Minimum unit pricing of alcohol - sales to trade: consultation analysis

Analysis and SG response to consultation on clarifying the position for certain wholesalers regarding compliance with minimum unit pricing of alcohol.


3. Analysis

3.1 There was only one open ended question in this consultation. Quantitative analysis of the responses was undertaken using frequency analysis. This categorised participants by sector/individual and their support of the suggested change. The results are presented in the report. Qualitative, thematic analysis was used on all responses to identify key themes in response to the question.

Demographics

3.2 A total of 11 written responses were received as part of the consultation. Of these 11 responses, five (45%) were from organisations and six (55%) were from individuals. The respondents were asked to comment on the proposed draft amendments to the 2018 Order. The 2018 Order set the Minimum Unit Price at 50 pence. Article 2 of the draft amending instrument proposes to amend the 2018 Order as follows:

"(2) In article 1(2) (interpretation), before the definition of "schedule 3", insert-

""sales to trade" means the selling of alcohol to trade to a person for the purposes of the person's trade;".

(3) After article 2 insert the following article-

"Sales to trade

2A. The minimum price per unit specified in article 2 does not apply for the purpose of sales to trade."."

3.3 The table below summarises the type of respondent to the consultation.

Table 1.1 Type of respondent to the consultation

Type of response Number Percentage (%)
Third Sector Health Body 1 9
Public Sector Body (non-Health) 1 9
Retailer 2 18
Other 1 9
Individual 6 55
Total 11 100

Responses to the proposed method

  • Eight (73%) of the respondents who commented on the proposed clarification for wholesalers were in agreement with the proposed method.
  • One (9%) of the respondents who commented on the proposed clarification for wholesalers was not in agreement with the proposed method, and considered the method should be more restrictive in terms of the definition of sales to trade.
  • One (9%) of the respondents who commented on the proposed clarification for wholesalers did not consider the method proposed would achieve the required clarification and that this would only be achieved through primary legislation.
  • One (9%) of the respondents did not directly address the question asked, but commented on Minimum Unit Pricing.

Other comments

3.4 Some of the respondents to the consultation mentioned specific queries, issues or concerns that they had with the proposed method of clarifying Minimum Unit Pricing and sales to trade. These were not directly related to the proposed Scottish Statutory Instrument but are reported on below for completeness.

  • One respondent welcomed confirmation of dual pricing being permissible within the licensing regime set out by the 2005 Act.
  • One respondent approved the requirement for dual pricing.
  • Two respondents called for a clarification of the definition of 'sales to trade'.
  • One respondent considered that the 2005 Act does not provide powers under which the proposed secondary legislation can be made, and that the best way to resolve the issue is to make a change to relevant primary legislation.
  • One respondent called for the consolidation of the 2005 Act.
  • One respondent commented that increasing the price would not help those with an addiction.
  • One respondent called for Minimum Unit Pricing to be abolished.
  • One respondent queried how a wholesaler would know they were selling to trade.
  • One respondent commented that they considered the timescale for implementation of Minimum Unit Pricing was too short.

How to access background or source data

The data collected for this social research publication:

are available via the Citizen Space online portal at: https://consult.gov.scot/alcohol-policy/wholesalers-minimum-unit-pricing/

Contact

Email: MUP@gov.scot

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