BALANCE RESPONSE TO THE CONSULTATION ON OPTIONS FOR IMPROVING INFORMATION ON THE LABELS OF ALCOHOL DRINKS TO SUPPORT CONSUMERS TO MAKE HEALTHIER CHOICES IN THE UK
RESPONSE TO THE ‘CONSULTATION ON OPTIONS FOR IMPROVING INFORMATION ON THE LABELS OF ALCOHOLIC DRINKS TO SUPPORT CONSUMERS TO MAKE HEALTHIER CHOICES IN THE UK
PART 1
Introduction
Balance is the ‘North East Alcohol Office’, which was set up in February 2009, to effect a cultural change in the region’s relationship with alcohol and to encourage a safe, sensible and social approach to drinking in localities across the North East. The office is funded on a per capita basis by Primary Care Trusts across the region and it also receives contributions from the Department of Health and the Home Office.
At present, men and women in this region drink significantly more on average than their counterparts in other regions and alcohol-related hospital admissions are approximately 60% higher than the national average for
The office has 3 strategic objectives, one of which is to ‘inform, educate and influence’ in relation to alcohol and in this context, we welcome the opportunity to comment on the options for improving unit and health information on the labelling of alcoholic drinks in the
This response is submitted on behalf of Balance, although it has been approved by stakeholders across the region.
Choice of Option
Balance believes that the existing voluntary agreement to include unit and health information on labelling has not worked, with only 15% of products complying with current guidance, against a target of 50% by 2008.
In our view, it is striking that 2 of the major alcohol producers on the UK market have thus far refused to implement the ‘Memorandum of Understanding’ and under existing voluntary arrangements, it can be argued that the industry is in a stronger position than the Government, enabling the majority of alcohol producers to resist the pressure for better unit and health information on labelling.
The office sees this as evidence that Option 1 (“Do Nothing”) and Option 2 (“Self-Regulation”) are not viable and we believe that decisive and prescriptive action is the best way forward. With this in mind, we fully endorse Option 3 (“Mandatory”) and would encourage the Government to introduce a mandatory labelling requirement, via legislation.
Timescales
On page 5, the document notes that “one option for action needs to be chosen…within a reasonable timescale”. Balance would welcome more clarity about what is meant by “a reasonable timescale” and, taking into account the current reticence of the industry to move quickly on the issue, would urge the Government to adopt clear and challenging milestones – for example, 50% compliance by December 2010 and full compliance by December 2011.
Coverage of the Mandatory Labelling Requirement
Balance acknowledges the logic for focusing regulations on 3 core requirements (as set out on page 21 of the consultation document). However, the office also feels that it is important to maximise the effect and reach of any legislation rather than trying to amend it at a later date and with this in mind, we believe that the mandatory labelling requirement should cover the following information:
§ Unit content of the particular drink as proposed on page 21 (and where applicable – for example, in the case of wine – it should highlight the unit content of a standard (175ml) glass, as well as the bottle);
§ The Chief Medical Officer’s guidelines on daily limits for lower risk regular consumption as proposed on page 21;
§ The Chief Medical Officer’s guidelines on alcohol and pregnancy as proposed on page 21;
Plus, additional requirements covering:
§ The Chief Medical Officer guidelines on alcohol consumption amongst children and young people. Balance believes this is best achieved by the addition of a supplement to the abbreviated pregnancy message as follows: “Avoid alcohol if pregnant, trying to conceive or below the age of 15”. (for reasoning, please see below);
§ Energy information on alcohol labels as on labels of other foodstuffs, in line with the arguments set out on page 13 of the consultation document (for reasoning, please see below).
Recent research amongst 11-15 year old across the English regions, showed that the North East is home to the highest proportion of children and young people who drink alcohol and the region also has the highest rate of under-18s admitted to hospital with alcohol-related conditions. What is more, local research has found that parents provide approximately 50% of the alcohol consumed by children and young people. This presents huge cultural and practical challenges for the region and with this in mind Balance would urge the Government to include a labelling requirement around the CMO guidelines on alcohol consumption amongst children and young people.
Likewise, local research has found that women in particular are concerned about alcohol contributing to weight gain and coupled with the Australian research (cited on page 9 of the consultation document), which showed that consumers saw value in highlighting the calorie content of alcoholic drinks, Balance supports the inclusion of energy information on alcohol labels.
Scope of the Legislation
As noted earlier, Balance shares the opinion that information on labels should not be viewed as a stand-alone measure, but as part of a wide-ranging campaign to raise consumer awareness and education on the health-risks linked to alcohol consumption. As such, the office believes that any legislation should include a mandatory requirement for unit and health information to be available at the point of sale enabling consumers to make informed choices about alcohol products. Balance believes such information should be clearly visible as posters in retail premises with additional shelf markers in off trade premises. The format for such displays is suggested in the appendix to this response.
Similarly, Balance feels that it would be beneficial for the Government to explore the possibility of extending the legislation to cover advertising and direct mail (such as supermarket promotion leaflets advertising alcohol).
PART 2
Response to Questions Relating to Option 3
Q1: Do you support legislating for a mandatory requirement on labelling?
Yes, Balance, the North East Alcohol Office, fully supports the introduction of legislation for a mandatory requirement on labelling.
Q2: Are there any changes to the proposed option content that improve understanding of this information?
Balance believes that the proposed content is clear and relevant. However, as acknowledged on page 8 of the consultation document, correct understanding and recognition of units and daily limits is mixed. With this in mind, Balance believes that labelling information should be part of a much wider campaign to raise consumer awareness about alcohol content and the health risks associated with excess alcohol consumption.
Question 3: Do you think that there should be criteria set to ensure the visibility of the proposed information and make sure that this is readable? If so, what should this be?
Balance believes that the labelling information must be clear, concise and easy to read, covering at least 1/3 of the back label or at least 1/6 of the overall label, in line with labelling requirements for tobacco products. There is a wealth of evidence to suggest that alcohol is one of the major public health concerns for this country, alongside smoking and obesity, and Balance feels that alcohol labelling should be dealt with in the same way as tobacco labelling in terms of the set criteria to ensure the visibility of proposed information.
Question 4: Are you content that the content of possible regulations on the labelling of alcoholic drinks is both reasonable and proportionate? If not, what amendments would you like to see and why?
Balance agrees that the content of possible regulations on the labelling of alcoholic drinks is both reasonable and proportionate. In fact, the office would like to see the legislation extended to cover additional fields of information (calorie content and the Chief Medical Officer’s advice around alcohol consumption amongst children & young people) and additional settings (e.g. point of sale information and advertising and direct mail).
Question 5: Are there any other additions, amendments or deletions you would like to see made to the proposed content? If so, what changes would you like to be made and why?
Balance believes that it would be beneficial to add the following information fields to the proposed content:
§ The Chief Medical Officer guidelines on alcohol consumption amongst children and young people – i.e. “an alcohol-free childhood is the healthiest and best option”; and
§ Energy information on alcohol labels as on labels of other foodstuffs, in line with the arguments set out on page 13 of the consultation document.
The office feels that alcohol consumption amongst children and young people is a major issue, particularly in the North East where levels of consumption are higher than in any other English region, with knock-on effects in terms of high teenage pregnancy rates, truancy from school etc. Setting out a requirement for labelling information about children and young people would raise awareness of the fact that an “alcohol-free childhood is the healthiest and best option” and support Balance and partner agencies in tackling alcohol consumption amongst children and young people.
Balance has carried out a piece of regional research, which suggests that some consumers (particularly young people and women) are concerned that drinking alcohol might make them put on weight. With this in mind, the office believes it would be beneficial to include energy information on alcohol labels, as it would raise awareness of links between excess alcohol consumption and possible weight gain.
Q6: Will there be any one-off costs for your business or those that you represent as a result of the outlined content for possible regulations on the labelling of alcoholic drinks under Option 3? If so, how much? Will these be costs from changing labelling or new labels and if so, could you please quantify them?
Not applicable, although Balance feels that any additional costs would only be incurred on a one-off basis and would be more than off-set by potential, long-term cost savings brought about by reductions in alcohol-related harm.
Q7: Will the proposed content of the regulations under Option 3 result in ongoing costs or benefits to your business or the businesses you represent? If so, could you please quantify them?
As noted above, Balance believes that the introduction of a mandatory labelling requirement, in addition to a wide-ranging, sustained campaign to raise consumer awareness and education on the health risks linked to alcohol consumption could impact upon behaviour, bringing long-term benefits to the NHS and other bodies in terms of reducing alcohol-related harms.
Q8: Will there be any other effects of the proposed requirements under Option 3 on the labelling of alcoholic drinks for your business or those that you represent? If so, could you please quantify them?
Not applicable.
Q9: Are you content with the suggested implementation period for Option 3 (two years from making regulations)? If not, please explain what difficulties may arise from this length of transitional period.
As noted above, Balance believes that it is essential to set clear timescales and milestones for implementation of the mandatory code. The office thinks it would be beneficial to set stretching targets and would encourage full compliance as soon as possible and by the end of 2011 at the latest.
Q10: Are any exemptions or modifications needed for labels on particular classes of alcohol product or for particular alcohol businesses such as small producers (e.g. for small packages or specific products)? If so, please explain how these should operate.
No, Balance believes that the only fair option is to introduce a mandatory labelling requirement for all alcohol products.
Q11: For enforcement agencies, what costs or benefits would you incur as a result of the proposed content of the regulations for Option 3 on the labelling of alcoholic drinks? Please quantify these costs or benefits if you can.
Balance works alongside the police and other enforcement agencies in the North East and the office anticipates that a wide-ranging consumer awareness and education campaign (including a mandatory labelling requirement) would have long-term benefits in terms of reducing alcohol-related crime, bringing potential cost-savings to the police and other enforcement agencies.
From an organisational viewpoint, one of Balance’s 3 strategic aims is to ‘Inform, Educate and Influence’ and the introduction of a mandatory labeling requirement would also support the delivery of this aim.
Q12: If you are a consumer or a group representing the interests of public health or consumers, would there be any benefits or disadvantages to you or the people you represent as a result of the proposed requirements under Option 3 on the labelling of alcoholic drinks? Please provide details.
Balance works alongside public health organisations across the North East and the office anticipates that a wide-ranging consumer awareness and education campaign (including a mandatory labelling requirement) would have long-term benefits in terms of reducing alcohol-related health harms, bringing potential cost-savings to the NHS and partner agencies.
Q13: If you are a small business or their representative organisation, to what extent would, you or the businesses you represent be particularly affected by the regulations on the labelling of alcoholic drinks? Please provide details of benefits and costs if you can.
Not applicable
Q14: If you are a business particularly serving minority ethnic communities, or their representative organisation, to what extent would you/the businesses you represent be affected by the proposed content of the regulations on the labelling of alcoholic drinks? Please provide details of benefits and costs if you can.
Not applicable
Q15: For all businesses, would the proposed content of the possible regulation of labelling alcoholic drinks have any effect, whether beneficial or detrimental, on competition between you and other businesses? If so, please specify.
Not applicable, although Balance believes that the introduction of a mandatory labelling requirement would not have any effect on competition between businesses, particularly if it was introduced across all businesses and brands of alcohol, without any exemptions.
Q16: For all businesses, would the proposed content of the regulations on the labelling of alcoholic drinks have any effect on your trade across the EU or / and beyond? If so, please specify and / or suggest any modifications.
Not applicable.
APPENDIX 1
Proposals for shelf markers in off licenses and supermarkets:
We suggest the display of all core requirements of the label at least every four meters of running length of shelves containing alcohol products. For unit content the display should refer to the individual product labels. eg “for unit content see product label”. We believe that the displays should use typescript of at least 24 point so that they can be read easily.
APPENDIX 2
Proposals for posters in licensed premises:
1. One or more A0 posters (84.1 x 118.9 cm) according to the rateable value of the licensed premises as follows:
Band 1 – with a rateable value under £15,000 - one poster
Band 2 – with a rateable value between £15,001 and £50,000 - two posters
Band 3 – with a rateable value in excess of £50,001 - three posters
2. Centre of the poster to be mounted at a height of six feet and to be visible from at least 50% of the alcohol retailing floor space with independent lighting.
3. Font size to be comparable to appendix 3
(Premises having the required technology could as an alternative use TV screens for display purposes. For such premises standards would need to be developed concerning the display times and duration.)
APPENDIX 3 Proposals for poster (DH approved) in licensed premises (currently in or soon to be in use in health and local authority premises in the North East of England):