AHA letter to the Portman Group

6 July 2018: Responding to a letter from the Portman Group, the AHA explains why it will not respond to the consultation on the Portman Group’s Code of Practice. Instead, we call on Ministers to put alcohol marketing regulation on a statutory footing and to introduce the kinds of restrictions being proposed in part two of the obesity strategy which are designed to protect children from fast food marketing.

 

Dear Mr Timothy,

I am writing in response to your letter of 27 April 2018 inviting the Alcohol Health Alliance UK (AHA) to respond to the latest review of the Portman Group’s Code of Practice.

As you will be aware, the AHA believes that alcohol marketing, including product and packaging design, should be regulated by an independent body and placed on a statutory basis. We support the World Health Organization’s view that the alcohol industry should have no role in policy making.

There is substantial evidence that the self-regulatory system does not work, a view endorsed in a comprehensive review of alcohol evidence carried out by Public Health England on behalf of the Department of Health. The report, published in 2016, states: “A consistent body of research demonstrated considerable violations of content guidelines within self-regulated alcohol marketing codes, suggesting that the self-regulatory systems that govern alcohol marketing practices are not meeting their intended goal of protecting vulnerable populations.”[1]

Furthermore, evidence indicates self-regulatory marketing systems which rely on individual complaints from members of the public are generally cumbersome and ineffective and are unlikely to bring about the changes required to protect vulnerable groups from the impact of alcohol marketing.[2]

Just today colleagues at Alcohol Concern/Alcohol Research UK have released a report on The Portman Group’s system which highlights problems with the Code of Practice and describes panel decisions which are not always consistent, often appear subjective and are not based on an explicit presentation of the rationale, or the evidence underpinning the deliberations. The report also records a lack of panel oversight and scrutiny and comments that the overall process is not held to public account. It concludes that as part of its proposed alcohol strategy, the UK Government should establish a thorough review of alcohol marketing regulation, noting that the establishment of an independent regulator, operating on a statutory basis, would oblige the regulator to answer fully to the public and Parliament.

Finally, AHA members were concerned when in 2017 The Portman Group weakened the minimum standards for alcohol labels by removing the requirement that they include the revised CMOs’ low risk drinking guidelines. This is a vital piece of health advice designed to help consumers drink at low risk levels and is most easily accessed if it is clearly and legibly printed on product labels.

For these reasons the AHA will not be responding to your consultation. Instead, we will be writing to ministers calling on them to put alcohol marketing regulation on a statutory footing and to introduce the kinds of restrictions being proposed in part two of the obesity strategy which are designed to protect children from fast food marketing.

Yours sincerely,

Professor Sir Ian Gilmore,

Chair, Alcohol Health Alliance

 

[1] The Public Health Burden of Alcohol and the Effectiveness and Cost-Effectiveness of Alcohol Control Policies: An Evidence Review – Public Health England

[2] Thomas F Babor, David Jernigan, Chris Brookes – The Regulation of Alcohol Marketing: From research to Public Health Policy. Addiction Volume 112 Supp: 1 Jan 2017