Alcohol Focus Scotland
AFS
Advocate for evidence-based policies to reduce the harm caused by alcohol.
ID: 652834032831-77
Lobbying Activity
Response to Revision of Food Information to Consumers for what concerns labelling rules on alcoholic beverages
22 Jul 2021
While the UK will not be impacted by the proposals, Alcohol Focus Scotland's work on alcohol labelling demonstrates the problems that the current approach to alcohol labelling within the EU has created for consumers. We support the feedback provided by Eurocare.
We believe that a lex specialis approach is desirable. Alcoholic beverages are not consumed in the same way, nor do they have the same effects, as other food products. As suggested by de Conick and Gilmore in the Lancet, the objectives of consumer protection as well as health and wellbeing of citizens would be better achieved through legislation specifically adapted to the characteristics of these products, rather than legislation applying to food products in general. Inspiration could be drawn from the success of the Tobacco Products Directive (2014/40/EU).
AFS supports option 2. Providing information via labels is a key way to address the ‘legitimate need’ of consumers of ‘access to clear, accurate information’ as identified by the United Nations.
In Scotland, 78% of people supported a list of ingredients and 59% supported calorie information as a legal requirement on alcohol labels.
At least four in five people in Scotland cannot correctly estimate the number of calories in common drinks. Some evidence suggests that providing nutritional information on alcohol labels could help improve alcohol health literacy; e.g. a randomised controlled trial found that energy labels increased the accuracy of energy content estimates.
Health warnings should also be a legal requirement for alcohol labels. The European Commission has stated that “citizens have the right to obtain relevant information on the health impact, and in particular on the risks and consequences related to harmful and hazardous consumption of alcohol”. Consumers also want this information: 63% of people in Scotland think a health warning should be displayed on alcohol labels as a legal requirement .
Only 45% of people in Scotland are aware that alcohol can cause cancer, despite 1,000 deaths each year from alcohol-related cancers. Health warnings on alcoholic drinks can increase awareness of the risks of drinking and even reduce consumption. E.g. a real-world experiment in Canada has shown that enhanced alcohol labels (which included a cancer warning, drinking guidelines and standard drinks per serving) can increase people’s knowledge of the link between alcohol and cancer and drinking guidelines, and prompt people to reduce their drinking.
AFS is strongly opposed to Option 0. The Scottish experience is that a voluntary approach to alcohol labelling fails consumers. A review of UK alcohol labels in 2019 found that 72% failed to list the ingredients in the product and just 7% displayed full nutritional information. Differences were found across drink and manufacturer type.
AFS is strongly opposed to Option 1. There could be no justification for the provision of mandatory information off-label. Recent polling revealed that only 3% of people in Scotland have visited a website address printed on an alcohol product to learn about alcohol health harms and this is supported by qualitative research with young adult drinkers. Relying on website links alone wrongly assumes that everyone has access to the internet; in 2019, only 84% of people in the UK, and just 40% of those aged over 65, used the internet 'on the go'.
Information on websites of industry-funded organisations cannot be trusted. E.g. two published academic studies have indicated that Drinkaware misrepresented the evidence on key risks of alcohol consumption during pregnancy and the alcohol-related risk of cancer. Research has shown that websites and materials of alcohol industry CSR organisations (e.g., IARD, Drinkaware, Drinkwise, Éduc'alcool) are designed to make health-related information about the harms of alcohol difficult to access, enhance exposure to misinformation, normalise drinking and prime people to drink.
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