Protect public health

Introduce Minimum Unit Pricing in England following the lead of the other home nations.

Alcohol is now 60% more affordable than it was in 1980. This increasing affordability means that strong alcohol products are sold for pocket money prices: three-litre bottles of 7.5% ABV cider, containing as much alcohol as 22 shots of vodka, are on sale for just £3.59. Making alcohol less affordable is the most effective way of reducing alcohol-related harm.

A Minimum Unit Price sets a floor price below which drinks cannot be sold, based on alcohol strength. This has the effect of increasing the price of the cheapest, strongest products whilst leaving the price of most drinks unchanged. A 50p minimum unit price would mean that a drink with two units of alcohol could not be sold for under £1. This policy has already been introduced in Scotland, and is due to be introduced in Wales later in 2019.

Launch a comprehensive review of alcohol duties, in preparation for a post-Brexit taxation structure that better reflects alcohol strength across categories and addresses anomalies between categories.

The current tax system means that some products can be sold for cheaper prices than others despite being of equivalent strength. Beer and spirits must be taxed according to alcohol content but wine and cider must be taxed according to volume. This incentivises wine and cider producers to make higher-strength products, since they would have a lower rate of duty per unit of alcohol.

The Government has given its support to the principle that duty should be proportional to alcohol content, as stated in a letter from former Health Minister Lord Prior.

The duty system could also be used to reduce alcohol’s escalating affordability, and the harm this generates. Duty increases have been shown to save lives and reduce alcohol harm. The most recent analysis shows that raising alcohol duty above inflation for five successive years would reduce over 600 fatalities a year. The additional revenues provided could provide vital funds to support the NHS and alcohol treatment services.

Develop a government-funded programme of health campaigns, without industry involvement and in line with the Chief Medical Officers’ guidelines to increase public knowledge of alcohol and its links to a wide range of physical and mental health conditions.

Public knowledge of alcohol’s links to a wide range of physical and mental health conditions in the UK is worryingly low. Only one in 10 are aware of the link between alcohol and cancer and 82% do not know the current Chief Medical Officers’ (CMO) low-risk drinking guidelines of 14 units per week.

The CMO guidelines were developed based on the principle that “people have a right to accurate information and clear advice about alcohol and its health risks” and that “government has a responsibility to ensure this information is provided for the public in a clear and open way, so they can make informed choices”. It is essential that government develops a programme of health campaigns to communicate the physical and mental health impacts of alcohol to the public.

The Scottish Government launched such a campaign in March 2019, called ‘Count 14’ to raise awareness of the CMO guidelines. It included live and on-demand TV, print, radio and digital advertising, a website with interactive resources, posters in GP surgeries and pharmacies and partnership work with national companies. The UK Government should seek to run a similar campaign which covers the rest of the country. Such a programme must be government-funded and government-run as research has demonstrated that industry-funded and run health information campaigns are ineffective and may even distort evidence and present misinformation to the public. Public Health England’s 2016 evidence review examining alcohol control policies and their effectiveness noted that the “delivery of education messages by the alcohol industry has no significant public health effects”.

Develop statutory minimum requirements for labelling alcohol products. This should include health warnings, ingredients and nutritional information, alongside existing advice.

Public knowledge of alcohol’s links to a wide range of physical and mental health conditions in the UK is worryingly low. 82% of people do not know the current Chief Medical Officer’s (CMO) low-risk drinking guidelines of 14 units per week. 80% of adults in the UK do not know or underestimate the calorie content of a large glass of wine.

Since these CMO guidelines were introduced in 2016, the majority of alcohol products still display the previous guidelines, which recommend higher levels drinking to be low-risk. A recent audit of alcohol products found that only one of 315 products reviewed contained the current guidelines and none contained specific health warnings. In the UK, only the strength of the alcohol (ABV) is legally required to be displayed on products. There is no legal requirement for alcohol product labels to contain nutritional information, ingredients including allergens, or any kind of health warning.

Introduce and enforce tighter alcohol marketing restrictions and regulation, without industry involvement, with a particular emphasis on protecting young people from exposure to alcohol marketing.

Marketing of alcohol in the UK is currently handled through a non-statutory, co- and self-regulatory system. The Advertising Standards Authority (funded by the advertising industry), Ofcom, and the Portman Group (funded by the alcohol industry) lead this.

Many have criticised this system as ineffective. The House of Commons Health Select Committee concluded that there are “major shortcomings in the current self-regulatory codes covering alcohol advertising.” Further, an examination of the Portman Group’s rulings on alcohol advertising complaints from 2006-17 found that “decision-making has not been consistent over time” and that “decisions have often appeared subjective”.

Particular concerns have been raised over the self-regulatory system’s inability to protect young people. Internal marketing communications from alcohol producers and their advertising agencies which came to light during a Health Select Committee inquiry into the industry’s conduct show that young people are a target of alcohol advertising – market research data from 15-16 year-olds were shown to have been used to inform campaigns.

The failings of the current system mean that statutory regulation of this marketing is required. This regulation ought to be overseen by an independent body, separate from alcohol industry interests and influence.

Improve alcohol licensing by:

• Introducing a licensing objective to protect public health.
• Including a new mandatory licensing condition requiring alcohol retailers to have a written policy on how they will prevent illegal sales to intoxicated customers along with a specific requirement for authorities to enforce the existing law that makes such sales illegal.
• Carry out a comprehensive review of online sales and home deliveries, to prevent sales to underage, vulnerable or intoxicated customers.

Licensing is a central tool in the prevention of alcohol-related harm. The physical and temporal availability of alcohol has been demonstrated to be related to levels of a wide range of alcohol harms, including increases in mortality rates, hospital admissions and crime rates. Research from Scotland, found that rates of crime, including violence, “were consistently and significantly higher in areas with more alcohol outlets.”

Alcohol has become more available in the UK in recent years. Not only did the number of licensed premises in the UK double between the 1950s and the 21^st century – a period when the population grew by only a fifth – but the Licensing Act 2003, brought about in an attempt to create a more leisurely, café-culture of drinking, also brought significant increases in both the temporal and physical availability of alcohol in England and Wales. Home Office data shows that between 2008 and 2017 there has been a 16% increase in premises with a 24-hour license.

Despite the strong evidence body suggesting alcohol availability is linked to harms, including health harms, public health remains excluded from the list of objectives that must be met in all licensing decisions. While this has been implemented in Scotland, public health is not a licensing objective in England and Wales, meaning “current licensing legislation does not enable local authorities to take a strategic view of the total availability of alcohol when making decisions about specific proposals”.

A review of licensing legislation also ought to consider online sales, including home deliveries, to prevent sales to underage, vulnerable or intoxicated customers.

Sales to drunk customers is an issue which ought to be considered in the upcoming Government Alcohol Strategy. Off-trade (off-licences, shops and supermarkets) alcohol is increasingly more affordable than that sold in the on-trade (bars, pubs, restaurants and clubs). As this affordability gap increases, the practice of pre-loading – drinking off-trade alcohol at home or another location before moving to the on-trade – seems unlikely to decrease. A new mandatory licensing condition requiring alcohol retailers to have a written policy on how they will prevent illegal sales to intoxicated customers, along with a specific requirement for authorities to enforce the existing law that makes such sales illegal, ought to be included in any updated alcohol strategy.