ClubsAustralia Response to Trade Measurement Regulation Consultation Paper
ClubsAustralia represents Australia’s 4000 licensed, not-for-profit clubs. Clubs are community based
organisations whose central activity is to provide local community and sporting facilities for their
members. Clubs contribute significantly to their local communities, through employment and
training, direct cash and in-kind social contributions and through the formation of social capital by
mobilising volunteers and providing a diverse and affordable range of services, facilities and goods.
Typically this includes bars and restaurants serving meals and alcohol at affordable prices.
ClubsAustralia welcomes the opportunity to respond to question four of the consultation paper and
discuss the impact of proposed alcohol measurement standards on the club industry.
(a) Should the range of spirits controlled under regulation be extended? Please provide your
reasons.
Clubs currently sell spirits in the standard amounts of 15ml, 30 ml or 60ml and most clubs have shot
glasses or pouring containers available in these standard sizes. ClubsAustralia would support an
extension of the list of spirits controlled under regulation should there be a sufficient level of
evidence to show that increased regulation will improve consumer safety.
(b) Should the requirements be extended to the sale of wine when not pre-packed (includes by the
glass and carafes)? Please explain your reasons.
The requirement should not be extended to the sale of wine by the glass because the cost to
industry to implement a change in the standard wine glass is substantial without guaranteeing
benefits for consumers.
Responsible service of alcohol will not be improved by introducing a standard plimsoll line on wine
glasses. Unlike beer and spirits the alcohol content of wine varies considerably and the standard
view that one 150ml glass equals one and a half standard drinks is not accurate all the time. The
Food Standards Code specifies that to be classified as wine the alcohol content can vary between 8
and 22 per cent and some wine varieties have an even lower alcohol content, for example imported
Moscato is under 8 per cent.
For consumers trying to count their standard drinks it is impossible to calculate standard drinks on
the volume of wine alone without also knowing the alcohol content of the wine. Clubs don’t typically
notify patrons of the alcohol content. Standard plimsoll lines on all glasses will present each glass as
a standard drink, when in reality a 150ml glass of wine could be more than or less than 1.5 standard
drinks. A plimsoll line may therefore serve to trick patrons rather than inform them.
Clubs serve wine types in glasses of different size and shape, for example dessert wine is often
served in smaller glasses and red wine in larger and wider glasses to allow the “nose” of the wine to
be maximised. A standard plimsoll size for glasses of different shapes and sizes will further confuse
patrons due to the different serve sizes and alcohol content of wine types.
For clubs with fine dining restaurants, plimsoll lines on glasses ruin the aesthetic and style of the
dining experience. Waiters with experience know how much a standard serve of wine in the club
constitutes, be that 180ml, 150ml or less. In an effort to diversify their income clubs have been
investing heavily in food service and introducing new, modern restaurants that provide a higher
quality dining experience. Elegant, modern glassware is an important part of this experience.
(c) If in favour of extending the provisions to the sale of wine when not pre-packed, should the
volume for individual glasses be:(i) 150 mL ii) 180 mL (iii) 150 mL and 180 mL? Please provide
reasons for your choice.
ClubsAustralia does not support extending the provisions to the sale of wine when not pre-packed.
(d) Alternatively, should these requirements be removed, allowing the marketplace to determine
the manner in which these beverages are sold? Please provide your reasons.
The marketplace is already determining the preferred size of wine glasses and carafes without a
standard measure for wine served in venues. Some clubs prefer 150ml glasses because each bottle
of wine represents 5 glasses. This can make the management of wine stock, ordering and counting
sales easier for venues. Plimsoll lines may help to reduce wastage for clubs and are a way of
communicating value for money to customers.
There are varied reasons for buying and using different style glasses and clubs should be allowed to
decide what works best for the benefit of their members and guests. Clubs already comply with a
range of responsible service of alcohol measures and a standard measure for wine glasses is not the
best way to promote responsible service of alcohol.
ClubsAustralia asserts that there is no reason to introduce a standard size for all venues as there are
options for clubs already available.
(e) What impact would any of the above proposals have on you and/or your organisation? Please
provide details of costs and benefits incurred.
If plimsoll lines are introduced for all venues serving wine the costs to clubs will vary across the
industry; depending on the size and type of club operation. Prices for wine glasses range from $3 for
a smaller, cheaper glass to $20 for a top quality glass. Each club uses glasses that reflect their
clientele and represent best value for money.
Large clubs with over 2000 wine glasses would face a substantial cost of replacing their glassware,
perhaps as high as $40,000. Any final implementation cost for clubs would depend on the types of
glasses preferred by the club.
Clubs may also incur additional costs when replacing old glasses with new standardised sizes. Clubs
may have shelves, glass racks or dishwashing machines suited to certain size glasses and these may
need to be replaced.
It is also worth noting that clubs are introducing toughened or shatterproof glassware to prevent
glasses from injuring patrons during accidental or deliberate breakage. State regulations, for
example glass bans for certain venues in NSW and Queensland, can also impact the types of glasses
used by clubs. In such cases clubs have recently incurred costs of replacing existing glasses to comply
with government regulation. Such clubs may argue that patron safety is better assured through
shatterproof glassware than through a new standard glass size.
Small clubs that rely on volunteer staff have a limited capacity to replace their wine glasses due to
their lower revenue levels. Replacing perfectly good glassware to meet a new standard size would
be especially wasteful for these clubs.
ClubsAustralia supports government regulation to ensure that glasses currently available on the
market hold the correct volume of wine as stated on the plimsoll line. ClubsAustralia believes that
clubs can best choose which glassware is suitable for their patrons and that responsible service of
alcohol benefits are not enhanced solely by mandating a standard size for wine serves.