Consultation on Restricting Alcohol Advertising and Promotion: Analysis of responses

1 Introduction

1.1 The Scottish Government is considering options for restricting the marketing of alcohol. A consultation seeking views on possible restrictions in various contexts, and matters related to such restrictions, was carried out between November 2022 and March 2023. This report presents the findings of an analysis of the responses to that consultation.

Policy context

1.2 High-risk drinking is a significant – and long-standing – public health issue in Scotland, with harmful consequences for individuals, their family and friends, as well as wider society and the economy. Moreover, excessive drinking compounds and entrenches health inequalities, with markedly higher levels of alcohol-related harm present in less affluent groups.^[2]

1.3 The Scottish Government's 2018 Alcohol Framework (the Framework) provided a detailed analysis of the Scottish context and set out a range of actions to reduce alcohol consumption and alcohol-related harms in Scotland. The Framework included actions such as evaluating current policy initiatives (e.g. Minimum Unit Pricing, Alcohol Brief Interventions), updating statutory guidance to provide clarity for Licensing Boards on licensing objectives (including the public health objective^[3]), developing and improving educational programmes for schools, undertaking awareness-raising activities, and working with alcohol producers to put health information on packaging.

1.4 The Framework identified four key areas where impacts would be sought: (i) protecting young people, (ii) tackling health inequalities, (iii) improving national systems, and (iv) (taking) a whole population approach. The Framework is closely aligned with the recommended World Health Organization approach of placing the three 'A's of prevention –Affordability, Availability and Attractiveness – front and centre.

1.5 The Framework set out the published research evidence supporting the restriction of alcohol advertising and promotion. It also included a commitment (Action 10) to 'consult and engage on the appropriateness of a range of potential measures, including mandatory restrictions on alcohol marketing, as recommended by the World Health Organisation, to protect children and young people from alcohol marketing in Scotland'. The current consultation, which featured in the Scottish Government's Programme for Government 2022/23, was intended to address this commitment.

About the consultation

1.6 The Scottish Government's consultation on restrictions to alcohol marketing ran from 17 November 2022 to 9 March 2023. The consultation paper, Consultation on Restricting Alcohol Advertising and Promotion, set out current evidence to support the introduction of alcohol marketing restrictions and described the action taken in this area in countries elsewhere in the world. The policy options discussed in the consultation paper had a clear focus on (the protection of) children and young people but also considered potential impacts on other at-risk groups (e.g. those in recovery from problematic drinking) and the wider adult population. The consultation paper contained 42 questions: 22 closed questions with an option to provide comments, and 20 open questions.^[4]

1.7 The consultation invited views on the following topics:

• Sports and events sponsorship (Q1–7)
• Outdoor and public spaces marketing (Q8–10)
• In-store marketing (Q11–13)
• Brand-sharing and branded merchandise (Q14–18)
• Print advertising (Q19–20)
• Online marketing (Q21–27)
• Television and radio advertising (Q28–29)
• Cinema advertising (Q30–31)
• Restrictions on the content of advertisements (Q32–34)
• Enforcement (Q35)
• Evaluation and provision of data (Q36–37)
• Other issues – The scope of restrictions, evidence and business impacts (Q38–41)
• Impact assessment (Q42).

1.8 The consultation questionnaire also included a question asking respondents to disclose any direct or indirect links they have to the alcohol industry.^[5]

1.9 The consultation paper was published on the Scottish Government's consultation webpage. Respondents could complete an online questionnaire or submit a response by email or post. An easy-read version of the consultation paper was also available on the consultation webpage.

1.10 In addition, Children in Scotland was commissioned to undertake engagement work with children and young people to elicit their views on this topic. This aspect of the consultation built on a programme of youth engagement work carried out before the consultation paper was published.^[6] Together this work delivered on the 'overarching commitment' set out in the Framework to 'put the voices of children and young people at the heart of developing preventative measures on alcohol'.

About the analysis

1.11 This report is based on a robust and systematic analysis of the responses to the consultation. Both quantitative and qualitative analyses were carried out. Frequency analysis was undertaken in relation to the closed questions and the findings are shown in tables throughout this report.

1.12 The aim of the qualitative analysis was to identify the main themes and the full range of views submitted in response to each question or group of questions, and to explore areas of agreement and disagreement among respondents.

1.13 Note that not all respondents answered every question, and some made comments in relation to an open question without ticking a response at the relevant closed question. Percentages shown in the tables throughout this report are based on the number of respondents who answered that question.

1.14 The report also includes an analysis of views gathered at engagement events organised by Children in Scotland (see Chapter 16). This analysis also incorporates findings from engagement activities carried out by other children and young people's organisations, and submitted as part of their consultation responses.

A caveat about the findings

1.15 As with all consultations it is important to bear in mind that the views of those who have responded may not be representative of the views of the wider population. Individuals (and organisations) who have a keen interest in a topic – and the capacity to respond – are more likely to participate in a consultation on that topic. This self-selection means that the views of consultation participants cannot be generalised to the wider population.

1.16 For this reason, the approach to consultation analysis is primarily qualitative in nature. Its main purpose is notto identify how many people held particular views, but rather to understand the full range of views expressed and any concerns that respondents may have. The qualitative analysis also helps in understanding the responses to the closed questions and giving greater insight into people's views.

The report

1.17 The remainder of this report is structured as follows:

• Chapter 2 presents information about the respondents to the consultation and the responses submitted.
• Chapters 3 to 15 present findings from the analysis of responses to the consultation.
• Chapter 16 provides a summary of the views of children and young people.

1.18 In addition, this report also contains three annexes:

• Annex 1 contains a list of the organisations that responded to the consultation.
• Annex 2 provides details of the campaign responses received in the consultation.
• Annex 3 provides information about the response rates for individual questions, broken down by respondent type.