EXECUTIVE SUMMARY

—  Our beer adds to the enjoyment of life for the overwhelming majority of our consumers; however we recognise that alcohol is associated with certain diseases, health conditions, and negative social consequences, especially when consumed excessively or irresponsibly.

—  The alcohol industry's role includes providing consumers with accurate and accessible information about its products and ensuring that they are marketed in a way that does not encourage irresponsible drinking.

—  As the link between producer and consumer, retailers, large and small, also have a big role in preventing irresponsible consumption and have a great deal of influence over the purchase of alcohol.

—  The actions of the Government in its annual budget over the past ten years have in our view supported the increased consumption of higher strength drinks through above inflation rises in beer duty, while introducing lower rises and even freezes on duty for stronger alcohol products such as wine and spirits.

—  There should be a downward adjustment to the excise duty rate for beer and the removal of the beer duty escalator at the earliest opportunity. This will aid the Government's objective of reducing alcohol misuse by providing a financial incentive for consumers to choose lower strength alcohol products.

—  The initial findings of the University of Sheffield's ScHARR Review of the Effects of Alcohol, Price and Promotion raised the concept of "floor prices". We consider this proposal to be both disproportionate and unnecessary; minimum pricing is an incredibly blunt instrument which imposes significant costs across large sections of society, whilst having very limited benefits in terms of curbing the excesses of the minority.

—  Instead of seeking to tackle alcohol misuse through blanket measures such as high prices that unfairly penalise the vast majority of adult drinkers who consume alcohol sensibly and legally, the UK should target the small minority who harm themselves or others when drinking alcohol.

—  Existing laws governing the sale and consumption of alcohol already provide the police and other enforcement agencies with the power to prevent much alcohol misuse and crime—these laws need to be fully enforced.

—  Tackling harmful drinking patterns will only be effective if people accept their individual responsibility. Increased pricing and restrictions on retailing are a small part of a wider issue which has individual judgement and accountability at its heart.

ABOUT SABMILLER PLC

  1.  SABMiller welcomes this opportunity to respond to the House of Commons Health Select Committee inquiry on alcohol.

  2.  Our response focuses on the Committee's request for evidence on the role of the alcohol industry, central government policy and solutions to tackling alcohol misuse.

  3.  One of the world's largest brewers, SABMiller has brewing interests and distribution agreements in over 60 countries across six continents. Our wide portfolio of brands includes premium international beers such as Miller Genuine Draft (MGD), Pilsner Urquell and Peroni Nastro Azzurro along with market-leading local brands such as Aguila, Castle, Miller Lite, Snow and Tyskie. Six of our brands are among the top 50 in the world. We are also one of the world's largest bottlers of Coca-Cola products.

  4.  Peroni Nastro Azzurro is the leading premium packaged lager sold in restaurants across the United Kingdom.

  5.  Originating from South Africa and now headquartered in London we are listed on the London Stock Exchange falling within the FTSE 20. Our annual turnover in the previous financial year was $21.4 billion.

  6.  SABMiller Core Principles:

—  Our beer adds to the enjoyment of life for the overwhelming majority of our consumers.

—  We care about the harmful effects of irresponsible alcohol consumption.

—  We engage stakeholders and work collectively with them to address irresponsible consumption.

—  Alcohol consumption is for adults and is a matter of individual judgement and accountability.

—  Information provided to consumers about alcohol consumption should be accurate and balanced.

—  We expect our employees to aspire to high levels of conduct in relation to alcohol consumption.

ALCOHOL AND HEALTH

  1.  Our beer adds to the enjoyment of life for the overwhelming majority of our consumers; however we recognise that alcohol is associated with certain diseases, health conditions, and negative social consequences, especially when consumed excessively or irresponsibly.

  2.  In general terms, moderate drinking is associated with a number of health benefits in some people.[414] The evidence also shows that moderate drinkers may experience health benefits in comparison to abstainers. These include lower overall mortality from all health causes.[415] Some people who are regular, moderate consumers of alcohol, including some daily drinkers, have lower risks for some diseases than individuals who drink less frequently.[416] The risk may be lower especially if drinking accompanies meals.[417]

  3.  Harmful outcomes, on the other hand, are generally associated with heavy drinking patterns and alcohol abuse. Harmful drinking patterns include both heavy long-term drinking and heavy drinking episodes, often referred to as "binge" drinking. The outcomes of these drinking patterns may manifest themselves as harm to health or as accidents and injuries.[418]

  4.  But it is important to note that some researchers associate health risks for some people with even moderate levels of consumption.

THE ROLE OF THE ALCOHOL INDUSTRY

  5.  The alcohol producer's role includes providing consumers with accurate and balanced reminders about its products, and ensuring that these products are marketed in a way that does not condone or promote irresponsible drinking.

  6.  As the link between producer and consumer, retailers, large and small, also have a big role in preventing irresponsible consumption and have a great deal of influence over the purchase of alcohol.

  7.  Government's role, both local and central, includes ensuring the laws on the sale and consumption of alcohol are fully enforced and placing restrictions only when targeted at problem groups not the majority who drink responsibly and cause no harm to themselves or others.

  8.  Producers, retailers and government also need to accept that tackling harmful drinking patterns will only be effective if people accept their individual responsibility towards their own alcohol consumption.

Provision of information

  9.  SABMiller is proactive in providing consumers with accurate and balanced information about alcohol through our innovative website, www.TalkingAlcohol.com. This award-winning website, the first of its kind from a major alcohol producer, describes in detail the health and social considerations of drinking alcohol such cancer, liver disease, and stroke among others are all discussed in a factual, balanced manner.

  10.  In addition to the health and social considerations of alcohol consumption, TalkingAlcohol.com provides our consumers with nutritional facts of more than 100 of our most popular brands of beer; such as alcohol content, calories, and cereal grains. There is also a detailed explanation of the brewing process so that consumers can better understand how beer is made, the ingredients that are used, and how the alcohol contained in beer is derived.

  11.  TalkingAlcohol.com is available in English, Spanish, Polish and Czech, with the Russian and Italian versions coming soon.

  12.  Elsewhere, industry has worked to provide relevant and factual information to consumers in accessible means such as through initiatives undertaken by the Drinkaware Trust of which SABMiller was the first corporate member.

  13.  The Drinkaware Trust is an independent charity set up with donations from the drinks industry to equip people with the knowledge they need to make decisions about how much they drink. The Trust promotes responsible drinking and seeks to find innovative ways to challenge the national drinking culture and tackle alcohol misuse.

Labelling

  14.  SABMiller supports the Government's voluntary labelling code and was the first alcohol producer to commit to fully implement the Government's voluntary code on labelling. Our premium brand, Miller Genuine Draft, was the first product to have the proposed labels in its entirety.

  15.  We agree with the Department of Health that there should be a debate on the merits of making the current voluntary agreement statutory as labels have been shown to be useful reminders to drinkers. However we do not believe that the use of such labels is in itself a suitable means for individuals to make fully informed choices about alcohol consumption.

  16.  Labelling should be a reminder about levels of unit consumption and key health messages, reinforcing the consumer's existing understanding of responsible alcohol consumption developed from the full provision of accurate, factual information.

Responsible marketing

  17.  Though we recognise that consumers are ultimately responsible for their own drinking decisions, our advertising will not present refusal, abstinence or moderate consumption in a negative light, suggest that alcohol has curative qualities, depict pregnant women, or be targeted to underage people.

  18.  In addition to compliance with the legislative codes, SABMiller adheres to the Code on Non Broadcast Advertising, Portman Group Code and the SABMiller Policy on Commercial Communications. When combined with the legislative codes, these voluntary codes help strike the balance between society's expectation for responsible advertising, our right to advertise a legal product in a free and competitive market, and the adult consumer's right to have information about our brands.

  19.  Currently our advertising in the UK is based on audience demographics, as directed by Ofcom. This is the case for all alcohol advertising in the UK. This approach states that at least 70% of the audience for a particular programme must be over 18 for alcohol advertisements to appear irrespective of the time of day.

The role of retailers

  20.  As well as ensuring our products are brewed and marketed responsibly, we also expect them to be sold and purchased legally and responsibly.

  21.  One of SABMiller's signature programmes conducted in the United States and under consideration for adaptation to the UK is the Responsible Retailing Programme. This programme is evidence-based, having been designed and researched over many years by Dr. Brad Krevor of the Responsible Retailing Forum at Brandeis University—with proven results.

  22.  The programme brings together local police, retailers, and the local authorities and community in an intensified programme to reduce sales to underage people. The programme brings tested training tools to retailers and their employees, and measures implementation of the tools through a mystery shopper programme.

  23.  To take an example from the UK, a scheme led by Trading Standards officials in St. Neots, Cambridgeshire has seen impressive initial results through the effective and coordinated enforcement of existing laws.

  24.  The Community Alcohol Partnership led to a fall in antisocial behaviour of 42% and a decrease in alcohol related litter by 92%.[419] This involved no additional resources, no increased purchasing age and did not shift the problem on to another area. Its success came from effective enforcement and education through a partnership approach and demonstrates that coordination of responsible business and other stakeholders can be highly effective.

GOVERNMENT POLICY

Beer duty escalator

  25.  The Government's consultation document, Safe, Sensible, Social, notes that the increasing consumer preference towards wine and spirits has been one of the drivers behind increased hospital admissions.

  26.  The actions of the Government in its annual budget over the past ten years have in our view supported this trend through above inflation rises in beer duty, while introducing lower rises and even freezes on duty for stronger alcohol products such as spirits.

  27.  This was best highlighted in the 2008 pre-budget report, which increased the duty on beer by 8% and the duty on spirits, following lobbying by distillers, by only 4%.

  28.  This shift to the consumption of higher strength alcohol will be exacerbated by the ongoing duty escalator for alcoholic drinks which, combined with the restoration of the 17.5% rate of VAT in January 2010, will see prices rise further. Again, beer will be the hardest hit by these increases and the duty on beer will rise a further 40% by 2012. This reduces the financial incentive for consumers to choose lower strength alcohol products.

Minimum pricing

  29.  The initial findings of the University of Sheffield's ScHARR Review of the Effects of Alcohol, Price and Promotion raised the concept of "floor prices".[420] These have also been proposed by the Scottish Government in their report Changing Scotland's Relationship with Alcohol. We consider these to be both disproportionate and unnecessary.

  30.  Minimum prices interfere with the underlying principles of a free market economy. The process of setting minimum prices is arbitrary to which there is no end, and it is predicated on the improbable assumption that raising the price of alcohol will make the minority of drinkers who misuse alcohol and/or engage in anti-social behaviour act differently.

  31.  Minimum prices are most likely to impact the drinking behaviour of those adults who enjoy drinking alcohol and who do so in a legal, moderate, and socially-acceptable way. In much of continental Europe, the price of alcohol is far cheaper than in the UK but there are not the same problems; societal tolerance (or intolerance) of those who drink irresponsibly or illegally appears to be a greater determinant of the extent to which a country will experience alcohol harm than the price of alcohol.

  32.  SABMiller recently commissioned Centre for Economics and Business Research (CEBR) to evaluate the ScHARR review of alcohol pricing and promotion effects on consumption and harm. The CEBR research found that:

"According to the UK Government's own research (Meier et al, University of Sheffield, 2008) those deemed to be hazardous or harmful drinkers are much less sensitive to higher prices than moderate drinkers, in terms of their overall alcohol consumption. Consequently, whilst all drinkers have to pay more for their purchases, moderate drinkers would be more responsive to price changes than those whom the Government is targeting. Based upon the University of Sheffield research, we estimate that a minimum price at 40 pence per unit would reduce consumption amongst harmful drinkers by only 2.3%."

  33.  This means that minimum pricing is an incredibly blunt instrument which imposes significant costs across large sections of society, whilst having very limited benefits in terms of curbing the excesses of the minority.

Mandatory retailing code

  34.  The Policing and Crime Bill, currently progressing through Parliament, proposes the creation of a mandatory code for retailers. Existing laws are already in place allowing those in breach of regulations to face penalties—these laws need to be fully enforced before any new measures are considered.

  35.  Individuals and those licensees who repeatedly fail in their legal obligations should be held. Further restricting the commercial freedom of retailers and venues would be indiscriminate in its approach and penalise licensees and retailers which operate effective policies towards the responsible sale of alcohol.

  36.  The underlying issue which must be acknowledged in an alcohol retailing code is that there is a shared responsibility on the part of both the retailer and the patron when it comes to alcohol service and consumption.

  37.  Existing laws are already in place allowing those individuals and transgressing licensees in breach of the law to face penalties—these laws need to be fully enforced before any new measures are considered.

Chief Medical Officer's Guidance

  38.  A recent study found that the wide availability of social sources, including parents and relatives, meant that reducing availability of alcohol from commercial sources has only a moderate impact on the amount of alcohol consumed by underage drinkers. Of those surveyed that did consume alcohol, 87% secured alcohol from social sources at least once over the relevant 30 day period.[421]

  39.  SABMiller welcomes the British Chief Medical Officer's Guidance on the Consumption of Alcohol by Children and Young People published in January 2009 which advises parents on how to encourage their children, and themselves, to develop a responsible attitude to drinking.

  40.  This guidance is an important contribution to reducing the harm caused by underage drinking and will hopefully discourage parents, friends and relatives from providing alcohol to those under the legal drinking age.

SOLUTIONS

Fair taxation for beer

  41.  The Department of Health's 2008 consultation for tackling alcohol misuse—Safe, Sensible, Social: Consultation on further action—cites "a shift to higher alcohol strength beverages, including a shift from beer to both wine and spirits" as one of factors responsible for the rise in harmful alcohol consumption. The decisions taken in the 2008 Pre Budget Report, at best do little to address this trend, and at worst actively undermine the work of the Department of Health and the Home Office, both of which are seeking to tackle the effects of alcohol misuse and its impact on public health and crime.

  42.  This shift to the consumption of higher strength alcohol will be exacerbated in the future by the incoming beer duty escalator which and the expected restoration of the 17.5% rate of VAT in January 2010. Again, beer will be the hardest hit by these increases and the duty on beer will rise a further 40% by 2012 The decisions taken on excise duty for alcohol will do little to reverse the trend identified by the Department of Health.

  43.  If HM Treasury wants to support the Department of Health and Home Office's initiatives to tackle alcohol misuse, there should be a downward adjustment to the excise duty rate for beer and the removal of the beer duty escalator at the earliest opportunity. This will aid the Government's objective of reducing alcohol misuse by providing a financial incentive for consumers to choose lower strength alcohol products.

A targeted approach, fully enforced

  44.  Instead of seeking to tackle alcohol misuse through blanket measures such as high prices that unfairly penalise the vast majority of adult drinkers who consume alcohol sensibly and legally, the UK should target the small minority who harm themselves or others when drinking alcohol.

  45.  These targeted efforts should include strict enforcement of existing laws on underage drinking, disorderly or violent behaviour, and drink driving; early medical screening and treatment for people with alcohol problems; educating parents on how to talk with their children about not drinking while being good role models themselves if they choose to drink; and penalising retailers who violate the laws regarding sale or serving of alcohol to name just a few.

  46.  The existing laws governing the sale and consumption of alcohol already provide the police and other enforcement agencies with the power to prevent much alcohol misuse and crime—these laws need to be fully enforced.

Personal responsibility

  47.  Tackling harmful drinking patterns will only be effective if people accept their individual responsibility. Increased pricing and restrictions on retailing will not solve the problem of alcohol misuse. These are a small part of a wider issue which has individual judgement and accountability at its heart.

  48.  While government, public services and industry have a role to play in raising awareness about the potential harm of excessive alcohol consumption, much of the information about alcohol is conveyed through informal channels. In particular, family and peers play a key role in the development of attitudes, awareness and behaviours around drinking. 378 Government and industry initiatives should seek to support them in their role.

  49.  Parents play a crucial role in teaching their children about the responsible consumption of alcohol. By strengthening their knowledge about alcohol consumption they can ensure that their children grow up to be responsible. Providing parents with accurate and balanced sources of information, such as TalkingAlcohol.com, means they can feel more confident in carrying out this responsibility.

  50. Several of SABMiller's businesses offer resources for parents to talk with their children about not drinking, such as Let's Keep Talking in the United States and We Can All Be Parents in Colombia.

Medical intervention

  51.  We encourage the development of medical interventions that can be adapted to a variety of health care settings for the identification, intervention, and treatment of people with alcohol problems.

  52.  Those individuals who have developed alcohol dependence require particular attention and treatment approaches, including psychological therapy, treatment with special medications, motivational interviewing and other interventions. Some individuals are able to modify their alcohol consumption and continue as moderate and non-problem drinkers. For others, abstention from alcohol is the only possible approach to dealing with the problem.

March 2009

378 Houghton, E, & Roche, A M (Eds). (2001). Learning about drinking. Philadelphia, PA: Brunner-Routledge.

415   Doll, R, & Peto, R (195). Mortality and alcohol consumption. British Medical Journal, 310, 470; Holman, C D, & English, D R (196). Ought low alcohol intake to be promoted for health reasons? Journal of the Royal Society of Medicine, 89, 123-129; Holman, C D, English, D R, Milne, E, & Winter, M G (196). Meta-analysis of alcohol and all-cause mortality: A validation of NHMRC recommendations. Medical Journal of Australia, 164, 141-145; Trevisan, M, Schisterman, E, Mennotti, A, Farchi, G, & Conti, S (2001). Drinking pattern and mortality: The Italian risk factor and life expectancy pooling project. Annals of Epidemiology, 11, 312-319. Back

416   Mukamal, K J, Conigrave, K M, Mittleman, M A, Camargo, C A, Jr, Stampfer, M J, Willett, W C et al. (2003). Roles of drinking pattern and type of alcohol consumed in coronary heart disease in men. New England Journal of Medicine, 348:109-18; Tolstrup, J S, Jensen, M K, Tjonneland, A, Overvad, K, & Gronbaek, M (2004). Drinking pattern and mortality in middle-aged men and women. Addiction, 99:323-30; Tolstrup, J.S., Heitmann, B L, Tjonneland, A M, Overvad, O.K., Sorensen, T I, & Gronbaek, M N (2005). The relation between drinking pattern and body mass index and waist and hip circumference. International Journal of Obesity (London), 29:490-497. Back

417   Trevisan, M, Ram, M, Hovey, K, Russell, M, Freudenheim, J, Muti, P, et al. (2001). Alcohol drinking patterns and myocardial infarction. American Journal of Epidemiology, 153, S97; Trevisan, M, Schisterman, E, Mennotti, A, Farchi, G, & Conti, S (2001). Drinking pattern and mortality: The Italian risk factor and life expectancy pooling project. Annals of Epidemiology, 11, 312-319. Back

418   Cunningham, R, Walton, M A, Maio, R F, Blow, F C, Weber, J E, & Mirel, L (2003). Violence and substance use among an injured emergency department population. Academic Emergency Medicine, 10, 764-775; Gutjahr, E, Gmel, G, & Rehm, J (2001). Relation between average alcohol consumption and disease: An overview. European Addiction Research, 7, 117-127. Back

419   Cambridge News. The party's over for underage drinkers. 07/07/2007. http://www.cambridge-news.co.uk/cn-news-home/DisplayArticle.asp?id=328865 Back

420   Meier, P, INDEPENDENT REVIEW OF THE EFFECTS OF ALCOHOL PRICING AND PROMOTION Part A: Systematic Reviews, 2008, p 34, http://www.dh.gov.uk/en/Publichealth/Healthimprovement/Alcoholmisuse/DH- 4001740? IdcService=GET-FILE&dID=178732&Rendition=Web Back

421   Mallie J Paschall, Joel W Grube, Carol Black, and Christopher L Ringwalt; Is Commercial Alcohol Availability Related to Adolescent Alcohol Sources and Alcohol Use? Findings from a Multi-Level Study; Journal of Adolescent Health; 2007 August; 41(2): 168-174. http://www.pubmedcentral.nih.gov/articlerender.fcgi?artid=2213632 Back