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

6. Other themes

While most of the themes evident in respondents’ comments were either in favour or opposed to the continuation or an increase in the minimum unit price, some wider perspectives were raised. This chapter covers three main areas: the role of MUP as part of a wider strategy to reduce hazardous and harmful drinking, the need for more consultation and engagement; and other comments about alcohol consumption in Scotland.

MUP as part of wider strategy

The role of MUP as part of a wider strategy was explored in many comments. These covered three themes which are detailed below:

• The need for more targeted action and support
• Support for a wide range of alcohol harm prevention measures
• Tackling the root causes of hazardous and harmful drinking

Need for more targeted action and support

A call for more support for hazardous and harmful drinkers was made by many; this was the fifth most prevalent theme overall, spanning both individuals and organisations, and those in support of and opposed to continuing MUP. Respondents argued MUP should not be seen as a substitute for treatment and care delivery, particularly for the most vulnerable or people with alcohol dependence. While individuals typically made brief comments to this effect, a range of points were made by organisations.

Greater investment in care, treatment and support for individuals and their families was commonly suggested, with many arguing that current resource allocations to these services are insufficient. For instance, Scottish Families Affected by Alcohol and Drugs highlighted gaps in alcohol treatment services and other preventative measures, and SHAAP highlighted a 40% reduction in people entering treatment in the past decade.

Over 20 organisations and three individuals in this theme, all of whom supported continuing MUP, urged the Scottish Government to consider introducing an Alcohol Harm Prevention Levy, as proposed by the NCD Alliance Scotland. This would be applied to recoup industry profits generated by MUP, on a ‘polluter pays’ principle. These funds could then be used to fund care and treatment services for individuals experiencing alcohol-related harms. Those advocating a levy included SHAAP, Alcohol Focus Scotland, NCD Alliance, UK Liver Alliance, Alcohol Health Alliance UK, Northern Ireland Alcohol and Drug Alliance, Scottish Directors of Public Health, NHS Highland, NHS Lothian, NHS Ayrshire & Arran, Alcohol and Drug Partnerships in Highland and Dumfries and Galloway, and Recovery Coaching Scotland CIC/Borders in Recovery Community.

“NHS Lothian also recommend that consideration should also be given to the implementation of a levy which would recoup the earnings made by the alcohol industry from MUP. This profit should instead be applied to tackling alcohol harms through services and treatment as alcohol harms cost Scotland an estimated £5-£10 billion every year.” – NHS Lothian

A few public health organisations specifically called for earlier detection of alcohol-related liver disease. They also advocated for the use of an inreach model, where community-based alcohol services link with health services, social care and police so those starting to come to harm from alcohol can be supported earlier. Other suggestions included residential rehabilitation and community-based alcohol and addiction services.

It was also noted that the MUP evaluation found the policy had led to unintended consequences amongst some, and it was generally felt that more effort should be made to mitigate these negative impacts. A few public health organisations welcomed the Scottish Government’s commitment in August 2023 to treating alcohol harms as an important health priority, in addition to the existing commitments around drug-related harms.

“However, MUP cannot be seen as the only required intervention: support for the most vulnerable and those most dependent on alcohol is necessary to minimise unintended consequences.” – Individual

Those against extending MUP argued for a greater focus on more targeted measures or interventions to support people with alcohol dependence or problematic drug use. They felt that other policies, and greater investment in treatment and recovery services, would be more effective than MUP. Some felt they would be more likely to support continuing MUP if the money raised was used specifically for alcohol support services.

“We agree that people with alcohol dependency and those drinking at harmful levels would benefit from treatment and care services… Action taken to reach these individuals to support them to reduce their drinking will reduce alcohol-related deaths.” – The Scottish Whisky Association

“At the moment, those who get in a position to change their lifestyle are abandoned due to a lack of and almost non-existent support. So many start again due to feeling abandoned by the system. Why should everyone pay the price for a minority who need better focused treatment, which they are crying out for?” – Individual

Support for a wide range of alcohol harm prevention measures

Many respondents advocated for a wide suite of measures to address Scotland’s relationship with alcohol. Around three quarters of those who expressed this view supported the continuation of MUP, with many seeing it as an integral part of Scotland’s existing alcohol harm reduction strategy. However, it was argued that MUP alone could not prevent harm from alcohol and that a range of preventative approaches, alongside sufficient care and treatment measures, were required. Moreover, members of the European Alcohol Policy Alliance argued that: “The effectiveness of Minimum Unit Price will be enhanced if implemented as part of a comprehensive set of measures, including actions on marketing, availability, and treatment.”

“We recommend that MUP should form a component part of a comprehensive alcohol harm reduction strategy. It should not be considered a stand-alone policy, but rather a vital tool in the harm prevention toolbox.” – SPECTRUM Consortium

“Many of the deaths and much of the harm caused by alcohol dependence is preventable through a combination of appropriate public health measures, and RCGP views minimum unit pricing as part of this. MUP is by no means a silver bullet, but it is an important tool which can be used alongside a variety of other measures to address the widespread harms of alcohol dependence and misuse in Scotland.” – Royal College of General Practitioners Scotland

“MUP alone is not enough to address Scotland’s difficult and long relationship with alcohol. To prevent further deaths and reduce harm from alcohol other actions are required and include further investment and improvements in treatment and care, comprehensive restrictions on the marketing and availability of alcohol, alongside the implementation of effective prevention policies. A wide package of measures is required and MUP is an essential component which we cannot afford to lose, especially as alcohol harms continue to rise year on year and in light of the projected harms modelled by the Sheffield Alcohol Research Group.” – The Special Interest Group for Alcohol

“Due to the complexity of alcohol-related harm in Scotland, multiple whole-population approaches and individualised interventions are required. MUP was never intended to tackle Scotland’s unhealthy relationship with alcohol on its own. However, it is a vital cornerstone of the Scottish Government’s alcohol strategy, which contains forty actions to reduce alcohol consumption and related harm in Scotland, so ongoing resource and commitment is required to reduce alcohol-related harms in Scotland significantly.” – WithYou

“MUP is one of the most effective and cost-effective tools that can be employed to reduce alcohol harm but must be part of a wider package of measures to reduce alcohol harm implemented by the Scottish Government. We are separately calling for the UK and Scottish Governments to reduce the number of alcohol-attributable cancer cases by implementing comprehensive policy measures which reduce the availability, marketing and affordability of alcohol.” – Cancer Research UK

Other specific measures which respondents suggested as part of a wider strategy included comprehensive restrictions on the marketing and availability of alcohol, e.g., minimising shelf space in retail, education, person-centred outreach, access to advocacy services, and extending specialist alcohol care teams. Aston Manor Cider described an intervention known as the Primary Care Alcohol Nurse Outreach Service. This approach saw specialist addiction nurses placed in 100 GP practices in areas of highest deprivation in Scotland to support those who had not engaged with or had low engagement with specialist community alcohol services. An evaluation of the scheme by the University of Glasgow found it had targeted the right population and received positive feedback from GPs and service users.

“It is likely that there are subgroups in society, often living in the most socio-economically deprived areas of Scotland, that remain vulnerable to alcohol health harms and require additional preventive, planned, and unplanned support from health-care services.” – School of Health and Wellbeing, University of Glasgow

“We believe [MUP] has a role to play alongside other measures to help reduce alcohol abuse in Scotland. That includes the work already done by retailers who support charities such as Drinkaware, Community Alcohol Partnerships, support in-store for communications and advice, and voluntary measures such as not displaying alcohol or alcohol product marketing in shop windows.” – Scottish Retail Consortium

"The SLTA fully supported the principle of a Minimum Unit Price for alcohol and commended the Scottish Government in 2011 for trying to tackle the problem of “cheap booze” and the consequences of irresponsible promotions on the people of Scotland. We recognised then that minimum unit pricing would not be a panacea, but controls on pricing, in our view, continue to be the foundations for other complementary policies to be effective in controlling irresponsible pricing and promotions.” – The Scottish Licensed Trade Association

A quarter of respondents who did not support continuing MUP advocated for many of the wider approaches described above, favouring education and various restrictions on the advertising and purchase of alcohol.

“Ultimately, the most efficacious policy is education. I more than appreciate that this means any change will be generational rather than immediate, but if we're totally honest, that is the case with any policy.” – Individual

Tackle the root causes of hazardous and harmful drinking

Some respondents advocated for greater efforts to address the underlying reasons why people use alcohol at hazardous and harmful levels. A range of respondents raised this theme, including those who supported the continuation of MUP and those who did not.

Multiple issues were mentioned by respondents, including poverty and deprivation, Scotland’s culture of drinking and individual challenges such as low mood or self-esteem, trauma, poor diet and lack of exercise.

"Instead of taking the usual sticking plaster approach to social problems, would it not be more practical to address the social reasons that result in people especially low income individuals, to abuse alcohol in the first place?” – Individual

“To the extent that this may have a disproportionate impact on those with low incomes, the response to that should be to address poverty and income inequality as issues in their own right rather than limiting the MUP.” – NHS Greater Glasgow and Clyde

“The Scottish government needs to tackle the root causes of alcoholism in the country, poverty, mental health, lack of esteem, and unemployment, instead of penalising all responsible drinkers by raising the prices.” – Individual

“The Salvation Army is clear that action needs to incorporate increased access to support services that help tackle the reasons why people have turned to alcohol in the first place.” – The Salvation Army

“Minimum unit pricing for alcohol does not address the socio-economic problems leading to alcohol and other addictions in the first place. While I accept that MUP has reduced hospital admissions for health-related impacts related to alcohol consumption, it has not addressed the root issue. Scotland has some of the worst poverty levels and drug addiction problems in Europe. We need a complete restructuring of services to tackle this all the way from schooling to health care to law enforcement.” – Individual

”We must not lose sight of the fact that MUP, while helpful, can only ever be one weapon in the armoury of seeking to tackle the public health problem that is alcohol consumption in Scotland. We would urge the Scottish Government to continue to escalate work in areas in this space in relation to education and rehabilitation, as well as wider work to tackle poverty and to better understand trauma.” – Church of Scotland (Public Life and Social Justice Programme Group)

“There was some qualitative evidence that individuals with alcohol dependence who are financially vulnerable reduced spend on food, and it is important that interventions to support recovery, the wider family, and mitigate the effects of poverty, particularly its impact on children, are also in place.” – PHS

Calls for more evidence and engagement

More research and evidence required

Some respondents, most of whom favoured MUP continuing, called for more research and evidence. These covered a range of requests, including:

• For the Scottish Government to take an evidence-based approach to all changes to alcohol policy, including continuing MUP and changing the minimum unit price.
• Monitoring and evaluating the relationship between MUP, the public health impact of MUP and its impact on people in areas of deprivation and marginalised groups, including unintended consequences.
• The Scottish Community Safety Network requested more information on “the impact of MUP in reducing unintentional harm and injury (accidents) and teasing that data out on alcohol-related hospital admissions”.
• Glasgow City Council suggested it would be useful to have more evidence of any impact of MUP on people with Alcohol Related Brain Disease (ARBD).
• Turning Point Scotland noted that, while MUP was not intended to reach people who were dependent on alcohol, there is anecdotal evidence of harm being caused to this group. They called for “a commitment to better understand this population, how they are impacted by MUP and how this impact can be prevented or mitigated.” NHS Ayrshire and Arran and SPECTRUM Consortium made similar points.

A few public health organisations made the same specific request for:

“Implement a comprehensive evaluation of government policy around alcohol to better understand the impact and effectiveness of different approaches specifically as they affect dependent drinkers, women, children and young people.

Further investigation of the identified changes in acute alcohol-related presentations to hospital in order to better understand and quantify the risks associated with this. For example, to what extent are these acute withdrawal presentations amongst dependent drinkers, and what would be the appropriate service response to avoid this for those most affected by issues of affordability.

Planning for the next decade – robust monitoring and evaluation mechanisms should be put into place so that population changes are accurately recorded. The SDsPH also recommend a research framework is developed to capture new learning and for the design of future policies.” – Scottish Directors of Public Health

The European Alcohol Policy Alliance and a few of its members hoped for more insight into “patterns of sales among particular populations and localities”, particularly cross-border sales, as they argued that the evaluation of MUP was not as detailed on this point as it could have been. The Scotch Whisky Association, who were opposed to MUP continuing, also called for impacts on online and cross-border sales to be monitored.

“Commercial operators often cite increased cross border sales as a reason not to implement price interventions in a country, though the evidence is that this is a minor influence in population consumption and harm. The introduction of minimum unit price in Scotland was an ideal opportunity to study this issue and while we note that there is no evidence that MUP drove significant cross-border alcohol import, which is in line with our expectations, it was disappointing that there was little quantitative data to support this conclusion.” – The European Alcohol Policy Alliance

Future engagement and consultation

Calls for continued or more engagement were made by some respondents, primarily retail organisations and producers. From the producers' perspective, the WSTA and spiritsEUROPE requested the Scottish Government commit to consulting on future increases and consider establishing a timetable for regular reviews.

The Scottish Wholesale Association noted their appreciation of the commitment to regular review of the effectiveness and proportionality of MUP. They welcomed future collaboration to ensure the concerns of affected businesses are considered, “ensuring a balanced approach that considers both public health objectives and the welfare of businesses across the sector”. The Scottish Retail Consortium noted retailers were able to implement MUP in partnership with the Scottish Government, including raising public awareness of the policy, and requested a similar approach if the minimum unit price changes. They also suggested that a higher minimum unit price may affect some retailers not previously in the scope of the policy and that those businesses should be allowed time to make the required changes. UKHospitality Scotland also called for the Scottish Government to engage with businesses and trade associations.

Singular suggestions from individuals included: talking to people with lived experience of hazardous and harmful drinking to develop policy; engaging with other key stakeholders in addition to the alcohol industry, including medical bodies and third sector organisations; and for greater publicity of future consultations among the general public.

“If the Scottish Government decide to continue implementing and raise the value of MUP, it is imperative that industry, including retailers, have a fair lead in time till implementation to ensure necessary administrative updates, pricing and promotional changes and staff training can be made to help prepare businesses for implementation.” – Association of Convenience Stores

Other comments on alcohol consumption in Scotland

Several respondents commented more broadly on the consumption and sale of alcohol. A range of points were made, particularly about off-trade sales i.e. alcohol sold for drinking off the premises.

The relationship between price and location of drinking was noted by some. One organisation noted that licensed premises are bound by the Licensing (Scotland) Act 2005 where one of the five objectives is to ‘protect and improve health’. The Institute for Social Marketing and Health reported on its research into how policies can support public health without impacting on-trade businesses. They argued increasing the minimum unit price could reduce the price differential between on-trade and off-trade sales, thus encouraging more people to drink in licensed premises rather than at home. This could also reduce the amount of drinking done at home before people go out, meaning people have consumed less before they arrive at hospitality venues.

Glasgow City Council highlighted that licensed premises had increased by 7% since the implementation of MUP compared to an increase of 13% of off-sales only provision, and that following the pandemic, 66% of all licensed premises were now able to sell alcohol for drinking off the premises. They concluded that: “While MUP has provided a price point per unit of alcohol, there remains a substantial price differential between off-sales and on-sales continuing to drive unregulated consumption and for off-sales premises to provide this cheaper alcohol.”

Scottish Families Affected by Alcohol and Drugs recognised that MUP effectively targeted those drinking at hazardous and harmful levels, given that these individuals are more likely to purchase alcohol from off-sales premises. They felt this was appropriate given that off-trade alcohol had become 64% more affordable compared to 1987. A small number of respondents called for the licensing regime to be addressed.

“We are supportive of a strong, robust licensing policy based on the concomitance of the available evidence. It is only through robust and probative policy that good law can be made.” – The Institute of Licensing

“I think another approach is needed rather than just raising prices. Perhaps looking at licensing both on and off sales, again, and availability, would be a better bet.” – Individual

“It is also our local experience that the legal framework for alcohol licensing remains too weak to enable meaningful and effective application of the public health objective in individual alcohol licensing decisions. Rather than the MUP mitigating the need for this, it is our view that the legal framework for the public health objective needs to be strengthened alongside the MUP in order to achieve an adequate overall impact on alcohol harms in Scotland.” – NHS Greater Glasgow and Clyde

Respondents commonly cited the evidence from PHS’ evaluation of MUP that overall alcohol consumption had reduced by 3% at a population level, driven by a reduction in off-trade sales. However, as noted earlier, the Retail Data Partnership Ltd queried this finding, arguing that their data showed a steady and consistent increase in the volume and value of sales and suggested a displacement, rather than reduction, in sales.

Other comments

A few respondents raised other points which did not align with the themes in this report. These were typically made by one or a very small number of respondents and included:

• That more consideration needs to be given to the proposals.
• A critique of the consultation including that it was difficult to navigate and that there should have been an opportunity to comment on the closed questions.