Notification Detail

Public Health (Alcohol) Bill 2015 (in so far as it relates to the 3 additional specifications to labelling, advertising and broadcast watershed).

Notification Number: 2018/22/IRL (Ireland)
Date received: 19/01/2018
End of Standstill: 20/04/2018 ( 20/07/2018)

Issue of comments by: Commission,Denmark,France,Greece,Poland,Romania,Slovakia,Spain,United Kingdom
Issue of detailed opinion by: Bulgaria,Italy,Portugal
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Message 001

Communication from the Commission - TRIS/(2018) 00131
Directive (EU) 2015/1535
Notificación - Oznámení - Notifikation - Notifizierung - Teavitamine - Γνωστοποίηση - Notification - Notification - Notifica - Pieteikums - Pranešimas - Bejelentés - Notifika - Kennisgeving - Zawiadomienie - Notificação - Hlásenie-Obvestilo - Ilmoitus - Anmälan - Нотификация : 2018/0022/IRL - Notificare.

No abre el plazo - Nezahajuje odklady - Fristerne indledes ikke - Kein Fristbeginn - Viivituste perioodi ei avata - Καμμία έναρξη προθεσμίας - Does not open the delays - N'ouvre pas de délais - Non fa decorrere la mora - Neietekmē atlikšanu - Atidėjimai nepradedami - Nem nyitja meg a késéseket - Ma’ jiftaħx il-perijodi ta’ dawmien - Geen termijnbegin - Nie otwiera opóźnień - Não inicia o prazo - Neotvorí oneskorenia - Ne uvaja zamud - Määräaika ei ala tästä - Inleder ingen frist - Не се предвижда период на прекъсване - Nu deschide perioadele de stagnare - Nu deschide perioadele de stagnare.

(MSG: 201800131.EN)

1. Structured Information Line
MSG 001 IND 2018 0022 IRL EN 19-01-2018 IRL NOTIF


2. Member State
IRL


3. Department Responsible
National Standards Authority of Ireland
1 Swift Square
Northwood
Santry
Dublin 9
D09 A0E4
Ireland
Tel: 00 353 (0)1 807 3854
Email: EUDirective2015.1535@nsai.ie


3. Originating Department
Tobacco and Alcohol Control Unit
Room 4.13
Department of Health
Hawkins House
Hawkins Street
Dublin 2


4. Notification Number
2018/0022/IRL - C50A


5. Title
Public Health (Alcohol) Bill 2015 (in so far as it relates to the 3 additional specifications to labelling, advertising and broadcast watershed).


6. Products Concerned
The provisions of the Public Health (Alcohol) Bill being notified relate to 3 additional specifications:
(i) the inclusion of an additional health warning for alcohol products and in advertisements for alcohol products. The text of the warning is "a warning that is intended to inform the public of the direct link between alcohol and fatal cancers".
(ii) a specification of the minimum proportion of printed material to be given to a health warning.
The existing provision provides that the Minister may prescribe the form of a warning including its size and colour and the size, colour and font type of the printed material on the warning. The amendment adds that "where at least one third of the printed material will be given over to evidence-based health warnings". When such Regualtions are being made, they will be notified to the Commission in draft form.
(iii) the introduction of a broadcast watershed for advertisements for alcohol products. The text of which is as follows "a person shall not broadcast, or cause to be broadcast, an advertisement for an alcohol product on a television programme service between the hours of 3.00 a.m. and 9.00p.m. A person shall not broadcast, or cause to be broadcast, an advertisement for an alcohol
product on a sound broadcasting services on a week-day between the hours of midnight and 10.00 a.m., or 3.00 p.m. and midnight."


7. Notification Under Another Act
- Directive 2000/13/EC on the labelling and presentation and advertising of foodstuffs


8. Main Content
3 additional specifications being notified:

Labels on alcohol products, websites where alcohol is sold online, and documents with kegs or casks must contain the additional cancer health warning. The text of the health warning is "a warning that is intended to inform the public of the direct link between alcohol and fatal cancers". (Section 12 of the Public Health (Alcohol) Bill)

In addition, a minimum proportion of the printed material is being specified for health warnings.
The existing provision provides that the Minister may prescribe the form of a warning including its size and colour and the size, colour and font type of the printed material on the warning. The amendment adds that "where at least one third of the printed material will be given over to evidence-based health warnings". When such Regualtions are being made, they will be notified to the Commission in draft form. (Section 12 of the Public Health (Alcohol) Bill).

Advertisements will also have to include the additional cancer health warning. The text of the health warning to be included is "a warning that is intended to inform the public of the direct link between alcohol and fatal cancers". (Section 13 of the Public Health (Alcohol) Bill)

Broadcast advertisements for alcohol products will be restricted to specified times based on the viewing and listening times of children. The text of which is as follows "a person shall not broadcast, or cause to be broadcast, an advertisement for an alcohol product on a television programme service between the hours of 3.00 a.m. and 9.00p.m. A person shall not broadcast, or cause to be broadcast, an advertisement for an alcohol product on a sound broadcasting services on a week-day between the hours of midnight and 10.00 a.m., or 3.00 p.m. and midnight. (Section 19 of the Public Health (Alcohol) Bill).


9. Brief Statement of Grounds
The Public Health (Alcohol) Bill aims to reduce alcohol consumption in Ireland to 9.1 litres per person per annum by 2020, and to reduce the harms associated with alcohol.

Cancer warning provision:

The World Health Organisation European Action Plan to Reduce the Harmful Use of Alcohol (2012-2020) recommends that measures are taken to introduce a series of warning or information on labels on all alcoholic beverage containers.

There is irrefutable evidence that alcohol causes cancer and that there is a direct causal link between certain fatal cancers and alcohol misuse. In 2007, the International Agency for Research on Cancer concluded that alcohol can be classified as a carcinogen to humans. According to the Health Research Board Report, “Alcohol in Ireland”, there is a causal link between alcohol and certain cancers: cancer of the mouth, throat, larynx, oesophagus, liver, bowel and breast cancer in women.

In effect, alcohol is converted by our bodies into a toxic chemical (acetaldehyde) which can cause cancer by damaging our DNA and in turn prevents cells from repairing this damage. Alcohol can also increase hormone levels such as oestrogen which increases the risk of breast cancer

Alcohol is responsible for 1 in 8 breast cancers in Ireland. Of the 6,601 women who died of breast cancer, 10.5% of those cases were attributable to alcohol. 900 people are diagnosed with alcohol related cancers and around 500 people die from these diseases in Ireland every year.

All alcohol related cancers show evidence of a dose-response relationship. Drinking patterns matter and episodic drinking or binge drinking steadily increases cancer risks. According to a recent Central Statistics Office report, Ireland was found to have the highest rate of heavy episodic drinking in the EU in 2014. Heavy episodic drinking is defined as consuming the equivalent of 6 drinks on one occasion.

In the case of breast cancer, a Harvard study involving 320,000 women found that two or more drinks a day increased the chances of developing breast cancer by 43% which is an alarming risk increase.

Alcohol is one of the most preventable causes of cancer after smoking. The only way to reduce the risk of an alcohol-related cancer is to change how we drink and how much we drink. The first step towards achieving this is to raise public awareness of the link between alcohol consumption and cancer. This additional warning ensures that people are made aware of the cancer risks, among other associated risks linked with alcohol consumption.

Broadcast watershed provision:

The UK medical journal, “The Lancet” stated in an article in April 2017 that “The strongest evidence for the impact of advertising on alcohol consumption comes from reviews of longitudinal and cohort studies observing children. These studies report consistently that exposure to alcohol advertising is associated with an increased likelihood that children will start to drink or will drink greater quantities if they already do.”

2006 research on the Effects of Alcohol Advertising Exposure on Drinking Among Youth showed that for each additional advertisement that a young person saw above the monthly youth average of 23, he or she drank 1% more alcohol.

In the Irish Health Behaviour in School-aged Children Study in 2014, one fifth of Irish children reported that they had an alcoholic drink in the last 30 days and 1 in 10 children reported having been drunk in the last 30 days.

In the most recent European School Survey Project on Alcohol and Other Drugs, 7 out of 10 of Irish 15-to-16 year olds had already drunk alcohol and more than 3 out of 10 had been drunk in the past. The same survey found that a quarter of Irish girls and nearly a fifth of Irish boys reported having been injured or involved in an accident due to alcohol.

Irish children and young people are continuously exposed to positive, risk-free images of alcohol and its use. The current regulatory system does not protect children from exposure to alcohol marketing and this failure is associated with increased consumption. The broadcast watershed and the other advertising provisions in the Bill are an attempt to change that position.


10. Reference Documents - Basic Texts
References of the Basic Texts: (i) Public Health (Alcohol) Bill 2015
http://www.oireachtas.ie/documents/bills28/bills/2015/12015/b120b15s.pdf
(ii) The World Health Organisation European Action Plan to Reduce the Harmful Use of Alcohol (2012-2020)
http://www.euro.who.int/__data/assets/pdf_file/0008/178163/E96726.pdf
(iii) Press release from the International Agency for Research on Cancer
https://www.iarc.fr/en/media-centre/pr/2007/pr175.html
(iv) “Alcohol in Ireland” - a Report by the Health Research Board
http://www.hrb.ie/uploads/tx_hrbpublications/Alcohol_in_Ireland_consumption_harm_cost_and_policy_response.pdf
(v) Steering Group Report on a National Substance Misuse Strategy 2012
http://health.gov.ie/wp-content/uploads/2014/03/Steering_Group_Report_NSMS.pdf
(vi) Regulatory Impact Analysis for the Bill
http://health.gov.ie/wp-content/uploads/2015/12/Appendix-IV-Regulatory-Impact-Analysis-RIA-Alcohol.pdf
Basic Texts have been forwarded within the framework of a previous notification: 2016/42/IRL


11. Invocation of the Emergency Procedure
No


12. Grounds for the Emergency
-


13. Confidentiality
No


14. Fiscal measures
No


15. Impact assessment
-


16. TBT and SPS aspects
TBT aspect

Yes

SPS aspect

No - The draft is not a sanitary or phytosanitary measure



**********
European Commission

Contact point Directive (EU) 2015/1535
Fax: +32 229 98043
email: grow-dir2015-1535-central@ec.europa.eu

Stakeholders Contributions

The TRIS website makes it easy for you or your organization to contribute with your opinion on any given notification.
Due to the end of standstill we are currently not accepting any further contributions for this notification via the website.


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  U.S. Alcohol Policy Alliance on 20-07-2018
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  Cancer Research UK on 20-07-2018
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Cancer Research UK welcomes the opportunity to submit written evidence to the European Commission’s consultation on the Republic of Ireland’s Public Health (Alcohol) Bill 2015, which explores provisions within the Bill relating to labelling, advertising and a broadcast watershed.

 

We believe that Republic of Ireland’s Public Health (Alcohol) Bill 2015 is progressive legislation that contains positive steps to make clear the direct link between alcohol consumption and fatal cancers to the public. The evidence base clearly supports this link, and it is important that the public is aware of this so they can make informed choices about what they consume.  


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  Irish Medical Organisation on 20-07-2018
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 Please find attached the submission from the Irish Medical Organisation on the Irish Public Health Alcohol Bill

Kind regards

Vanessa Hetherington

Assistant Director, Policy and International Affairs

Irish Medical Organisation

 


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  European Public Health Alliance on 20-07-2018
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Contribution to TRIS notification 2018/22/IRL (Ireland) - Public Health (Alcohol) Bill

The European Public Health Alliance (EPHA) is Europe’s leading NGO alliance advocating for better health. EPHA is a member-led organisation made up of public health NGOs, patient groups, health professionals and disease groups, working to improve health and strengthen the voice of public health in Europe.

www.epha.org

The Public Health (Alcohol) Bill is a landmark legislative package to tackle alcohol-related harm in Ireland. EPHA is encouraged by the comprehensive nature of the Bill, which aims at lasting positive health impacts by employing a mix of evidence-based policy tools, including those related to labelling and marketing.

The measures proposed under the Bill follow international recommendations, such as the World Health Organization’s (WHO) European action plan to reduce the harmful use of alcohol 2012–2020. This action plan was endorsed by all 53 countries in the WHO European Region, including all European Union (EU) Member States.

In relation to the cancer warning measures under the Bill, as highlighted in the TRIS contributions by public health expert organisations, there exists robust evidence for a link between alcohol and several cancers.

It is well-established that EU Member States are entitled to decide on the level of human health protection pursued in their national contexts. The national legislator also has a significant margin of discretion in the choice of measures to achieve health objectives [see for instance, European Court of Justice Case C333/14, 23 December 2015, point 55].

In this light, it is of paramount importance that the European Commission ensures that EU Member States are supported, and not unduly restricted, in exercising their right to regulate for public health. This to benefit the health and well-being of EU citizens, and to pursue the core aims of the Union which include the promotion of well-being [Article 3(1) Treaty on European Union], as well as the internal market – established to work for the sustainable development of Europe [Article 3(3) Treaty on European Union].

 


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  Irish Cancer Society on 20-07-2018
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The Irish Cancer Society welcomes the opportunity to respond to the consultation on the Public Health (Alcohol) Bill, Ireland, 2015.

We strongly encourage the European Commission to facilitate the additional notified specifications, particularly with regard to labelling and advertising.

Please find attached our submission on the Public Health (Alcohol) Bill, Ireland, 2015.


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  Alcohol Justice on 20-07-2018
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  EASL on 19-07-2018
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  The Standing Committee of European Doctors (CPME) on 19-07-2018
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European doctors on the Irish Public Health (Alcohol) Bill 2015

Contribution to the European Commission’s Technical Regulation Information System (TRIS) database

 

The Standing Committee of European Doctors (CPME) represents national medical associations across Europe. CPME is committed to contributing the medical profession’s point of view to EU institutions and European policy-making through pro-active cooperation on a wide range of health and healthcare related issues.

We welcome the propositions by the Irish Government addressing alcohol related harm. The Public Health (Alcohol) Bill is an important piece of legislation tackling Ireland’s harmful relationship with alcohol[1]. It aims to reduce the damage that alcohol causes to individuals, families and society, with an emphasis on protecting children and young people from alcohol harm. Its goal is to reduce the per capita alcohol consumption from 11 litres to 9.1 litres for every person aged 15 and over by 2020. The Bill includes i.a. health warnings on labels and stricter regulation on alcohol marketing.

CPME believes that attaching warning labels to packaging is effective. Product labels can serve several purposes: providing information about the product to the consumer, enticing the consumer to buy the product and alerting consumers about the dangers and health risks of the product. Labelling has been shown to be an effective mean of raising awareness of the health-related consequences of alcohol consumption, which is perhaps unsurprising given the frequently demonstrated efficacy of this measure in tobacco public health policy internationally. Research of health warnings displayed on tobacco products show that whereas small or obscure text-only warnings seem to have minimal impact, prominent health warnings on the face of containers serve as an effective source of health information.[2][3]

Moreover, alcohol is one of the few substances linked to an increased risk of cancer[4]. Therefore, CPME supports the proposal to introduce cancer warning labels. Alcohol is classified as a group 1 carcinogen by the WHO’s International Agency for Research on Cancer (IARC)[5] as there is a proven, causal link between alcohol and several types of cancer, including cancer of the mouth, pharynx, larynx, oesophagus, liver, bowel and female breast. Even low levels of alcohol intake are associated with a risk of cancer.

CPME also believes that stricter controls in alcohol advertising with a view to protecting children and young people are beneficial. In our position on the EU Audiovisual Media Services Directive[6], we have proposed to prohibit commercial communications for alcoholic beverages to limit the exposure of children and minors. Exposure to alcohol advertising increases the likelihood that young people start drinking at an early age, and to drink more once older. Furthermore, CPME recognises that broadcasting watershed is a well-known and effective measure utilised by many European countries to protect children from harmful TV marketing.

Irish authorities have taken appropriate steps to alert and inform the public about the dangers of alcohol and its proven relation to several types of cancer. Health is a public interest and must be respected in policy making. It is our hope that the European Union institutions and its Member States will allow Ireland to put the health of their citizens above profits of the alcohol industry.



[1] Mongan D, Reynolds S, Fanagan S and Long J. Health-related consequences of problem alcohol use. Overview 6  Dublin: Health Research Board 2007: 45-46 (Irish adults are one of the highest per capita consumers of alcohol in Europe consuming approximately 11.0 litres per capita. Alcohol is associated with more than 60 acute and chronic health disorders ranging from accidents and assaults to mental health problems, cardiovascular disease, liver cirrhosis and certain cancers. While chronic conditions more often affect older people, acute conditions are more prevalent amongst younger people).

[2] Hammond D. Health warning messages on tobacco products: a review in Tobacco Control, Vol. 20, May 2011, pp. 327-337.

[3] Sambrook Research International, A review of the science base to support the development of health warnings for tobacco packages, Newport, 2009, pp. 7-12.

[4] United European Gastroenterology (UEG) report: Digestive Health Across Europe (2018); Schutze M. Et al Alcohol attributable burden of incidence of cancer in Eight European Countries based on results from Prospective Cohort Study. BMJ; 2011; 342: d1584 in Clarke N. Et al. A report on the Excess Burden of Cancer Among Men in the Republic of Ireland, Centre for Men’s Health, Institute of Technology Carlow; 2013 for the Irish Cancer Society; Laffoy M, McCarthy T, Mullen L, Byrne D, Martin J. Cancer incidence and mortality due to alcohol: an analysis of 10-year data. Ir Med J. 2013;106(10):294-7.

[5] WHO’s International Agency for Research on Cancer (IARC). List of classifications.


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  Nordic Alcohol and Drug Policy Network on 19-07-2018
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Comments to Public Health (Alcohol) Bill 2015 (in so far as it relates to the 3 additional specifications to labelling, advertising and broadcast watershed).


Nordic Alcohol and Drug Policy Network (NordAN) congratulates Irish Government for their dedication to reducing alcohol consumption and related harm through this bill and wishes to stress following aspects which, in our mind, supports the bill and the whole alcohol policy.

Keeping in mind that the causal link between alcohol and cancer is well established as is also clearly shown in the World Cancer Research Fund International´s contribution and keeping in mind also that the awareness of that link is poor in many countries, Ireland included, we see that Irish Governments bill is not only justified but shows what kind of responsibility a state has when regulating a commodity like alcohol.

While experts have known since 1987 that alcohol can cause cancer, the message in our public space about it hasn´t been clear. As economic operators are muddying the waters claiming that overall responsible drinking is even healthy and showing through their massive marketing campaigns that drinking is and should be part of everyday life, many health experts and doctors sometimes calm down people´s concern saying that alcohol´s carcinogenic effects are too small to bother oneself with it. Even if people are aware of that link, most are confused as the messages of that fact - alcohol is carcinogenic - are contradicting. The government has an obligation to inform its citizens and make sure that these proven facts and information that affects people´s health and their daily life are brought to their attention. Clearly and free of any vested interests. For that purpose information through labelling is logical and most direct.

Alcohol is one of the most peculiar commodities in our markets. People are using it as part of culture and lifestyle. Alcohol industry is building up a tradition, showing the historical background and claiming that alcohol has been part of our lives for centuries, if not for thousands of years. While that is actually true, some of the major health effects of alcohol are known to us only the last 40 years. Alcohol´s teratogenic effect was first established in 1973 and as already mentioned, alcohol was listed as carcinogenic in 1987. Interestingly, some countries have liberalized their alcohol policies since then and not the other way around, as would be more logical. European Union has its own role here as Sweden and Finland had to weaken their advertising restrictions in 1995 when entering the Union.

At the same time, alcohol industry has increased their ways of marketing and with the social media now, people are targeted by alcohol advertising more than ever before. So there is a clear contradiction, between the growing evidence and understanding regarding alcohol and the actual practice how we regulate the substance. It seems to be logical that when European Code Against Cancer states that "avoiding alcohol completely will help reduce your cancer risk", meaning there is no risk-free drinking, we would forbid companies to advertise alcohol, in other words, encourage people to drink. But as already mentioned, the reality, in general, has been very different.

As a Nordic and Baltic network, we do want to remind that measures that Irish Government plans to implement are not extreme and that there are similar and even stronger positive examples in Europe that show the effectiveness of these regulations. Iceland, Norway and Faroe Islands are having a total ban on alcohol advertising and Lithuania became the first EU country to introduce a total ban in 2018. Lithuania also introduced (2017) a requirement for labels of distilled beverages of 1.2%ABV or higher and fermented beverages of 0.5% or higher to include a pictogram warning of the potential effects of drinking alcohol during pregnancy.

Ireland has shown the way when it comes to tobacco policy. Positive initiatives start from somewhere and when it comes to public health, it usually causes problems for alcohol industry. We encourage Ireland to stay the course and continue with policies that prioritize people´s health and wellbeing. And we hope that both the European Union and Member States are willing to see the same way and also take an example from Ireland.


Contact details

For more information please contact:

 

Lauri Beekmann

Executive Director

NordAN

Marjamaa 2

Türi 72214, Estonia

Tel +372 5261884

E-mail: beekmann@nordan.org

www.nordan.org

 

 

The Nordic Alcohol and Drug Policy Network

NordAN was established in September 2000 as a network of non governmental, voluntary organizations who all worked to reduce the consumption of alcohol and other drugs and who supported a restrictive alcohol and drug policy and who did not receive contributions from the commercial alcohol industry.


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  Alcohol Focus Scotland on 19-07-2018
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SUBMISSION TO EUROPEAN COMMISSION -

 

IRISH PUBLIC HEALTH (ALCOHOL) BILL

 

 

 

Alcohol Focus Scotland (AFS) is the national charity working to prevent and reduce alcohol harm in Scotland through the implementation of effective alcohol control policies and legislation.  AFS welcomes the opportunity to submit our opinion to the European Commission on the Irish Public Health (Alcohol) Bill in so far as it relates to the three additional specifications on labelling, advertising and broadcast watershed.

 

 

 

General comment

 

AFS welcomes the proposals set out in the Public Health (Alcohol) Bill, including those relating to labelling, advertising and a broadcast watershed. Alcohol places a significant burden on health, the economy and society across Europe. Governments that choose to adopt evidence-based policy interventions to prevent alcohol harm should be applauded.  Irish authorities have taken appropriate steps to inform the public about the dangers of drinking alcohol in relation to cancer prevention, and to protect children from the impact of alcohol marketing.  

 

It is our hope that the European Union institutions and its Member States will allow Ireland to put the health of their citizens ahead of profits of the alcohol industry.  The right to health should be considered alongside the right of commercial operators to trade, to property and to expression.  Under European law, the legal right for commercial operators to promote their goods and services through marketing communications are not absolute and can be restricted on public health grounds, provided that the restrictions imposed are proportionate.[1]  When assessing the proportionality of marketing restrictions, both UK courts and the Court of Justice of the European Union (CJEU) have clearly stated that the EU and Member States have a broad margin of discretion in how they decide to protect public health, including through the imposition of extensive marketing restrictions. 

 

This response briefly outlines evidence from Scotland and the UK that supports the proposals in the Bill, acknowledging the wealth of evidence already presented within the notification from the Irish Government.

 

 

 

Labelling

 

Alcohol is linked to over 200 diseases and injury conditions including cancer, heart disease and liver disease,[2] and the public have the right to know about these harms, in order to make informed choices about their drinking.  Worryingly, in many countries awareness of these harms is currently very low.  In the UK, research has found that only 1 in 10 people are aware of the link between alcohol and cancer,[3] despite the strong evidence linking alcohol consumption to at least seven types of cancer including breast, bowel, throat and mouth.[4]  Labelling of alcohol products has been shown to increase awareness of the harms associated with drinking.[5]  There is strong public support for information on labels, including health warnings; around a third of people believe that cancer health warnings on labels would reduce the amount of alcohol they consume.[6]  

 

 

 

In 2016 the UK Chief Medical Officers (CMOs) updated the low risk drinking guidelines for adults taking account of the latest available evidence linking alcohol to a number of health conditions, notably cancer. Weekly guidelines were revised to 14 units for both men and women.[7] The new guidelines were based on two principles:

  1. People have a right to accurate information and clear advice about alcohol and its health risks.
  2. Government has a responsibility to ensure this information is provided for the public in a clear and open way, so they can make informed choices.

Based on the latest available evidence on effectively tackling alcohol harm, and taking account of consumer rights relating to knowledge of the health effects of drinking alcohol, the UK CMOs’ guideline development group recommended that health warnings and consistent messaging should appear on all alcohol advertising, products and sponsorship.[8]  AFS supports the Irish Government’s proposals, which are consistent with these recommendations.  

 

 

Advertising and watershed

 

The pervasive nature of advertising in the UK means children are regularly exposed to alcohol messages, despite the existence of regulatory codes designed to restrict exposure of under-18s to alcohol marketing.  Children can also demonstrate high levels of awareness and familiarity with alcohol brands; a survey of Scottish primary schools found 10 and 11 year olds were more familiar with certain beer brands than leading brands of biscuits, crisps and ice cream.[9] 

 

Research indicates that alcohol marketing has an impact on children and young people; they find alcohol marketing messages appealing,[10] and alcohol marketing influences their attitudes.[11]   Most significantly, exposure to alcohol marketing reduces the age at which young people start to drink, increases the likelihood that they will drink, and increases the amount of alcohol that they consume if they already drink.[12] 

 

Television remains an important medium for alcohol advertisers to reach large audiences, with about half of alcohol advertising expenditure on measured media spent on TV advertising.[13]  Around 650,000 alcohol adverts are shown on UK TV each year, with almost half broadcast before 9pm, during peak viewing hours for children and young people.[14]

 

In 2017, an international expert group on alcohol marketing made a number of recommendations to protect children in Scotland from the impact of alcohol marketing; this included restrictions on alcohol advertising on television during certain time periods.[15]  The introduction of such restrictions should reduce children’s exposure to alcohol marketing, and create a more transparent system of regulation, providing certainty about the times when alcohol adverts can be shown.  AFS therefore welcomes the advertising and watershed proposals within the Irish Bill.    

 

 

  

 



[1] Alemanno, A., & Garde, A. (2013). Regulating Lifestyles in Europe: How to prevent and control non-communicable diseases associated with tobacco, alcohol and unhealthy diets? Stockholm: Swedish Institute for European Policy Studies (SIEPS). Accessed at: http://www.sieps.se/en/publications/2013/regulating-lifestyles-in-europe-how-to-prevent-and-control-non-communicable-diseases-associated-with-tobacco-alcohol-and-unhealthy-diets-20137/sieps_2013.pdf?

[2] World Health Organization (2015). Alcohol Factsheet. Geneva: World Health Organization. http://www.who.int/mediacentre/factsheets/fs349/en/

[3] Alcohol Health Alliance (2017). Right to Know: Are alcohol labels giving consumers the information they

need? London: Alcohol Health Alliance.  Accessed at: http://12coez15v41j2cf7acjzaodh.wpengine.netdna-cdn.com/wp-content/uploads/2017/08/Right-to-Know-AHA-August-2017-1.pdf

[4] Alcohol Health Alliance UK (2017). Alcohol and cancer: knowing the risks.  London: Alcohol Health Alliance. Accessed at

http://12coez15v41j2cf7acjzaodh.wpengine.netdna-cdn.com/wp-content/uploads/2017/06/Alcohol_and_cancer_4pp.pdf

[5] Public Health England (2016). The Public Health Burden of Alcohol and the Effectiveness and Cost-

Effectiveness of Alcohol Control Policies: An evidence review. London: Public Health England.  Accessed at:

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/583047/alcohol_public_health_burden_evidence_review.pdf 

[6] Maynard, O., Blackwell, A., Munafò, M. & Attwood, A. (2018).  Know your limits: Labelling interventions to reduce alcohol consumption.  London: ARUK. Accessed at: http://alcoholresearchuk.org/downloads/finalReports/FinalReport_0150.pdf

[7] UK Chief Medical Officers (2016). UK Chief Medical Officers’ Low Risk Drinking Guidelines. Accessed at: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/545937/UK_CMOs__report.pdf

[8] Department of Health (2016). Alcohol Guidelines Review – Report from the Guidelines development group to the UK Chief Medical Officers. London: Department of Health. Accessed at: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/545739/GDG_report-Jan2016.pdf   

[9] Alcohol Focus Scotland, Alcohol Concern, Balance North East and Drink Wise (2015). Children’s Recognition of Alcohol Branding. Accessed at: http://www.drugs.ie/resourcesfiles/ResearchDocs/Europe/Research/2015/ChildrensRecognitionOfAlcoholMarketingBriefing.pdf

[10] Winpenny, E. et al (2012). Assessment of young people’s exposure to alcohol marketing in audiovisual and online media. RAND Europe. Accessed at: https://ec.europa.eu/health/sites/health/files/alcohol/docs/alcohol_rand_youth_exposure_marketing_en.pdf

[11] Chia, S.C. (2006). How peers mediate media influence on adolescents sexual attitudes and sexual behavior, Journal of Communication, 56(3): 585−606; Chia, S.C. (2010). How social influence mediates media effects on adolescents’ materialism. Communication Research, 37(3): 400−19.

[12]Anderson et al. (2009), Impact of Alcohol Advertising and Media Exposure on Adolescent Alcohol Use: A Systematic Review of Longitudinal Studies, Alcohol and Alcoholism, 44(3):229-43; Smith, L. & Foxcroft, D. (2009), The Effect of Alcohol Advertising, Marketing and Portrayal of Drinking Behaviour in Young People: A Systematic Review of Prospective Cohort Studies, BMC Public Health, 9:51; Jernigan, D. et al. (2016) Alcohol Marketing and Youth Consumption: A Systematic Review of Longitudinal Studies Published Since 2008, Addiction, 112: 7–20

[13] Mintel (2014). Drinking in the Home – UK – 2014. Mintel.

[14] European Commission. (2015, April). Study on the exposure of minors to alcohol advertising on linear and non-linear audio-visual media services and other online services, including a content analysis. National Institute for Health and Welfare, Centerdata, and GFK.  Accessed at: https://publications.europa.eu/en/publication-detail/-/publication/6a5c648b-9e8f-11e5-8781-01aa75ed71a1/language-en

[15] Alcohol Focus Scotland (2017). Promoting good health from childhood: Reducing the impact of alcohol marketing on children in Scotland. Glasgow: Alcohol Focus Scotland. Accessed at: https://www.alcohol-focus-scotland.org.uk/media/213609/Promoting-good-health-from-childhood-report.pdf


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  Royal College of Physicians on 19-07-2018
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 The Royal College of Physicians (RCP) is grateful for the opportunity to respond to the consultation on the Public Health (Alcohol) Bill, Ireland, 2015. Our response has been attached. I would be grateful if you could confirm receipt.


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  World Cancer Research Fund International on 17-07-2018
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 World Cancer Research Fund International comment on the Irish Public Health (Alcohol) Bill

 

About World Cancer Research Fund International

World Cancer Research Fund (WCRF) Internationalleads and unifies a network of cancer prevention charities with a global reach, dedicated to the prevention of cancer through diet (including alcohol consumption), weight and physical activity. 

We are a leading authority on cancer prevention research related to diet (including alcohol consumption), weight and physical activity. We work collaboratively with organisations around the world to encourage governments to implement policies to prevent cancer and other non-communicable diseases (NCDs).

For more information, please visit www.wcrf.org 

Contact

For any queries about World Cancer Research Fund International’s comment, please contact policy@wcrf.org

 

Summary

WCRF International welcomes the proposals set out in the Irish Public Health (Alcohol) Bill, to require a cancer health warning on labels of alcohol products, a cancer health warning in advertisements of alcohol products and restrictions to broadcast advertisements for alcohol products, as alcohol is a known carcinogen. This comment outlines evidence on the links between alcohol and cancer, supporting the Bill’s proposals.

 

Evidence to support policy

The Continuous Update Project (CUP) is World Cancer Research Fund (WCRF) Network’s ongoing programme to analyse cancer prevention and survival research related to diet (including alcohol consumption), nutrition and physical activity from all over the world. Among experts worldwide it is a trusted, authoritative scientific resource which underpins current guidelines and policy on cancer prevention and survival. 

Scientific research from around the world is continually added to the CUP’s unique database, which is held and systematically reviewed by a team at Imperial College London. An independent panel of experts carries out ongoing evaluations of this evidence, and their findings form the basis of the WCRF Network’s Cancer Prevention Recommendations.

Through this process, the CUP ensures that everyone, including policymakers, health professionals and members of the public, has access to the most up-to-date information on how to reduce the risk of developing cancer.

The WCRF Network’s Third Expert Report, Diet, Nutrition, Physical Activity and Cancer: a Global Perspective, launched in May 2018, brings together the very latest research from the CUP’s review of the accumulated evidence on cancer prevention and survival related to diet (including alcohol consumption), nutrition and physical activity. For a full list of contents, see dietandcancerreport.org

The CUP is led and managed by WCRF International in partnership with the American Institute for Cancer Research, on behalf of WCRF UK, Wereld Kanker Onderzoek Fonds and WCRF HK. 

 

Alcohol and cancer

WCRF International analyses global research on how consuming alcoholic drinks affects the risk of developing cancer. Our independent panel of global experts has been evaluating the evidence on cancer prevention for many years. Evidence from the Continuous Update Project shows that even small amounts of alcoholic drinks can increase the risk of some cancers and there is no level of consumption below which there is no increase in the risk of at least some cancers.

 

There is strong evidence that consuming alcoholic drinks increases the risk of mouth, pharynx and larynx cancers, oesophageal cancers (squamous cell carcinoma) and breast cancer (pre and postmenopause). Two or more alcoholic drinks a day (30 grams or more) increases the risk of colorectal cancer and three or more alcoholic drinks a day (45 grams or more) increases the risk of stomach and liver cancer.

 

For some cancers, there is an increased risk with any amount of alcohol consumed, whereas for other cancers the risk becomes apparent from a higher level of consumption, of about two or three drinks a day (about 30 or 45 grams of alcohol per day). The evidence shows that, in general, the more alcoholic drinks people consume, the higher the risk of many cancers. The exception is kidney cancer, where the risk is lower for up to two alcoholic drinks a day; however, for more than two drinks a day the level of risk is unclear. 

 

 

Type of alcoholic drink and cancer risk

Alcoholic drinks of all types have a similar impact on cancer risk. 

 

Cancer Prevention Recommendation related to alcohol

“Limit alcohol consumption. For cancer prevention it’s best not to drink alcohol” is one of World Cancer Research Fund International’s ten Cancer Prevention Recommendations. https://www.wcrf.org/dietandcancer/cancer-prevention-recommendations

 

The Cancer Prevention Recommendations are made by our Independent Expert Panel and based on strong evidence. 

 

Public health and policy implications

 

A comprehensive package of policies is needed to reduce alcohol consumption at a population level, including policies that influence the availability, affordability and acceptability of alcoholic drinks. Ireland’s Public Health (Alcohol) Bill does this by including multiple measures including minimum price, labelling of alcohol products, advertising restrictions, separation and visibility of alcohol products, and regulation to sale and supply of alcohol products.

 

References

World Cancer Research Fund/American Institute for Cancer Research. Diet,
Nutrition, Physical Activity and Cancer: a Global Perspective.
Continuous Update Project Report 2018. Available at 
dietandcancerreport.org

World Cancer Research Fund/American Institute for Cancer Research. Continuous Update Project Expert Report 2018. Alcoholic drinks and the risk of cancer. Available at dietandcancerreport.org 

World Cancer Research Fund/American Institute for Cancer Research. Continuous Update Project Report: Diet, Nutrition, Physical Activity and cancers of the Mouth, Pharynx and Larynx. 2018. Available at dietandcancerreport.org

 

World Cancer Research Fund/American Institute for Cancer Research. Continuous Update Project Report: Diet, Nutrition, Physical Activity and Oesophageal Cancer. 2016. Available at dietandcancerreport.org

 

World Cancer Research Fund/American Institute for Cancer Research. Continuous Update Project Report: Diet, Nutrition, Physical Activity and Breast Cancer. 2017. Available at dietandcancerreport.org

 

World Cancer Research Fund/American Institute for Cancer Research. Continuous Update Project Report: Diet, Nutrition, Physical Activity and Colorectal Cancer. 2017. Available at dietandcancerreport.org

 

World Cancer Research Fund/American Institute for Cancer Research. Continuous Update Project Report: Diet, Nutrition, Physical Activity and Stomach Cancer. 2016. Available at dietandcancerreport.org

 

World Cancer Research Fund/American Institute for Cancer Research. Continuous Update Project Report: Diet, Nutrition, Physical Activity and Liver Cancer. 2015. Available at dietandcancerreport.org

 

 


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  IOGT-NTO on 16-07-2018
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IOGT-NTO Stakeholder Contribution on TRIS notification 2018/22/IRL:

Public Health (Alcohol) Bill 2015 (in so far as it relates to the 3 additional specifications to labelling, advertising and broadcast watershed).

Introduction

IOGT-NTO is the largest temperance organisation in Sweden. It is one of Sweden’s oldest NGOs with a long tradition of cultural, social and educational efforts in local communities as well as vast experience of working with evidence-based alcohol policy measures.

IOGT-NTO would like to strongly support the notified Irish proposals.

Structure of submission

Our submission is divided into 3 parts:

1.       A comment on the economic conflicts of interest among TRIS stakeholder contributors

2.      A comment on the evidence linking alcohol consumption to several fatal cancers

3.     A comment on Ireland’s rights under the EU-treatise and similar measures already in place in other Member States

Annex:

1.       Cancer-related burden of disease for Ireland by risk factor.

2.      Breast cancer-related burden of disease for Ireland by risk factor.

3.    Andréasson S, Chikritzhs T, Dangardt F, Holder H, Naimi T & Stockwell T. (2016) Alcohol and Cancer. Stockholm: IOGT-NTO, Svenska läkaresällskapet and CERA.

1.      Economic conflicts of interest among TRIS stakeholder contributors

IOGT-NTO would like to first stress that the contributions of alcohol producers and their respective trade associations under the TRIS-procedure should be viewed critically in light of their inherent conflict of interest with public health.

The primary purpose of alcohol companies is to receive a return on invested funds by producing and selling their products. Alcohol industry trade associations represent the common interests of these companies. There is a clear contradiction between increased alcohol consumption and better public health outcomes.[1] Therefore, similar to the tobacco industry[2], the commercial interest of the alcohol industry runs counter to public health interests.

Consequently, because of the impact on their sales, alcohol producers and their trade associations can be expected to try to prevent, delay or undermine public health legislation that aims to reduce alcohol consumption.

The Irish Public Health Bill is specifically aimed at reducing alcohol consumption[3] in order to reduce the high levels of alcohol-related harm experienced in Ireland[4]. With this in mind, it is not surprising that alcohol industry trade associations are mobilising to attempt to prevent, delay and undermine the proposed bill. These actions can be identified nationally in Ireland[5], on the EU-level through the TRIS-process, and, as we can see in some TRIS-submissions, also globally through Free-Trade Agreements and the WTO.

Moreover, how the alcohol industry talks about alcohol and cancer demonstrates this conflict of interest. The way that alcohol producers and their side-organisations communicate on the topic of alcohol and cancer was studied by Petticrew et al. in 2017. The study concludes that:

 most of the organisations were found to disseminate misrepresentations of the evidence about the association between alcohol and cancer.

The researchers also found parallels to the methods used to talk about smoking and lung cancer traditionally employed by the tobacco industry.[6]

2.     Evidence linking alcohol consumption to several fatal cancers

IOGT-NTO notes the strong international evidence supporting the causal link between the consumption of alcoholic beverages and several types of cancer.

In annex to this document, we have attached our research report from 2016/2017 on alcohol and cancer.[7] The report is published by The Swedish Society of Medicine and IOGT-NTO in partnership with CERA, an interdisciplinary centre at Gothenburg University for education and research into hazardous use, abuse and addiction. The report is a collation and aggregation of facts and figures from international research. It is produced by a group headed by Harold Holder that comprises some of the most renowned researchers in the field of international alcohol research. The main conclusion of the report on alcohol and cancer was that:

Alcohol causes cancer. Any alcohol consumption increases the risk of certain cancers, and higher levels of consumption further increase those risks.”

The conclusion is in line with the findings of the World Cancer Research Fund’s Continuous Update Project report about alcohol and cancer. The report concludes that there is strong evidence for a causal link between alcohol and certain types of cancer.[8] For breast cancer, the report finds no threshold-level of consumption below which risk doesn’t increase, meaning that the risk increases already by the first glass.

The evidence base for the carcinogenicity of alcoholic beverages is also echoed by the International Agency for the Research on Cancer (IARC) under the World Health Organisation (WHO) who finds sufficient evidence to say that:

The occurrence of malignant tumours of the oral cavity, pharynx, larynx, oesophagus, liver, colorectum and female breast is causally related to the consumption of alcoholic beverages.”

In Ireland, alcohol is the second largest risk factor for cancer as measured in disability-adjusted life years (DALYs). For breast cancer specifically, alcohol is the largest risk factor.[9] See annex for detailed figures.

A special Eurobarometer on “EU citizens’ attitudes towards alcohol” carried out in 2009 also found that a large part of the Irish population did not know about the link between alcohol and cancer.[10] In the Healthy Ireland Survey, commissioned by the Irish Ministry of Health in 2016, only 27% of Irish women surveyed reported knowing about the link between alcohol and breast cancer.[11]

The European Union has recognised the need to promote information regarding preventative measures targeted at individuals and public at large.  Since 1987 it leads the initiative of the European Code Against Cancer, the current fourth edition has a revised message in terms of alcohol consumption:

“If you drink alcohol of any type, limit your intake. Not drinking alcohol is better for cancer prevention.”

As stated on the European Code Against Cancer website:[12]

“There is no doubt that drinking alcohol can cause at least seven types of cancer: those of the mouth, gullet (oesophagus), throat (pharynx and larynx), liver, large bowel (colon and rectum), and breast.

Consumption of any amount of alcohol increases your cancer risk. The more alcohol you drink, the higher the risk of developing cancer. Reducing your consumption or – even better – avoiding alcohol completely will help reduce your cancer risk.”

It only appears appropriate that an EU Member State should be allowed to inform their citizens of the potential health risks associated with alcohol consumption.

3.     Ireland’s rights under the EU-treatise and similar measures already in place in other Member States

In IOGT-NTO’s view, the Irish proposals concerning labelling, advertising and a broadcast watershed for alcohol marketing are in conformity with Ireland’s duties under the EU-treatise. In line with the principle of subsidiarity, EU Member States have the right to determine the level of public health protection which they deem appropriate as well as the measures suitable and necessary to attain that level.

It is clear from the Regulatory Impact Analysis of the Irish Public Health (Alcohol) Bill that the Irish proposals are based on the World Health Organisation’s recommendations for effectively reducing alcohol related harm.[13]  This is fully in line with the stated goal of the European Commission[14] and the Council[15] to support Member States in reaching the World Health Organisation target to reduce alcohol related harm by 10% by 2025.

In addition, there already exists extensive precedence through similar measures in other Member States, justified through public health or customer protection arguments. This further demonstrates the conformity of the Irish measures with the single market framework.

Warning labels are already present for tobacco products in the EU. For alcohol, France has a mandatory pictogram to alert consumers to the risks of consuming alcohol during pregnancy.[16]

Mandatory public informational or warning messages attached to certain types of advertising vary in scope and wording but apply to a wide range of products around EU Member States, from alcohol (Estonia/Sweden) to unhealthy foods (France) and financial services (Ireland).

Watersheds for alcohol advertising are also employed in many other Member States (Austria, Bulgaria, Cyprus, Denmark, Finland, Germany, Hungary, Italy, Latvia, Lithuania, Malta, the Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia and Spain).

4.     Conclusion

One of the objectives of public bodies should be to effectively protect people from risks and threats that they cannot tackle as individuals. Irish authorities are taking appropriate steps to alert the public to the dangers of drinking alcohol when it comes to cancer prevention.

Health is a public interest to consider in the development and implementation of all policies. It is our hope that the European Union institutions and its Member States will allow Ireland to put the health of their citizens ahead of the profits of the alcohol industry.

IOGT-NTO

Johnny Mostacero                              Peter Moilanen

President                                             Secretary General



[1] Babor, T., Babor, T. F., Caetano, R., Casswell, S., Edwards, G., Grube, J. W., & Giesbrecht, N. (2010). Alcohol: no ordinary commodity: research and public policy. Oxford University Press.

[2] As codified in article 5.3 of the FCTC: http://www.who.int/fctc/text_download/en/

[4] For example: 11.0% of all Irish public healthcare expenditure in 2012 was spent on dealing with inpatients with either a wholly or partially alcohol-attributable condition  and the direct cost to the Irish economy of alcohol related absenteeism has been estimated to around 40 million Euro.

Mongan, D., & Long, J. (2016). Alcohol in Ireland: consumption, harm, cost and policy response. Health Research Board.

[6] Petticrew, M., Maani Hessari, N., Knai, C., & Weiderpass, E. (2018). How alcohol industry organisations mislead the public about alcohol and cancer. Drug and alcohol review, 37(3), 293-303.

[7] Andréasson S, Chikritzhs T, Dangardt F, Holder H, Naimi T & Stockwell T. (2016) Alcohol and Cancer. Stockholm: IOGT-NTO, Svenska läkaresällskapet and CERA. http://iogt.se/wp-content/uploads/Alkohol-och-cancerrapport-2016_ENG.pdf

[8] World Cancer Research Fund/Americal Insitute for Cancer Research. Continuous UIpdate Project Expeter Report 2018. Alcoholic Drinks and the Risk of Cancer. Available at dietandcancerreport.org

[9] Institute for Health Metrics and Evaluation (IHME). GBD Compare Data Visualization. Seattle, WA: IHME, University of Washington, 2017. Available from http://vizhub.healthdata.org/gbd-compare. (Accessed 2018-06-12)

[10] https://ec.europa.eu/health/sites/health/files/alcohol/docs/ebs_331_en.pdf

 


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  Scottish Health Action on Alcohol Problems on 11-07-2018
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  Institute of Alcohol Studies on 04-07-2018
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Institute of Alcohol Studies comment:

Irish Public Health (Alcohol) Bill

 

The Institute of Alcohol Studies (IAS) is an independent institute bringing together evidence, policy and practice from home and abroad to promote an informed debate on alcohol’s impact on society. Our purpose is to advance the use of the best available evidence in public policy decisions on alcohol. For more information please visit www.ias.org.uk.

 

IAS welcomes the proposals set out in the Irish Public Health (Alcohol) Bill, including those relating to labelling, advertising and a broadcast watershed. Alcohol places a significant burden on health, the economy and society across Europe. Governments that choose to adopt evidence-based policy interventions to prevent alcohol harm should be applauded. The findings from the Irish experience following the introduction of the measures outlined in the Bill will be extremely helpful in informing policy debates in other European countries, particularly the United Kingdom (UK), given the strong similarities in national drinking habits and alcohol harm trend data. This response briefly outlines evidence from the UK which supports the proposals in the Bill, acknowledging the wealth of evidence already presented within the notification from the Irish Government.

 

Labelling

 

Labelling of alcohol products has been shown to increase awareness of the harms associated with drinking[1]. Alcohol is linked to over 200 diseases and injury conditions including cancer, heart disease and liver disease, and the public have the right to know about these harms, in order to make informed choices about their drinking. Worryingly, in many countries awareness of these harms is currently very low. In the UK, research has found that only 1 in 10 people are aware of the link between alcohol and cancer[2], despite the strong evidence linking alcohol consumption to at least seven types of cancer including breast, bowel, throat and mouth[3].

 


 

In 2016 the UK Chief Medical Officers (CMOs) updated the low risk drinking guidelines for adults taking account of the latest available evidence linking alcohol to a number of health conditions, notably cancer. Weekly guidelines were revised to 14 units for both men and women[4]. The new guidelines were based on two principles:

 

1.       People have a right to accurate information and clear advice about alcohol and its health risks.

2.       Government has a responsibility to ensure this information is provided for the public in a clear and open way, so they can make informed choices.

 

The UK CMOs’ expert report recommended that health warnings and consistent messaging appear on all alcohol advertising, products and sponsorship. The Irish Government’s proposals are therefore in alignment with the recommendations of the UK CMOs, based on the latest available evidence on effectively tackling alcohol harm and taking account of consumer rights relating to knowledge of the health effects of drinking alcohol.

 

Marketing and watershed

 

There is strong international evidence to show that exposure to alcohol marketing increases the risk that children will start to drink alcohol, or if they already drink, will consume greater quantities[5]. One means of exposure of children to alcohol advertising is via television broadcast, particularly family programmes scheduled at prime time viewing periods. One study in the UK indicated that between 2007-2011, more than half (56%) of all TV alcohol adverts seen by children aged 4-15 years were aired before 9pm[6]. A watershed ban on alcohol marketing before a set time in the evening would work to protect young children from unhealthy alcohol advertising and would promote a family entertainment environment free from harmful exposures.

 

Institute of Alcohol Studies

4 July 2018

 

 

 

 

 



[1] Public Health England (2016) ‘The Public Health Burden of Alcohol and the Effectiveness and Cost-Effectiveness of Alcohol Control Policies: An evidence review’. Accessed at: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/583047/alcohol_public_health_burden_evidence_review.pdf

[2] Alcohol Health Alliance (2017) ‘Right to Know: Are alcohol labels giving consumers the information they need?’. Accessed at: http://12coez15v41j2cf7acjzaodh.wpengine.netdna-cdn.com/wp-content/uploads/2017/08/Right-to-Know-AHA-August-2017-1.pdf

[3] Alcohol Health Alliance UK (2017) ‘Alcohol and cancer: knowing the risks’. Accessed at http://12coez15v41j2cf7acjzaodh.wpengine.netdna-cdn.com/wp-content/uploads/2017/06/Alcohol_and_cancer_4pp.pdf

[4] UK Chief Medical Officers (2016) ‘Low risk drinking guidelines’. Accessed at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/545937/UK_CMOs__report.pdf

[5] Public Health England (2016)

[6] Ofcom (2013) ‘Children’s and young people’s exposure to alcohol advertising 2007-2011’. Accessed at https://www.ofcom.org.uk/__data/assets/pdf_file/0018/51507/alcohol_report_2013.pdf


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  European Alcohol Policy Alliance on 02-07-2018
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European Alcohol Policy Alliance (Eurocare) welcomes the propositions of the Irish Government with relation to tackling alcohol related harm.

As a general comment Eurocare would like to highlight that measures in the Public Health (Alcohol) Bill are in line with the latest evidence base in the field of alcohol policy.

World Health Organization Global strategy to reduce harmful use of alcohol as well as the World Health Organization European action plan to reduce the harmful use of alcohol 2012–2020 encompass measures proposed by the Irish Bill. 

Moreover, the Sustainable Development Goal 3, Goal 3. Target 3.5, with which the European Union has an obligation to comply, calls for strengthening of the prevention efforts in the area of alcohol related harm.

The Irish provisions also closely follow the 2006 European Union strategy to support Member States in reducing alcohol related harm.

Alcohol and Cancer

Volume 96 of the IARC Monographs found there to be ‘sufficient evidence for the carcinogenicity of alcoholic beverages in humans. The occurrence of malignant tumours of the oral cavity, pharynx, larynx, oesophagus and liver is causally related to the consumption of alcoholic beverages.’ Since 1987, connections between alcohol intake and cancer of the breast, colorectum and liver have also been identified. Indeed, the 2010 monograph identified a relative increased risk for breast cancer for which ‘regular consumption of even 18g of alcohol per day the relative risk is significantly increased. ’18g per day is equivalent to just under 2 regular glasses of wine, 1.3 pints of beer or nearly 6cl of whiskey. Likewise, the monographs confirm an increased relative risk in colorectal cancer for regular drinkers of 50g of alcohol per day.

Need for increased awareness

Experts have known since 1987 that alcohol can cause cancer, but the connection between the two is often unknown, or ignored. Research in Europe has shown that 1 in 10 Europeans do not know about the connection, and that 1 in 5 do not believe that there is a connection between cancer and the drinks[1]

Low levels of public awareness can be found across Europe, latest survey in France has shown that only 23% of respondents identify it as the second risk factor for cancer after smoking[2].

The European Union has recognised the need to promote information regarding preventative measures targeted at individuals and public at large.  Since 1987 it leads the initiative of European Code Against Cancer, the current fourth edition has a revised message in terms of alcohol consumption:

If you drink alcohol of any type, limit your intake.

Not drinking alcohol is better for cancer prevention.

As stated on the European Code Against Cancer website[3]:

There is no doubt that drinking alcohol can cause at least seven types of cancer: those of the mouth, gullet (oesophagus), throat (pharynx and larynx), liver, large bowel (colon and rectum), and breast.

Consumption of any amount of alcohol increases your cancer risk. The more alcohol you drink, the higher the risk of developing cancer. Reducing your consumption or – even better – avoiding alcohol completely will help reduce your cancer risk.

It only appears appropriate that an EU Member State should be allowed to inform their citizens of the potential health risks associated with alcohol consumption.

Labelling as a tool to inform and educate

Product labels can serve a number of purposes: providing information about the product to the consumer, enticing the consumer to buy the product and alerting consumers to the dangers and health risks from the product.

It has been noted that the US health labels have prompted discussions[4] about the dangers of drinking, steadily increased awareness of the labels, and there is evidence of increased public support for alcohol labeling by the US public following its introduction.[5]

Similarly, pregnant women who saw the labels were more likely to discuss the issue; in addition a ‘dose-response’ effect was found such that the more types of warnings the respondents had seen (on adverts at point of-sale, in magazines and on containers) the more likely they were to have discussed the issue.[6]

In France comparable results were found in relation to introduction of the pictogram in 2006.  A study of public awareness regarding the dangers of drinking alcohol during pregnancy indicated a positive evolution in terms of changing the social norm towards ‘no alcohol during pregnancy’.[7]

It could plausibly be argued that where label regulations have been used, there has indeed been a shift towards regarding alcohol as more problematic and heavier drinking has become less ‘normalised’.[8]

Furthermore, warning label messages might serve to legitimate a socially challenging intervention, such as increasing activities that aim to reduce the likelihood of an inebriated person getting behind the wheel.[9]

The tobacco labelling experience offers strong evidence that warning labels can be effective, not only in increasing information and changing attitudes, but also in affecting behaviour.

Results from the International Tobacco Control evaluation also support the effects of pictorial labelling. At least one-quarter of respondents from all four countries reported that the package warnings had made them more likely to quit.[10]

Cigarette packages warnings have had most critical influence in a more indirect manner, such as by influencing non-smokers to encourage smokers to stop through peer pressure – an important influence of the warnings that might be very difficult to assess.[11]

Marketing and watershed

Exposure to alcohol advertising increases the likelihood that young people start drinking at an earlier age, and to drink more if they already consume alcohol[12].

Despite being a key health determinant alcohol is still heavily marketed with young people as an important target group. In 2009, the Science Group of the European Alcohol and Health Forum reviewed evidence[13] looking at the impact of marketing on the volume and patterns of drinking alcohol. It concluded that alcohol marketing increases the likelihood that young people will start to drink alcohol and that if they are already drinking, they will drink more in terms of amount and frequency. According to the WHO European Charter on Alcohol 1995, “All children and adolescents have the right to grow up in an environment protected from the negative consequences of alcohol consumption and, to the extent possible, from the promotion of alcoholic beverages”. Reducing exposure to alcohol marketing by young people should be a key objective

Watershed is a well-known measure utilised by other European countries such as: Austria, Bulgaria, Cyprus, Denmark, Finland, Germany, Hungary, Italy, Latvia, Lithuania, Malta, the Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain.[14]

Final remarks

To conclude, one of the objectives of public bodies should be to effectively protect people from risks and threats that they cannot tackle as individuals. Irish authorities have taken appropriate steps to alert the public to inform them about the dangers of drinking alcohol in relation to cancer prevention.

Health is a public interest worthy of consideration in development and implementation of all policies. Right to health should be considered alongside the right of the commercial operators to trade, to property and to expression. It is our hope that the European Union institutions and its Member States will allow Ireland to put the health of their citizens ahead of profits of the alcohol industry.

Contact details

For more information please contact:

Mariann Skar

Secretary General

Eurocare 

Rue Archimede 17
1000 Brussels, Belgium
Tel
+32 (0)2 732 67 82

GSM +32 (0)47 4830041

E-mail: Mariann.Skar@eurocare.org



[1] EU citizen's attitudes towards alcohol, Eurobarometer EUROBAROMETER 72.3. Special Eurobarometer 331

[2] Résultats d’un sondage réalisé par Opinion Way pour la Ligue contre le cancer

[4] Kaskutas and Greenfield 1992. In Stockwell T. (2006) A Review of Research Into The Impacts of Alcohol warning Labels On Attitudes And Behaviour. University of Victoria, Canada.

[5] Greenfield (1997) in Stockwell T. (2006) A Review of Research Into The Impacts of Alcohol warning Labels On Attitudes And Behaviour. University of Victoria, Canada.

[6] Kaskutas and Greenfield 1992. In Stockwell T. (2006) A Review of Research Into The Impacts of Alcohol warning Labels On Attitudes And Behaviour. University of Victoria, Canada.

[7] Guillemont J. (2009) Labelling on alcoholic drinks packaging: The French experience. Presentation to the CNAPA meeting, February 2009 retrieved from: http://ec.europa.eu/health/archive/ph_determinants/life_style/alcohol/documents/ev_20090217_co08_en.pdf

[8] Wilkinson C. and Room R. (2009) Warnings on alcohol containers and advertisements: International experience and evidence on effects. Drug and Alcohol Review, 28, 426-435

[9] Tam, W. T. Et al (2010) Do Alcohol Warning Labels Influence Men’s and Women’s Attempts to Deter Others from Driving When Intoxicated?. Human factors and Ergonomics in Manufacturing Service Industries, 20 (6), 538-546

[10] FerrenceR, Hammond D, Fong GT. Warning labels and packaging In: Bonnie RJ, Stratton K, Wallace RB, eds ending tobacco problem: blueprint for the national. Committee on Reducing Tobacco Use: strategies, barriers, and consequences. Washington: National Academy Press, 2007: 435-48

[11] Wogalter, S.M. and Brelsford, W. J. (1994) Incidental exposure to rotating warnings on alcoholic beverages. Proceedings of Human Factors and Ergonomics Society 38th Annual meeting

[12] AMPHORA project; Andreson et al. (2009) Impact of alcohol advertising and media exposure on adolescents’ alcohol use: a systematic review of longitudinal studies. Alcohol 44(3), 229-243
Smith and Foxcroft (2009) The effect of alcohol advertising, marketing and portrayal on drinking behaviour in young peoples: systematic review of perspective cohort studies. BMC Public Health, 9, 51.

[13] Science Group of the Alcohol and Health Forum (2009) Does marketing communication impact on the volume and patterns of consumption of alcoholic beverages, especially by young people?  As retrieved from: https://ec.europa.eu/health/ph_determinants/life_style/alcohol/Forum/docs/science_o01_en.pdf

[14] Advertising restrictions on national television WHO Global Health Observatory Data Repository (European Region) 2012


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  United European Gastroenterology on 28-06-2018
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A chara, 

Please find below recommendations from United European Gastroenterology (UEG) on the Irish Public Health (Alcohol) Bill.

 

Recommendations from UEG on the Irish Public Health (Alcohol) Bill

United European Gastroenterology (UEG) is a professional medical association combining scientific European societies concerned with digestive health. In addition to promoting high-quality clinical care, scientific research and training, UEG also aims to increase awareness of gastrointestinal diseases amongst the greater public and decision-makers.  

The provisions taken within the Irish Public Health (Alcohol) Bill (health warnings on labels, minimum unit pricing and stricter regulation on the advertisement of alcohol) are necessary to tackle the issue of alcohol related harm and to prevent onset of many digestive diseases. Alcohol consumption is a risk factor in over 60 types of diseases, with nearly one quarter of all deaths from gastrointestinal diseases – including liver cirrhosis, pancreatitis and digestive cancers – directly attributed to alcohol. In 2017, UEG released a report that highlights the indisputable link between alcohol and several forms of digestive cancers – oesophageal, liver, pancreatic, colorectal and gastric cancers.

According to our experts, the risk of cancer incidence rises exponentially with the amount of alcohol consumed. Drinking 3 times the recommended amount increases the risk of oesophageal cancer by 8. Alcohol accounts for up to half of all liver cancer cases in Europe, and even moderate alcohol consumption increases risk for oesophageal and colorectal cancer in particular.

The survival rates for pancreatic cancer are alarmingly low, at 3-6%, and the median survival rate after diagnosis is just 4.6 months. Incidence of this kind of cancer are growing, and according to our experts, this is directly linked to alcohol misuse.

We are in support of the progressive proposal for alcohol labels to carry information alerting consumers to the cancer link proposed by the Irish Public Health (Alcohol) Bill. UEG is in support of this as it is a rational and responsible response to a growing health problem and we are in favour of restrictions on alcohol advertising and marketing, especially where children are concerned, and mandatory labeling. The adoption of the Irish Public Health Bill would be a positive move in the right direction to improve public health and reduce incidences of digestive cancer.

References:

Alcohol and Digestive Cancers Across Europe: Time for Change https://www.ueg.eu/publications/alcohol-and-digestive-cancers-report/

Digestive Health Across Europe: Issues, challenges and inequalities
https://www.ueg.eu/epaper/UEG_DigestiveHealthAcrossEurope/index.html#0
    


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  Alcohol Action Ireland on 27-06-2018
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A chara

Please find attached a submission on the Public Health (Alcohol) Bill 2015.

Yours sincerely

Eunan McKinney

on behalf of Alcohol Action Ireland

 

 

 

 


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  spiritsuisse on 01-05-2018
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  Distilled Spirits Council on 20-04-2018
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  Winemakers Federation of Australia on 20-04-2018
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  FIVS on 19-04-2018
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Irish Public Health (Alcohol) Bill

FIVS’s Submission Regarding the

 Technical Regulation Information System (TRIS) Notification

19 April 2018

 

Dear Sir and Madam,

In January 2018, the Irish Government notified to the European Commission, under the TRIS procedure, new amendments to its draft Public Health (Alcohol) Bill initially notified in 2016. These changes included:

  • mandatory cancer warnings on alcohol beverages labels and advertising materials[1];
  • a requirement that health warnings take up at least one third of printed materials for the labelling of alcohol products[2]; and
  • a ban on all alcohol broadcast advertising before 9pm[3].

These new elements are to be added to the provisions initially present in the version of the Bill notified in 2016 (TRIS notification 2016/42/IRL and WTO notification G/TBT/N/IRL/2) to which 10 European Union Member States communicated their opposition. This first notified draft included the following:

  • minimum unit pricing of alcohol products; 
  • health labelling of alcohol products; 
  • the regulation of advertising of alcohol products; 
  • the regulation of sponsorships by alcohol companies; 
  • the structural separation of alcohol products in mixed trading outlets; and
  • the regulation of the sale and supply of alcohol in certain circumstances. 

 FIVS, as a non-EU trade association, welcomes the opportunity to share its comments on the Irish Public Health (Alcohol) Bill. As mentioned, it has been re-notified through the European Union TRIS notification process due to the adoption of three additional mandatory requirements for labelling, advertising, and broadcasting.

FIVS is a Paris-based, non-profit organisation founded in 1951, that serves all sectors of the alcohol beverage industry. The organisation has 56 members from 24 countries/regions and includes companies, distributors, importers, exporters, and trade associations.

Our association is supportive of national initiatives which seek to address harmful uses of alcohol. Nevertheless, without questioning the public health objectives pursued by the Irish authorities, we regret that the draft Bill comes as a challenge to the free movement of goods within the European Single Market and creates disproportionate and unnecessary obstacles to international trade. We would stress that the Irish Government has not offered reasoned justifications for these measures.

In addition, by aiming to reduce per capita alcohol consumption figures, we consider that the Bill fails to focus on what should be the relevant objective: reducing the harmful use of alcohol.

1.       The Irish Bill introduces unjustified and disproportionate measures

On the Matter of Justification:

FIVS regrets that the Irish Government has not presented scientific or evidence-based arguments to justify the introduction of either the requirement that a label make reference to the direct link between alcohol and fatal cancers and/or the rule that at least one third of alcohol beverages labels be devoted to health warnings. 

On the Matter of Disproportionality:

The Irish Authorities state in the ‘Message’ section of the TRIS Notification (Part 9 entitled “brief statement of grounds”) that “There is irrefutable evidence that alcohol causes cancer and that there is a direct causal link between certain fatal cancers and alcohol misuse.”  However, while consuming alcohol may be a risk factor in the case of some cancers, it is not necessarily the cause of individual cancers.

The linkages between alcohol and cancer risk are complex and cannot be adequately explained in a single warning label. About seven of the 200 estimated cancers are reported to be alcohol-related, i.e., alcohol intake increases the risk of those types of cancer.

A focus on one health issue alone offers little in the way of a full or accurate picture to help consumers make informed choices about their drinking choices. Warning labels should be proportionate to the risks faced by consumers, but cancer labels alone do not allow consumers an accurate or a proportionate view of the effects of moderate alcohol consumption.

Besides, the proposed warning would be unprecedented within the European Union on a legally sold foodstuff[4]. Eating processed meat, salt-preserved foods and drinking very hot beverages are respectively associated with an increased risk of colorectal, stomach and oesophageal cancers.

On the basis of the above, FIVS considers that the notified cancer warning, directly linking alcohol consumption with fatal cancers, would be disproportionate, unjustified and hence not consistent with Article 36 of the Treaty on the Functioning of the European Union (TFEU).

2.       The Irish Bill challenges the free movement of international goods within the European Single Market

Barrier to trade N°1: The ‘Irish-only’ label

The requirement of a warning informing consumers of the direct link between alcohol and fatal cancers (unlike a targeted communication on the dangers associated with the consumption of alcohol during pregnancy or a targeted communication on excessive alcohol consumption), constitutes an unprecedented labelling initiative.

Where one could understand the political choices of new labelling requirements for health, economic, and cultural considerations, such initiatives should be proportionate and in line with the European free movement of goods principle.

We are convinced that the cancer warning labelling requirement, together with the requirement that health warnings take up at least one third of printed materials for the labelling of alcohol products, are disproportionate[5] and regret that these measures would prevent internationally traded wine and spirits to circulate freely within the European Single Market.

Indeed, such requirements would require alcohol beverages producers to prepare specific labels for the Irish market.

 

FIVS considers that the labelling requirements included in the Irish Bill would create a barrier to trade and entry into the Irish Market, and would have the equivalent effect of quantitative restrictions, which are incompatible with Article 34 and 35 of the TFEU.

Barrier to trade N°2: the Bill prevents foreign operators’ products to become known by Irish consumers

According to the new amendment to the Bill, regarding the ‘Content of advertisements’, a cancer warning will have to be included in every advertisement for alcohol products.

Not only do we find such cancer warning requirements disproportionate and unjustified[6], but we are also concerned that together with the advertising restrictions initially notified in 2016 – severely restricting advertising content and placements – this would make the very limited advertising options require a mandatory cancer warning. This requirement would in turn place foreign operators at a severe disadvantage in the Irish market, while favouring operators whose brands are already well-established in the country.

FIVS regrets that advertising restrictions previously notified, and now coupled with the issue of cancer warnings on alcohol advertising, would prevent foreign operators from making Irish consumers aware of their products and would offer an unfair advantage to products that are already well-established within that market.

FIVS has Remaining Concerns on TRIS Notification 2016/42/IRL

The new measures of the Bill, as re-notified on TRIS, come in addition to:

-          Minimum unit pricing for alcohol beverages;

-          Health labelling of alcohol products (dangers associated with alcohol consumption and pregnancy); 

-          Advertising restrictions (placement, content, and publication);  and

-          Sales restrictions (structural separation of alcohol products in mixed trading outlets, promotions, and reduced price prohibitions).

As raised by many countries through the WTO TBT process, the previously notified version of the Bill was already problematic and still remains flawed. Without entering into detail into these provisions, as they are not the ones notified here, FIVS would like to stress that we still consider them as creating unnecessary obstacles to international trade and the free movement of goods within the European Single Market.

From what we have understood, the Irish Government did not engage in bilateral or multilateral discussions with third countries that have commented on the notified Bill, nor did it decide to change the content of its proposed legislation, or provide reasoned justifications for the measure. Therefore, we ask that the Commission requests that Ireland replies in good faith to the concerns previously raised by third countries via the TBT notification process.

FIVS Calls for a Future WTO TBT Notification of the Amended Bill

FIVS hopes it can rely on the Commission, on behalf of Ireland, to notify the final version of the Bill through the WTO TBT notification process, hence providing EU trading partners with the possibility to officially share comments on the proposed technical standards.  



[1] Section 12(1)(iii) and Section 13(2)(c).

[2] Section 12(10)(a).

[3] Section 19.

[4] At an international level, only Korea requires a cancer warning on alcoholic beverages. However, this warning norm does not link cancer to alcohol consumption per se, but ties it to the excessive consumption of alcohol.

[5] For more information on the disproportionality of the measure, see Part. 1.

[6] For more information on the disproportionality of the measure, see Part. 1.


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  New Zealand Winegrowers on 19-04-2018
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Please find attached a submission on the Public Health (Alcohol) Bill 2015.

Yours sincerely

Jeffrey Clarke
General Manager Advocacy
New Zealand Winegrowers


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  Spirits Canada on 06-04-2018
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 The attached is sent on behalf of Mr. Jan Westcott, President & CEO of Spirits Canada.