Health Committee - The Government's Alcohol StrategyWritten evidence from the British Retail Consortium (GAS 14)
1.0 Introduction
1.1 The British Retail Consortium (BRC) is the trade association of the retail sector and is the authoritative voice of the industry. The BRC brings together the whole range of retailers across the UK, from independents to large multiples and department stores, selling a wide selection of products through centre of town, out of town, rural and online stores.
1.2 Our membership includes all the major food retailers, who between them account for over 90% of the UK’s grocery sales, including alcohol. Representing our role as responsible retailers we are actively involved in delivering and commenting on alcohol policy.
1.3 Alcohol sales are an important element of a supermarket’s turnover, typically about 10%, but it is not the only product we sell and we are actively involved in a wide range of public health issues such as obesity and tobacco cessation.
1.4 Our members agree with the outcomes set out in 1.6 of the alcohol strategy and have been working for a number of years to change the culture of consumption in the UK. We particularly support the comment in 5.1 that ultimately, individuals need to take control and change their behaviours. Retailers are working with their customers to help them achieve that change.
1.5 It is worth remembering that sales and consumption of alcohol from the off trade is different to the on trade. We know, for example, that the vast majority of alcohol is purchased as part of a wider shop with food and that alcohol can be bought in larger amounts for consumption over a long period or shared with others; simply offering consumers value on their purchase does not mean they will exceed sensible drinking limits, a point we reinforce through comprehensive labelling and advice.
1.6 Finally to clarify, we are retailers not health experts, which is reflected in our response and we have answered those parts of the terms of reference most relevant to us. Our overall approach, which is reflected in the submission, is we expect all policy to be based on sound evidence.
1.7 The key points in our submission are:
Retailers have a clear role, alongside other groups, in helping encourage responsible consumption.
The best way to meet the challenge is by changing our drinking culture.
The most effective way to change culture is through information and education.
The majority of our members (with the exception of Waitrose and other retailers) believe controls on pricing and promotion are not the most effective tools and can impact on responsible drinkers, who make up the vast majority of drinkers.
2.0 Retailers as Responsible Sellers
2.1 Our members recognise the responsibility which is attached to the right to sell alcohol and have been at the forefront of the delivery of policies to tackle alcohol abuse and change the culture of drinking in the UK. They are continuing to lead the alcohol industry in preventing sales to underage customers, reinforcing the Government’s health advice on recommended drinking limits and supporting the work of the Drinkaware Trust.
2.2 Our members are putting resources into these various initiatives, as we believe the best way to tackle the issue is by ensuring a permanent change in the UK’s relationship with alcohol which is only achieved by changing culture.
2.3 On underage sales, BRC members have led the industry by forming with members of the Wine and Spirit Trade Association (WSTA) and the Retail of Alcohol Standards Group (RASG) to agree common, effective methods to prevent sales. This led to the Challenge 21 and then Challenge 25 which has become established practice across the industry reduced illegal sales and changed the culture amongst younger, legal drinkers who now expect to carry ID and be challenged.
2.4 RASG also led to the development of Community Alcohol Partnerships (CAPs) which are local collaborations of retailers, police, local authorities and schools and are successfully tackling not only underage drinking but also low level disturbances.
2.5 Our members have also been extremely active, working with health departments throughout the UK to tackle health issues, reinforcing sensible drinking limits and raising awareness of the problems of excessive consumption. BRC members rolled out the UK health department’s alcohol health label on all their own brand products by the end of 2010, well in advance of the rest of the alcohol industry which is yet to complete this. They have reinforced the on pack label through dedicated in store campaigns.
2.6 We have also been the most active sector in the DH Public Health Responsibility Deal. BRC members are supporting all the relevant alcohol pledges, the continued rollout of CAPs, the health label, support for the Drinkaware Trust and most recently, contributing to the removal of 1bn units of alcohol from the market.
2.7 The continued support for the Drinkaware Trust is important to BRC members. The Trust’s work, overseen by independent experts, to target key parts of society is a key method of harnessing industry’s resources in a responsible and progressive way. Retailers make a large contribution through their promotion of campaigns in store as well as contributing financially directly to the Trust.
3.0 Who is Responsible for Alcohol Policy within Government
3.1 Our experience in recent years is an increasing focus on tighter regulation, particularly through changes to the licensing laws in the UK, and less focus on public health education. Extensive legislative time has been taken to increase penalties for illegal sales, amend the way licences are awarded, alter the hours when stores can trade and create additional taxation from alcohol sales but less emphasis to tackle individuals directly, through improved education in schools or challenging public health campaigns.
3.2 This approach was highlighted in the recent launch of the alcohol strategy. The Government chose to tailor its comments to the media on minimum pricing and promotions but there was little mention of the 1bn unit reduction which was launched the same day as a new pledge under the Responsibility Deal. It was clear the emphasis was on regulation and not the delivery of policy through voluntary initiatives.
3.3 Our members have invested resources in initiatives such as Drinkaware Trust and clear labelling as we believe helping consumers to understand drinking limits and tailor consumption accordingly is the way to change culture and achieve long term change, particularly working with the next generation of drinkers. The problem appears to be that the political expediency of being seen to do something takes precedence over a consistent public health campaign that would span several Parliaments and whose results will not be seen for a number of years.
4.0 Coordination of Alcohol Policy Across the UK
4.1 Our experience is not favourable of coordination between Governments or health departments on alcohol policy. Whilst all are actively tackling alcohol issues there are nuances in the approach which are leading to different regulations and policy across the UK and at different timescales. An inconsistent approach to regulation is challenging and burdensome for our members that operate on a UK basis.
4.2 Different approaches to regulation can prove counter-productive due to intra UK trade. Regulation on promotions in one devolved administration can lead to an increase in trade with a neighbouring country where the same regulations do not apply. Similarly, we could have the situation where countries have different levels of minimum pricing again leading to an increase in cross border trade.
4.3 We are also not convinced that all the measures are driven by evidence. Scotland, for example, introduced a Public Health Levy which was simply a tax on larger supermarkets that sell alcohol and tobacco with no justification of why it should be size limited and no plans on how the revenue would be used to improve public health.
4.4 We believe a more coordinated approach would increase the impact on consumers and by sharing resources increase the evidence base. The initiatives our members are engaged in are used throughout the UK ensuring a consistent message on health consumption and recognising consumers move around and increasingly use the internet to order goods.
5.0 The Role of the Alcohol Industry in Addressing Health Problems
5.1 Our members believe alcohol sellers have a responsibility in playing a full role in helping customers make healthier choices. This involves clear information on units of alcohol linked to official drinking guidelines, the promotion of a range of alternative alcohol and non alcoholic drinks and contributing towards targeted education campaigns through Drinkaware. Retailers are not, however, the only ones who can drive change, that will also depend on the role of Government, other parts of the alcohol industry and importantly individuals, taking responsibility for their own drinking and the role they have in influencing others.
5.2 The Responsibility Deal has given an increased emphasis to the role industry can play and brought a wider section of the industry together to work collaboratively. We have been disappointed that some health groups have chosen not to engage with the process, our belief is there was a poor understanding of what could and could not be delivered through it and that public health initiatives must be given time to work. We feel, however, the change of emphasis in the alcohol strategy towards regulation on how alcohol can be sold and promoted severely restricts the opportunity for further pledges from the retail sector.
5.3 Generally our view is there has been a good improvement in collaboration throughout the alcohol industry in recent years to tackle alcohol issues. This is demonstrated by the wide membership of the Responsibility Deal and the support for the Portman Code and the work of the Drinkaware Trust.
6.0 The Evidence Base for Introducing a Minimum Price per Unit of 40p
6.1 The majority of our members (with the exception of Tesco, Co-op, Waitrose and Spar) oppose the introduction of minimum pricing believing the more effective method is to change the culture of drinking through information and education, which would avoid penalising the vast majority of the population who drink within the Government’s health guidelines. Those other members listed above would be prepared to consider minimum pricing, alongside other measures if there was evidence to support its use.
6.2 Minimum pricing could also lead to a shift in product choice. For example, it could have a significant impact on own brand products which could be removed from the market as they would be uncompetitive against established branded products. This reduces competition, affects own brand producers and less consumer choice.
6.3 We believe clear information for consumers, combined with proven, targeted campaigns aimed at parents and drinkers will change the culture of alcohol. We acknowledge that consumption levels have been high but are encouraged that the trend in recent years is for falling consumption generally and a reduction in those exceeding health guidelines. We believe this trend will continue as education continues, particularly with parents and children, where the data on later take up and lower consumption of alcohol by children is encouraging.
6.4 The General Lifestyle Survey 2010 published this March provides evidence of the small but steady decline in consumption and also reinforces the point that the vast majority of the population, who already drink responsibly would be penalised by a minimum price. It showed only 17% of women (21% in 2005) and 26% of men (31% in 2005) reported drinking more than the weekly guidelines of 14 units for women and 21 for men. This means the vast majority of the population drink within weekly guideline limits.
6.5 The Lifestyle Survey also suggests that a minimum price would have little impact in tackling the problem of excessive consumption amongst higher income consumers. The group comprising managerial and professional households reported more frequent and heavier consumption than those in the manual household group. We know the “hidden drinker” is a major concern, but we believe this group would be much less susceptible to the impact of minimum pricing.
7.0 The Effects of Marketing on Alcohol Consumption, in Particular in Relation to Children and Young People
7.1 Our members’ marketing of alcohol is aimed at adult consumers who, in almost all cases, buy alcohol alongside other grocery items. Whilst we accept that marketing is designed to increase purchases it is not designed to increase consumption, as it can be purchased over a long period and shared with friends within responsible drinking guidelines. It is also factual, giving information on prices and offers, in no way designed to be attractive to children.
7.2 All our members are supporters of the Portman Code which ensures that in store promotion of products themselves is not inappropriate and could appeal to children and will remove products where they are found to be in breach of the Code.
8.0 Public Health Interventions such as Education and Information
8.1 Our members support the use of education and information, both to help existing drinkers consume responsibly and also to influence the approach of the next generation of drinkers. As well as making clear information available on sensible drinking limits our members have given support to the independent Drinkaware Trust to develop targeted campaigns. Our members have ensured the Trust’s campaigns are effective and impactful and believe continuing support will drive cultural change.
8.2 We believe it is important to ensure consistent messaging on drinking is given through all available routes to reinforce them. For example, universal use of the DH health label, on all products and in the on trade will drive home the need to understand the units in different drinks and sensible consumption limits, in a similar way to the Challenge 25 campaign which is so effective in preventing underage sales.
8.3 We also believe there is a responsibility on Government to consider its role in education and challenging parents to ensure children are not exposed to irresponsible behaviour and are introduced to alcohol in a responsible manner.
9.0 Reducing the Strength of Alcoholic Beverages
9.1 Our members fully support the Responsibility Deal pledge on reducing the units of alcohol in the market by 1bn by reducing the strengths of their own brand products and promoting lower strength branded products. We believe the wider availability of lower strength products and a reduction in the strength of well known brands will help consumers subtly reduce their consumption without them noticing the difference.
9.2 We are already seeing an increase in sales of lower strength products and expect this trend to continue as members support the Responsibility Deal pledge.
10.0 Raising the Legal Drinking Age
10.1 We don’t believe a change is necessary and believe consistent messages on consumption by younger people would be a more effective target. Retailers have successfully driven down sales to underage customers through the Challenge 25 policy. We know, however, from research that parents and older peers continue to supply alcohol to younger people and feel there should be more attention on the irresponsibility of proxy buying and more pressure on parents to ensure they are not ignoring advice on sensible consumption by young people.
11.0 Plain Packaging and Marketing Bans
11.1 We do not support plain packaging and have concerns this could lead to an increase in fraud. We feel a better answer is to ensure all alcohol products, wherever they are sold, have the full DH health label to reinforce unit awareness and sensible drinking limits.
11.2 We do not support marketing bans as our members simply use these to give consumers information on pricing and promotions which may drive purchasing patterns but are not proven to drive excessive consumption.
May 2012