Consultation on Restricting Alcohol Advertising and Promotion: Analysis of responses

14 Other issues (Q38–Q41)

14.1 Section 14 in the consultation paper addressed a number of overarching issues related to the possible introduction of restrictions on alcohol marketing. It included four questions. Two questions invited views on whether a comprehensive package of restrictions covering multiple media streams should be introduced and whether restrictions on any other marketing methods or channels (other than those covered in the consultation paper) should be considered. The other two questions in this section asked about evidence and impacts on the alcohol industry in relation to restrictions on marketing.

Question 38: Do you think the Scottish Government should look to introduce a comprehensive package of restrictions across a number of marketing channels? If so, what do you think this package should include? [Yes / No / Don't know]

Question 39: What, if any, additional alcohol marketing methods or channels not covered in the consultation would you like Scottish Government to consider restricting and why?

Question 40: What further evidence on alcohol marketing would you like the Scottish Government to consider?

Question 41: If you sell, distribute, advertise or manufacture alcohol, or represent those who do, how do you think the potential restrictions in this consultation paper would impact you, and the wider alcohol sector?

A comprehensive package of restrictions (Q38)

14.2 The Scottish Government's consultation paper put forward a range of possible options for restricting the marketing of alcohol in Scotland. Each option was considered on an individual basis. However, the consultation paper recognised the often multistranded nature of alcohol marketing campaigns, the cumulative effect of marketing across multiple channels and the potential overlap between individual restrictions. Given this context, Question 38 invited views on whether the Scottish Government should aim to introduce a comprehensive package of restrictions that would apply across multiple marketing channels. Table 14.1 shows the following:

• Overall, around a fifth of respondents (19%) thought the Scottish Government should introduce a comprehensive package of restrictions across a number of marketing channels, while three-quarters (77%) thought it should not. The remaining 4% selected 'don't know'.
• Levels of agreement with the proposition were higher among organisations (24%) than individuals (18%). Levels of disagreement with the proposition were lower for organisations (73%) than individuals (78%).
• All public health and third sector organisations (100%) agreed that the Scottish Government should introduce a comprehensive package of restrictions across a number of marketing channels. By contrast, almost all alcohol producers and retail and hospitality organisations (98% in both cases) disagreed with this approach. A large majority of advertising and media organisations (89%) and events and sporting organisations (78%) also disagreed. Among other organisation types, 45% agreed with the suggested approach and 55% disagreed.

Percentages may not total 100% due to rounding.

14.3 In addition, 428 CAMRA 1 campaign respondents and 90 CAMRA 2 campaign respondents indicated that they did not support the introduction of a comprehensive package of restrictions across a number of marketing channels.

14.4 In general, respondents used this question to reprise the views they had expressed at earlier consultation questions. Public health and third sector organisations, a range of respondents in the 'other organisation types' category (mainly academic organisations, local authorities and some public bodies), and around one in five individuals were in favour of introducing a comprehensive package of restrictions across a number of marketing channels. By contrast, all other organisation types and a large majority of individuals were not.

14.5 The views of both these groups are briefly summarised below. This is followed by a summary of the alternative approaches suggested by respondents who were opposed to further restrictions on alcohol advertising. For ease of reference, suggestions of alternative approaches made in relation to other consultation questions are also included here.

Support for a comprehensive package of restrictions

14.6 The main arguments in support of a comprehensive package of restrictions were that:

• The introduction of a comprehensive package of restrictions was the best way to achieve a reduction in the harm caused by alcohol. Respondents who favoured this approach repeatedly said that this is the view of both the World Health Organization and the Alcohol Marketing Expert Network. Respondents noted that a comprehensive approach would require a coordinated UK-wide approach, and they encouraged the Scottish Government to put pressure on the UK Government (and internationally) in this regard.
• Restrictions would be more effective, and easier to implement and enforce, if they were introduced on a comprehensive – and statutory – basis. Respondents said that piecemeal restrictions did not work, and any loopholes or inconsistencies would be exploited by the alcohol industry. More specifically, respondents said that the existing codes of conduct were often under-interpreted and under-enforced, and regularly violated. They often drew parallels with the tobacco industry in this regard and argued that it was the comprehensive nature of the statutory restrictions introduced that had underpinned the success of the efforts to reduce smoking.
• There was widespread public support for a comprehensive approach. Respondents said this was supported by the general public, by children and young people, by those in recovery, and by all those who were considered to be vulnerable. This was also consistent with taking a human rights approach to the issue.
• Any economic costs in terms of job losses resulting from additional restrictions on alcohol advertising would be offset by decreases in health care costs, and a healthier and more productive workforce.

14.7 Respondents in favour of a comprehensive package of restrictions on alcohol marketing confirmed that this should cover all the channels discussed in the consultation paper. Restrictions should also be regularly reviewed to ensure that they kept abreast of developments in marketing technology and the importance of social media influencers.

Opposition to a comprehensive package of restrictions

14.8 The main arguments given by respondents opposed to a comprehensive package of restrictions were that:

• Advertising and marketing of products by the alcohol industry are not the root cause of alcohol harm, and the imposition of marketing and advertising restrictions will therefore not do anything to reduce alcohol harm. Most people drink responsibly, and it is therefore not appropriate to introduce such widespread restrictions. The Scottish Government should instead focus on educational approaches (at both community and national level) and on promoting cultural change.
• The Scottish Government does not have powers to legislate for restrictions in other parts of the UK or further afield. Any restrictions covering Scotland only will distort markets, cause displacement of marketing activity, and put drinks producers in Scotland at a competitive disadvantage.
• The existing system of self-regulation, based on voluntary codes of conduct, works well and is effective. In particular, the current system of self-regulation ensures that advertisers are subject to standards which aim to prevent children and young people from being targeted by alcohol marketing and advertising. A comprehensive package of restrictions is therefore not necessary and is disproportionate and heavy handed.
• There are many direct and indirect benefits to Scotland associated with the alcohol industry. Respondents said the consultation document does not provide a balanced view in this regard. No economic assessment had been provided – this would be expected to highlight that the benefits of introducing comprehensive restrictions would be outweighed by the costs. Respondents repeatedly emphasised that the introduction of a comprehensive package of restrictions would be deeply damaging to businesses, especially those in rural areas, and to SMEs, and that there would be unintended consequences for the food and drink sector and other sectors (music, sport, advertising, etc.).

Alternative approaches

14.9 Respondents who opposed the introduction of (further) restrictions on alcohol advertising often suggested that there are alternative – better, more cost-effective – ways of approaching the issue of reducing alcohol harms in Scotland.

14.10 The main suggestions were to:

• Introduce targeted restrictions with the aim of reducing exposure to alcohol marketing among under-18s.
• Undertake a full review of the current arrangements and use the findings of the review to update and improve the status quo.
• Improve education and awareness on the risks associated with harmful drinking. It was noted that where children and young people are concerned, the most important influences on attitudes and behaviours are parents, families, friends and peer groups – so any education and awareness campaigns and initiatives should be targeted not just at individuals themselves but at wider social groups.
• Improve, and widen access to, treatment and services for those affected by harmful drinking.
• Apply a levy to alcohol marketing spend, which could be used to fund education, prevention and treatment.
• Place advertising restrictions on 'un-targetable' media only (e.g. outdoor advertising, print media).
• Intervene in relation to those companies and organisations who produce cheap alcohol products which are not advertised or marketed but are largely responsible for alcohol harm in Scotland.

14.11 Respondents (including some who supported restrictions on alcohol advertising) called for the Scottish Government to work in collaboration with the alcohol industry to improve and strengthen the current approach to encouraging and promoting responsible drinking. This could include (i) reviewing the effectiveness of current approaches – respondents said it is vital to do this before any new measures are introduced, (ii) strengthening the regulatory codes currently in use, (iii) giving consideration to placing (some of) the codes onto a statutory basis and (iv) increasing the use of public health messaging and warnings on alcohol products.

Restrictions on other marketing methods or channels (Q39)

14.12 The consultation paper considered possible restrictions on a wide range of marketing methods and channels. Question 39 invited views on whether restrictions should be considered for any additional methods or channels.

14.13 Respondents who were opposed to a comprehensive package of restrictions on alcohol advertising and marketing confirmed at Question 39 that they did not wish to see any additional restrictions.

14.14 By contrast, respondents who were in favour of a comprehensive package of restrictions made a range of suggestions for further controls. Many of these suggestions had been raised in relation to previous questions which asked about restrictions in certain contexts. These respondents proposed additional restrictions on:

• Price promotions – Respondents were in favour of prohibiting the use of price as a promotional tool in all contexts (including point-of-sale promotions on online websites, discounts for bulk buying etc.).
• Packaging and labelling of alcohol products – Respondents suggested that all alcohol products should carry (i) health warnings (warnings about drinking while pregnant were often specifically mentioned) (ii) information about nutritional content and (iii) calorie information. Some respondents also suggested that plain packaging should be considered for all alcohol products.
• The number of licences which could be issued for specific populations / geographic areas – respondents said that some areas had an overprovision of alcohol licences.
• Any advertising and marketing which might be seen by children and young people – for example, there should be a ban on alcohol or alcohol marketing in educational settings of all kinds.

14.15 Respondents in this group also wanted to see a ban on (i) all forms of celebrity or 'social influencer' promotions or endorsements of alcohol products (ii) the use of alcohol as a prize in competitions or as a reward and (iii) social responsibility programmes sponsored by the alcohol industry.

14.16 Some of these respondents also emphasised that any legislation should be written in such a way as to provide a list of exceptions to restrictions (if any were to be permitted), rather than a list of items which were to be prohibited. (That is, the default option should be that everything in relation to marketing and advertising of alcohol products is prohibited.) Moreover, the legislation should be regularly reviewed to keep pace with any unforeseen developments in the marketing and advertising methods employed by the alcohol industry.

Evidence on alcohol marketing (Q40)

14.17 The consultation paper provided a summary of evidence from national and international research on alcohol use and alcohol marketing. Question 40 invited respondents to submit any further evidence that should be considered as part of the policy development process.

14.18 The types of comments offered in response to this question differed substantially depending on whether the respondent supported or opposed the proposals set out in the consultation paper. It should be noted that, in answering this question, both groups drew on the wide and extensive range of evidence sources they had cited at multiple points earlier in their response.

14.19 Those who supported the proposals for a comprehensive package of restrictions on the marketing of alcohol products (i.e. a 'blanket ban') (i) presented evidence on the harms caused by alcohol consumption in Scotland and on the impact of alcohol marketing, (ii) affirmed their agreement with the evidence base set out in the consultation paper, and (iii) identified a wide range of areas for further research and exploration.

14.20 By contrast, those who opposed the proposals for a comprehensive package of restrictions on the marketing of alcohol products (i) presented a critical assessment of the ('partial', 'selective', and 'inadequate') evidence base set out in the consultation paper, (ii) highlighted the absence of any impact assessment(s) exploring the costs and benefits of the proposals, and (iii) identified a wide range of negative impacts which would follow from the introduction of a comprehensive ban. Some of these respondents also raised objections about the way their organisations had been described and characterised in the consultation paper.

14.21 Each of these perspectives is described in greater detail below.

Views of those who support a comprehensive package of restrictions

14.22 Public health and third sector organisations, some organisations in the 'other organisation type' category (i.e. academic organisations, some local authorities and public bodies), as well as a range of individuals supported the proposals for a comprehensive package of restrictions. These respondents provided comments in relation to three main areas.

14.23 First, respondents in this group provided detailed, wide ranging, and often quantified accounts of the harms caused by (problematic or excessive) alcohol consumption in Scotland. The harms identified related to (i) health impacts (including high levels of alcohol-related deaths, the risks of premature death, and the increased risks for a wide range of other physical and mental health conditions), (ii) economic impacts (in terms of costs to the health service and other services, working days lost to sickness absence, etc.), and (iii) social impacts (including impacts on families, isolation, homelessness, etc.).

14.24 Second, respondents in this group affirmed (and sometimes repeated) the evidence which was referenced in the consultation paper. These respondents repeatedly emphasised the evidence which suggested a link between exposure to alcohol marketing and an increase in alcohol consumption (and thereby an increase in alcohol-related harms). This relationship between exposure and harm was – according to these respondents – evident across all demographic subgroups, but respondents often focused their comments on the effects for children and young people, those in recovery, and those who were vulnerable for any reason.

14.25 Third, respondents in this group acknowledged that there were gaps in the evidence base and it was therefore vital to continue to gather and assess evidence in this area. The areas identified for further research and study covered both very broad areas and much more specific questions. Examples of broad topics suggested for further research included:

• How does the risk of alcohol harm vary across social, economic, and geographic communities? How does the risk vary across 'protected characteristics'?
• What impact does alcohol consumption during adolescence have on brain development and cognitive functioning?
• How will a reduction in alcohol consumption affect the uptake of other risky behaviours (e.g. gambling)?
• How can the impacts of digital marketing and advertising approaches be understood and evaluated?

14.26 Examples of more focused, specific questions suggested for further research included:

• What is the impact of advertising on the sale of NoLo products?
• How does alcohol packaging affect consumer behaviour and sales?
• Does licensing legislation need to be updated given the widespread use of online sales?

Views of those who oppose a comprehensive package of restrictions

14.27 Advertising and media organisations, alcohol producers, events and sporting organisations, retail and hospitality organisations, some organisations in the 'other organisation types' category (i.e. business and private sector organisations, and organisations involved in setting standards or developing codes of practice), as well as a wide range of individuals were opposed to the proposals. These respondents provided comments in relation to three main areas.

14.28 First, respondents in this group disputed the evidence set out in the consultation paper. They variously described the evidence as 'out-of-date', 'partial', and 'biased'. Specific concerns identified by respondents included that:

• The evidence presented in the consultation paper was drawn from a narrow, and highly selective range of sources. Respondents said there was undue emphasis on evidence generated by 'Scottish Government bodies' – they particularly highlighted the reliance on research generated by (or promoted by) Alcohol Focus Scotland. Respondents in this group thought there needed to be a broader and more inclusive range of evidence presented – including evidence generated by advertising and media organisations, alcohol producers, regulators, and the alcohol industry itself.
• There is limited (or no) recognition in the consultation paper of the work that has been done by the regulators and by the alcohol industry itself to ensure that children and young people are not (unduly) exposed to alcohol advertising.
• There is clear evidence from a range of sources (including some sources quoted in the consultation paper) that whilst advertising and advertising budgets have increased substantially in recent years, alcohol consumption (as well as binge drinking, drunk and disorderly conduct, hospitalisations for underage drinking, etc.) has decreased; thus the causal link between (increased) advertising and (increased) consumption claimed in the consultation paper does not stand up to scrutiny. Respondents emphasised repeatedly that there was simply no robust evidence of a positive association between alcohol advertising and (the scale of) alcohol harm.
• Even on its own terms (i.e. accepting the evidence base which had been presented) the case for introducing a comprehensive ban on advertising has not been made. Respondents quoted paragraph 1.21 of the consultation paper which said: 'There is limited academic evidence on the impact alcohol marketing has on the adult population.' They also questioned why the evidence presented in relation to the impact of marketing restrictions and / or bans in other countries should lead to a conclusion that introducing a ban would be an effective approach to adopt in Scotland; this (they stated) was clearly not the case.
• The consultation paper suggested that (the existence of) NoLo products drives sales of alcoholic drinks. There is no evidence that this is the case.

14.29 Second, respondents highlighted the absence of any impact assessment(s) to accompany the consultation paper (and the proposals). Respondents thought it was vital that evidence about the anticipated economic impacts of the proposals (the costs and the benefits) should be presented – both a Business and Regulatory Impact Assessment (BRIA) and an Island Communities Impact Assessment (ICIA) were mentioned in this regard. More generally, respondents queried why the consultation did not contain any information about the positive impacts of the alcohol industry (in relation to, for example, tourism, exports, retail, hospitality, the economy in general, innovation, entrepreneurship, social and mental health, etc.).

14.30 Third, respondents described a wide range of negative impacts that they thought would flow from the introduction of restrictions and that had not been discussed in the consultation paper. In particular, they saw the potential for negative effects in terms of:

• Severe job losses (evidence was presented on the number of jobs in the Scottish economy supported by alcohol advertising and by the alcohol industry more generally)
• Disproportionate effects – in economic terms – on remote and rural, and island communities, and on small businesses (evidence was offered about the proportion of alcohol-industry jobs located in these areas)
• Negative impacts on the arts and culture sectors, which would struggle to find replacement funding to run events, etc.
• Legislative difficulties – which would arise as a consequence of the fact that the proposals to ban advertising in certain media channels are not currently within the legislative competence of the Scottish Government.

14.31 Further details on the expected negative impacts as perceived by those who have direct or indirect links to the alcohol industry are presented below in paragraphs 14.37–14.41.

14.32 Three other substantive issues were commented on as follows:

• There were objections to the way the alcohol industry had been portrayed in the consultation paper. Moreover, some organisations objected to the way their work had been characterised or, they said, mischaracterised or omitted. This latter point was made, specifically, by those involved in the current system of self-regulation (i.e. the Advertising Standards Authority, the Portman Group, the Independent Complaints Panel) who did not think their work to encourage responsible drinking, and to protect vulnerable groups, was accurately reflected in the consultation paper.
• Advertising and media organisations, as well as some involved in retail and hospitality questioned the statement in the consultation paper that, without marketing, alcohol products in each beverage sector are 'essentially variations of the same thing'. These respondents argued that branding (merchandise) enhances and distinguishes world-famous brands, and their craft and design, and provides unique points of difference.
• These respondents acknowledged the importance of addressing alcohol-related harm in Scotland, and made a range of alternative suggestions about how this could be approached. (See paragraph 14.10 for a summary of these suggestions.)

Other comments on evidence

14.33 Two other notable themes arose in relation to the need for evidence for: (i) current policy development (specifically regarding licensing issues) or (ii) future evaluation. These are discussed briefly below.

Current policy development – requirement to evaluate existing licensing arrangements

14.34 A common theme in the responses from licensing organisations and retail and hospitality organisations was that formal evaluation of the impacts of the current regulatory / licensing processes should be undertaken before any new restrictions on alcohol marketing are introduced. In particular, they said:

• No steps have been taken to analyse the impacts of rules introduced by the Alcohol etc. (Scotland) Act 2010 regarding single display areas and bans on promotional activity within 200m outside off-sales premises.
• There has also been no post-legislative scrutiny of existing licensing laws, not only in relation to their effects on alcohol-related harm, but also in relation to whether they have achieved the aims intended when they were introduced – with the exception of a study into the efficacy of minimum unit pricing.

14.35 Licensing bodies and retail and hospitality organisations called on the Scottish Government to formally review the existing licensing framework to determine (i) if current laws are working effectively, (ii) the administrative burden of existing licensing requirements on licence holders, and (iii) where enforcement powers exist, whether they are being used. This should be done before any significant new laws are introduced.

Future monitoring and evaluation requirements

14.36 Question 40 specifically sought views about what further evidence should be considered as part of the policy development process. However, some respondents also offered suggestions regarding future monitoring and evaluation requirements – if additional restrictions on alcohol marketing are introduced. Suggestions were made both by those who supported and those who opposed the introduction of restrictions and included the following:

• A robust evaluation framework should be designed together with policy and legislation. It was noted that there is limited evaluation of European alcohol legislation, and therefore any learning from Scotland would add to the international understanding of the topic.
• Key performance indicators should be developed and monitored. These should include youth drinking patterns and attitudes (it was noted that the last available information from SALSUS^[21] is now several years out of date).
• Any monitoring activities should measure impacts on: (i) the vast majority of people who consume alcohol responsibly, (ii) the viability of small, independent breweries, distilleries and cider producers, (iii) consumer choice, (iv) the Scottish economy, and (v) the ability of community groups and not-for-profit organisations to run events and festivals.

Impacts on alcohol-related businesses (Q41)

14.37 The Scottish Government acknowledged that the introduction of restrictions on alcohol marketing could have significant implications for those involved in producing, advertising, selling or distributing alcohol. It noted the importance of gathering industry views to allow potential impacts and possible support for the industry to be considered alongside any restrictions. A final question in this section was aimed at those involved in the alcohol industry and asked respondents for views on the impact of potential restrictions for their business and for the wider alcohol sector.

14.38 The analysis presented here is based on the views of respondents who said they had 'direct' or 'indirect' links to the alcohol industry. This includes alcohol producers and related organisations; advertising and media organisations; events and sporting organisations; retail and hospitality organisations; and some organisations in the 'other organisation types' category. It also includes the views of individuals who said they had direct or indirect links to the alcohol industry and who provided a substantive comment at Question 41.

14.39 Respondents' views about the potential impacts of the proposed restrictions have been noted throughout this report in relation to each question. This section, therefore, summarises – very briefly – the main impacts identified by respondents, not only in relation to their own businesses / activities but in relation to their supply chains and the Scottish economy more widely.

14.40 Respondents saw the potential for significant negative impacts on:

• The alcohol drinks industry: Respondents repeatedly said that marketing is a crucial part of any successful business, and without marketing no business can prosper. They thought the proposed restrictions would be most damaging to new small / micro businesses in the brewing and distilling sectors who would find it impossible to establish and build their brands and could end up closing as a result. The proposals would also damage the reputation of Scotland's internationally renowned whisky industry, making it harder for this sector to compete in a global market. It was suggested that some companies may opt to move their marketing functions out of Scotland resulting in a loss of business for Scotland-based advertisers. The impacts on the drinks industry will also inevitably have knock-on effects for a wide range of other sectors. As most distillers and brewers are based in rural areas, there is likely to be a disproportionate effect on rural communities.
• Advertising, marketing and media sectors: Organisations working in this sector noted that a large proportion of their revenue comes from their work with alcohol brands. This group expected that the proposed restrictions would result in a substantial loss of revenue for their businesses, leading to job losses / redundancies as well as a loss of creative skills. (Respondents said this sector supports a diverse range of creative professionals including digital strategists, art directors, designers, filmmakers, photographers, 3D artists, printers, coders, social media experts, etc.).
• Arts, music, heritage and culture sectors: Respondents noted that these sectors rely on alcohol sponsorship and, in many cases, alcohol sales. They thought the proposed restrictions on alcohol marketing would make many existing events and music / cultural festivals unviable. This, it was suggested, would result in less activity in the arts and music sectors, smaller audiences, businesses and charities closing, job losses, and a loss of opportunities for nurturing homegrown talent. It would also have knock-on effects on the tourism and hospitality sectors. This group suggested that, ultimately, this will diminish Scotland's cultural vibrancy and international image.
• Sporting organisations and sports clubs at national and local levels: The main impact identified in relation to sport concerned the significant loss of income that would result for both professional and grass-roots sports clubs if alcohol sponsorship were banned. Respondents thought these effects were likely to be most damaging in local communities where distilleries and breweries play an active role in supporting local sports clubs and teams. Respondents thought the proposed restrictions would have knock-on effects on aspiring athletes and local communities as a result.
• The tourism and hospitality sectors: Respondents thought the proposals would have significant negative impacts on Scotland's tourism and hospitality sectors. These sectors, it was noted, were only just starting to recover from the effects of the COVID pandemic. Respondents said the proposals would make it impossible for distilleries and breweries to promote visitor experiences, thus undermining years of investment to make Scotland an attractive food and drink visitor destination. Such impacts were likely to be greatest in rural areas. It was also suggested that the scaling back of music and cultural events due to lack of alcohol sponsorship would have impacts on visitor numbers and the vibrancy of Scotland's city centres.
• The retail sector: Respondents in the retail sector thought the proposals would result in increased regulation and costs for retailers. These costs, they noted, would ultimately be passed on to consumers who were already facing a cost-of-living crisis. In addition, at a time when many businesses in Scotland (especially small independent retailers) were struggling to survive, it was suggested the proposals could be devastating. Large retail organisations pointed out that many of their suppliers are small businesses and, therefore, any suggestion that the proposals should apply only to large businesses would nevertheless have adverse impacts on small businesses. Retailers in museum and gallery settings noted that their sale of alcohol in gift shops is primarily targeted at non-UK visitors to Scotland. These respondents thought the proposed restrictions would damage the profitability of gift items and thus have a negative effect on an important source of revenue. There was also a suggestion among retailers that the proposals could lead to an increase in alcohol-related crime and increased safety risks for retail staff.
• Local communities – especially those in rural areas: Respondents thought communities across Scotland would be adversely affected by the proposed changes to sports and cultural event sponsorship. It was reported that the majority of the industry's sponsorship activity is targeted at community teams and events. In many rural areas there are few, if any, other industries that have the financial resources to provide the same level of support. Some respondents were particularly concerned about the impacts on (i) annual fixtures such as Highland Games, and (ii) local community pubs which were described as 'vital social hubs' in rural communities.
• The Scottish economy: Some respondents discussed the potential effects on the Scottish economy in general. These included the loss (or stifling) of business and job creation opportunities, loss of tax revenues, businesses moving overseas, and damage to the reputation of Scotland as the 'world's greatest distilling nation'. They suggested the proposals would destroy the economic opportunity that brewing, distilling, hospitality, tourism and retail represents for the Scottish economy. Some respondents argued that the proposals contradicted the stated ambitions of the Scottish Government's National Strategy on Economic Transformation.

14.41 Finally, as stated repeatedly elsewhere in this report, respondents expressed concern that no Business and Regulatory Impact Assessment(s) had been undertaken. This was thought to be an important omission given (i) the extensive impacts the proposals would have on Scottish businesses and the Scottish economy and (ii) the financial implications of potentially setting up any new regulatory bodies.