Restricting alcohol advertising and promotion: consultation

8. In-store alcohol marketing

“When you go to the till, you pass the big alcohol bit” (9-11 year old, Children’s Parliament)

“Alcohol is right at the counter… it’s a trigger for me, so I have to avoid it. I don’t go there. If I haven’t got milk, I have to wait until I go to the [big] shops.” Lisa, 1 year sober

8.1 In-store alcohol marketing concerns all the activity that takes place inside a shop or supermarket to increase the visibility and attractiveness of a product to induce sales. This could be, for example, moving a product from an aisle shelf to an end-of-aisle display.

8.2 In Scotland, the way that alcohol is sold in the retail setting is regulated in part through the licensing system. To sell alcohol there are specific conditions attached to the mandatory Premises Licence including the requirement to only display alcohol for sale within an alcohol display area/s in store. Temporary price reductions and quantity discounts (e.g. multi-buys or discounts on bulk purchases) are also prohibited.

8.3 Alcohol promotions, connected to that specific premises, are restricted to the alcohol display area or to tasting rooms and are prohibited within a 200 metre vicinity of the premises.

8.4 Despite the current rules, alcohol is still legally promoted in-store through the placement of alcohol. Research shows that over half (58%) of children and young people surveyed in Scotland report seeing alcohol marketing in-store. This could be a wide range of marketing activities such as an aisle-end display with promotional materials or signage.

8.5 Visibility of alcohol in the retail environment may influence children to think of alcohol in the same way as other everyday consumer goods sold at shops like food, clothes and medicines, and contribute to the normalisation of alcohol. This may create positive attitudes around alcohol which later influence consumption decisions.

8.6 People in recovery in Scotland have reported that retail-based environments are their single biggest challenge to recovery. Key factors included the visibility of alcohol in shops and in-store marketing and price promotions. Those in the early stages of recovery cited the everyday difficulties of negotiating the city space whilst avoiding alcohol triggers. Participants who avoided alcohol outlets spoke not only of avoiding premises themselves, but also of the need to avoid the alcohol aisles due to both the presence of alcohol and in-store marketing and price promotions.

“I had to get my neighbour to get my shopping, I just did not trust myself – it looked too good.”

Person in recovery

“I would like to see more consistency and at the very least alcohol being hidden in the back corner, this would make things easier.”

Person in recovery

How can we address this issue?

8.7 The Children’s Parliament project recommended further restrictions on the in-store environment.

Children’s Parliament

Investigators felt that alcohol should not be advertised or displayed in shops where children can see it. Children do not want to be exposed to alcohol in or outside shops and supermarkets. Investigators called for alcohol to be sold in adult-only sections of shops, separate rooms in regular shops and supermarkets dedicated to alcohol sales.

Window Displays

8.8 In order to reduce exposure to alcohol in the retail environment, we are considering whether the restrictions around the alcohol display area need to be tightened. This would prohibit window displays from being included within the permitted alcohol display area, which would reduce the visibility of alcohol from outside the shop itself. Evidence shows that shop fronts are a source of marketing exposure for both children and young people as well as those in recovery.

Defining location of alcohol display areas

8.9 Current regulation sets out that alcohol can only be displayed for sale in one specific area of the premises. This one area must be agreed with the Licensing Board but can be situated in main thoroughfares within the shop, including near the entrance or exit, or near checkouts.

8.10 This could be addressed by defining where an alcohol display area could be located, for example near the back of the shop away from entrances, exits or checkouts. Where alcohol is displayed behind the checkout this could be required to be in a closed cupboard, like tobacco products. For some small shops this could significantly limit how alcohol could be sold. Further work will need to be undertaken on the impact to small retailers before any potential restrictions were introduced.

8.11 The use of mixed aisles could be restricted. This would stop one side of a shop aisle featuring alcohol products but the other featuring non-alcohol products. This would limit the visibility of alcohol to only those who make a specific decision to buy alcohol rather than being visible to anyone.

Limiting aisle-end displays

8.12 Aisle-end displays increase prominence and visibility of products to consumers and are used to drive product sales. A UK study found that an end-of-aisle position for alcohol, including beer, wine and spirit products, increased sales by between 23.2% and 46.1%. Another study found a substantial increase in sales of products positioned at the ends of aisles, soap and milk in this case. This may be because aisle-end displays increase visibility and thereby impulse or unplanned purchase.

8.13 Aisle-end displays of alcohol are therefore likely to do two separate things:

• drive sales of alcohol amongst legal age purchasers
• increase the visibility of alcohol and alcohol brands amongst all consumers, including children and those in recovery.

Question 11

Do you think that we should further restrict the visibility of alcohol in retail environment, giving reasons for your response?

For example by;

• restricting window displays of alcohol,
• restricting the use of mixed alcohol and non-alcohol aisles,
• prohibiting aisle-end displays of alcohol,
• redefining the alcohol display area, and/or
• covering alcohol behind till areas similar to tobacco.

Please tick one

Yes

No

Don’t Know

Please explain your answer in the text box.

Illustrative example – Irish approach

8.14 In 2018 Ireland introduced a policy of structural separation of alcohol within the retail environment to reduce alcohol consumption, delay the initiation of alcohol consumption by children and young people and in doing so reduce alcohol-related harms. The legislation mandates specific ways that alcohol can be displayed and advertised within mixed retail outlets, shops that sell alcohol and other products.

8.15 Retailers who sell alcohol alongside other products, can store alcohol in one storage unit behind the counter. This cannot be accessible to members of the public and should remain closed when not in use, with products not visible when closed. In addition to this one unit, mixed retail shops can also display and advertise alcohol products using one of the following three options:

• A separate area of the shop separated by a physical barrier (1.2 metres+ high) and through which alcohol and advertisements for alcohol are not visible.
• One or more enclosed adjacent storage units in which alcohol is not visible up to a minimum height of 1.5 metres.
• A maximum of three open adjacent units, each not exceeding 1 metre wide and 2.2 metres high.

8.16 Restrictions on placement within Ireland came into force in November 2020, as such there is no evaluation yet of impact. However, we welcome views on if we should consider further restricting the placement and location of alcohol in stores. The Irish approach is used to illustrate what this could look like in Scotland.

Question 12

Do you think we should consider structural separation of alcohol in Scotland to reduce the visibility of alcohol in off-trade settings (e.g. supermarkets)?

Please tick one

Yes

No

Don’t Know

Please explain your answer in the text box.

Question 13

How do you think structural separation of alcohol in Scotland could operate? (e.g. with barriers, closed display cases)

Please explain your answer in the text box.