Consultation on Restricting Alcohol Advertising and Promotion: Analysis of responses

3 Sports and events sponsorship (Q1–Q7)

3.1 The first type of alcohol marketing considered in the consultation paper was sports and event sponsorship. Section 6 of the consultation paper provided an overview of the relationship between alcohol brands and sport, describing the nature of sports sponsorship and the range of marketing activities this might involve. It also presented research findings relating to the impact of such marketing activity on groups such as children and young people and those recovering from alcohol abuse. Additionally, the consultation paper discussed alcohol sponsorship of non-sporting events, noting that, while the same evidence base was not available, there was an assumption that marketing in this context was likely to have similar impacts as sponsorship of sporting events. Thus, the consultation paper considered the option of restricting alcohol sponsorship in the context of both sporting and non-sporting events.

3.2 Seven questions sought views on prohibiting alcohol sponsorship of sports and events, the type of marketing that should be prohibited, any exceptions to the prohibition, and whether any prohibition should be preceded by a lead-in period. This chapter presents an analysis of the views on each question.

Question 1: Do you think we should prohibit alcohol sports sponsorship in Scotland? [Yes / No / Don't know]

Question 2: If sports alcohol sponsorship were to be prohibited, what types of marketing do you think should be covered by a prohibition?

Question 3: What, if any, sporting activities or events do you think should be excepted from a prohibition on alcohol sports sponsorship, and why?

Question 4: Do you think we should prohibit alcohol events sponsorship in Scotland? [Yes / No / Don't know]

Question 5: If alcohol events sponsorship were to be prohibited, what types of marketing do you think should be covered by a prohibition?

Question 6: What, if any, events do you think should be excepted from a prohibition on alcohol events sponsorship, and why?

Question 7: If alcohol sponsorship restrictions are introduced, do you think there should be a lead-in time for these? [Yes / No / Don't know] How long might this be and how would it work?

Prohibiting alcohol sports sponsorship (Q1)

3.3 Question 1 asked respondents for their views on whether alcohol sports sponsorship should be prohibited in Scotland. Table 3.1 shows the following:

• Overall, around a fifth of respondents (21%) thought that alcohol sports sponsorship should be prohibited, while around three-quarters (77%) thought it should not. The remaining 2% selected 'don't know'.
• Levels of agreement with the proposition were similar for both organisations (24%) and individuals (20%). Levels of disagreement with the proposition were also similar for both organisations (73%) and individuals (77%).
• All public health and third sector organisations (100%) agreed that alcohol sports sponsorship should be prohibited. By contrast, almost all alcohol producers (92%), events and sporting organisations (95%), retail and hospitality organisations (89%) and advertising and media organisations (86%) disagreed with this approach. Half of other organisation types (50%) agreed with the approach, while 45% disagreed.

Table 3.1: Q1 – Do you think we should prohibit alcohol sports sponsorship in Scotland?

	Yes		No		Don't Know		Total
Respondent type	Number	Percent	Number	Percent	Number	Percent	Number	Percent
Alcohol producers	8	6%	121	92%	2	2%	131	100%
Events and sporting organisations	0	0%	62	95%	3	5%	65	100%
Retail and hospitality organisations	3	5%	51	89%	3	5%	57	100%
Public health and third sector organisations	64	100%	0	0%	0	0%	64	100%
Advertising and media organisations	1	5%	18	86%	2	10%	21	100%
Other organisation types	11	50%	10	45%	1	5%	22	100%
Total, organisations	87	24%	262	73%	11	3%	360	100%
Total, individuals	400	20%	1,509	77%	44	2%	1,953	100%
Total, all respondents	487	21%	1,771	77%	55	2%	2,313	100%

Percentages may not total 100% due to rounding.

3.4 In addition:

• 428 CAMRA 1 campaign respondents indicated that they did not support restrictions on alcohol sports sponsorship.
• 67 Publicans campaign respondents answered 'no' at Question 1.

Support for prohibiting alcohol sports sponsorship

3.5 All public health and third sector organisations, most academic organisations, and one in five individuals supported a ban on alcohol sports sponsorship. These respondents gave three main reasons for their views relating to: (i) the effectiveness of sports sponsorship as a form of alcohol marketing, (ii) the perceived contradiction of alcohol sponsorship in the context of healthy behaviours such as physical activity and sport, and (iii) the public support for prohibiting alcohol sports sponsorship. The points made by respondents regarding each of these are discussed briefly here.

Alcohol sports sponsorship is an effective form of marketing

3.6 Respondents who supported a ban on alcohol sports sponsorship noted the 'pervasive and widespread' nature of alcohol sports sponsorship in Scotland, and they suggested that sponsorship, as a form of marketing, works by creating a 'positive, emotional relationship' between an alcohol brand and the supporters of a sports team.

3.7 This group cited evidence which (they said) shows that, among adolescents and young adults, (i) sports sponsorship is associated with increased awareness and more positive attitudes towards both the specific advertised alcohol brand and towards alcohol more generally, and (ii) self-reported awareness of alcohol marketing is associated with binge drinking and other forms of high-risk drinking. They also reported evidence that alcohol sports sponsorship has been associated with increased consumption among adults who participate in sport.

3.8 This group noted that the Portman Group's Code of Practice on Alcohol Sponsorship permits alcohol sponsorship of sports / teams where under-18s comprise less than 25% of the participants, audience or spectators,^[9] and that large numbers of children and young people might be exposed to alcohol marketing during such events. Moreover, where a sporting event is broadcast on television, it may reach an even larger audience of children and young people.

3.9 Some public health organisations commented that, in Scotland, large numbers of people attend weekly football matches, and are thus regularly exposed to alcohol marketing. Respondents identified three groups, in addition to children, who were likely to be most affected by alcohol sports sponsorship:

• Men aged 45 and over – This group makes up the majority of football fans in Scotland and is also the group most likely to experience alcohol-related harm.
• People (including children and young people) in recovery from alcohol problems – Attending sporting events and even watching sporting events on TV has been reported to act as a trigger for this vulnerable group.
• Adolescents and young adults – Respondents cited evidence to suggest that sports sponsorship may increase awareness of specific alcohol drinks and brands among adolescents and young adults. In addition, they reported that exposure to alcohol advertising and sponsorship has been associated in some research studies with earlier age of initiation of alcohol consumption in non-drinkers and more hazardous drinking in young people who are already drinkers.

The perceived contradiction of alcohol sports sponsorship

3.10 A second common theme in the responses from those who supported a ban on alcohol sports sponsorship is that the purpose of such sponsorship is to create an association between sport, health and wellbeing on the one hand, and alcohol on the other. In creating this association, the implication is that drinking alcohol is compatible with a healthy lifestyle.

3.11 Some respondents pointed out that participation in sport and physical activity offers protection from a range of conditions, including type 2 diabetes and some forms of cancer. It also supports mental wellbeing. In contrast, they argued, alcohol use increases the risk of these conditions and contributes to poor mental health.

3.12 Respondents in this group argued that alcohol sports sponsorship is incompatible with messages about healthy lifestyles. These respondents thought that sport should not be used to promote the use of an 'addictive' and 'harmful' substance.

Public and sports sector support for prohibiting sports sponsorship

3.13 Public health and third sector organisations highlighted recent polls that have shown a greater proportion of the general public in Scotland are in favour of prohibiting alcohol sports sponsorship than are opposed. They also pointed to specific sports teams that have refused sponsorship from alcohol companies – suggesting that views on this issue are beginning to change among sporting groups. Some respondents noted that restrictions on alcohol sponsorship in sport have been implemented in some other European countries, including France, which has hosted high-profile international sporting events with sponsorship restrictions in place.

Opposition to prohibiting alcohol sports sponsorship

3.14 Most respondents (apart from public health and third sector organisations, academic organisations, and a minority of individuals) opposed a ban on alcohol sports sponsorship. These respondents gave four main reasons for their views relating to: (i) the lack of evidence that prohibiting alcohol sponsorship would affect alcohol consumption, (ii) the important role of alcohol sponsorship in supporting both elite or professional and grassroots sporting clubs, (iii) the effectiveness of existing self-regulation, and (iv) the potential for negative impacts on a key sector of the Scottish economy. The points made by respondents regarding each of these topics are discussed briefly here.

Lack of evidence on the effectiveness of prohibiting alcohol sports sponsorship

3.15 Respondents who opposed a ban on alcohol sports sponsorship pointed to evidence that alcohol consumption – particularly among children and young people – has been declining in recent years. Some in this group argued that the evidence suggests that there is an inverse relationship between the amount of money spent by the alcohol industry on advertising and sponsorship on the one hand, and certain types of alcohol-related harms (such as deaths, hospitalisations, and underage drinking) on the other.

3.16 This group also argued that studies which show that young people may see, and have an awareness of, alcohol advertising do not demonstrate that this awareness leads to increased alcohol consumption. These respondents made the point that children and young people's awareness of alcohol brands might come from numerous sources, including from their own homes – and not simply through exposure to advertising and sponsorship of sporting events. This group also cited studies from France which did notdemonstrate a significant decline in alcohol consumption as a result of introducing legislation to prohibit alcohol sports sponsorship.

Importance of alcohol sponsorship in supporting sports clubs

3.17 A second common theme among those who opposed a ban on alcohol sports sponsorship was that such arrangements provide vital financial support to Scottish sports clubs – and particularly to grassroots clubs in remote and rural areas where alternative sources of sponsorship may not be readily available. Respondents making this point noted that such groups often rely on sponsorship from local distilleries, breweries and pubs for the funding of uniforms, improvements in facilities / equipment, transport to matches, etc.

3.18 Some respondents in this group suggested that the sponsorship of local sports teams is not always commercially driven (that is, the aim is not to recruit consumers); rather, it is part of a company's contribution to their local community.

3.19 Some also noted that financial support for aspiring young sports people is limited and would be further restricted without funding from the alcohol industry. Some clubs suggested that ticket prices and membership fees would also increase as a result of implementing a ban, thus creating a barrier to participation and attendance for people on lower incomes.

3.20 One additional point expressed by this group was that a 'blanket ban is not the answer' as a blanket ban does not take into account the difference in types of funding available to different sports and different types of sporting organisations.

The effectiveness of existing self-regulation

3.21 A third theme in the comments at Question 1 was that existing self-regulation of alcohol sponsorship in sport works well. Respondents who made this point highlighted the Portman Group's Code of Practice on Alcohol Sponsorship, and the Code on the Naming, Packaging and Promotion of Alcoholic Drinks which both stipulate that young people under 18 and vulnerable people should not be targeted by alcohol marketing.

3.22 Some respondents also commented that, as part of existing sponsorship agreements in Scotland (and elsewhere in the UK), alcohol companies are required to ensure there is a visible commitment to promote responsible drinking (i.e. through prominently displayed responsible drinking messages), and to support diversionary / community activities.

Potential negative impacts on businesses of prohibiting alcohol sports sponsorship

3.23 Finally, those who opposed a ban on alcohol sports sponsorship highlighted the potential impacts of such a move on Scottish businesses. Those who raised this issue pointed out that alcohol was a significant Scottish export, and its production and sale was a major contributor to the Scottish economy. Concerns were voiced, in particular, about the effects on smaller and new alcohol producers who may rely on sports sponsorship to raise awareness of their brands and get a foothold in a competitive market.

3.24 It was also suggested that restrictions on sports sponsorship would have a particularly negative impact on the global reputation of Scotch Whisky. Those who made this point thought such restrictions would send a message to the world that the Scottish Government believes its own national drink is harmful, and that the public must be protected from it.

Other views on alcohol sports sponsorship

3.25 Respondents who answered 'don't know' at Question 1 generally expressed mixed views about the proposal to prohibit alcohol sports sponsorship. These respondents recognised the potential public health benefits of a ban but were also concerned about the possible unintended consequences for the funding of and participation in sport (particularly for small community clubs). This group also thought that, if alcohol sponsorship were withdrawn, other types of businesses linked to addictive and unhealthy behaviours – including gambling companies and fast-food chains – would step in to fill the gap.

Coverage of a prohibition on alcohol sports sponsorship (Q2)

3.26 Question 2 asked: if alcohol sports sponsorship were to be prohibited, what types of marketing should be covered by the prohibition? Examples given in the consultation paper included: (i) prohibiting the use of alcohol brands on clothing worn by players or staff, (ii) prohibiting alcohol being advertised on pitch side hoarding, pitches, trophies, tunnels or interview boards, (iii) prohibiting players or staff from featuring in alcohol adverts in print or online, and (iv) prohibiting online content from linking sports teams, players or competitions to an alcohol brand.

3.27 Respondents who supported a ban on alcohol sports sponsorship often suggested multiple types of marketing that they thought should be covered. In addition to the examples listed in the consultation paper, they also wanted to see a ban on:

• Sports logos / iconography on alcohol products
• Limited edition alcohol products featuring the names of teams
• The promotion of NoLo alcohol-branded products at sporting events
• Advertising inside and outside of stadiums
• The promotion of sponsors through hospitality events and the offer of free alcohol
• Partnership activity promoting brands through visits to breweries and distilleries
• The naming of stadiums and cups / leagues for alcohol sponsors
• Exclusive 'pourage rights'^[10]
• 'Alibi' marketing.^[11]

3.28 Some respondents in this group specifically stated that any ban on alcohol sponsorship / marketing in sport should apply equally to professional and amateur sports.

3.29 Others offered more general suggestions – commenting that the Tobacco Advertising and Promotion Act 2002 would provide a useful basis for designing a prohibition on alcohol sponsorship. This group noted that the 2002 Act does not attempt to provide an exhaustive list of the types of sponsorship that are prohibited, which (in their view) would only create loopholes that would be exploited by the alcohol industry.

3.30 In the main, respondents who opposed a ban on alcohol sports sponsorship did not offer suggestions regarding the coverage of a ban. This group simply repeated their views that alcohol sponsorship of sport should not be restricted further than it already is. Some alcohol producers and sellers suggested that the Scottish Government should continue to work in partnership with the alcohol industry, regulators and others to ensure that alcohol sports sponsorship makes a positive contribution to changing Scotland's relationship with alcohol.

Exceptions to a prohibition on alcohol sports sponsorship (Q3)

3.31 Question 3 asked: what, if any, sporting activities or events should be excepted from a prohibition on alcohol sports sponsorship, and why?

3.32 In general, respondents who supported a ban on alcohol sponsorship in sport thought there should be no exceptions and those who opposed a ban on alcohol sports sponsorship thought all sporting activities / events should be excepted. The latter group usually repeated or referred back to the reasons they gave at Question 1 for opposing a ban (see paragraphs 3.14–3.25). These views are not discussed here again.

Support for a complete ban

3.33 Those who thought there should be no exceptions gave the following reasons for their views:

• A comprehensive and clear ban would be more effective in reducing exposure to alcohol marketing, and in providing clarity to the industry. It would also be easier to implement and enforce. Respondents wanted the Scottish Government to adopt the same model used to prohibit the marketing of tobacco products.
• A blanket ban would be fairer – if some sports and sporting events are able to benefit from alcohol sponsorship and others are not, it will lead to complaints.
• Exceptions would lead to loopholes; loopholes will be exploited by the alcohol industry and would lead to litigation.
• Sporting events intended for over-18s should not be excepted since, in all likelihood, some children and young people will attend or watch such events.
• There is no logical reason for introducing exceptions. The introduction of exceptions would undermine the purpose of introducing a prohibition in the first place.

Support for exceptions in some circumstances

3.34 Among respondents who opposed a ban on alcohol sports sponsorship, a recurring view was that, if a ban on sponsorship was to be introduced, this should only apply to sports involving children or young people as participants or as the primary audience – an arrangement which, they pointed out, was already in place. (Note, however, there was sometimes disagreement in this group about whether children and young people should be defined as being under 16, under 18, or under 21.) Those who raised this issue thus thought that sports mainly involving adults as participants or as the primary audience should be exempt.

3.35 As noted above, respondents who supported a ban on alcohol sports sponsorship typically thought there should be no exceptions. However, very occasionally, this group offered suggestions about sports that they thought could be excepted, if exceptions were permitted. Respondents who opposed a ban on alcohol sports sponsorship also (very occasionally) made suggestions about additional exceptions if a ban were introduced. The suggestions made by these two groups overlapped to a large extent, and therefore their views are discussed together here.

3.36 The types of sports and games most commonly suggested as exceptions were:

• Sports / games that are played in pubs (including darts, snooker, and pool)
• Adult-only sports, or sports for which under-16s are not permitted entry (the examples given were boxing and horseracing)
• Events that involve drinking competitions (e.g. Drinkers World Cup)
• Sports / games that are not associated with alcohol-related anti-social behaviour (examples given were rugby, tennis, dressage, show jumping, chess)
• E-sports (described as a 'fledgling industry').

3.37 Occasionally, respondents also suggested that exceptions should be made for shinty (described as a 'niche sport') and outdoor pursuits such as sailing, shooting and fishing.

3.38 In addition, both those who favoured a ban on alcohol sports sponsorship, and those who did not, often suggested that exceptions should be made for small community / amateur teams and / or sub-premier league sports teams, as these teams are frequently supported by local distilleries, breweries or pubs and would not have easy access to alternative forms of sponsorship. At the same time, some respondents who opposed a ban on alcohol sports sponsorship also suggested that all major sports leagues and all professional sporting teams should also be exempt – on the basis that these sports attract global audiences to whom Scottish alcohol products can be marketed.

3.39 In terms of sporting events, various respondents suggested exceptions should be made in relation to:

• Any international or UK-wide sporting event or competition and / or events run by organisations from outside Scotland – for example, European football competitions, where foreign teams may have alcohol sponsors and wear branded shirts, and international golf tournaments that may be too expensive to organise without alcohol sponsorship
• Sporting events televised after the 'watershed'
• Corporate events, awards events, and hospitality in VIP areas involving food.

3.40 Finally, there was also a suggestion that there should be no ban on the use of alcohol (champagne, in particular) to celebrate success in sport.

Prohibition of alcohol events sponsorship (Q4)

3.41 Question 4 asked respondents for their views about whether alcohol sponsorship of non-sporting events (i.e. music and cultural events) should be prohibited. Table 3.2 shows the following:

• Overall, about a fifth of respondents (17%) thought alcohol events sponsorship should be prohibited in Scotland, while four-fifths (81%) thought it should not. The remaining 2% selected 'don't know'.
• Levels of agreement with the proposition were similar for both organisations (20%) and individuals (16%). Levels of disagreement with the proposition were also similar for both organisations (79%) and individuals (81%).
• Almost all public health and third sector organisations (95%) thought alcohol events sponsorship should be prohibited. By contrast, all events and sporting organisations and advertising and media organisations (100% in both cases), and almost all alcohol producers (99%) and retail and hospitality organisations (95%) disagreed. Around half of other organisation types (45%) agreed while half (55%) disagreed.

Table 3.2: Q4 – Do you think we should prohibit alcohol events sponsorship in Scotland?

	Yes		No		Don't Know		Total
Respondent type	Number	Percent	Number	Percent	Number	Percent	Number	Percent
Alcohol producers	1	1%	125	99%	0	0%	126	100%
Events and sporting organisations	0	0%	64	100%	0	0%	64	100%
Retail and hospitality organisations	2	3%	56	95%	1	2%	59	100%
Public health and third sector organisations	57	95%	1	2%	2	3%	60	100%
Advertising and media organisations	0	0%	20	100%	0	0%	20	100%
Other organisation types	10	45%	12	55%	0	0%	22	100%
Total, organisations	70	20%	278	79%	3	1%	351	100%
Total, individuals	318	16%	1,587	81%	46	2%	1,951	100%
Total, all respondents	388	17%	1,865	81%	49	2%	2,302	100%

Percentages may not total 100% due to rounding.

3.42 In addition:

• 428 CAMRA 1 campaign respondents and 90 CAMRA 2 campaign respondents indicated that they did not support restrictions on alcohol events sponsorship.
• 67 Publicans campaign respondents answered 'no' in response to Question 4.

3.43 It should be noted that there may have been some confusion in relation to these questions. Some respondents (mainly individuals, but also some organisations) appeared not to have understood the distinction being made in the consultation paper between Questions 1–3 (which asked about alcohol sports sponsorship) and Questions 4–6 (which asked about the sponsorship of non-sporting events). Thus, their comments at both sets of questions made reference to sports, athletes, sports teams, games, and sporting events.

Support for prohibiting alcohol events sponsorship

3.44 Most public health and third sector organisations, most academic organisations, and one in six individuals supported a prohibition on alcohol events sponsorship. This group generally gave reasons that were the same or similar to those they gave in support of banning alcohol sports sponsorship. They highlighted the pervasiveness of alcohol sponsorship at music and cultural events; and evidence of the effectiveness of alcohol sponsorship in (i) raising awareness of brands and (ii) encouraging more alcohol consumption – and at an earlier age – among children and young people.

3.45 Some in this group also suggested that there was evidence of public support for restrictions on alcohol events sponsorship – especially among the parents of young people.

3.46 The point made most often by this group was that alcohol sponsorship of music and cultural events implies that alcohol consumption is both normal and necessary for the enjoyment of entertainment, music, and social interaction. There was also a view that, by allowing the alcohol industry to continue funding music and cultural events through sponsorship arrangements, the idea is perpetuated that the alcohol industry 'has a social conscience or is beneficent'.

3.47 Respondents called for public spaces at events – except those intended specifically for the sale and consumption of alcohol – to be free from alcohol marketing. This, they said, would help reduce the exposure to alcohol marketing among groups who are vulnerable to alcohol-related harms – including children and young people and people in recovery wishing to avoid alcohol triggers.

Opposition to prohibiting alcohol events sponsorship

3.48 Apart from public health and third sector organisations and academic organisations, most other organisations and four in five individuals opposed a ban on alcohol events sponsorship. These respondents gave a range of reasons for their views, with some referring back to points they made in opposing a ban on alcohol sports sponsorship. Within this group, organisers of large-scale arts and music events, those representing museums and galleries, organisations responsible for the care of heritage sites, and funders of the arts sector in Scotland often provided long and detailed accounts of why they were opposed.

3.49 The two main points made by these respondents related to (i) the lack of evidence to justify restrictions on alcohol sponsorship of non-sporting events and (ii) the significant impact that a ban on alcohol events sponsorship would have – both on the arts, music and heritage sectors, and on the Scottish economy more widely.

Lack of evidence to justify prohibiting alcohol sponsorship of non-sporting events

3.50 This group argued that the proposal to ban alcohol sponsorship of music and cultural events was not based on evidence, and they drew attention to the statement in the consultation paper that 'the extent and impact of sponsorship of non-sporting events has not been researched' (paragraph 6.20). They also pointed out that the consultation does not recognise the wide-ranging types of events currently sponsored by alcohol brands, nor the varied nature of events audiences. They emphasised that it cannot be assumed that all types of alcohol sponsorship of all types of events would have the same impact on alcohol consumption.

3.51 These respondents argued that in the absence of any evidence to justify such a restriction, it would be inappropriate to proceed, given the likelihood of significant negative consequences for the arts and heritage sectors in Scotland. Instead, they called on the Scottish Government to undertake the necessary research, and they cautioned against any assumption that evidence gathered in relation to alcohol sponsorship in sport would translate directly to (or mirror) the sponsorship of non-sporting events. In particular, they said that cultural events programmes can be differentiated in ways that sporting events cannot. Thus, alcohol sponsorship can be more targeted and tailored in relation to cultural events than it can be in relation to sporting events.

3.52 This group called for any research in this area to focus on (i) the visibility of alcohol advertising at non-sporting events, (ii) the demographic profile of audiences who attend such events, (iii) the value of alcohol sponsorship to the arts, music and heritage sectors, (iv) the likely impacts of a sponsorship ban on these sectors, on communities, and on the cultural landscape of Scotland more generally, and (v) the impact of advertising and sponsorship of non-sporting events on alcohol-related harms and drinking behaviour.

3.53 Respondents were also sceptical that there was public support for banning alcohol sponsorship of non-sporting events. They highlighted evidence that suggested that the general public were in favour of Scottish whisky, gin and beer producers being allowed to continue to sponsor culture and heritage events in Scotland.

Impacts on the arts, music and heritage sectors – and the wider economy

3.54 Respondents who opposed a ban on alcohol sponsorship of non-sporting events questioned whether such a ban was likely to have any measurable effect on alcohol use in Scotland. At the same time, they expressed concern that the Scottish Government had given no consideration to the likely significant impact that a ban would have on Scotland's arts, music and heritage sectors.

3.55 This group repeatedly made the point that banning alcohol sponsorship would have a major impact on the arts and cultural life of Scotland. They noted that many events are already under severe financial pressure due to increased costs and customers having less disposable income. They pointed out that audiences had still not recovered to their pre-Covid levels. In addition, they said that many previous sponsorship arrangements (for example, with the financial services industry) have been recently scaled back because of increased costs for sponsors or changes in their commercial priorities. Respondents expressed concern that the Scottish Government now appeared to be seeking to further restrict the sources of income available to the arts and music sectors without any offer of making up the shortfall.

3.56 One organiser of a major international arts festival said that alcohol sponsorship allowed them to fund extensive community-based outreach work and subsidy programmes. There was concern that withdrawal of such a significant source of funding would force arts and cultural events organisers to operate increasingly on a commercial model and decrease access to the arts, particularly for those on lower incomes or in areas of deprivation – thus undermining a range of Scottish Government commitments set out, for example, in the Culture Strategy and the National Performance Framework.

3.57 The point was also made that countries like France, Ireland and Norway (cited in the consultation document as places where events sponsorship had been banned) have very different funding landscapes for the arts. Unlike in Scotland, all these countries provide generous state subsidies or other forms of public funding to the creative sector.

3.58 Respondents in this group repeatedly said that if alcohol sponsorship of arts, music and heritage events were banned, many events currently held in Scotland would no longer be viable. This would result in the closure of venues, significant loss of employment, and loss of opportunity for the next generation of Scottish artists and musicians.

3.59 They also noted that the arts and music festivals generate significant income for the Scottish tourism and hospitality sectors. If these events were no longer held, the impact would be felt widely across Scotland. Some events organisers said their sponsorship arrangements are largely with Scotland-based drinks companies – giving those brands an opportunity to showcase their products to visitors from across the UK and internationally.

Other views on alcohol events sponsorship

3.60 Respondents who answered 'don't know' at Question 4 often highlighted reasons for and against prohibiting alcohol events sponsorship. While some in this group saw a need to address the over-consumption of alcohol, they also thought a blanket ban on sponsorship was not the best approach to take. Some argued for an approach that takes account of the nature and target audiences of events.

3.61 It should be noted that a small number of public health organisations answered 'no' or 'don't know' in response to Question 4. One of these commented that 'the link between sport and alcohol feels like an important one to break; it is perhaps less important for other areas, but clear guidance and the use of alternative sponsorship should be considered'. Two other respondents pointed out that it creates an ambiguity to ban alcohol sponsorship at events where alcohol is being served.

Coverage of a prohibition on alcohol events sponsorship (Q5)

3.62 Question 5 asked: if alcohol events sponsorship were to be prohibited, what types of marketing do you think should be covered by a prohibition?

3.63 Those who opposed a ban on events sponsorship gave two main responses at this question. These were (i) 'None' (that is, no types of marketing should be covered by a prohibition) or (ii) 'I don't think (or agree) that alcohol events sponsorship should be prohibited'. In most cases, such responses were made without further comment. A third very common response among this group was simply to refer back to their response at Question 4, without further comment.

3.64 However, occasionally respondents in this group did offer suggestions. These largely focused on prohibiting any form of marketing that (i) is targeted at events intended primarily for children, young people and families, (ii) glamorises or encourages over-indulgence, or (iii) promotes 'free' or 'cheap drinks' – all of which, they said, are currently banned by existing codes of practice. Occasionally, respondents in this group suggested a ban on alcohol marketing that involves celebrity endorsements, giving away free branded merchandise or follow-up marketing, and / or the naming of events for alcoholic drinks.

3.65 In contrast, most respondents who supported a ban on alcohol events sponsorship wanted all types of marketing to be covered. This, they said, would include festivals, concerts and cultural events, and community festivals and events. This group suggested, once again, that the Tobacco Advertising and Promotion Act 2002 could provide a useful model for such restrictions.

3.66 Some respondents in this group made more specific suggestions. These respondents thought that a ban on alcohol events sponsorship should cover:

• Alcohol-branded logos worn by staff
• Banners, branded event merchandise or hand-outs of alcoholic products, and the use of images associated with alcoholic products to promote non-alcoholic products
• Advertising of alcohol inside and outside venues where events are taking place
• All online, broadcast, print, and social media promotional activity relating to the event, including ticketing
• Product endorsements by event staff or anyone providing entertainment
• In-person and virtual events.

3.67 There were suggestions that the definition of 'event' should be clear to avoid ambiguity or loopholes.

Exceptions to prohibiting alcohol events sponsorship (Q6)

3.68 Question 6 asked respondents for their views about what, if any, events should be excepted from a prohibition on alcohol events sponsorship, and why. The most common view among those who opposed a prohibition on alcohol events sponsorship was that 'there should be no ban' or 'alcohol sponsorship of events in Scotland should not be prohibited' – with no further comment.

3.69 However, some respondents in this group did make suggestions about events that should be excepted from any future prohibition on alcohol events sponsorship, if it is introduced. Among this group, the recurring view was that all events targeted primarily at adults (over-18s was the usual interpretation) should be exempt from a ban, and only events targeted primarily at children and young people (as audience or participants) should be subject to a ban. Respondents in this group also often suggested that, if a ban were introduced, local community or charity events (including Highland Games) should be excepted.

3.70 Other relatively frequent suggestions included:

• Food and drink festivals and exhibitions (including beer / ale / gin / whisky / cocktail festivals)
• Charity fundraisers
• Hotel and bar promotional events
• All cultural events (including events held in galleries and museums)
• Regional events / festivals
• Music and arts festivals.

3.71 Finally, a few respondents in this group thought certain types of alcohol sponsors should be exempt from any ban – in particular, small craft breweries and distilleries.

3.72 Among respondents who supported a ban on alcohol events sponsorship, the most common view was that there should be no exceptions since 'consistent, comprehensive, and clear bans are more effective and easier to implement and enforce than partial or unclear ones'.

3.73 However, a few individuals and organisations in this group suggested possible exceptions – if exceptions were to be permitted – and there was some overlap between these suggestions and those made above by respondents who opposed a ban on alcohol events sponsorship. These included:

• Events targeted at adults / people over 18 (including live, broadcast or online events)
• Locally organised events
• Food and drinks festivals (e.g. beer / gin / whisky festivals, etc.) or any promotion or event run by a brewer, or other company promoting their own brand
• Cultural events with small venue-based settings (e.g. Celtic Connections, the Fringe)
• Cultural events that attract a mainly tourist audience (e.g. Edinburgh Military Tattoo)
• National or international events showcasing Scotland's brewing or distilling heritage.

3.74 Some public health and third sector organisations also suggested that alcohol marketing could take place at clearly defined bar / alcohol sections at events – where the bar is separated from general public view and marketing is only visible to those intending to purchase alcohol.

3.75 Finally, within this group, it was noted that some other countries permit exemptions to statutory events sponsorship restrictions. In Ireland, for example, sponsorship restrictions apply only to events that are aimed at children (as participants or audience), or events which involve driving or motor racing. It was suggested that this could be a model for Scotland to follow if there is not support for a full ban on alcohol events sponsorship.

The option of a lead-in period (Q7)

3.76 The consultation paper recognised that banning alcohol sponsorship of sporting and non-sporting events could present challenges for organisations with current sponsorship agreements in place. It also recognised that sponsorship arrangements, by their very nature, often run over a number of years. Thus, Question 7 asked for views on whether there should be a lead-in time if restrictions on alcohol sponsorship of sporting and non-sporting events were introduced.

3.77 Table 3.3 shows the following:

• Overall, around two-thirds of respondents (62%) thought that there should be a lead-in time if alcohol sponsorship restrictions are introduced in Scotland, while a quarter (24%) thought there should not. The remaining 13% selected 'don't know'.
• Levels of agreement with the proposition were similar for both organisations (61%) and individuals (63%). Levels of disagreement with the proposition were also similar for both organisations (28%) and individuals (24%).
• Among organisations, levels of agreement were highest among public health and third sector organisations (95%), events and sporting organisations (74%), and other organisation types (60%). Levels of agreement were lower among retail and hospitality organisations (42%), and advertising and media organisations (36%); a relatively high proportion of this final group (43%) selected 'don't know'.

Table 3.3: Q7 – If alcohol sponsorship restrictions are introduced, do you think there should be a lead-in time for these?

	Yes		No		Don't Know		Total
Respondent type	Number	Percent	Number	Percent	Number	Percent	Number	Percent
Alcohol producers	40	43%	40	43%	13	14%	93	100%
Events and sporting organisations	35	74%	6	13%	6	13%	47	100%
Retail and hospitality organisations	18	42%	23	53%	2	5%	43	100%
Public health and third sector organisations	59	95%	1	2%	2	3%	62	100%
Advertising and media organisations	5	36%	3	21%	6	43%	14	100%
Other organisation types	9	60%	4	27%	2	13%	15	100%
Total, organisations	166	61%	77	28%	31	11%	274	100%
Total, individuals	1,072	63%	410	24%	233	14%	1,715	100%
Total, all respondents	1,238	62%	487	24%	264	13%	1,989	100%

Percentages may not total 100% due to rounding.

3.78 Respondents' comments at Question 7 indicated that those who opposed a prohibition on alcohol sponsorship of sporting and / or non-sporting events found this tick-box question difficult to answer. This group frequently described this question as 'leading' or 'biased', or said 'the wording of this question pre-supposes the introduction of sponsorship restrictions' – which they did not agree with. Some in this group answered 'yes' on the basis that if a ban on sponsorship were introduced, it should have a long lead-in time; however, these respondents were concerned that their response would be (incorrectly) interpreted as implying support for a prohibition on alcohol sponsorship. Because of this, others in this group refused to answer the tick-box at Question 7 at all, and still others opted to say 'don't know' instead.^[12] Respondents who supported a ban on alcohol sponsorship did not have the same difficulties with this question. This point needs to be taken into consideration when interpreting the findings shown in Table 3.3 above.

3.79 Because of the difficulties some respondents had with this question, the analysis of the comments at Question 7 is not presented in terms of 'support for' or 'opposition to' a lead-in time. Instead, the comments are discussed as 'views on lead-in times among those supporting a prohibition on sponsorship' and 'views on lead-in times among those opposing a prohibition on sponsorship'.

Views on lead-in times among those supporting a prohibition on sponsorship

3.80 Respondents who supported a ban on alcohol sponsorship acknowledged the importance of a lead-in time to avoid the potential legal and financial consequences of organisations having to withdraw from existing sponsorship contracts. In general, however, this group favoured a short lead-in time often suggesting that it should be 'as short as feasible'. Among organisations, specific suggested lead-in times ranged from 6 months to 3 years, with the most common view being that '2 to 3 years' would be a suitable timescale. Individuals proposed similar lead-in times.

3.81 Note that one public health organisation that supported a ban on alcohol sponsorship answered 'no' at Question 7. This organisation wanted no lead-in time for sponsorship restrictions, arguing that this was in line with a children's rights approach.

Views on lead-in times among those opposing a prohibition on sponsorship

3.82 As noted above (see paragraph 3.78), those who opposed a ban on alcohol sponsorship answered this question in a variety of ways. Regardless of how these respondents replied to the tick-box question, they all essentially expressed the same views in their comments – often stating explicitly that they did not support a ban on alcohol sponsorship. In many cases, this type of comment was the only view expressed.

3.83 Less often, respondents in this group went on to discuss the importance of a lead-in time and to offer a suggestion about how long this should be. Some did not suggest a specific lead-in time but said that existing sponsorship arrangements should be able to be honoured in full. A recurring view among this group was that a long lead-in period would give sporting and music / cultural organisations time to seek alternative sources of revenue and would give the alcohol industry time to adjust and plan for the changes.

3.84 Among organisations that proposed a specific lead-in time, the most common view was that 5 to 10 years would be appropriate, although some suggested much longer periods. Occasionally, individuals in this group suggested lead-in times ranging from 1 year to 25 years. However, individuals were more likely to propose lead-in times involving hundreds, thousands or even millions of years – thus essentially reiterating their opposition to a ban on alcohol sponsorship. Other individuals made more general statements saying, simply, 'as long as possible'.

3.85 Both organisations and individuals in this group often said that, if sporting groups and events organisations were unable to find alternative sponsorship, the Scottish Government should make up any shortfall.