The Scottish Retail Consortium (SRC) has submitted a response to the Scottish Government consultation on Restricting Alcohol Marketing and Promotion.
In the response the SRC outlines the following concerns with the measures outlined in the consultation:
- The absence of a Business and Regulatory Impact Assessment, or any engagement with industry, mean the proposals in the consultation are presented without any understanding of the impact on businesses or the economy. That makes it impossible to assess whether they are a proportional public health intervention.
- The proposed in-store changes alone would cost around £96 million to the retail industry through the costs of refitting stores. This cost would stack on top of the £250 million already being spent on the deposit return scheme, and other costs if mooted changes to where high fat, salt, and sugar products can be placed in store.
- The very broad changes to branding could mean off-trade retailers would have to cover windows or branding.
- The proposals to ban alcohol merchandising could include removing fashion items with brand names, or stationary which references alcoholic products.
Commenting on the consultation response, Ewan MacDonald-Russell, Deputy Head of the Scottish Retail Consortium, said:
“Scottish retailers take their duty to sell alcoholic products responsibly seriously. They already comply with a complex and onerous licensing system and have successfully implemented Minimum Unit Pricing. Retailers are legally constrained on where they can sell alcohol in store and follow strict voluntary codes of conduct which ensure alcohol is not marketed at children.
“We don’t believe the evidence in this consultation in any way explains how and why the further measures to restrict how retailers operate would have a specific link to reducing alcohol-related harms. However, we are clear the cost of these measures would be very significant. It would cost over £96 million just to refit Scottish shops to conform to the most extreme of these requirements. That doesn’t include the costs of removing alcohol related merchandise from stores, of changing frontages to hide any sign of alcohol, or the loss of revenue from reduced tourism or events.
“The failure to consult with industry ahead of the publication of the consultation and lack of any accompanying regulatory impact assessment – against the government’s own rule – has made this consultation exercise nearly pointless. Sadly, the consultation doesn’t bring us closer to tacking Scotland’s terrible problems with alcohol misuse because the measures aren’t placed in the context of Scotland’s economy. We hope the Government will learn the lesson from this debacle and engage properly to develop proportional evidence-based interventions which retailers can get behind and which can make a real difference to tackling alcohol misuse amongst the minority who abuse it.”