I thank the Deputies and Senators for the opportunity to address the committee on the heads of the public health (alcohol) Bill. I am the director of the Alcohol Beverage Federation of Ireland, ABFI. We represent manufacturers and distributors of alcoholic beverages on the island of Ireland.
To give the members some background information on the sector, in economic terms it generates in excess of €2 billion in excise and VAT receipts annually for the State, makes more than €1 billion in purchases and has exports of more than €1.2 billion. It also supports in excess of 92,000 jobs in rural and urban Ireland.
The ABFI recognises that alcohol misuse, which manifests itself in harmful drinking, drinking to excess and under-age drinking, must be addressed. The ABFI fully supports efforts to reduce alcohol misuse and welcomes the opportunity to engage with the Oireachtas on this important legislation. We support the education of consumers to allow them to make the right choices about their alcohol consumption, and we support the use of evidence-based approaches that will reduce the harm associated with the abuse of alcohol.
The consumption of alcohol has fallen by approximately 25% over the past 15 years, based on Revenue Commissioners clearance and Central Statistics Office population data. The most recent research from the European School Survey Project on Alcohol and Drugs, ESPAD, showed under-age drinking in Ireland has declined across many metrics between 1999 and 2011. While the trends are moving in the right direction, there is still much work to be done.
With regard to specific elements of the Bill, we welcome the intention to move the voluntary codes of behaviour on advertising, marketing and sponsorship to a statutory basis. The voluntary codes already in existence work well and this move will strengthen them. Marketing and sponsorship activities undertaken by companies operate under the principle of audience profiling. This means that at least 75% of the audience for any marketing initiative must be older than 18 years of age. We work closely with the Government and industry body, the alcohol marketing communications monitoring body, AMCMB, independently chaired by Mr. Peter Cassells, which has strict rules on the volume and placement of all alcohol advertisements in all media, that is, how much advertising and where an alcohol advertisement is permitted to be placed. These codes were drawn up between the Department of Health and the industry and were reviewed and updated in 2008.
We also work with the Advertising Standards Association of Ireland the independent self-regulatory body set up and financed by the advertising industry and committed, in the public interest, to promoting the highest standards of marketing communications. Since 2003, an independent pre-clearance house, CopyClear, has been in existence. All advertising copy is sent for pre-clearance to CopyClear, a group of independent advertising professionals who vet any marketing for compliance with the ASAI codes on content. This process is unique to Ireland. No other market puts its alcohol advertising through such rigorous scrutiny to ensure it complies with both the letter and spirit of the codes.
The codes in operation today function well, and the ABFI welcomes the intention to move them to a statutory basis. The statutory code system should cover the general areas of volume, content and placement. There should be strict penalties for non-compliance with the codes. There should be a strong and comparative evidence base for all measures arising out of the detailed information available on viewership and readership profiles. The drafting of the regulations should involve a wide group of stakeholders, including the Department of Communications, Energy and Natural Resources, the Broadcasting Authority of Ireland and other regulatory bodies, to ensure the system functions correctly and does not unfairly disadvantage domestic media companies.
Regarding the proposal to introduce a watershed ban on advertising on television and radio, a watershed will only apply to domestic broadcasters. It will not apply to broadcasters operating outside the jurisdiction. A watershed will not apply to programming that is viewed on demand or online. The ABFI restates its view that the best way to limit the exposure of those under 18 to alcohol advertising is through audience profiling.
Regarding structural separation, the ABFI welcomes the proposal in the heads of the Bill to move the Responsible Retailing of Alcohol in Ireland voluntary code to a statutory basis and to review the effectiveness of the code in two years. We believe this takes into account the success of the code. Compliance with the code is high, at 83% overall and 95% at multiple level in the latest annual report. It is an example of an industry code that works well.
The ABFI welcomes appropriate labelling which enables the consumer to make informed decisions when purchasing alcohol. The purpose of labelling on alcohol products, much like food, is for consumers to be provided with accurate information that is clear, consistent and easily understood. The ABFI recognises that calorific information, when portrayed in a consumer-friendly and scientifically verifiable manner, is of use to the consumer. The industry welcomes the Government’s proposed introduction of labels indicating the dangers of drinking while pregnant. In fact, some companies, such as Irish Distillers and Heineken, already do this on a voluntary basis. The ABFI has consistently called on the Department of Health to introduce a requirement for this labelling since 2007. It is essential the proposed inclusion of any health warning labels on packaged alcohol products is proportionate, measured and informative.
For consumers to understand the amount of alcohol they are consuming, the ABFI supports the inclusion of alcohol content information in the form of a standard drink or unit. The proposed introduction of grams as the measure of alcohol content will confuse consumers and compromise their ability to make an informed decision when purchasing or consuming alcohol. The research performed by Stockwell and Kerr that the heads of the Bill references also states that “grams or other weight-based measures are unlikely to be useful in helping drinkers to understand alcohol”.
Member states take their lead on alcohol labelling from EU legislation. An EU committee is reviewing the potential for a harmonised unit at EU level. It is also evaluating the various issues associated with alcohol products, specifically around nutrition and calories. The Commission is expected to publish the findings of its research in a report due in 2015, and as the issues are being considered formally at EU level, now might not be the most appropriate time to develop national measures.
Regarding minimum unit pricing, the ABFI supports the Government’s intention to address the sale of cheap alcohol. In 2014, an industry-wide initiative called on the Government to address the sale of cheap alcohol, introduce a statutory ban on price-based advertising and introduce statutory codes to regulate the merchandising of alcohol. There is full agreement in the ABFI that the best and quickest way to do this is by the reintroduction of a ban on below-cost selling of alcohol. The ABFI calls on the Government to reintroduce the relevant section of the groceries order to deliver this.
Our view is that minimum unit pricing will be ineffective as a measure to address the sale of cheap alcohol. It is based on a theoretical model with a multiplicity of assumptions, some of which might not be relevant to Ireland. Specifically, the model deals with the impact of a change in price on demand for alcohol or price elasticity. There is no price elasticity data available for Ireland. The Sheffield report states: "While we have attempted to estimate Irish-specific elasticities, the current data do not allow this to be done robustly". This calls into question the validity of the model for MUP that is used and the outputs it delivered in an Irish context, particularly how individual groups respond to changes in price, which is the foundation for the model and the conclusions drawn. Minimum unit pricing is also currently before the European Court of Justice and it might be a number of years before its legality is ruled upon.