Why the secrecy? Bringing transparency to alcohol labelling

On 25 June the All-Party Parliamentary Group (APPG) on Alcohol Harm (for which we provide the secretariat – find out more here) hosted a meeting on the topic of alcohol labelling.

Labels on food, drinks and other products are important. They are how we find out about ingredients, about what we’re bringing into our homes or putting into our bodies. They help us make decisions about which products to buy, and how to use them. As such, UK and EU law dictates that we have detailed information on products of all types, especially food and drink.

You might expect that alcohol, as a product which can seriously harm health, would be subject to even stricter rules, Yet, as it stands, in the UK there are no requirements for any of the following information to be included on alcohol labels:

The only legally-required information is the percentage ABV (alcohol by volume) and a few other pieces of factual information such as the country of origin and the volume in cl or ml.

In January 2016 the UK’s Chief Medical Officers – the top doctors – published new low-risk drinking guidelines based on the latest evidence. Yet at the time of writing, more than two and a half years later, only a vanishingly small minority of alcohol labels show these guidelines. Worse, an Alcohol Health Alliance survey of 320 products found that two-thirds of labels still display the old guidelines, which indicate a weekly maximum that is more than 14 units – in some cases double that. The impact of withholding this information from consumers is clear; only 16% of the public are aware of the guidelines, meaning that the vast majority do not have the information they need to make informed choices around their drinking.

At the APPG speakers drew attention to the fact that unit information – which is currently displayed on alcohol packaging - only makes sense to consumers if they are made aware of the low-risk drinking guidelines. Without these, it is an out of context number that is either useless or, in the case of outdated guidance being given, misleading.

The current system of alcohol labelling regulation is self-regulatory and voluntary. It is this system that, many speakers said, is at the heart of many problems with alcohol labelling. The Portman Group, the industry-funded body which regulates alcohol labelling, issues guidance which recommends that labels also include units per container, a pregnancy warning icon, and signposting to drinkaware.co.uk. Speakers at the APPG argued that this is insufficient – but even this low bar is not being met, because none of these recommendations are mandatory. Units per container in particular are not found on the majority of alcohol labels.

At the APPG speakers and the audience were asked to consider three key questions: do citizens need alcohol labelling to improve? Do we want it to improve? And is it possible for it to improve?

Dr Mark Egan from the Behavioural Insights Team, an organisation which uses behavioural insights to inform policy and improve public services, opened the event. He discussed the team’s online experiment which tested six label designs against the industry standard to see whether different design approaches could better communicate the low-risk drinking guidelines. They found that using pictographs was best at helping consumers estimate most accurately how many servings of alcohol they could have before they reached the 14-unit weekly limit. This would show, for example, six wine glass symbols to represent the number of glasses you could have in a week, with one of the glass symbols shaded, to represent how much one serving equals. This research forms part of a larger report which will be published by the Behavioural Insights Team and Public Health England later this year.

Next, Ed Morrow spoke about the Royal Society of Public Health’s report, Labelling the Point, which demonstrates consumer desire for better information on alcohol labels. Consumers were clear that they did not want to refer to information online – they wanted it on the bottle. The report found that including calorie information on labels alongside ABV significantly reduced the proportion of people saying they would choose a higher ABV drink.

Aleksandra Kaczmarek from Eurocare spoke about the EU context. Eurocare is an alliance of public health organisations advocating for the prevention and reduction of alcohol-related harm in Europe. She explained that legislation on ingredients and nutritional information is harmonised across EU member states under Reg (EU) no 1169/2011, meaning that in theory individual governments cannot make it mandatory to include this information on product labels, although there is nothing to stop the industry from voluntarily including it. However, the picture is more complicated than that.

It was long thought that ingredients and nutritional information could not be made compulsory on alcohol labels. But in 2016 the Irish government proposed a bill which did just this. Since then, there has been a great deal of back and forth between the European Commission and various alcohol producers on whether this is allowed. In March 2017 the European Commission published a report stating that no objective grounds were identified which would justify the absence of information on ingredients and nutritional information on alcoholic beverages. In March 2018 the industry proposed a self-regulatory system, which includes making the information available online. However, Kaczmarek was clear that this would not be in consumers’ best interests as 66% of consumers never or rarely go online to look for ingredients and nutritional information. The European Commission is currently assessing the proposal before responding.

The above is all true for ingredients and nutritional information. But health information – for example, pregnancy warnings and CMO guidelines – is controlled by national governments, and so could be made mandatory by any EU country. Only political will is required to do so. France has already made pregnancy warnings mandatory in 2007. This means that, regardless of the situation with the UK’s exit from the European Union, the UK government are able to take steps towards making the inclusion of accurate, transparent information on alcohol labels compulsory.

Finally, Prof. Alan Tapp, Professor of Marketing at the Bristol Social Marketing Centre, discussed current alcohol marketing regulation in the UK. You can find out more about alcohol marketing here. While labelling and marketing are not one and the same, they are closely connected. UK alcohol marketing regulation specifies what marketing cannot say and do; for example, it cannot appeal directly to children. But Prof. Tapp said that this simply creates obstacles for marketing firms and alcohol producers to dodge. There are other models that provide greater protection for consumers; for example the French model, known as the Loi Evin, which specifies what alcohol marketing can say, rather than what it can’t. Other models include performance-based regulation which would set a target outcome for alcohol producers, for example to reduce underage drinking by a certain percentage.

The meeting was an opportunity for people working across the alcohol harm reduction sector to come together with Parliamentarians to discuss the potential for a better future for alcohol labelling which would help to reduce alcohol harm. There’s real energy around this at the moment, partly because of BBC Panorama’s recent, excellent programme looking at drinking in the UK, in which Adrian Chiles explores labelling, in addition to other methods of reducing alcohol harm, such as minimum unit pricing.

It’s time for fair, transparent alcohol labelling in the UK. Coming up in September 2019 is the alcohol industry’s deadline for including the up-to-date drinking guidelines on their labels. It remains unclear whether this deadline will be met; we hope so. If not, it is vital that the if the regulatory system is reviewed and reformed. As Chiles said on Panorama: “It doesn’t seem a lot to ask for the alcohol industry to meet its own commitments when it comes to labelling, and if they don’t for the government to lay the law down to force them to do it.”