Consultation on Restricting Alcohol Advertising and Promotion: Analysis of responses

Footnotes

1. These include the Code of Non-broadcast Advertising and Direct & Promotional Marketing (CAP), the Code of Broadcast Advertising (BCAP), the Portman Group's Codes of Practice, and the Responsible Marketing Pact.

2. Public Health Scotland, Alcohol overview.

3. As set out in the Licensing (Scotland) Act 2005, the protection and improvement of public health is one of five licensing objectives that licensing boards must take into consideration when granting or renewing licences.

4. The online consultation questionnaire included two final questions asking for views about the consultation process and the Citizen Space platform for responding to the consultation. The analysis of these questions is not included in this report but has been passed to the Scottish Government to help improve future consultation exercises.

5. This question was not numbered in the consultation paper but appeared as Question 1 in the online and offline questionnaires. The question numbers in the bulleted list above and throughout this report are those used in the consultation paper.

6. See Young Scot: Preventing Harm – Alcohol Marketing and Young People and Children's Parliament: Alcohol-free Childhood.

7. In some cases, the respondent submitted a duplicate response – one by email and one through Citizen Space – or sent (by email) follow-up material to their Citizen Space response. In other cases, the respondent submitted two (and in one case three) different responses.

8. Where the respondent submitted multiple different responses, if their answers to the closed questions differed across their responses, their most recent response was retained and comments from their earlier response(s) were copied into that.

9. Portman Group (2014) Code of Practice on Alcohol Sponsorship (First edition), Section 3: Rules for Responsible Alcohol Sponsorship.

10. Pourage rights: the right to make available, sell, dispense and serve beverages during events and / or within a venue, which may or may not be to the exclusion of other beverage vendors, and to identify the holder of such a right as the "official" provider of such beverage at the venue.

11. Alibi marketing: when features that are synonymous with a brand / product are used, without making explicit reference to that brand / product. An example given frequently by respondents was in relation to Guinness's 'Greatness' campaign where the phrase 'Greatness' was presented using the same fonts and colour scheme as the Guinness beer.

12. Note that 166 respondents made comments at Question 7 without first answering the tick-box question whereas fewer than 5 respondents made comments at either Question 1 or Question 4 without having first answered the closed questions. Similarly, just 2% of respondents overall answered 'don't know' in response to Question 1 or Question 4, compared to 13% overall at Question 7.

13. Note that in May 2023 the Scottish Government announced in a statement to the Scottish Parliament the intention to carry out further consultation on regulations to restrict the promotion of high fat, sugar and salt products.

14. The introduction of the proposed deposit return scheme has been delayed until October 2025, at the earliest. See the Scottish Government website.

15. Community Alcohol Partnerships bring together and support local partnerships of councils, police, retailers, schools, health providers and community groups across the UK to reduce alcohol harm among young people, improve their health and wellbeing and enhance their communities. The initiative is core-funded by the Retail of Alcohol Standards Group.

16. NoLo drinks are defined as products with an ABV ranging from 0% to 1.2%. ABV is Alcohol by Volume – a measure of alcoholic strength.

17. Age-gating involves a webpage or pop-up page which asks a user to confirm their age or date of birth in order to be given access to the main website. Age verification requires the user to provide proof of their age or date of birth.

18. Interest-based targeting of online advertising is based on the browsing habits of users. Thus, an advertiser wishing to reach those over 18 can include in their social media targeting strategy other topics likely to be of interest only to adult age groups. A person browsing for home insurance or business travel, for example, might also receive adverts for alcoholic drinks. (See ASA's Age Restricted Ads Online.)

19. Regulatory Reform (Scotland) Act 2014, Part 2: Primary Authorities.

20. Both the ASA and Portman Group systems rely on members of the public seeing, and knowing how to report, marketing which may breach the rules.

21. SALSUS: Scottish Schools Adolescent Lifestyle and Substance Use Survey.