tonic portman group code consultation response
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Consultation Response
Code of Practice on the Naming,
Packaging and Promotion of Alcoholic
Drinks
11 May 2012
CONTENTS FOREWORD 1
SECTION 1 – BACKGROUND 2 SECTION 2 – KEY FINDINGS 3
Communication of alcoholic strength
Sponsorship
Use of images of under-25s in marketing
SECTION 3 – EXPERT WORKSHOPS 4 SECTION 4 – NEXT STEPS 4 SECTION 5 – FURTHER INFORMATION 4
1
FOREWORD
Responsible alcohol producers are serious about tackling alcohol misuse as it
is in their long-term business interest to make sure that their products are
marketed and sold responsibly.
That’s why effective self-regulation is so important to prevent irresponsible
marketing. The Portman Group Code is well recognised as a good example of self-
regulation and has been commended by regulation experts, our European
counterparts, and is referenced in the Government’s recent alcohol strategy.
However, we cannot be complacent and it is vital that the self-regulatory framework
remains fit for purpose. It is five years since the Code was last reviewed in which
time the marketing environment has undergone significant change, including the
rapid growth in social networking and the use of digital media. Our self-regulatory
framework has continually evolved in response to these developments. Our pledge
to carry out a formal review of the Code under the Government’s Public Health
Responsibility Deal is part of this ongoing commitment.
I would like to thank those that responded in writing to our consultation and everyone
who attended one of our expert workshops. This level of expertise and engagement
is vital in helping us to conduct a comprehensive Code review.
The aim of this response is to provide an overview of the process so far and to
highlight the key areas on which we will focus as we develop the next edition of our
Code over the summer. We aim to publish the new Portman Group Code in Autumn
2012 and will then allow a period of six months before the Code comes into force in
Spring 2013.
As transparency is an important principle of good regulation, we are publishing all
consultation responses received together with the detailed analysis of these
responses from our independent consultants. .
If you would like to discuss the process or find out more about the regulation of
alcohol marketing, do get in touch.
Henry Ashworth Chief Executive, Portman Group
2
1. BACKGROUND
The review of the Portman Group’s Code of Practice on the Naming, Packaging and
Promotion of Alcoholic Drinks is to ensure that there are no regulatory gaps and that
the rules that govern alcohol marketing remain up-to-date and fit for purpose. The
consultation closed on 31 January following a 14 week public consultation period.
We received 49 submissions from a wide range of stakeholders including health,
voluntary and charity organisations, Government, alcohol companies and trade
associations. We appointed an independent firm, Tonic Consultants, to analyse the
consultation responses and to make initial recommendations to the Portman Group.
Tonic’s report, featuring evaluation and analysis of the responses, along with all non-
confidential responses to the consultation, can be found on our website
http://www.portmangroup.co.uk/?pid=44&level=2
2. KEY FINDINGS
The responses covered all aspects of the Code, and represented a good balance of
views with the health, voluntary and charity sector accounting for just over a third of
the responses, industry and trade associations accounting for a third of responses
with the remainder coming from other interested parties.
There was majority support for changes to be made in three key areas. We expect to
amend the Code in these areas and also produce detailed guidance to support any
rule changes.
These key areas are: communication of alcoholic strength; sponsorship; and the use
of images of under-25s in alcohol marketing. Further detail on these areas is
summarised below:
Communication of alcoholic strength
The Government’s Alcohol Strategy has provided a clear mandate to review any
rules which might currently inhibit the promotion of lower strength alcohol products
within their category. From the responses received, there was majority support that
the rule on alcoholic strength should be amended to allow better communication of
factual information about strength on product labels and in marketing. However, any
change in this area must not undermine the existing rule which prevents products
being promoted on the basis of high alcoholic strength or intoxicating effect. In
addition, there was general support for greater flexibility for marketing of products
with a relatively lower alcoholic strength within their category, including support from
the health and voluntary sector organisations.
3
Sponsorship
There was majority support for more detailed guidance on responsible sponsorship.
Furthermore there was majority support in favour of this guidance having some
binding elements, although it should mostly be non-binding. There was also general
support for Portman Group’s guidance to be consistent with the Scottish sponsorship
guidelines which have just undergone a comprehensive review.
Use of images of under-25s in marketing
There was majority support for amending the Code broadly in line with the Portman
Group’s proposal. This would clarify how images of under-25s could appear in
marketing material, for example individuals were not seen to be: consuming alcohol,
about to consume or having just consumed alcohol; not endorsing the brand; and
being only incidental to the marketing.
3. EXPERT WORKSHOPS
To develop detailed proposals and recommendations for these three elements of the
Code, we held expert workshops bringing together stakeholders and interested
parties with relevant expertise. The recommendations and outcomes from the
workshops will feed into the proposed new Code and supporting guidance
documents.
Responses also identified other areas of the Code which would benefit from further
guidance and clarity. Where changes to the Code are not considered to be
fundamental, guidance will follow in due course.
4. NEXT STEPS
We will be working on the new edition of the Code, and some of the supporting
guidance over the summer. We will also take the opportunity to undertake some
improvements to the layout of the Code.
We expect the new Code and guidance to be launched in Autumn 2012 with a six
month grace period to allow the industry to adjust to any new rules. The existing will
continue to apply during that time.
4
In the event that any new binding rules for a particular medium or activity are
required, we will embark on a further technical consultation exercise on that specific
element.
We will also be embarking on a training and awareness programme to bring the
industry and their agencies up to speed with any significant changes that may affect
them.
5. FURTHER INFORMATION
Further information can be found in the Code Consultation section on the Portman
Group’s website www.portmangroup.org.uk, or follow us on Twitter
www.twitter.com/portmangroup
Portman Group
11 May 2012
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