I warmly thank colleagues who signed my motion and facilitated this debate on what I believe to be an important public health issue. Even more, I thank those intrepid souls who have stayed behind to hear the opening speech, and those who are participating in the debate—it has been a long day for us all.
I thank members of the cross-party group on improving Scotland’s health: 2021 and beyond, of which I am co-convener. Many of the members are active campaigners against the irresponsible marketing of health-harming products. Specifically, I am grateful to Alcohol Focus Scotland and the Advertising Standards Agency for their briefings.
It is undeniable that marketing drives the consumption of health-harming products, including alcohol. On average, every week, there are 22 alcohol-specific deaths in Scotland and 683 hospital admissions. Those are not just statistics, they are people, families, and communities that are deeply affected by alcohol harm.
The first United Kingdom-wide study that examined awareness of alcohol marketing and ownership of alcohol-branded merchandise in young people was co-ordinated by researchers from the institute of social marketing at the University of Stirling and Cancer Research UK. It found that young people, above and below the legal purchasing age, are conscious of alcohol marketing and that almost one in five owns alcohol branded merchandise. At least half of 11 to 19-year-olds who were surveyed saw the equivalent of one alcohol advert every day, while a third of under-18s saw two a day. On the whole, young people easily recalled around a third of the alcohol brands in the survey.
Those findings are supported by a study that was conducted in 2015 by Alcohol Focus Scotland, Alcohol Concern, balance north east and Drink Wise, which found that 10 and 11-year-olds were more familiar with certain beers than with leading brands of biscuits, crisps and ice cream.
Of course, awareness is not an issue in itself, but when Dr Nathan Critchlow presented the UK-wide survey to the cross-party group on Scotland’s health, he emphasised results that demonstrated that, in current drinkers, alcohol marketing awareness was associated with increased consumption and greater likelihood of higher-risk consumption. Dr Critchlow’s assertion is consistent with international research that shows that children find alcohol marketing messages appealing and that that influences their perception of alcohol. We must all be cognisant that alcohol marketing reduces the age at which young people start drinking, increases the likelihood that they will drink and, if they already drink, the amount of alcohol that they consume.
Alcohol marketing is particularly prominent in the sports sector. Alcohol brands are high-profile sponsors of major sporting events that are viewed by millions of adults and children alike.
Scottish Women’s Football is setting a sterling example in that regard, by taking a strong stance against alcohol sponsorship, as part of its aspiration to represent a clean sport. As SWF chair Vivienne MacLaren put it:
“Accepting alcohol and gambling sponsorship would be incompatible with our role in promoting healthy lifestyles amongst girls and women and supporting them to make positive choices.”
Alcohol and gambling industry sponsorship represents major funding sources for grass-roots sport, and it is a bold and admirable step to reject outright such financial backing. I hope to see more sporting bodies and teams follow the lead of SWF and reject alcohol marketing.
At the February meeting of the CPG on Scotland’s health, attendees unanimously agreed that alcohol marketing has no place in childhood. I whole-heartedly believe that all children should have the opportunity to play, learn and grow in spaces that are healthy, safe and free from exposure to alcohol advertising and sponsorship.
Television advertising remains one of the biggest sources of exposure to alcohol imagery, and commercial adverts for alcohol continue to air before the 9pm watershed. Later this year, the Advertising Standards Authority will publish research on children’s exposure to alcohol product ads on TV. However, according to the ASA’s research, in 2017, children’s exposure to alcohol ads, relative to that of adults, was 22 per cent. That figure is too high.
As colleagues know, powers over broadcast advertising are reserved to the UK Government. Therefore, I welcome the Scottish Government’s assurances that it continues to urge its UK counterparts either to protect children and young people from exposure to alcohol marketing on television before 9pm and in cinemas, or devolve the powers so that we can make that decision in Scotland.
Of course, we have powers to regulate other marketing channels, including public spaces, alongside digital and online routes. That is why I welcome the commitment within the Scottish Government’s “Alcohol Framework 2018: Preventing Harm” to “consult and engage” on measures
“to protect children and young people”.
Restricting alcohol advertising is one of the World Health Organisation’s three “best buys”, or most cost-effective methods of reducing alcohol consumption and related harm across a population. Those restrictions ensure that vulnerable groups, such as children and young people, and those who are recovering from alcohol dependence, are specifically protected from the impact of alcohol marketing. I trust that that is something that the Scottish Government will consider carefully in its next steps on changing Scotland’s relationship with alcohol.
We can learn lessons from our Irish neighbours, who, last year, signed into law the Public Health (Alcohol) Act 2018. That world-leading legislation prohibits the advertising of an alcohol product in or on a sports area during a sports event. It also introduces a broadcast watershed ban on TV alcohol advertising from 3 am to 9 pm and, for alcohol advertising on radio programmes, from midnight to 10 am and 3 pm to midnight. Another key tenet of the new law is the introduction of a structural separation of alcohol from other products in retail outlets, as happens in many other countries. Over the next three years, I will watch the act’s implementation, with a view to pushing for evidence-led best practice in Scotland.
Looking more broadly at alcohol marketing, I note the calls from a number of organisations to end self-regulation in the alcohol industry, particularly a report published last year by Alcohol Concern and Alcohol Research UK entitled “Fit For Purpose? An analysis of the role of the Portman Group in alcohol industry self-regulation”.
The Portman Group is one of the key regulators of alcohol industry marketing and promotion in the UK, with a code of practice that applies to the naming, packaging, marketing and promotional activity of UK alcohol products. According to the group’s website, it is currently funded by eight member companies, one of which accounts for more than half of the UK alcohol market.
One shortcoming of the group’s self-regulatory approach is its position that a drink may appeal to children if it “resonates with under-18s in a way that it does not with over-18s”. That narrow definition precludes taking action on drinks that appeal to the full range of consumers, including under-18s, and places the focus of enforcement on drinks with a superficial appeal to young children—who are likely to be less interested in alcohol—as distinct from adolescents.
The Portman Group and other regulatory bodies must move beyond the false assumption that underage drinkers are only attracted to childish imagery and accept that appealing to the youth market inevitably captures adolescents. Other criticisms of the self-regulatory approach include overly subjective decision making despite the wide body of evidence available regarding purchasing and drinking behaviours, such as the comprehensive research by Dr Critchlow that has already been described.
I trust that the Scottish Government will consider the shortcomings of self-regulation in its consultation on measures to protect children and young people from alcohol marketing and will work with UK counterparts to strengthen regulation where powers are reserved. The marketing of health-harming products is an issue that involves organisations ranging from the Scottish and UK Governments to regulators such as the ASA, Ofcom and the Portman Group, to alcohol brands, advertising agencies, sporting bodies, cultural event organisers and more.
One body alone cannot manage the multichannel reality of modern marketing practices. Ensuring that our children grow up in spaces free of alcohol-related marketing requires a carefully co-ordinated approach. Yet, just because something is challenging does not mean that we should not pursue it. Just this week, we heard that alcohol sales in Scotland have fallen to their lowest level in 25 years, and data from NHS Scotland showed that alcohol consumption dropped 3 per cent from 2017 to 2018, demonstrating the positive impact of minimum unit pricing. Progressive action works.
Let us build on the momentum from the 2018 alcohol framework, its commitments and the assertive rejection of health-harming sponsorship by Scottish Women’s Football to foster an environment in which children are free from the known harms of irresponsible alcohol marketing.