30 May 2012
The Scotch Whisky Association believes
Minimum Unit Pricing of alcohol is illegal, will be
ineffective in tackling misuse and will damage the Scotch
It is opposed to the Scottish Government's Minimum Pricing of
Alcohol (Scotland) Bill which has been passed by the Scottish
Parliament and is currently awaiting Royal Assent.
The Association would also like the UK Government reconsider its
plans to push ahead with this misguided policy.
The Scotch Whisky Association is opposed to minimum pricing
- Minimum pricing will not be effective in tackling alcohol harm.
Research for the Scottish Government shows it will not reduce the
number of drinkers drinking at hazardous levels.
- Minimum pricing was ruled illegal as a barrier to trade by the
ECJ more than 30 years ago. The Bill in its entirety should be
notified to the European Commission.
- Minimum pricing will damage the Scotch Whisky industry. If the
Government secured a public health exemption to trade rules, it
would establish, for the first time, a precedent of 'health
justified' barriers to trade that would be used against Scotch
Whisky overseas, undermining decades of work by the industry
against trade barriers around the world.
Minimum pricing - the evidence
There is no strong evidence as to the effectiveness of minimum
pricing in reducing alcohol-related harm. Minimum pricing is a
regressive policy that will hit responsible drinkers and, in
particular, those on lower incomes at a time when household budgets
are under extreme pressure.
The updated Sheffield modelling ontinues to show the
number of hazardous and harmful drinkers would not fall with the
introduction of minimum pricing. It shows a reduced impact compared
to the previous reports and estimates that on average, a harmful
drinker would have to spend only £1.88 extra per week.
The volume of pure alcohol sales in Scotland has been stable
over the past number of years. Average alcohol prices are broadly
the same between Scotland and England, although they were slightly
higher in Scotland in 2010 compared to England, yet consumption is
greater in Scotland. In England there has been a reduction in
consumption, but some indicators of harm, such as alcohol-related
hospital admissions, continue to increase. This raises doubts over
claims that higher prices will address alcohol misuse in
There is a problem with alcohol misuse in Scotland, however
recent statistics show that alcohol-related health harms are
decreasing. Hospital discharges and alcohol-related deaths have
shown a decline in recent years . Deaths from alcoholic liver
disease have also been declining since 2006.
This suggests the message of responsible drinking may be getting
through. This improvement is witnessed before measures that have
been introduced under the Alcohol Etc (Scotland) Act have taken
effect. If we are to improve attitudes to alcohol in Scotland and
excessive drinking, it is important that we recognise these
improvements rather than reinforce the Scottish stereotype.
Minimum pricing is likely to be illegal
Minimum pricing on spirits has been ruled illegal by the
European Court of Justice as a barrier to trade. The Court has said
countries can take measures to tackle alcohol related-harm but
should use other less trade restrictive means, including tax or
To override this legal barrier, a government would need to
justify a 'public health' exemption - the harm being so great that
rules governing international trade could be overridden. This
exemption only applies where other less trade restrictive measures
are not available.
Claims that as a 'premium product' Scotch has nothing to fear
are wrong. A significant proportion (25-30%) of Scotch Whisky sales
in Scotland could be hit, harming producers of 'own label' brands.
This would affect the Scottish economy and many economically
disadvantaged areas, which are centres of Scotch Whisky production,
would be especially badly hit.
A minimum price for alcohol in Scotland is likely to lead to
copycat measures overseas and dampen Scotch Whisky sales,
threatening the industry's £4.23billion a year exports.
Scotch Whisky accounts for around 80% of Scottish food and drink
exports. It is Scotland's largest single product export
If international trade rules are overridden by the Scottish
Government, Scotch Whisky will have no protection against
discriminatory measures introduced against it by governments
abroad. Spuriously based 'health justified' trade barriers will
undermine decades of improving market access for Scotch, something
supported by both the Scottish and UK Governments. Falling sales
would damage the wider Scottish economy.
Minimum pricing could cost the industry half a billion pounds in
exports if other countries follow Scotland's lead.
Alternatives to minimum pricing
A legal alternative to minimum pricing would be to introduce a
floor price for alcoholic drinks based on duty and VAT, and in
collaboration with the UK Government remove the current tax
differentials between different alcohol beverages.
Tackle the problem of misuse - but not with minimum pricing.
The alcohol industry has no problem with a reduction in
excessive and harmful drinking leading to a reduction in
consumption. Scotland's drinking culture needs to change to one
that is healthier, positive and responsible. The alcohol industry
wants to ensure that those drinking too much increasingly recognise
that they are not the norm. Many industry members currently work
with the Scottish Government to help achieve this.