Alcohol - Health Committee Contents

Memorandum by the National Association of Cider Makers (AL 15)


  The National Association of Cider Makers (NACM), which represents producers of cider and perry in England, Wales and Northern Ireland, welcomes the opportunity to offer comments to the Health Select Committee—Alcohol Enquiry.


  The cider industry is characterised by its wide range of scale of production with two major producers, a handful of medium scale producers and a very long tail of very small scale with some perry and cider makers produce less than 70Hl per annum.

  The principal raw material for making perry and cider is pears for perry and apples (both cider apples and dessert apples) for cider. The source of the pears and apples for making perry and cider is from a wide variety of orchards, varying in scale from two to three trees to large orchards in England and Wales.

  Cider and perry is sold throughout the United Kingdom in a wide range of outlets from major national and regional pub chains, major multiple retailers to farm shops and local pubs and local supermarkets.

  The share which cider and perry have of the total UK alcoholic drinks market is only very small at about 7%, compared to beer (41%), wine (25%), spirits (25%) and RTDs (alcopops) (1%). Of cider's 7% share of the alcoholic drinks market less than that 10% is strong white ciders >7.5% ABV, accounting for only 0.7% of the total alcohol market. Furthermore this product is declining in sales volumes and is increasingly representing a reducing share of the alcoholic drinks market.


  NACM appreciates the Government's desire to tackle alcohol misuse and believes that Government should take appropriate measures to address this issue and introduce policies that will contribute to the significant reduction in the harm which arises from misuse.

  A review of published reports in the public domain produced by the UK Government and other bodies, quite clearly demonstrates that no one alcoholic drink is responsible for alcohol misuse—misuse is caused by certain drinkers who clearly misuse alcohol and by some under 18s who are clearly breaking the law. This therefore is not a problem about problem drinks but about problem drinkers.


  For the Government to succeed in bringing about a cultural change in how alcohol is consumed by the irresponsible minority then as an urgent priority, it needs to identify and deal with the real causes of alcohol misuse (and indeed substance abuse in general). It is misplaced to focus on the availability and affordability (price and promotion) of alcohol as the sole and root cause of misuse. The real drivers behind harmful drinking, binge drinking behavior and under 18's alcohol misuse tend to get overlooked as a consequence. This means adopting or calling for a combination of long-term measures such as improving education, awareness campaigns, etc and short-term measures which can also be effective such as enforcing the legislation that already exists.

  NACM acknowledges that Government has committed resources to initiatives in this area as indeed has industry. NACM is a supporter of the Drinkaware Trust and of "Project 10" a £100 million (over five years) industry education initiative.


  The Minister of State for Public Health, stated in the Ministerial Foreword to the "Safe, Sensible, Social—Consultation, on Further Action";

    "... retailers and consumers of alcohol act responsibly and it is the irresponsible minority on which our efforts should be focused. It is right to consider ways to tackle irresponsible practices but we must ensure that any measures do not unduly penalise those consumers who benefit from legitimate promotions responsibly."

  NACM fully endorses the position stated by the Minister. It is important to bear in mind that the distinction must be made and maintained to ensure that whatever means are introduced they are targeted at preventing harmful drinking without punishing the majority of people who drink responsibly. The industry is concerned that the introduction of measures that have a broader impact and go beyond targeting problem drinkers will bring with it unintended consequences.

  To this end industry has a legitimate role to play in working with Government in reaching solutions.

  NACM firmly believes that any policy considerations, by the Government, to address the specific misuse of alcohol by problem drinkers, should be:

    1. Based on robust evidence (ensuring that studies are peer reviewed) that is relevant to equivalent environments, as opposed to deploying convenient data to fit an argument.

    2. Given that the majority of the public drink sensibly and that alcohol is misused by a minority of drinkers, general population measures such as increasing taxes or other means of raising prices (curbing promotions, introducing minimum pricing etc.) are not the appropriate means for tackling misuse—it penalises the majority of sensible drinkers without necessarily dealing with alcohol misuse. People's lives are already being negatively impacted by problem drinkers and it seems ironic that this negative impact should be doubly visited upon them by having to endure restrictions, inconvenience, and ultimately higher prices, as set out in the consultation document, to deal with the problem drinkers.

    3. Dealt with, in the many instances of misuse, by better/more effective enforcement. No new legislation is required. NACM believes that the Government should focus on maximising the effective use of existing legislation to target problem drinkers and that it should avoid using one-size-fits-all measures that just punish everyone.

    4. There is a need to ensure that measures proposed do not in fact work against the Government's overarching objective of reducing alcohol related harm. (This point is elaborated further below but deals particularly with the area of advertising and promotions.)

  Below, NACM would like to comment on some specific policy areas which have been discussed recently.


  A key point that comes across in the School of Health and Related Research at Sheffield University (ScHARR) Study on "Price, Promotion and Harm" is that very little research has been conducted in the UK that throws light on individual behaviour with regard promotional activity of alcoholic drinks and harms. A significant amount of the material ScHARR draws on derives from the USA. A basic sociological critique of the ScHARR report would immediately pick up on the "situational relevance" of those studies to the UK. The USA operates different laws regarding drinking which vary from State to State, there are different sales tax regimes, the socio-ethnic and psychosocial dynamic in the USA is not replicated in the UK, etc.

  Notwithstanding these short-comings ScHARR has failed to recognise that promotional activity provides a direct and more effective way to introduce consumers to new products and product variants. Restricting promotions will inhibit new product introductions.

  The average strength of cider in the UK has reduced. There are also plans to introduce into the UK market significantly lower strength cider but before the product is put on sale more widely it is being trialed/promoted in a limited number of retail outlets. However, without the ability to promote such new products, producers will not be able to introduce them to the public at large. Of concern is that inevitably the market will stagnate and will become characterized by lower quality and cheaper products.


  Advertising is already strictly regulated. NACM does not believe that any further restrictions on advertising will address any particular misuse issues. The consequences of further restrictions will be to shut down a further avenue for bringing to market newer and better quality products.

  The Sheffield University review failed to provide compelling evidence that would warrant the Government to introduce controls on promotions and advertising. The review cited publications and references making causal links but some of these documents have not been peer reviewed. NACM reiterates its position that evidence should be robust.


  NACM is fully supportive of improved alcohol product labeling. The leading members of NACM, accounting for a significant volume of cider on the market, include on their cans and bottles:

    —  Unit information.

    —  Sensible drinking messaging.

    —  Promote "Drinkaware".

    —  And by the year end one will start to see bottles and cans carrying the "pregnancy advice information/logo".

    —  Company websites include the sensible drinking message and age restrictions to entry.

Monitoring the industry's voluntary labelling agreement

  Paragraphs 2.28 to 2.33 of "Safe, Sensible, Social—Consultation, on Further Action" address the uptake of the voluntary labelling agreement and disappointment is expressed in paragraph 2.31 that only 57% of products contained alcohol unit information and only 3% contained the labelling scheme information "in its entirety".

  It is greatly appreciated that the Department of Health, Campden and Chorleywood Food RA are working together with the industry to develop a robust and reliable set of data on this issue, compared to the misleading numbers reported. Although not part of the 1998 agreement to incorporate alcohol unit information on cans and bottles, over 65% of cider by volume is declaring its unit strength. This was in response to the commitment set out in the Social Responsibility Standards, published in November 2005, to which the NACM was a signatory.

  As mentioned above members of the NACM are introducing the labelling scheme information on bottles and cans. However, this can only be done with planned label changes over a period of time to avoid writing off (and additionally creating its own waste issues) £ms of packaging materials.

  It also has to be recognised that that not all cans and bottles are the same size and with the smaller containers there is a practical limitation to including all five components of the labelling scheme. It is the NACM's understanding from the various versions of the Memorandum of Understanding, that have been in circulation that it was acceptable for these smaller containers to only include three components of the labelling scheme. This needs to be formally recognised in any follow up "uptake audit" that will be commissioned.

  NACM is aware that the Government is holding legislation in reserve to secure a greater uptake of the labelling scheme information (suggested in paragraph 2.33). If this approach were to be actively pursued it would halt, in its tracks, any further voluntary introduction of the key components of the labelling scheme because it would introduce uncertainty as to what would be specifically required to be included on cans and bottles re exact wording, use or non use of the pregnancy logo, dimensions of characters, positioning of statements etc. The industry would not want to write off two sets of packaging. Furthermore legislation would recognise the industry's legitimate request for a period of 12 to 18 months for transition period to permit existing non complying packaging to be sold through.


  NACM was one of the first signatories to the Portman Group "Code of Practice on the Naming, Packaging and Promotion of Alcoholic Drinks" and its members fully subscribe to it. As others will also indicate the Portman Group is an excellent example of self regulation that demonstrably works which has been recognised by the Better Regulation Taskforce and the International Harm Reduction Association.

  The Better Regulation Taskforce described The Portman Group Code as a good example of a Code that works well, demonstrating how effective self-regulation can be.

  The International Harm Reduction Association included the latest edition of the Code in its "50 Best Collection on Alcohol Harm Reduction", published in May 2008 (ref IHRA.) The Collection contains project reports, documents and research papers from around the world, chosen by an international panel of experts for their evidence-base, reasoning, justification and contribution to alcohol harm reduction.

  NACM firmly believes that the Portman Group Code of Practice is fulfilling, effectively, a valuable self regulatory role with regard to the way producers package, name and market their products and as should be fully supported by Government agencies. This support should include promoting greater awareness amongst TSOs and Licensing Officers of their role with the code in ensuring compliance at local level when non-complying products are included in the Retailer Alert.


  Penalising the industry and the general population is not an appropriate way forward in either seeking to bring about the desired changes in reducing alcohol harm or dealing with alcohol misuse (the problem drinkers).

  Furthermore before any action is considered with regard to promotions and advertising it is vital that research is undertaken that is situationally relevant to the UK to avoid ill-considered policy proposals: proposals that could undermine efforts to promote a cultural change if new products are not provided a route to market.

  To restate, there are no problem drinks, only problem drinkers and therefore measures need to be targeted at these misusers. Furthermore NACM believes that the panoply of powers available to the police and local authorities should be used much more effectively both against individuals who misuse alcohol and those who willfully seek to break the law in obtaining alcohol underage, as well as against those retailers who sell alcohol irresponsibly.

March 2009

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