Consultation on Restricting Alcohol Advertising and Promotion: Analysis of responses

I wish to make the following points in response to the consultation:

Qs 1–3 on advertising in sport:

Alcohol producers and hospitality businesses, and particularly smaller and independent brewers and publicans, work closely with grassroots and community sports clubs. I believe that banning local pubs and brewers from sponsoring sports events will be damaging both to community sport and to local businesses which are at the heart of their communities.

Qs 4–7 on events sponsorship:

Banning alcohol sponsorship of events could make a whole range of community events unviable. This would be detrimental to businesses, tourists and consumers like me.

It is confusing that the Scottish Government talks about championing Scottish-made products like beers and whisky, but then proposes measures that would make it really hard for smaller producers to succeed.

Qs 8–10 on outdoor alcohol advertising:

This would stop hospitality businesses, brewers and other alcohol producers from advertising offers or events, and could see local alcohol producers banned from advertising or displaying their products at farmers markets and other local events. I don't think banning local, artisanal producers from these sorts of events makes sense, and will again just damage small businesses and choice of Scottish produce.

I am also concerned about this stopping the running and promotion of beer and other drinks festivals organised by local businesses or consumer groups like CAMRA, as they could not be advertised in public.

This will mean that consumers can't sample and enjoy a range of products from Scotland's small, local and independent producers at festivals. Beer and other drinks festivals are also often held in community halls, local hospitality businesses and other public buildings, which brings money into the local economy.

Academic research led by Iganzio Cabras from Northumbia University has shown that beer festivals provide a significant boost the local pubs and social clubs, and the wider local economy. That will be lost if drinks festivals are unviable because they can't advertise or accept sponsorship from brewers or pubs.

Qs 11–13 on the display of alcohol in shops:

I believe that making shops hide beer and cider behind a screen, or in a separate section of bigger shops, is a step too far that would place a big burden on small businesses. This would also de-normalise the responsible, moderate consumption of alcohol – which is how the vast majority of people drink.

This proposal would also penalise responsible drinkers and prevent consumers from exploring new and innovative products. The choice of distinctive, local and independent beer and ciders has exploded in recent years – this would be at risk if customers cannot easily see, explore and choose new products in shops. Large, global brewers with high levels of brand recognition would be ok, whilst Scotland's small, independent producers would struggle to maintain brand recognition and lose out. Again, these are proposals from the Scottish Government that will damage the home-grown alcohol producers that the Scottish Government claims to champion.

Qs 14–17 on alcohol branded merchandise:

Branded merchandise helps smaller and independent brewers and other alcohol producers bring in revenue. This extra revenue, and with it choice of products for the consumer, will be at risk if alcohol branded merchandise is banned.

This feels like a particularly punitive measure, at a time when hospitality businesses and alcohol producers are facing extraordinarily tough trading conditions.

Question 18 on no and low alcohol drinks:

I do not believe that restrictions should be placed on the advertising and promotion of low and no alcohol products. These are alternatives for people who don't want to drink as much so it makes no sense that the Scottish Government would try and ban this.

Q19 & 20 on advertising in print and media:

Responsible advertising of alcoholic products should not be banned in the print and traditional media, where existing codes of practice are followed.

I am also concerned that banning CAMRA and other community groups from advertising events and drinks festivals in local newspapers and other media would mean that those events wouldn't get enough publicity, and therefore footfall, to go ahead in future.

That will reduce choice for consumers and damage small and Scotland-based businesses the most. This is yet another proposal in this consultation that doesn't make any sense if the Scottish Government wants to support Scottish businesses and produce.

Q21–27 online and social media advertising:

Banning any type of advertising of Scotland's small, local and independent brewers, cider makers and wider alcohol producers – and their products – online and on social media would be devastating to the smallest and start-up businesses.

This would have a knock-on effect on choice in the beer, cider and wider alcohol market if only large and multinational brewers, cider makers and other drinks producers are able to bring products to market.

The existing Advertising Standards Agency regime makes sure that online advertising and social media advertising does not reach children and young people, and that action is taken against businesses that breach the existing codes.

Q28–30 on TV, radio and cinema advertising:

Responsible advertising of alcoholic products should not be banned on TV, radio and in cinemas where existing codes of practice are followed.

This would be a draconian measure which will again just damage smaller and independent brewers and other drinks producers and reduce choice of quality drinks for consumers.

Other Comments (Qs 31 – 40):

Whilst I support appropriate regulation and efforts to tackle irresponsible and harmful drinking, I am deeply concerned that these draconian proposals would unfairly penalise all responsible drinkers.

It is astonishing that the Scottish Government doesn't understand that these proposed restrictions will damage small, local and independent businesses, and with it the choice available to consumers in their communities, whilst having limited impact on global drinks producers and big pub and bar chains. A lot of these proposals are in complete opposition to the Scottish Government's statements about supporting the best of Scotland's hospitality sector and drinks producers.

Local pubs and breweries provide community meeting spaces and play a vital role in tackling loneliness and social isolation in both rural, urban and suburban communities. Prohibiting their ability to offer advertising and sponsorship would damage their viability and their involvement with the communities they are imbedded in.

Consuming beer, cider and other drinks in the responsible setting of a public house, brewery taproom, social club or at a drinks festival brings with it wellbeing and mental health benefits. Sharing a drink is also vital to helping tackle loneliness and social isolation. These activities, and the future of pubs, brewers and wider alcohol producers, is at risk if these proposals on advertising and promotion of alcohol go ahead.

I am also concerned about the cumulative impact of regulations on the beer and pubs sector in Scotland, including the proposed Deposit Return Scheme, which are already providing an excessive burden on businesses and having an impact on consumer choice. Given that alcohol is already one of the most regulated sectors of the economy, further restrictive regulations on advertising could sound the death knell for small and independent businesses in this industry, having a hugely damaging impact on consumer choice and the future of community pubs and the Scottish economy.

Campaign text

Whilst I do not live in Scotland, I believe that these proposals from the Scottish Government would be devastating to visitors and tourism in Scotland, as well as having a damaging impact on beer and pub businesses selling into the Scottish market. I also have concerns that it puts the viability of Scottish producers and small businesses at risk, reducing the choice of products from Scotland for consumers elsewhere in the UK.

Banning advertising and the sponsorship of events would be detrimental to businesses, tourists and consumers like me.

It is confusing that the Scottish Government talks about championing Scottish-made products like beers and whisky, but then proposes measures that would make it really hard for smaller producers to succeed.

As a visitor to Scotland, a ban on outdoor and public advertising – and prohibiting the display of alcoholic products in shops – will make it impossible for me to discover, choose and try new and innovate alcoholic products. I fear this would only damage small businesses and choice of Scottish produce.

The choice of distinctive, local and independent beer and ciders has exploded in recent years – this would be at risk if customers cannot easily see, explore and choose new products in shops. Large, global brewers with high levels of brand recognition would be ok, whilst Scotland's small, independent producers would struggle to maintain brand recognition and lose out.

Similarly, if the running and promotion of drinks festivals is banned then consumers – both locals and tourists alike - can't sample and enjoy a range of products from Scotland's small, local and independent producers at festivals. Beer and other drinks festivals are also often held in community halls, local hospitality businesses and other public buildings, which brings money into the local economy.

Academic research led by Iganzio Cabras from Northumbia University has shown that beer festivals provide a significant boost the local pubs and social clubs, and the wider local economy. That will be lost if drinks festivals are unviable because they can't advertise or accept sponsorship from brewers or pubs.

I believe that responsible advertising of alcoholic products should not be banned in the print and traditional media or online and on social media where existing codes of practice are followed. This would damage the ability of producers to get their products into the Scottish market.

It would also damage the viability of Scottish businesses, particularly small, local and independent producers, thereby reducing consumer choice in other parts of the UK if these businesses cannot succeed.

It is astonishing that the Scottish Government doesn't understand that these proposed restrictions will damage small, local and independent businesses, and with it the choice available to visitors to Scotland. A lot of these proposals are in complete opposition to the Scottish Government's statements about supporting the best of Scotland's hospitality sector and drinks producers.

Further restrictive regulations on advertising could sound the death knell for small and independent businesses in this industry, having a hugely damaging impact on tourism, consumer choice in Scotland and choice in the rest of the UK of Scottish products from small, local and independent producers.

Do you think we should prohibit alcohol sports sponsorship in Scotland?

No

Please explain your answer in the text box:

Alcohol industry sponsorship of sports helps secure the long-term viability of community and grass-roots sports. This funding helps broaden participation and should not be constrained. Alcohol branding of sporting events aimed at adults also helps create a connection with the hospitality industry and creates demand for our business when the sporting events take place.

Do you think we should prohibit alcohol events sponsorship in Scotland?

No

Please explain your answer in the text box:

Cultural events are the fabric of Scotland which attract people from all over the world. Implementing what is effectively a funding cut will have a profound effect on the viability of Scotland's cultural events and festivals. Restrictions on alcohol sponsorship will also have a knock-on effect on local economies and businesses like ours, which benefit from the passing trade any major event brings. If funding is cut many of these events will not be able to proceed at their current scale, if at all, and in turn my business will suffer and places in jeopardy the jobs of the people I employ in my business. Securing alternative sources of funding – especially during hard economic times - would be hugely difficult and the Scottish Government must acknowledge that.

Do you think we should prohibit alcohol marketing outdoors, including on vehicles, and in public spaces in Scotland?

No

Please explain your answer in the text box:

Pubs are on their knees as a consequence of inflationary pressures, rising energy costs, Covid recovery and the forthcoming implementation of the Deposit Return Scheme. This proposal will pile additional costs on us at the worst possible time as we will have to adapt our premises / frontage to comply with any regulations. Imposing restrictions on our external frontage also risks creating a scenario where our town centres lose character and heritage that pubs like ours provide.

Do you think that we should prohibit the free distribution of alcohol branded merchandise in Scotland?

No

Please explain your answer in the text box:

If restrictions on the free distribution of branded merchandise including glassware, external furniture and placemats are imposed it will cost our business around £2,000 per year to make up for this to replace branded equipment for our pub which is normally provided free of charge by producers, at a time when we simply cannot afford that. We would also question the efficacy of prohibiting the free distribution of merchandise in addressing alcohol consumption.

Do you think that any potential alcohol marketing restrictions should apply to low or no alcoholic drinks products, where these carry the same brand name, or identifiable brand markings, as alcoholic drinks?

Not Answered

Please answer in the text box below:

Low and no alcohol products enable pubs to cater for a wider range of consumers whilst also encouraging responsible consumption. The Low and No category has grown over recent years and we have seen this reflected in the number of people who ask for these products in our pub. The development of these products should be welcomed by the Scottish Government, not restricted as is being proposed. We have seen our customers moderate their consumption of alcohol through the use of these products. Low and no alcohol products have helped pubs continue to serve customers who drive following the changes to Scotland's strict drink-drive limits. Reducing the potential for more low and no alternatives across all alcohol products may force trade away from pubs, and indeed, other hospitality settings.

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? Please add your response in the text box:

The Scottish Government should be proud of its nation's drinks industry and the economic benefits it brings – we should be supporting the success of our sector, not restricting its potential.