Today (9 March 2023) was the closing date for the Scottish Government’s consultation on alcohol advertising. This consultation included a section on alcohol-free drinks, so Club Soda responded.
In developing our response, we drew on three pieces of research:
- An opinion poll of 2,000 UK adults and a booster poll of adults in Scotland about their drinking habits and their attitudes to alcohol-free drinks
- Focus groups with Club Soda members, exploring individual experiences of alcohol-free drinks
- A review of existing research which draws together the latest evidence on drinking behaviours and the role of alcohol-free drinks.
We think it’s important to be transparent about the work we do. So below is a list of the questions in the consultation we responded to and the information that we submitted.
If you want to read the research report, you can download it free here.
Do you think that any potential alcohol marketing restrictions should apply to low or no alcoholic drinks products, where these carry the same brand name, or identifiable brand markings, as alcoholic drinks?
We have just published detailed research into this issue and we will also email this document to you. The research draws on UK wide polling with a Scottish booster survey, in-depth focus groups with our members, and a thorough review of available evidence on alcohol-free drinks. A summary of our research shows the following.
Our polling shows that Scottish people drink alcohol-free drinks more regularly than the UK as a whole. They also drink alcohol and soft drinks more often.
The most common reasons given for drinking alcohol-free drinks were “to enjoy the taste of an alcoholic drink without getting drunk” (39%), “to cut down the amount of alcohol I drink overall” (36%) and “to take a temporary break from drinking” (31%).
They are also enjoyed as an alternative to sugary soft drinks, because they contain less sugar. These individuals accounted for one in five (19%) of Scots, compared to one in six (15%) across the UK. Those who don’t drink them “prefer soft drinks like coke or orange juice” (42%) instead, or would prefer to drink alcohol (48%).
Limited availability of alcohol-free drinks leaves most people facing a stark choice between sugar and alcohol. Given the twin public health challenges caused by sugar and alcohol, we believe it is nonsensical and counterproductive to restrict the promotion of health-positive alternatives for adult drinking.
Your consultation document makes the bold and unsubstantiated assertion that alcohol-free drinks are largely bought and consumed in addition to alcohol, and do not make a positive difference in helping people change their drinking habits. There is no data-driven evidence to suggest this is the case. In fact, emerging academic research we review in our report is beginning to show how consumption of alcohol-free drinks leads to a reduction in alcohol use. Our research shows clearly that individuals use alcohol-free alternatives to sustain long-term behaviour change.
Scottish respondents in our polling were asked whether they would be more likely to buy alcohol-free drinks from an alcohol company or an alcohol-free specialist producer. Of the 354 respondents who expressed a view, half (49%) preferred alcohol-free drinks from formerly alcohol-only brands. One in five (19%) preferred drinks from companies that do not produce any alcoholic drinks.
This confirms the evidence from our previous research that most people discover alcohol-free drinks through a brand they used to drink as an alcoholic product. These brand extensions give current drinkers the confidence to try an alcohol-free alternative, and are an easier way of reducing alcohol consumption than purely alcohol-free brands.
Promotion of alcohol-free versions of alcoholic drinks
Compared to the UK as a whole, Scots had an even more positive view of sports sponsorship by alcohol-free versions of alcoholic drinks. For example, when asked about Guinness 0.0’s sponsorship of the Six Nations rugby tournament, over nine in ten Scots (92%) had a favourable view. More than half (53%) were fairly positive, and the remainder were very positive.
Promotion of alcohol-free drinks generally
Scottish people were also more positive about the potential for promoting alcohol-free drinks more widely as an alternative to alcohol. Eight out of ten (79%) wanted to see alcohol-free alternatives more extensively promoted, compared to two-thirds of respondents (67%) in the UK as a whole. These responses show that UK adults are generally in favour of promotion of alcohol-free drinks. And those living in Scotland are even more favourable.
We acknowledge that there is always a balance to be struck by Governments on freedom of choice and tackling systemic health problems through public policy. Alcohol’s long use throughout history makes this particular substance a hard one to tackle.
But our research makes it clear that alcohol-free drinks are a force for good, regardless of who produces and promotes them. There is strong data and evidence that shows alcohol-free drinks are helping people change their drinking habits and reduce their alcohol consumption. They allow Britain to keep socialising whilst changing the drink that is strongly associated with being social.
It is also worth reminding ourselves of why it is we learn to like alcohol in the first place. We like it because of its effects, not because of its taste (this is a learnt behaviour). From our experience working with younger people and with muslims who have never drunk alcohol, we know that they do not like the taste of alcohol, and steer away from bitter drinks like gin and tonic and beer. Alcohol-free drinks do not lead them on to alcohol. Equally people who choose an alcohol-free drink because they are avoiding alcohol want to replicate a taste they have learnt to like but without the intoxicating effects of alcohol.
We can’t know all the motives of alcohol brands when it comes to creating alcohol-free brand extensions. It is clear from our research however, that consumers feel more confident to try an alcohol-free drink when it is from a brand they have already drunk as an alcohol-full product. Large brands, who have the budgets to promote their alcohol-free extensions, have been more effective than anyone else in shifting consumer behaviours away from alcohol to alcohol-free. This works by normalising asking for an alcohol-free drink in a way that small challenger brands never could do.
Finally, we are deeply disappointed that your consultation document has cherry-picked evidence on alcohol-free drinks to frame them negatively, rather than seeing them as part of the answer to one of public health’s biggest issues. We suggest that the Scottish Government look again at alcohol-free drinks’ role in society, more thoroughly reviews the available evidence, and considers proactive incentives and policies that could speed up the adoption of alcohol-free alternatives for adults. We would suggest looking at:
- Not waiting for Westminster to decide on the best descriptors for alcohol-free drinks, and sorting this now at a devolved level. By coming into line with the European standard, that 0.5% or below is alcohol-free, the Scottish Government could give consumers consistent messaging about what is alcohol-free.
- The wider promotion of alcohol-free drinks to significantly help adults with sugar and calorie reduction. For example, taking away VAT on alcohol-free drinks in on-trade settings would be a further incentive to swap from alcohol or a sugary soft drink to adult alcohol-free drinks.
- Promote the value of switching from alcohol to alcohol-free in public health messaging campaigns.
- Supporting independent Scottish alcohol-free brands as part of your economic strategy. This might include support for small challenger brands to connect more effectively with the consumers and to enable Scottish alcohol-free drinks businesses to benefit from exporting to the growing international markets for their products.
What further evidence on alcohol marketing would you like the Scottish Government to consider?
Whilst we would agree that there is too much advertising of everything in life in general, it is clear from our community and consumers of alcohol-free drinks that they would like alcohol-free products to be more visibility promoted. They are perceived as a good thing and people want to enjoy similar ‘promotions’ from alcohol-free products as you get for alcohol (for example alcohol-free options at a bottomless brunch, promotions in supermarkets etc).
It is also clear that, as a new category of drinks, there is still much more to do to drive awareness of availability of alcohol-free drinks. This in turn promotes the value of not drinking as a viable and socially acceptable choice. It takes pressure off people not wanting to drink. The promotion of alcohol-free drinks has significantly contributed to the rapid shift in consumers’ relationship with alcohol over the last five years. We think there is a need to continue encouraging people to try alcohol-free drinks as part of ‘sober sampling’. There is consistent evidence that substitution is a positive behaviour change tool, and we are just scratching the surface of alcohol-free drinks’ potential contribution to reducing people’s alcohol use. Promotion of alcohol-free as a normal drink helps change perceptions and reduce social pressure to drink.
There is much concern in the public health community about so-called “alibi marketing”. We do not perceive alcohol brands as promoting alcohol-free as a tactic to encourage the consumption of their alcoholic products. Indeed, our research shows exactly the opposite – that the promotion of alcohol-free products encourages their increased consumption, and a diversion away from alcohol. We are by no means advocates of big alcohol here, but we would suggest that these companies are able to produce alcohol-free drinks at scale, and are well placed to meet consumer demand for alcohol-free products. Alcohol sales are falling as people are drinking less, and drinks companies want to produce a product that keeps those not drinking with their brand, not as a tool to keep them drinking alcohol.
If you sell, distribute, advertise or manufacture alcohol, or represent those who do, how do you think the potential restrictions in this consultation paper would impact you, and the wider alcohol sector?
As part of our social impact mission our intention is to open a Tasting Room and Bar in Scotland soon. The proposed restrictions could, depending on the details of how they were implemented, at least reduce the range of drinks we were able to offer. They could also make our operations more costly and stop us from advertising our space which would also affect our ability to deliver our social impact mission, to help people drink more mindfully and live well, to as many people.
Are there any relevant equality issues that Scottish Government should be considering at this stage in the policy development?
The proposals in this consultation are based on an assumption that everyone drinks alcohol and the aim is to stop people drinking alcohol. However, the proposed restrictions could have an adverse impact on people who have never drunk alcohol, by inhibiting options for them to be included in social spaces. It suggests that those not drinking alcohol should always be happy with a sugary soda designed for children, rather than a healthy, good tasting, adult drink. We would hope that the Scottish Government would want to avoid reinforcing the dominant social narrative of bars and restaurants as booze-led spaces for people only interested in alcohol. A broader view of the impacts of this proposed policy is required.
Our links to the alcohol industry for transparency
Our low and no-alcohol Tasting Room shop and bar in London stocks drinks between 0.05% and 0.5%. Based on current descriptors, these are ‘low’ alcohol, although we follow the growing international consensus that 0.5% and below drinks are alcohol-free.
We also have a very small number of drinks over 0.5% ABV that are lower strength than their alcohol-full counterparts. This is because we believe mindful drinking is as much about what people choose when drinking as what they drink when they are not drinking alcohol. This is based on our social impact mission to help people drink more mindfully and live well. We help people moderate as well as go alcohol-free.
We stock some alcohol-free drinks produced by alcohol brands – Adnams Ghost Ship, Wild Wave, wines and Smidgin, Crodino made by Campari, Guinness 0.0, and Beavertown’s low and low and alcohol-free variations. We have in the past undertaken research funded, but not directed by, AB InBev and Heineken. Brands like Adnams and Heineken sponsored our previous Mindful Drinking Festivals, including our festival in Glasgow in 2018.
We provide free behaviour change courses for people who work in the drinks industry funded by The Drinks Trust (an industry-funded charity) to support staff in the sector to drink more mindfully.
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