We are extremely concerned by the scope and nature of the measures proposed by Scottish Government Ministers to restrict alcohol advertising and promotion, and we do not support them. We believe that they are disproportionate, unsupported by convincing evidence, and would do serious damage to the Scottish economy on multiple fronts. We do not believe that they will achieve the policy objectives which the Scottish Government seeks to meet.
The proposed measures are sweeping in scope. They are so stringent that they almost amount to a greater intervention than prohibition; and the way in which the consultation is framed treats alcohol brands as bad faith actors, seeing them as enticing people into greater consumption even when they put time, effort and money into low- or no-alcohol products to help meet the very public policy objective that the Scottish Government identifies. We do not believe that this approach is justified; nor do we believe that it will be beneficial to the Scottish economy. Quite the reverse: it may well accelerate the trend of marketing budgets moving out of Scotland, and the imperilling of not just hospitality venues, but also essential elements of the Scottish tourism industry and critical Scottish exports.