The Portman Group has published its response to the latest draft World Health Organisation (WHO) action plan to implement the Global Strategy to Reduce the Harmful Use of Alcohol. We are concerned that the action plan is moving away from the stated aims of the strategy. We call on the WHO to commit to a renewed focus on harmful drinking and to recognise the industry as a constructive partner in tackling harm.
As the UK alcohol industry voluntary regulator and social responsibility body we have been committed to promoting responsible drinking for over 30 years. We have worked in conjunction with the sector and others to reduce harms and have seen significant declines over most metrics in the decades we have operated.
Perception of the industry
We are disappointed that the latest draft continues to frame the industry negatively and therefore does not utilise the ideas, enthusiasm and energy that the sector has in dealing with harm. It fails to recognise the ongoing work of the industry to promote moderation as well as tackling alcohol harm in both the UK and around the world, and its engagement as a constructive partner.
We believe the UK market stands as an international example of industry best practice and the substantial progress that has been made to tackle the harmful use of alcohol in the country. This has been achieved, in part, through the ongoing success of voluntary cross-industry initiatives, as well as public-private partnerships implementing public health initiatives which should not be downplayed in the current action plan.
There has been significant progress made in tackling alcohol-related harm. The moderate majority of consumers drink responsibly and the work to get here should be recognised and used as a foundation for further work.
A commitment to alcohol responsibility is evident in initiatives across the whole of the sector. This includes the high retailing standards to prevent underage sales by the UK Retail of Alcohol Standards Group, who operate the Challenge 25 scheme where 99% of retailers seek evidence that people looking under the age of 25 are of legal age to purchase alcohol.
The sector also voluntarily funds a number of partnership schemes at a local level such as Community Alcohol Partnerships (CAP). Over the past 14 years, CAP have worked across 216 projects with local authorities, police, schools and local retailers to prevent underage drinking and alcohol harm to young people through a three-pillar model to educate, prevent underage sales and engage young people in positive activity to enhance their confidence, health and wellbeing[i].
Let’s focus on reducing harmful alcohol use
There is more work to be done and the action plan could be used to galvanise action. It should focus on reducing harmful alcohol use. Unfortunately it is unhelpfully diluting its focus to emphasise a reduction in overall use and the blunt measure of alcohol consumption per capita. This is especially pertinent given the polarisation in alcohol consumption and harm witnessed under COVID-19, where alcohol related deaths in England and Wales rose by 20% from 6,209 in 2019 to 7,423 in 2020[ii]. Surely this emphasises that we need to focus resources at targeted support and treatment for those drinking to highest harm.
However, the plan focuses on reducing overall alcohol consumption seeking an unrealistic 20% target to be achieved in less than a decade. It needlessly focuses capacity and resources on those individuals already drinking at moderate low levels which is close to 4 in 5 people in the UK[iii]. This is a chance to help the world come up with recommendations to reduce those drinking at the highest harm levels which, if the plan remains unchanged, will be missed and by shifting its focus away from harmful drinking, it will likely undermine the commitment of the strategy to a harm reduction approach.
Drinking and pregnancy
In the spirit of focusing on harm, we also welcome and are supportive of the inclusion of taking appropriate action to ‘prevent drinking in pregnancy and prevent foetal alcohol spectrum disorders (FASD)’ in the action plan, as an important targeted step in order to prevent alcohol harm.
We also welcome the removal of the previous wording regarding the ‘prevention of drinking among women of childbearing age’. This sentence was ill considered and was language that was counterproductive to the vital intention to prevent FASD.
This point echoes the need for the strategy to return to a focus on alcohol misuse and harm, rather than a broad attempt to reduce all consumption regardless that the majority of drinkers drink within Government recommended guidelines. When encouraging moderation and responsibility, it is essential that the steps seem reasonable, proportionate and appropriate, otherwise it may result in the counterproductive situation where people potentially ignore public health advice.
Valuing the regulators
We believe the WHO should also take note of the success of the self-regulatory and co-regulatory system which exists in the UK, with the Portman Group working alongside the Advertising Standards Authority (ASA) and Ofcom to ensure that alcohol marketing is covered in the round across all platforms. Portman Group and ASA data shows widespread industry compliance and support for this system, ensuring that alcohol is only marketed to adults in a responsible manner.
The Portman Group Code of Practices on the Naming, Packaging and Promotion of Alcoholic Drinks and Alcohol Sponsorship are a prime example of how self-regulatory action, with wide industry buy-in across the supply chain from producers to retailers, can have a demonstrable impact in protecting the most vulnerable in society and is a legitimate model to be included in the Action Plan. The Code of Practice, now in its 25th year, ensures that alcohol is marketed in a socially responsible way, only to those aged 18 and over, and in a way that does not have particular appeal to vulnerable consumers. Respect for the complaints process has led to more than 160 irresponsible and inappropriate products either being re-branded or removed from the market, in turn driving industry changes and protecting consumers.
The success of self-regulatory and voluntary measures, combined with a variety of initiatives from the UK Government to tackle alcohol-related harm, also underscores that the action plan should recognise the broad suite of policy options and interventions included in the Global Strategy for reducing harmful alcohol use.
The success of industry initiatives also demonstrate that the sector has a serious commitment to tackling harm in the UK and across the world. The industry is responsible and should continue to be seen as an active and willing partner as part of a ‘whole-of-society’ approach to tackling harmful alcohol use.
What next?
The Global Strategy is an opportunity to make the most of all the ideas, initiatives and investment from NGOs, governments, industry and bodies such as the Portman Group to tackle alcohol harm. This should be the focus of the plan and an opportunity to be captured. We hope that we can play our part and for the successes and learnings which come from the sector to be utilised.
The baton is now handed to the UK Government. We support much of their submission which recognises the need to focus on harm. We hope that the UK’s voice will be heard within WHO and that the action plan can be drawn back to delivering the agreed strategy. We stand ready to work with Government and the WHO.
[i] Community Alcohol Partnerships 2020 Annual Report, accessed July 2021
[ii] ONS: Quarterly alcohol-specific deaths in England and Wales, May 2021
[iii] NHS England, December 2020 / Scottish Health Survey, September 2020/ National Survey for Wales, September 2020 / Health Survey Northern Ireland, December 2020