Restricting alcohol advertising and promotion: consultation

1. Why do we need to take action?

1.1 In 2020, Scots bought enough alcohol for everyone aged over 16 to drink 18 units of alcohol every week. This is equivalent to around 23 bottles of spirits, or around 90 bottles of wine, per adult each year; which is 28% more than the UK Chief Medical Officers’ low-risk guidelines of 14 units per week.

1.2 In 2021, 1,245 people in Scotland died from illnesses that can only be caused by drinking alcohol. That is an average of 24 people dying every week. Each one of these deaths is tragic and entirely preventable.

1.3 In addition to deaths wholly caused by alcohol, some deaths are partly attributable to alcohol consumption. Analysis found there were 3,705 deaths attributable to alcohol consumption in 2015. Of these, 1,048 (28%) were due to cancers, 544 deaths were from heart conditions and strokes, and 357 deaths were from unintentional injuries such as falls.

1.4 In the 2020/21 financial year, there were 35,124 alcohol-related hospital admissions (stays) in general acute hospitals in Scotland. That is nearly 700 hospital admissions every week.

1.5 There is a stark social gradient to alcohol harms. In the 10% most deprived areas of Scotland, rates of alcohol-specific deaths and alcohol-related hospital stays were eight times higher than in the 10% least deprived areas.

1.6 Wider harms related to drinking can include someone committing, or being a victim of a crime; or a child being neglected or distressed because of drinking in the family.

1.7 In taking action to prevent and reduce alcohol-related harms, we take a whole population approach which aims to reduce alcohol consumption and therefore the risk of alcohol-related harms across the population. Although we recognise that there is no safe level of regularly drinking alcohol, we are looking to embed lower and safer consumption levels throughout the population. This is in line with the UK Chief Medical Officers’ lower-risk drinking guidelines.

1.8 We follow the recommended international evidence-based approach. The World Health Organization (WHO) points to three ‘best buys’ as the most effective measures to prevent and tackle alcohol-related harm – reducing the Affordability, Availability and Attractiveness of alcohol. Building on this, the WHO launched its new SAFER initiative – a package of five evidence-based, high impact strategies which WHO recommends governments should prioritise to tackle alcohol-related harm.

• Strengthen restrictions on alcohol availability.
• Advance and enforce drink driving countermeasures.
• Facilitate access to screening, brief interventions, and treatment.
• Enforce bans or comprehensive restrictions on alcohol advertising, sponsorship, and promotion.
• Raise prices on alcohol through excise taxes and pricing policies.

1.9 Measures introduced by the Scottish Government reflect this approach, including the introduction of minimum unit pricing (MUP), lowering the drink-drive limit and facilitating the alcohol brief intervention programme.

1.10 Marketing is ‘the business activity that involves finding out what customers want, using that information to design products and services, and selling them effectively.’ This is often defined by reference to the four P’s – Product, Place, Price, and Promotion. This consultation is largely focused on Promotion which covers a wide range of activity used to communicate with consumers and promote alcohol products or brands. This includes advertising on television, in public spaces, via social media, as well as promotion via sports and events sponsorship as well as through branded merchandise.

1.11 The consultation also includes consideration of Place, a product’s distribution strategy with a focus on ensuring it is easily accessible to potential buyers, in the section on placement of alcohol products in in retail outlets.

1.12 We know that alcohol marketing like any other form of marketing, aims to make the product look as attractive and appetising as possible, in order to encourage consumers to purchase it. Fundamentally, marketing is about persuasion and aiming to direct people into desired action. Without branding and other marketing strategies, alcohol products in each beverage sub-sector are essentially variations of the same thing.

1.13 Marketing does not occur in only one area of our lives but is visible in the information we see on our billboards, that we read in our newspapers, that we see during our television programmes. It is on the adverts on our search engines and the information before the feature film in the cinema. Marketing strategies do not rely on the reach and persuasion of one single activity but involve a range of activities interwoven to interact and complement each other, and maximise the likelihood of reaching and persuading consumers.

1.14 This means that we need to consider the areas where Scotland can implement restrictions including on advertising in outdoor and public spaces, alongside areas where we can work with the UK Government to take action such as on television and radio.

1.15 It is only by tackling this interconnected nature of marketing activities that we will be able to make a difference in the volume and range of alcohol marketing that is seen across Scotland. This consultation sets out the areas where we could take action and seeks views on each.

1.16 The purpose of taking action to restrict alcohol marketing is threefold and summarised by the WHO as:

• to prevent young people from being exposed to alcohol marketing (which is known to influence the decision to start consuming alcohol and to increase alcohol use)
• to reduce the presence of alcohol cues that can induce reactivity and craving in alcohol-dependent persons
• to prevent influence on social norms relating to consumption in general, given the negative public health, economic and social consequences of alcohol use.

1.17 Although the proposed actions outlined in the consultation are population-wide and are intended to have an impact on everyone in Scotland, there is a focus on reducing the impact of alcohol marketing on children and young people. The strongest academic evidence^[1] underpins the impact alcohol marketing has on children and young people and is set out through the consultation. This is the basis on which a number of other European countries have taken action to restrict alcohol marketing.

1.18 Taking action to reduce the exposure children and young people have to alcohol marketing aims to reduce the attractiveness alcohol has to them. There is a connection between children and young people seeing alcohol marketing and drinking; seeing it leads young people to start drinking earlier, to drink more if they are already drinking, and to drink at heavy or problematic levels. Reducing the appeal that alcohol has to children and young people will reduce the range of alcohol harms specific to them (such as effects on their physical development and mental health), and prevent the harms linked to continuing to drink into adulthood. Therefore much of the discussion in this consultation concerns children and young people, but the intended impacts on people in recovery and the adult population generally are discussed where the proposed actions are particularly relevant to them.

1.19 ‘Children and young people’ will be used throughout the consultation to refer generally to those under 18 years old; however in some academic evidence the impact of alcohol marketing on those aged 18-25 years old may also be included.

1.20 Taking action to restrict alcohol marketing also aims to reduce the appeal that alcohol has to higher-risk drinkers and those in those in recovery from problematic drinking. There is evidence that those who drink heavily have increased susceptibility to alcohol marketing and that this can translate into drinking behaviours. For those in recovery, alcohol marketing can be a trigger which threatens their recovery and can be responsible for relapse. Although there is less research on this group, compared to children and young people, any relevant research is set out in this consultation.

1.21 There is limited academic evidence on the impact alcohol marketing has on the adult population, and as such this is a secondary focus of this consultation. It is likely that alcohol marketing also makes alcohol more attractive to adults generally and influences consumption. Alcohol marketing normalises alcohol and creates and sustains expectations about alcohol as positive, aspirational, commonplace, and even part of a healthy lifestyle. It can have a number of impacts on behaviour including encouraging someone to try an alcoholic product for the first time, encouraging someone to buy more or more frequently, capturing market share from competitors or enticing previous consumer to return. Studies indicate that the way alcohol is portrayed within alcohol adverts acts as a cue for drinking and influences consumption.

1.22 The Scottish Government may not have the powers to implement all of the restrictions outlined in this consultation. Some proposed restrictions may require the UK Government to take action or devolve powers to the Scottish Ministers. This consultation does not mean the actions outlined will take place – of course, the proposals discussed are subject to the outcomes of this consultation. However, gaining your views on these measures is of value to the overall consideration of alcohol marketing restrictions and the further development of policy proposals.

1.23 It is also important to be aware that pricing is outside the scope of the consultation given Scottish Government’s wider work on MUP and restricting multi-buys.