LVA Opening Statement to the
Joint Committee on Health and Children
on the
Public Health (Alcohol) Bill 2015
26th March 2015
Licensed Vintners Association, Anglesea House, Anglesea Road, Ballsbridge, Dublin 4.
Tel: 01 668 0215 Fax: 01 668 0448 E-mail: [email protected]
Introduction
Good morning. I’d like to begin by thanking the Chairman and members of the Committee for the
opportunity to present the views of the Licensed Vintners Association (LVA) on this important Bill.
We are the representative organisation for the publicans of Dublin. Collectively our members sell
around 30% of the alcohol in the on-trade in Ireland and employ over 12,000 people. See
www.lva.ie for more information.
As we have already made a written Submission to the Committee on the Public Health (Alcohol)
Bill, and I trust that this has been circulated to you, I propose to summarise our key points in the
Statement.
In overview, we broadly welcome the thrust of this Bill and feel that many of its provisions are long
overdue. Our specific points on each of the main headings of the Bill are as follows:
Head 5 – Labelling of Alcohol Products.
In principle, the LVA does not oppose the requirement that alcohol product containers set out:
(a)
(b)
(c)
(d)
Quantity in grams of alcohol.
Energy value.
A warning about the danger of consuming alcohol.
A warning about the danger of consuming alcohol when pregnant.
However, we do believe that the information about quantity in grams of alcohol will be of no benefit
to consumers as they will not understand it. We note that subhead 5, (4) requires licensees with an
on-licence to prominently display a notice inside the premises setting out this information. We
believe that this is the most appropriate and feasible means for publicans to comply with the
labelling requirements set out above.
However, given the nature of the on-trade, and the variety of ways in which alcohol is served (e.g.
draught, poured (spirits, wine), bottles (beer, wine), it is our view that the required notice be the sole
means of communicating the labelling requirements within the on-trade environment.
In addition, to minimise the administration and bureaucracy required to comply with the labelling
requirement, we propose that a standard notice template be developed, in conjunction with the
Department of Health, that sets out the required information by category, rather than by brand. This
information would be supplied by standard pub serving.
Providing this information by brand would be an administrative nightmare and prove overwhelming
for consumers.
Head 6 Minimum Price of Alcohol Products.
The LVA fully supports the proposed introduction of a Minimum Price for Alcohol. In addition, we
believe that the Minimum Price must be set at a high enough level to make a significant impact on
consumption patterns. Put simply, the Minimum Price must be significantly higher than the offtrade market price levels existing in March 2015.
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Subhead 1 (e)
We also fully support this sub-head but propose it should go further, namely, that alcohol should not
be permitted to be sold as part of a “bundled” offer under any circumstances. Our concern here is
that the other bundled products would be deeply discounted to drive alcohol sales. Such promotions
could potentially be funded by the increased retailer margins under Minimum Price. This scenario
must not be permitted under this legislation.
Head 7 Calculation of Minimum Unit Price Alcohol Products.
The LVA argues that the policy objective here should be to return off-trade alcohol price levels to
those existing at the time of the abolition of the Groceries Order in March 2006, adjusting for
inflation in the intervening period.
Accordingly, based on CSO price levels applying at the time of abolishing the Groceries Order, and
adjusting for inflation of 13.6% since then, the off-trade prices that should apply today should be
(rounded):
500ml can lager
700ml bottle vodka
75cl bottle table wine
€2
€23.50
€10
We understand that the Minimum Price will be exclusive of VAT and excise, and that it intended to
be applied at the same rate, whether the alcohol is sold in beer, cider, spirits or wine form.
However, we wish to point out that excise is levied at varying rates depending on the alcohol
category involved. Excise levels in Ireland are extraordinarily high in all categories. VAT at 23% is
further applied to all alcohol categories.
The Government needs to take care that the imposition of a Minimum Price, excise and VAT applies
fairly and equally across all alcohol categories.
The LVA recommends that the focus be to achieve minimum retail prices (inclusive of the
Minimum Price, excise and VAT) that are similar to March 2006 levels in real terms.
This may require that the Minimum Price per unit of alcohol will vary by category.
Ultimately, the aim of introducing the Minimum Unit Price is to impact the retail price.
Accordingly it needs to be communicated in retail price terms (including all taxes) to consumers and
the public.
The retail price levels proposed here will eliminate deep price discounting in all categories, and will
have an immediate and direct impact on alcohol consumption, levels and patterns.
Head 9 Control of Marketing and Advertising of Alcohol Products.
The LVA supports the provision that the marketing and advertising of alcohol in a manner that is
intended or likely to appeal to children be prohibited.
In our view, the main brand owners are responsible in this regard.
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We urge the Government to ensure there is a fair and appropriate balance between prohibiting
advertising / marketing likely to appeal to children, which is a priority, and facilitating brand owners
invest in their brands and implement responsible advertising and marketing programmes.
We urge the Joint Committee on Health and Children to give some consideration to the prohibition
of price-based advertising of alcohol as this has a much more immediate and direct impact on
consumer behaviour.
Head 15 Amendment of Section 9 of the Intoxicating Liquor Act 2008.
It is the LVA’s position that Section 9 of the 2008 Act should be commenced immediately.
Developing and implementing a statutory code for a 2-year period is a poor substitute for full
structural separation. We further believe there is no scenario where such a statutory code could
prove more effective than structural separation.
The LVA notes that the current voluntary code operated and monitored by RRAI (Responsible
Retailing of Alcohol Ireland) is completely ineffective.
We believe that full structural separation would achieve the aim of dramatically reducing the
visibility of alcohol in mixed trading retail environments. In addition, the structurally separate unit
must be required to have:
(i)
Its own dedicated staff.
(ii)
Its own customer pay points and till systems.
These are required to ensure there is specific staff accountability for alcohol retail sales, to facilitate
specific staff training in the responsible retailing of alcohol and to provide for effective point-of-sale
control.
We note this Head provides the EHOs with the powers to enforce the provisions of section 9 in the
event of its commitment.
There appears to be no clarity on which state organisation / officers are responsible for enforcing the
proposed statutory code on the display, sale, supply, advertising, promotion or marketing of alcohol.
This needs to be made explicit.
Conclusion:
The LVA welcomes the publication of the General Scheme of the Public Health (Alcohol) Bill 2015
and supports many of its key provisions. In particular we urge the Government to ensure that a
Minimum Price (including excise and VAT) is achieved that results in significant change in
consumer behaviour and purchasing patterns. Returning alcohol prices, in real terms, to the levels
that applied prior to the abolition of the Groceries Order is a rational approach and would be a
positive step. The issues caused by the wide availability of very cheap alcohol are obvious to all.
In addition, reducing the availability and in-store visibility of alcohol via structural separation is also
essential and we urge the Committee to recommend full structural separation in this regard. There is
no scenario where a statutory code would prove more effective than structural separation.
Thank you for your attention.
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