... I write this as an alcoholic, now over 20 years sober.” – Individual

“Increasing the MUP means true alcoholics will use increasingly scarce funds in an already difficult cost of living crisis. This has a huge impact on women who are trying to hold their households and budgets together.” – Individual

Organisations that raised this issue also highlighted that the people percieved to be targeted by MUP were often among the most vulnerable members of society. It was suggested that the evidence accompanying the consultation found MUP could further disadvantage them despite being the most in need of targeted support to address their alcohol use. As a result, these respondents were likely to recommend further investment in alcohol treatment services or to use this as justification for ending MUP, both of which are outlined separately below.

“Whilst the purpose of MUP is to reduce alcohol consumption across the entire population, if MUP does not reduce consumption and harms of those who consume the most, then the policy has failed and should not continue. Therefore, if MUP were to continue, this would be punitive against the most vulnerable people in the midst of the cost-of-living crisis as they will maintain their consumption whilst forgoing food and home heating.” – GMB Scotland

“While we agree that MUP has had a positive impact on the wider population and should continue, we are not willing to overlook the harm it causes to a particularly vulnerable group of people in order to benefit the greater good. Secondly, future consideration and discussion of MUP should include consideration of this population who do not benefit from it. We cannot push ahead with a policy that delivers such positive impact for most while causing harm for some without connecting our thinking and our investment to ensure that harm is mitigated.” – Turning Point Scotland

The available evidence has not proven that MUP is effective

Many respondents argued that there was insufficient evidence to justify the proposals or that the existing evidence, such as the PHS evaluation, is selective, biased, misleading or flawed. This was the third most prevalent theme overall. The use of hypothetical, theoretical or modelled data was highlighted as a reason why the evidence was unconvincing, and respondents argued that the findings presented were often considered tentative, inconclusive or mixed, or that the evidence did not support the policy.

“The suggestion that MUP has "worked" is based on very selective reading of the data. It has been straightforward for commentators to read the same data and report that MUP has not worked. My reading of supporters of both conclusions leads me to believe that it has not worked and should not be further supported.” – Individual

“The evidence that MUP works is presented as estimates and likelihood. If MUP works there would be conclusive evidence of its success. The absence of this indicates a failure.” – Individual

“The 'evidence' to support the continuance of MUP has not been subject to robust challenge or even review. The report merely infers that MUP may be a contributing factor to positive outcomes without demonstrable data for our own analysis. Alcohol-related deaths have continued to rise, and I fear this policy is performative rather than efficacious.” – Individual

Some, for instance, pointed to an increase in alcohol-specific deaths since the introduction of MUP. A few cited National Records of Scotland figures which show that there were 1,276 alcohol-specific deaths registered in Scotland in 2022 – an increase of 2% (31) on 2021. Others highlighted alternative research findings to suggest the policy had not been effective. A few organisations highlighted that only one report from eight relevant studies considering alcohol-related health outcomes had identified positive impacts. The Law Society of Scotland noted that despite this, PHS’ evaluation reported ‘strong evidence’ MUP had reduced morbidity and mortality rates; it was argued that this was not a true evidence-based approach.

“Rather than looking at all of the evidence as a whole and drawing conclusions based on the strongest indicators, the PHS report would appear to have selected the evidence that best supports the theorised outcomes, even when that evidence is in the minority or has fundamental flaws in its ability to prove the purported impacts” - The Institute of Licensing

The Retail Data Partnership, which analyses data from more than 250 convenience stores, expressed surprise that the evidence suggested a reduction in alcohol sales following MUP implementation, as its data found a steady and consistent increase in the volume and value of sales, even when the effects of lockdowns during the pandemic were removed. They suggested instead that there was a shift in purchase patterns from supermarkets to convenience stores and to sales of multipacks. Some respondents also noted a shift to drinking stronger alcoholic beverages such as spirits. The Retail Data Partnership also argued their data contradicted the ‘consumption’ section of the Appendix in the PHS report that suggested the purchase of alcohol from the off-trade reduced, and believed this was due to partial data being used which failed to incorporate data from small independent retailers.

“As highlighted by the recent analysis published, to date, assessing the impact MUP over the past five years, the data and findings provided have been substantially inconclusive. Recent changes to drinking habits in Scotland are a reflection of multiple factors far outweighing any impact MUP has had. The Covid-19 pandemic and subsequent fluctuations in behaviour, in particular an increased cost in hospitality and on-licenced consumption, mitigates and significantly skews any data collected since March 2020” – Scottish Grocers’ Federation

MUP does not work

In addition to those who questioned the evidence of the effectiveness of MUP, many respondents, primarily individuals, expressed a more direct view that MUP had not worked or had had minimal impact. It was variously described as a failure, ineffective, flawed, unfair and having had no effect on reducing alcohol-related health issues or deaths. While many did not explain why they felt this way, several others reiterated that the evidence did not show that MUP had yielded the desired results.

“It has not worked so far, and this new price increase will not work.” – Individual

MUP hasn't worked. The latest proposal is basically ‘That hasn't worked, we must do more of it’." – Individual

“It is clearly a failed policy with the proposed new increased rate basically covering inflation since the introduction of the policy which hurts the occasional drinker more than it has any effect on lowering deaths from alcohol-related problems.” – Individual

Unfair to moderate drinkers

Overlapping with the theme of an increased financial burden, many respondents argued that the proposal to increase the minimum unit price was unfair to moderate or social drinkers. These respondents were mostly individuals who felt those who drink casually, occasionally, responsibly and in moderation should not have to pay more for alcohol. A few additionally criticised a situation where, in their view, the majority is penalised for the actions of a minority and to tackle a problem they are not responsible for.

A few organisations, including GMB Scotland and East Ayrshire Local Licensing Forum, either raised the same issue or argued that responsible drinkers would consume less in the event of a price increase, negatively impacting sales. The Federation of Independent Retailers was pleased that a price of 80p or more was not being considered as they felt this would impact this group of drinkers.

Respondents also commented that the cost of living crisis impacted those who enjoyed drinking in moderation and that household budgets were already squeezed. They saw any increase in the price of alcohol as a financial punishment or penalty despite their responsible drinking.

“There's absolutely nothing wrong with having a glass of wine to relax over a meal. Personally, I drink around 12 units a week, but I get annoyed when I've got to shell out more.” – Individual

“Why should those that have an occasional tipple have to suffer because a minority of individuals cannot control themselves?” – Individual

“In Scotland the majority of adults that drink, do so within the CMO guidelines. The Scottish Health Survey 2021 states that 77% of the population either do not drink or drink below the CMO weekly low risk drinking guidelines. However, it is recognised that MUP is a whole population policy and as such targets all adults that drink, despite the fact that 4 in 5 drink moderately. All those who consume alcoholic drinks responsibly as part of their social life would be negatively impacted by such a large MUP increase.” – The Scotch Whisky Association

Increased negative impacts or unintended consequences

Many respondents, mostly individuals, expressed a view that continuing MUP or increasing the minimum unit price would result in further unintended harm if hazardous and harmful drinkers could no longer afford more expensive alcohol. These included increases in poverty as described under the theme about increased financial burden, but also increased abuse, crime and use of other dangerous or illegal substances. For instance, the potential for theft, shoplifting or illegal activity, such as illicit trading, was commonly mentioned, including by a few in the retail sector.

A transition to stronger alcohol or other more dangerous substances, including drugs or alcoholic replacements, was also commonly predicted. For example, one individual reported that someone had broken into a car garage to obtain paint thinners in their town. Similarly, Glasgow City Council noted reported cases of drinking hand sanitiser amongst dependent drinkers who could not afford to buy alcohol. There was a concern that young people might choose illicit drugs rather than alcohol. Concerns were also noted that increased prices could lead to people being pushed further into poverty, becoming isolated or to negative impacts on family members, including increased neglect or abuse.

“Over the past year, the level and impact of retail crime has increased significantly. This includes increased volumes of shop theft as well as more frequent instances of abuse, threats and violence towards retailers and shop workers. This growing concern harms not only the people who work in retail but the wellbeing of families and the wider community. Three prominent factors which have driven the increase in retail crime in the past year are the cost-of-living crisis (product price and available income), the growth in organised groups committing larger-scale theft, and flash points relating to restricted and age-restricted items. As household budgets have become limited, more consumers are willing to engage in shop theft or purchasing illicit/stolen goods. Therefore, a significant increase to the price of some products, as a result of increasing MUP, will inevitably lead to higher levels of crime and illicit trade.” – Scottish Grocers’ Federation

“As a knock-on, there has been an increase in drug-related deaths as it was cheaper than drink. An increase in MUP will turn more people to drugs thus increasing drug deaths.” – Individual

“I believe MUP has a huge impact on child poverty and neglect and also domestic conflict.” - Individual

“I live in a very deprived area. I believe the more we increase alcohol, the more will turn to drugs. Drugs are a few pounds a hit. Especially attractive to the young and those on low incomes.” – Individual

Wider negative impacts on business

Other potential negative impacts for businesses in Scotland were raised by many. This included both individuals and organisations and those in favour of and against continuing MUP. Individuals raised concerns about the impact on hospitality, including pubs and restaurants, smaller retailers, smaller brewers and distilleries, and tourism, suggesting there could be job losses in those sectors. A small number of individuals in the brewing, whisky and spirits sector elaborated on their call for MUP to be scrapped by describing the potential for MUP to reduce investment in the sector, prevent workforce growth and lower pay awards. These concerns were reiterated by GMB Scotland.

“I own a tiny brewery in Glasgow… Our industry has been subject to horrifying increases in costs over the last years combined with an increasing inability of consumers to meet those costs. We are still facing the fallout of Brexit, Covid, and the Ukrainian conflict. Westminster has recently enacted the most punishing duty increases in decades and is promising further increases imminently. Businesses are closing and people are losing their jobs with alarming frequency. In circumstances like these, the need to be proportionate, pragmatic and evidence-constrained in the burdens we place on businesses is even more acute than usual.” – Individual

Organisations raising concerns were primarily producers, alcohol industry representative bodies and the retail sector. If there is an increase in the minimum unit price, three requests were repeatedly made of the Scottish Government:

  • Ensure there is sufficient communication to raise public awareness of the change.
  • Allow for appropriate timescales for the sector to implement the change without incurring unnecessary costs. Twelve months was often recommended. One concern was the need for retailers to manage their stock, some of which may have been bought in advance but may be less appealing to consumers at a higher price. Time to prepare for a change would allow retailers to sell existing stock and plan their future stock.
  • Amend the wording of the existing legislation to say that the price should always be rounded to the nearest whole penny, rather than the nearest whole number, to simplify the selling of single products compared to multipack products.

“Although we understand that retailers will not be implementing any new legislation, there will be a significant change. Furthermore, a new Minimum Unit price may result in retailers curating the range of products that they stock, and no longer requiring particular products in which case the retailers will need sufficient time to comply with the relevant Groceries Supply Code of Practice obligations. We would therefore request a period of no less than nine months following the passing of the new law for implementation purposes.” – The Co-operative Group

“We would also ask Scottish Government to look at the interaction of MUP and linear pricing rules. The current MUP law says that any fraction above a whole penny must be rounded up to the next whole penny. Linear pricing rules from the Alcohol etc Act also say that a multipack cannot be sold for any less than the multiple of the single unit (where sold). So if there is a product that a trader sold in both single cans and a 4pk, MUP for the single can might be 100.2p and MUP for the 4pk 400.8p. The rounding up means that the trader would have to charge 101p for the single can, but linear pricing means that they would have to sell the 4pk for 4x101p = 404p, rather than the 401p the MUP calculation alone demands. Traders will want to work out whether an odd number like 65p is more likely to create these anomalies than an even one like 50p. Alternatively the rounding up rule could be revised or removed, so that any figure less than half a penny may be rounded down instead.” – The Wine & Spirit Trade Association (WSTA)

Explicit opposition to MUP continuing

Several respondents explicitly called for MUP to be stopped, scrapped or abolished in their response to Q3, though comments were generally brief, particularly those from individuals. Organisations who left comments to this effect included the Wine & Spirit Trade Association (WSTA), spiritsEUROPE, Aston Manor Cider, and GMB Scotland. Reasons given by respondents in this theme included public resentment, unintended consequences, a lack of evidence to support the policy or a belief that MUP had not achieved its aims.

“Alongside distorting a commercial market, it results in unintended consequences that unduly penalise many stakeholders, not least legitimate consumers, especially those in low-income households. Hence, we do not believe there is a valid case to continue this policy.” – Aston Manor Cider

MUP must not continue. It is damaging to the pay, terms and conditions of those who work in the sector; it has encouraged divestment; it has limited growth of the workforce; and it risks deindustrialisation. Furthermore, public support for MUP has drastically decreased.” – GMB Scotland

“You should just let MUP lapse in April 2024 and most certainly should not even be thinking about raising it. Give us a break.” – Individual

A group of individuals in this theme provided similarly worded responses stating: “As a worker in Scotland’s brewing, whisky and spirits sectors (BWS), MUP must be scrapped”. Most did not go into detail though one explained:

MUP is a tax on a successful sector during the cost-of-living crisis. Just like all other businesses, BWS is impacted by inflation – in particular high energy costs. Brewing and distilling are energy-intensive processes, as is the bottling process, which is where a significant proportion of the BWS workforce work. The costs of production and, therefore, products are already increasing. BWS does not need a double whammy hit of inflation and MUP.” – Individual

Criticism of the Scottish Government’s approach

General criticism of the Scottish Government and SNP

A critique of the Scottish Government and SNP was given by several respondents, all bar one of which were individuals. Respondents criticised the Government more widely, particularly the perception that their preferred way to solve a problem or implement change was to raise taxes or introduce financial penalties. A few also cited other alcohol-related restrictions on citizens, and higher taxes than elsewhere in the UK. They suggested that the impact of such approaches would be fewer votes for the SNP in future elections.

A few felt Scottish Government priorities were wrong or contradicted the aim of MUP, for instance, allowing alcohol advertising at large public events or having a bar in the Scottish Parliament. A few expressed perceptions that the money raised by increasing the price of alcohol was used to supplement government spending or SNP priorities and felt this was inappropriate. The Scottish Wholesale Association, the only organisational respondent in this theme, noted that SNP MPs had called upon the UK Government to rule out further duty increases on Scotch whisky ahead of the Chancellor’s 2023 autumn statement.

“This is another stealth tax and yet another SNP act of folly. Stop trying to take as much money as you can from hard working families and concentrate on not wasting what you do get via already highest taxes in the UK.” – Individual

“You have turned Scotland in to a joyless miserable place where you tax the majority because of the minority.” – Individual

“The Scottish Government’s answer to all problems seems to be charge the public more for everything. Income tax, council tax, ULEZ tax etc.” – Individual

Scottish Government overreach

Several respondents, all individuals, suggested the proposals represented overreach by the Scottish Government into people’s personal lives. Some felt that MUP was an imposition that represented a ‘nanny state’. State interference was not desired by these individuals, who emphasised the need for personal freedom and responsibility, and that the market should determine the price of alcohol.

“This government thinks it can take away items from people [as] they see fit. If people don't want to drink, that’s their choice, and so is being able to drink without barriers. I am not a drinker.” – Individual

“The exercise is, in my view, more aligned to the Scottish Government's wish to control every aspect of people's lives than it is for any health benefit.” – Individual

Singular comments included that Scotland was becoming more restrictive than England, creating a culture of oppression and that people were being treated like children.

Concerns that retailers profit from MUP

A concern that the money raised from MUP went to retailers was raised by several respondents, mostly individuals. These respondents felt this was inappropriate, with suggestions that this increased retailer profits, contributed to inflation and was a missed opportunity.

Aligned with the theme of support for wider approaches and a levy described in Chapter 6, it was common for respondents to state that if the money raised through MUP was fed into prevention, care and treatment services, they would have more support for the policy.

“During a discussion around MUP, one family member said: ‘Try and get them to plough some of that [money] into treatment. That’s the only reason I would say to increase it – if the increase was getting fed back into the treatment sector. As opposed to profiting the producers and retailers and the government, and it’s no’ helping people who need help.’” – Scottish Families Affected by Alcohol and Drugs

“It would be different if the money made by this policy was being used to tackle the hazardous drinking, but it isn't, it just goes back to the retailer.” – Individual

“I wouldn’t mind so much if the extra costs went to, for example, the NHS, but my money goes to supermarket profits.” – Individual

Explicit opposition to an increase in the minimum unit price

Several respondents, primarily individuals, answered Q3 with a comment which explicitly opposed an increase in the minimum unit price, or argued that the specified price of 65 pence per unit is too high. Some of these respondents were part of the coordinated response from individuals working in the brewing, whisky and spirits sector. It should be noted, however, that around one third of those highlighting their opposition to an increase in the minimum unit price did support MUP continuing at Q1.

Reasons for opposing the increase to 65 pence per unit included that:

  • The current price of 50 pence per unit is already sufficient, or too high.
  • A 30% increase was considered too large or would disproportionately affect those who could least afford an increase.
  • The evidence was insufficient to justify the increased rate.
  • The cost-of-living crisis meant now was not the right time to increase the price per unit.
  • Inflation had already increased the cost of alcohol and eroded people’s income.
  • That a high inflation rate and the higher consumption levels resulting from the pandemic are temporary factors.
  • It was virtue signalling or patronising.

“I believe that the pricing is at a fair level and should not be increased as it will add to the cost-of-living crisis.” – Individual

“Maintain the current level it deals adequately with the problem of the cheap ciders etc.” – Individual

SWA has concerns regarding an increase in the price per unit. SWA would like to express real concerns regarding the potential impact of any increase to the 50ppu level on the Scottish wholesale sector and its partners throughout the drink supply chain. SWA does not endorse a rise in the price per unit and specifically opposes any amount surpassing 65ppu, should the government choose this as the designated price. SWA seeks further clarity on the future MUP pricing strategy and is keen to understand the government's intended approach in this regard.” – Scottish Wholesale Association

“There is no justification to increase MUP to 65p. Whilst inflation has increased rapidly, wages and salaries have not. Since the introduction of MUP in 2018 and 2022, there has been only 1.14% real terms pay increase when adjusted for inflation. Proposals to increase MUP from 50p to 65p would amount to a 30% increase. This far outstrips any increase in earnings and would not be proportionate. Therefore, if MUP is to remain at all, it must not go above 50p.” – Individual

An organisation specified they did not wish to see MUP automatically uprated or linked to inflation, but suggested options for how it could be reviewed.

“When reviewing the level at which the MUP is set, consideration should be given to a range of factors: trends in consumption, drinking patterns, health and social harms, price and affordability and the overall economic and social context.” – Scotch Whisky Association

A small number who supported MUP but not a 65ppu minimum unit price suggested alternatives, ranging from 55p to 60p per unit, or called for the rate to remain unchanged at 50ppu.

The consultation report cites increased alcohol deaths for 2022 as an additional factor in recommending setting the level at 65ppu. However, this rise in alcohol deaths may need to be considered in the context of the increased alcohol consumption levels associated the Covid-19 pandemic- a factor which is unlikely to be germane in years to come. In conclusion, we would be in favour of 60ppu, a slightly lower rate than that advocated in the consultation document, as long as it is in association with a form of regular rate escalation.” – Church of Scotland (Public Life and Social Justice Programme Group)

MUP increases the potential for cross-border trade

The likelihood of MUP increasing the potential for people to purchase their alcohol in England or online was raised by some respondents, a mix of individuals and organisations. Some individuals reported that they would do this or knew people who did. They raised concerns about the negative impact on Scottish businesses close to the border or on the environment due to increased travelling.

“If it continues, I personally will go south and buy enough for the year and bring it home for responsible consumption, which will hit Scottish retailers in the pocket, so they lose out too.” – Individual

“I have found myself on holiday stocking up on purchases when in England and am aware of several people who also do this, depriving the Scottish economy of well-needed funds.” – Individual

Organisations called for more research or monitoring into the problem of cross-border or other forms of trade, such as online. For instance, the Scottish Wholesale Association raised concerns of their members, particularly if the minimum unit price is increased, noting that the Interim Business and Regulatory Impact Assessment (BRIA) had also highlighted this issue and indicated that the price differential could be substantive. This is also explored more in the ‘more research and evidence’ theme in Chapter 6.

“There is a growing concern amongst SWA members near the border that this trend could evolve into a more substantial issue, potentially leading to adverse effects on businesses already contending with narrow profit margins. This becomes especially challenging given the competitive advantages enjoyed by businesses based in England. The prospect of increased cross-border purchasing introduces additional hurdles and potential loss of business for Scottish wholesalers, compounding the existing pressures they are already facing…. To put into context what a 65p per unit charge would look like for a household: The absolute minimum price for a 15pk of 440ml, 4%abv lager (1.8 units) is currently £13.50. At 65 ppu this would add an additional 15x (1.8 units x 15p) = £4.05. The total New Minimum retail price = £17.55, which is a 30% increase in the consumer cost. Compare this with the rest of the UK where, on promotion, the same pack can retail at £12. Consumer savings of £5.55 per 15-pack, in contrast to the current £1.50 difference, raises significant concerns about the potential for a substantial surge in cross-border purchasing.” – Scottish Wholesale Association

MUP is disproportionate

A few respondents expressed a view that, as a population-wide measure applying to all who buy alcohol, MUP is too blunt an instrument. Comments included that MUP is indiscriminately targeted, or disproportionate to the problem it is designed to tackle.

“Whilst any alcohol-related death is tragic, the WSTA does not believe that Minimum Unit Pricing is an effective or proportionate measure to tackle alcohol-related harm and that targeted measures have significantly greater impact without penalising the vast majority who do drink responsibly within the Chief Medical Officer guidelines.” – WSTA

Some producers and retail organisations in this theme still supported continuing MUP, including Budweiser Brewing Group UK and Ireland and the Association of Convenience Stores, but Molson Coors Beverage Company did not. Industry representatives made alternative suggestions for how MUP or alternative initiatives could be more targeted, notably by concentrating on the reform of the alcohol duty system or a similar approach that focuses on increasing the cost of alcohol based on the strength of alcohol.

“The new duty system structure aims at supporting public health, alongside boosting innovation, and reflecting modern drinking practices. It broadly taxes alcohol products in reference to their alcohol content, and crucially, as opposed to flat rates, it differentiates between lower ABV products, such as beer, and higher ABV products, such as spirits, which are taxed at a higher rate. The potential to improve public health outcomes by steering consumers toward low, lower and 0% alcohol-strength products like beer has been recognised by the World Health Organisation (WHO) in the WHO Global Alcohol Action Plan (May 2022). If a policy of MUP is pursued in Scotland, an alternative MUP approach based on ABV bands, whereby lower strength products like beer are differentiated against higher strength products like spirits, could be less regressive and is also estimated to be more effective in tackling the stated objective of reducing harmful drinking.” – Molson Coors Beverage Company

Some producers argued that a differentiated approach based on alcohol strength could also mitigate against an apparent shift in consumption towards higher-strength alcohol as a result of MUP. They called for more research into changing consumption patterns before MUP is continued or amended. Budweiser Brewing Group UK and Ireland also raised concerns around the apparent shift towards higher-strength alcohol. They reported findings from studies in Russia that male mortality had improved with a shift from hard to light alcohol, such as from vodka to beer.

The Scottish Beer and Pub Association and Budweiser Brewing Group UK and Ireland also argued that a deposit return scheme alongside MUP could compound a shift towards higher-strength alcohol consumption. It was argued that both policies running together would distort the price per unit as lower-strength products like beer are almost always sold as muti-packs and could lead to people losing money compared to if they bought single bottles of wine or spirits.

“While Budweiser Brewing Group recognises that the deposit is returnable and is conceived to motivate behavioural changes, the reality is that some consumers will not return the containers and will be economically impacted by the higher costs. For consumers who do not, or cannot, return their containers, the deposit is, in essence, a price increase. Other consumers, those most impacted by alcohol dependency and abuse, will have a higher propensity to purchase higher-strength products to negate the impact of the deposit. In the current fiscal environment, these impacts will be heightened as household budgets across all of Scotland are reduced.” – Budweiser Brewing Group UK and Ireland

People are drinking less

A few respondents highlighted that people in Scotland now drink less alcohol, mainly to argue that MUP should not be continued. Organisations used research findings to illustrate this point. For instance, the WSTA highlighted findings in a study by the Portman Group that indicated that around a third of adult drinkers in Scotland semi-regularly drink alcohol alternatives, and that over a fifth drink less alcohol as a result of consuming low and no alcohol alternatives. The Scotch Whisky Association and Molson Coors Beverage Company highlighted evidence from the Scottish Health Survey 2021 that reported steady declines in those drinking at hazardous and harmful levels.

“Whilst per capita alcohol consumption continued to decline after the introduction of MUP, this was/is the established trend over several years prior to this policy.” – Aston Manor Cider

Two respondents who supported the continuation of MUP also made general points on this theme – that young people were drinking less or that the closure of many pubs and breweries evidenced a decline in alcohol consumption.



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