Sir, – The Public Health (Alcohol) Bill in its current form runs the risk of doing little to reduce alcohol misuse, while threatening the 92,000 jobs supported by the drinks industry across Ireland.
The drinks industry has acknowledged repeatedly that alcohol misuse, which manifests itself in harmful drinking, drinking to excess and underage drinking, needs to be addressed.
It is not in the best interests of the drinks industry when people misuse our product as it places a huge risk on the sustainable future of the industry. Ultimately, alcohol misuse damages our brands and our reputation.
We have shown leadership in this space and the industry’s commitment to responsible consumption regulation costs €30 million to €40 million a year beyond normal compliance costs. The industry is also subject to some of the most stringent alcohol advertising legislation in Europe, with codes drawn up with and monitored by the Department of Health.
The suggestion, then, that the drinks industry should have no role to play in the formation of public policy is biased.
The World Health Organisation outlines in its global strategy to reduce the harmful use of alcohol that appropriate engagement of civil society and economic operations is essential.
It states that economic operators in alcoholic production and trade are important players in their role as developers, producers, distributors, marketers and sellers of alcohol beverages.
In this regard, we look forward to working with Minister for Health Leo Varadkar to deliver meaningful targeted public health initiatives.
However, we do have real concerns that the content of the Bill will not meaningfully address misuse and will undermine a sector that is of great importance to the regional Irish economy and future indigenous export growth.
We welcomed the Bill putting the drinks industry’s strict advertising codes, which include banning promotional campaigns aimed at children, on a statutory footing.
However we are concerned that additional advertising restrictions on content are excessive and their effectiveness is unproven.
New product development will decrease or stop altogether, the market will simply leave this country – taking with it the most creative and well-paid jobs in the sector.
We have seen a similar scenario play out in France when it introduced a law that has led to a reduction in innovation but no reduction in misuse.
There are also omissions from the Bill that – if included – could have had an impact on the target audience.
The Alcohol Beverage Federation of Ireland has sought to work with the Department of Health to regulate online and digital marketing, a key medium when seeking to regulate advertising to under-18s and one which is ignored in this legislation.
Looking at some of the proposed measures we see examples of nanny-state thinking.
The proposals on structural separation and how alcohol is displayed in shops undermine the sensibilities of people, and what is being suggested with regard to labelling will damage producers that are trying to get a foothold in the export market.
In addition, minimum unit pricing as proposed is a blunt instrument; it does not exist in this form in any other country and all assumptions around its efficacy are therefore based on theoretical models.
Furthermore, with a question mark over concurrent implementation in Northern Ireland, any such measure will drive Irish consumers over the Border to shop.
We believe that the reintroduction of a ban on below-cost selling would be a much more effective means of ensuring alcohol is not sold as a loss-leader and would end the deep discounting that distorts the market.
Ireland already has the most expensive alcohol in the European Union and one is left wondering whether the issue of alcohol misuse would already be resolved if punishing moderate drinkers and hard-pressed consumers was the solution. – Yours, etc,
ROSS MacMATHÚNA,
Alcohol Beverage
Federation of Ireland,
IBEC,
Lower Baggot Street,
Dublin 2.