Health Committee - The Government's Alcohol StrategyWritten evidence from Greene King (GAS 57)


Greene King, one of the UK’s largest pub retailers and largest brewer of cask ale, is generally supportive of the Government’s Alcohol Strategy. In particular, we support the intention to implement a Minimum Unit Price (MUP) for alcohol as we believe it is the most effective form of direct intervention for reducing the rising incidence of alcohol related problems in the UK.

However, we are concerned that a number of important stakeholders, including Government and the media, fail to recognise that there are different types of alcohol and alcohol drinking behaviour.

It is important to understand exactly what type of alcohol is being drunk, where it is being drunk, how it is being drunk and by whom. Alcohol is not a single product, different types of alcohol have different effects on society and this should be reflected in policy. We have seen significant changes in the nation’s drinking behaviour in the last 30 years and we believe that this should be reflected in government policy going forward.


1. Greene King is one of the UK’s largest pub retailers and brewers. It operates c. 2,400 pubs, restaurants and hotels across England, Wales and Scotland, which include Hungry Horse, Old English Inns, Loch Fyne Restaurants and Eating Inn. Greene King also brews Greene King IPA, the no.1 cask ale in the UK, Old Speckled Hen, the no.1 premium ale in the UK, Abbot Ale, the no.1 premium cask ale in the UK and Belhaven Best, the no.1 ale brand in Scotland. The brewer has operated from its Bury St Edmunds base since 1799.

2. Greene King welcomes the Health Committee’s Inquiry into the Government’s Alcohol Strategy. We also welcome the Coalition Government’s plans to introduce minimum unit pricing (MUP), with a commitment to consult on the most effective price level for MUP.

3. As a brewer and pub operator, we have long called for MUP as one of the most effective and targeted measures in the fight to tackle the growing health and societal problems of binge drinking and related anti-social behaviour. Alcohol pricing and availability are key to this abuse, which is carried out by a minority of people, fuelled by the easy availability of alcohol from retail outlets, often at very cheap prices.

4. We are committed to supporting the Government’s policy unit team in its work to define the appropriate level per unit and the mechanism for determining any future level. It is our view that 40 pence per unit is too low a level to have enough of an impact on public health. We favour the 45–50 pence per unit as favoured by the Scottish Government.

5. Greene King believes that MUP alone cannot deliver the desired societal and health improvements and that MUP should be introduced alongside other supportive measures including restrictions on the availability of alcohol in unsupervised environments and specific restrictions on promotions, alcohol displays, time of sale and better health education. We believe that the Government should work with the industry, health groups and other stakeholders to develop an effective code on these measures to tackle the problem.

Establishing who is responsible within Government for alcohol policy in general, policy coordination across Whitehall and the extent to which the Department of Health should take a leading role

6. With the growing impact of alcohol misuse being felt across society, it is logical that all Government departments should be involved in shaping and implementing alcohol policy. We believe that the initiative should be co-ordinated and led by a single Department and that that Department should be the Home Office.

The issue about alcohol is misuse and not use, and as a responsible brewer of beer and retailer of alcohol, we have concerns that this key distinction could get blurred under a different Government Department lead.

Given the Coalition’s commitment to a more joined-up Government, we believe that a working party of senior officials should be convened from across Government departments, led and co-ordinated by the Home Office. This is not just an issue for the Department of Health; we see areas of compatibility with HM Treasury, and the Departments for Education, Communities, Business, Culture and other areas of Government.

Coordination of policy across the UK with the devolved administrations, and the impact of pursuing different approaches to alcohol

7. We welcome a standard MUP across the UK so that brewers, retailers and consumers have a clear understanding of pricing and the purpose underpinning the policy.

Different levels would be potentially divisive, confusing to consumers and would potentially cause domestic “booze cruises” across UK national borders. This problem already exists in the USA, where excise duty varies across state lines.

Government would also have to police illegal cross-border activity. If HMRC is concerned that above 40 pence per unit it would lose duty revenue, it should consider the wider costs to government of not having an effective MUP for alcohol and net those off.

The role of the alcohol industry in addressing alcohol-related health problems, including the Responsibility Deal, Drinkaware and the role of the Portman Group

8. Greene King actively supports the Public Health Responsibility Deal and is pleased to report good progress on a number of pledges since it was launched last year. We also support the role of the Portman Group. Overall, we believe industry does have an important role to play in addressing alcohol-related illness and disorder.

9. As part of our own efforts to affect behaviour, Greene King has created Enjoy Responsibly, a website that provides practical information and advice on responsible drinking. The site looks at issues around alcohol, including how alcohol affects your health and alcohol and the law, as well as resources such as a unit calculator and links to local support services.

10. Responsible drinking must become more than “just a slogan” and ideally, as in parts of continental Europe, be repositioned as part of an overall social and dining experience.

11. The shift in consumption to stronger wines, spirits and ciders, increasingly consumed at home, continues to compound the UK’s alcohol-related problems. Though any solution must be effective in curbing irresponsible consumers and retailers, we believe it should be structured and targeted so that it does not penalise the vast majority who drink responsibly and who view alcohol as a welcome part of their socialising with friends and family.

12. We believe that MUP, rather than further penal duty increases, would go a long way to addressing this problem. We believe the price should be set at a meaningful level and should be introduced alongside other measures to restrict the availability and limit the promotion of alcohol in certain channels. We would also like to see extra funding to improve the culture of alcohol consumption in the UK, with the intention of reducing alcohol-related crime and illness.

The evidence base for, and economic impact of, introducing a fixed price per unit of alcohol of 40p, including the impacts on moderate and harmful drinkers; evidence/arguments for setting a different unit price; the legal complexities of introducing fixed pricing

13. Like both the Scottish and UK Governments, we refer to the limited evidence from countries such as Canada and theoretical studies from bodies such as the University of Sheffield and the IFS. The Government has to set an MUP that positively impacts on the public health without meaningfully distorting the market in order not to fall foul of competition law. We believe this is achievable at 45–50p.

The effects of marketing on alcohol consumption, in particular in relation to children and young people

14. The Government has already banned the advertising of alcohol on sites close to schools. We endorse and support this policy. However, as a commercial business, Greene King would be opposed to banning of alcohol marketing outside our pubs or restaurants, as that would be anti-competitive.

15. Where bans have occurred in other countries, it is the incumbent producers who benefit most as it creates a barrier to entry into the market. We don’t believe the marketing of alcohol affects how much is drunk, rather which brands are drunk.

The impact that current levels of alcohol consumption will have on the public’s health in the longer term

16. Whilst overall alcohol consumption has fallen recently, it is still at a very high level by historical standards. Combined with this is the fact that alcohol misuse is having an increasingly detrimental effect on public health. There appears to be a strong correlation between the increase in alcohol related harm and the shift in consumption away from beer to higher abv drinks such as cider, wine and spirits.

More needs to be done to combat the increasing prevalence of consumption of higher abv drinks, primarily purchased from the off-trade, in order to curb the growing public health problem related to alcohol.

17. The problems affecting the public’s health in the longer term, given the current levels of alcohol consumption, are significantly about the type of alcohol consumed; where it is consumed, and by whom it is consumed. Each year, the statistics around public health worsen in relation to alcohol misuse, despite the fact that consumption of beer is decreasing. In fact the entire decline in alcohol consumption in the last ten years consisted of beer.

18. Beer is already heavily taxed. However, Government income from beer duty has risen by just 1% per annum since 2006, with volume sales declining almost in parallel to duty increases. By further pushing up the minimum price per unit of alcohol through a statutory minimum price and by switching duty from beer to cider, wine and spirits, the higher ABV alcohol products, the government would be financially better off whilst also tackling irresponsible consumption of alcohol.

19. The combination of a MUP and duty transfer would encourage a switch in purchasing and consumption from the unregulated off-trade to the highly regulated on-trade, and from higher abv cider, wines and spirits to lower abv beer.

Both trends would help to address the impact of binge drinking and would materially lower the cost to government particularly in relation to the current excessive NHS and Policing costs, from alcohol related harm and disorder. These trends would also increase overall VAT receipts for government.

International evidence of the most effective interventions for reducing consumption of alcohol and evidence of any successful programmes to reduce harmful drinking, such as:
Public health interventions such as education and information

20. As in other walks of life, we believe that “prevention” is better than cure. Greene King would like to see the introduction of Alcohol education in all UK schools as a fundamental part of the curriculum alongside other forms of personal, social and health education. We understand that there is a large burden on the various curricula of the UK; however, the statistics around under-age drinking show that action is required and that alcohol education should be a fundamental national concern.

21. We would draw the Committee’s attention to the WHO report Global Status Report on Alcohol and Health 2011

22. The Global status report on alcohol and health (2011) is a comprehensive perspective on the global, regional and country consumption of alcohol, patterns of drinking, health consequences and policy responses in Member States. It represents a continuing effort by the World Health Organisation (WHO) to support Member States in collecting information in order to assist them in their efforts to reduce the harmful use of alcohol, and its health and social consequences.

23. Greene King has created an alcohol-support education website, Enjoy Responsibly:

Reducing the strength of alcoholic beverages

24. Greene King was keen to see the Government reduce duty on below 2.8% ABV products and in response to that move, we launched, in September 2011, Tolly English Ale as our brand in this new category. We have been pleased with the performance of the brand so far.

Raising the legal drinking age

25. The current legal drinking age in the UK is appropriate. However, young people need better advice from Government and industry sources on the effects of alcohol on young people which can be more detrimental than on adults.

May 2012

Prepared 21st July 2012