Health Committee - The Government's Alcohol StrategyWritten evidence from Heineken (GAS 12)

Summary

HEINEKEN is the UK’s leading beer and cider producer and the name behind drinks brands such as Foster’s, Strongbow, Kronenbourg 1664, Bulmers, John Smith’s and Heineken®. We also own circa 1,400 pubs and directly employ 2,400 people in our UK business, operating from sites in London, Edinburgh, Manchester, Tadcaster and Herefordshire.

As a responsible alcohol producer, Heineken believes it has an important role to play in tackling alcohol misuse and encouraging people to drink responsibly. We want our products to be made, sold and enjoyed responsibly.

Alcohol consumption in the UK has declined in recent years and the majority of people drink responsibly. Alcohol policy should be targeted at the minority who misuse alcohol.

Alcohol-related policy measures should be necessary, evidence-based and proportionate.

We believe that the most effective way to promote responsible drinking is not through Government action in isolation but through a partnership approach involving Government, industry and NGOs. Industry has a role to play in this as it can reach consumers in ways that the Government cannot.

Our commitment to working with Government and NGOs can be demonstrated though the pledges we made under the Public Health Responsibility Deal. This includes our individual commitments to:

remove 100 million units from the market each year from 2013 by lowering the abv of a major brand ; and

improve unit awareness by introducing 11 million unit labelled glasses into the on trade.

There is no evidence that minimum unit pricing will reduce alcohol misuse. It will affect all consumers regardless of whether they contribute to alcohol harm.

There is uncertainty on the legality of minimum pricing and whether the policy will be implemented. We agree with the Government’s view that there is not any evidence to suggest a ban on alcohol advertising would be a proportionate response.

We welcome the Government’s intention to look at the current barriers to promoting low strength products.

1. Introduction

1.1. HEINEKEN welcomes the opportunity to respond to this call for evidence.

1.2. HEINEKEN is the UK’s leading beer and cider producer and the name behind drinks brands such as Foster’s, Strongbow, Kronenbourg 1664, Bulmers, John Smith’s and Heineken®. We also own circa 1,400 pubs and directly employ 2,400 people in our UK business, operating from sites in London, Edinburgh, Manchester, Tadcaster and Herefordshire.

2. General Comments

2.1. We recognise the need to tackle alcohol misuse. We also believe that moderate alcohol consumption can be part of a healthy lifestyle. Recent Government data shows that:

UK Consumption has fallen in recent years. HMRC duty clearance data show that consumption per head has fallen by 13% since 2004. The ONS General Lifestyle Survey shows that average consumption in the UK has fallen by 20% between 2005 and 2010.

Binge drinking continues to decline. The ONS General Lifestyle Survey shows that the proportion of men drinking more than 8 units on their heaviest drinking day in a week fell from 23% in 2005 to 19% in 2010. Women drinking more than 6 units were 15% in 2005 and 13% in 2010.

2.2. We believe that alcohol misuse is a complex set of issues, not one single problem, that should be tackled by targeting at the groups of problem drinkers—be it underage drinking, town centre disorder or chronic alcohol misuse.

3. Responsibility within Government for Alcohol Policy

3.1. The question of which Government Department should have responsibility for alcohol policy is not a matter for industry. Different Departments will necessarily have responsibilities for different elements of alcohol policy and the alcohol industry. However, it is important that Government policy is proportionate and based a strong, robust evidence base.

4. The Coordination of Alcohol Policy Across the UK

4.1. We are a UK wide business and as far as possible it is preferable and more efficient to work within a UK wide regulatory framework.

5. The Alcohol Industry’s Role in Addressing Alcohol-Related Health Problems

5.1. As a responsible alcohol producer, Heineken believes it has an important role to play in tackling alcohol misuse and encouraging people to drink responsibly. We want our products to be made, sold and enjoyed responsibly.

5.2. We believe that the most effective way to promote responsible drinking is not through Government action in isolation but through a partnership approach involving government, industry and NGOs.

5.3. Industry has much to contribute to such a partnership as it can reach consumers in ways which government cannot. For example:

Following HEINEKEN’s takeover of Scottish and Newcastle, one of the first things we did was delist White Lightening in March 2010. We followed this by delisting Strongbow Black in November 2010.

5.4. HEINEKEN has been an active partner in the Responsibility Deal and has signed up to all of the alcohol pledges. The full list of general Responsibility Deal pledges can be found here (http://responsibilitydeal.dh.gov.uk/pledges/). Some highlights include:

Encouraging better consumer education of the harms of alcohol by (i) supporting Drinkaware and (ii) providing information on unit labelling alongside the CMO guidance on alcohol consumption on our packaging;

Supporting local authority partnerships with the policy, local agencies and retailers by providing £150 million to Best Bar None and £70 million to Community Alcohol Partnerships; and

On alcohol advertising near schools, HEINEKEN goes further than the Responsibility Deal pledge and work with our agencies to ensure that no advertisement for our brands is placed within 200 metres of a school.

5.5. In addition to the general alcohol pledges that the alcohol industry made as part of the Responsibility Deal. HEINEKEN made two further pledges as an individual business:

Remove 100 million units of alcohol from the UK market each year through lowering the abv of a major brand by 2013.

Improving unit awareness amongst UK consumers by providing 11 million unit labelled glasses to the on trade.

6. Minimum Unit Pricing

6.1. HEINEKEN is opposed to a policy of minimum unit pricing both in principle and in practice.

6.2. There is no evidence that minimum pricing will reduce harmful drinking—It assumes a link between price and reducing harm that is not supported by the evidence:

Since 2004, there has been a 13% reduction in alcohol consumption in the UK, but no decrease in alcohol harm or alcohol related hospital admissions. If getting the whole population to drink less worked as a theory, we should be seeing the benefits now.

At an evidence hearing to the Health Select Committee on 17 April 2012, Dr John Holmes of the Sheffield Alcohol Research Group said “... young binge drinkers do not buy as much cheap alcohol as older people simply because they tend to drink more of their alcohol in the on trade, which is largely not sold at prices which will be affected by this policy”.

6.3. Minimum pricing affects everyone—Evidence suggests that the heaviest and most harmful drinkers are the least responsive to price changes. This means that higher prices will penalise moderate drinkers whilst having little impact on those whose behaviour we want to change- harmful drinkers. Minimum pricing is also regressive, hitting those on lowest incomes the hardest and assumes that higher price alcohol is not misused.

6.4. Minimum pricing will have an impact on UK investment and employment—There is uncertainty on the legality of minimum pricing and whether the policy will be implemented. This will have a significant impact on investment decisions in the UK market. By announcing minimum pricing without definitive legal advice, the Government has put the industry in a position of uncertainty. This uncertainty will have an impact on investment decisions in the UK market.

6.5. The brands most likely to be affected will be domestically produced beers and ciders—which are more likely to be sold in the UK market. As a business we tend to only import premium products which attract a premium price. Domestically produced products support more jobs but are more reliant on UK demand and investment.

6.6. We believe Government should focus on targeted interventions for different types of alcohol misuse, be that under-age drinking, town centre disorder or long-term chronic drinking. Each problem is different and therefore the solution is different.

7. The Effects of Marketing on Alcohol Consumption

7.1. We agree with the Government’s view that there is not any evidence to suggest a ban on alcohol advertising would be a proportionate response.

7.2. The UK already has some of the strictest restrictions on alcohol advertising and marketing in the world. The industry’s self–regulation through the Portman Group Code of Practice on the Naming, Packaging and Promotion of Alcoholic Drinks works to ensure that products do not encourage irresponsible consumption or appeal to children. Alongside this, the Advertising Standards Authority enforces strict standards in all “paid for” space such as television and radio.

8. Education and Information

8.1. We believe that better education to help people make sensible choices about their consumption is very important. In recent years there have been concerted alcohol education and information campaigns by government, industry and NGOs and evidence suggests this is having an impact. HEINEKEN has played a part of this by:

Providing support to Drinkaware, the alcohol education charity. This includes financial support and support in kind by including Drinkaware branding on our packaging, print advertising and TV end frame advertising.

Providing unit-labelled packaging for our brands and supplying 11 million unit-labelled glasses to our on-trade customers.

Integrated responsible drinking campaign as part of our sponsorship of the John Smith’s Grand National.

8.2. Recent cases studies show that consumer education is an effective measure.

8.3. The Drinkaware “Why let the Good Times Go Bad” campaign challenges the acceptability and desirability of drunkenness among young adults. Independent research among 18–24 year olds shows that after seeing the Drinkaware “Why let good times go bad?” campaign, 56% claimed it made them consider drinking differently and 80% claimed to have adopted at least one of the campaign’s tips to help them moderate their drinking.

9. Reducing the abv of Alcoholic Beverages

9.1. HEINEKEN was the first company, in 2011, to make a public pledge to remove 100 million units of alcohol from the UK market each year through lowering the abv of a major brand by 2013 as part of the Responsibility Deal.

9.2. We have also worked with the industry on the collective Responsibility Deal pledge announced in March by the whole alcohol industry to remove more than 1 billion units of alcohol by 2015.

9.3. We welcome the statement in the alcohol strategy that the Government will work with the Advertising Standards Authority and other bodies to look at the rules and incentives that inhibit the development of lower strength products.

Plain packaging

9.4. The Government is currently consulting on the issue of plain packaging for tobacco. To consider this in relation to alcohol products therefore effectively equates drinking with smoking, which we utterly reject. Smoking is harmful in any quantity, whereas moderate alcohol consumption can be part of a healthy lifestyle.

May 2012