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Freda Wallace is the cohost of the Gender Nebulous podcast.
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I want to comment on a rant that was previously posted on this podcast. The rant in question was posted with episode 120 Levelling the Field and the topic was Minimum Unit Pricing for Alcohol or MUP. MUP, long-time listeners may recall, prohibits the selling of an alcoholic beverage below a price determined by the alcohol content of the beverage.
To recap, by my reading, William made three arguments. First, that the MUP policy is motivated by a desire to advantage pubs over off license competitors. Second, that demand for alcohol is inelastic and therefore this measure is unlikely to be an effective measure for reducing alcohol consumption. Third, and relatedly, that higher prices may paradoxically lead to increased consumption. Therefore, it was concluded that MUP should not be perceived as a public health measure. Supporting evidence is presented by pointing out that page 26 of the 2011 Fine Gael General election manifesto says that below cost alcohol sales will be banned to support the viability of pubs. Further, it was noted that Ireland has both high alcohol consumption and high alcohol prices so the correlation is not there to support price increases as a preventative measure. Finally, marketing strategies from other industries, like the diamond trade, were identified as positive examples of an industry conspiring to increase the price to increase the importance of the product.
Firstly, I think we shouldn’t dismiss MUP as a public health measure without presenting what public health professionals think of it. There is peer reviewed academic literature which describes how an advocacy coalition called Alcohol Health Alliance Ireland was formed by the public health community specifically to secure the enactment of the 2015 Public Health (Alcohol) bill which contains MUP alongside other provisions. The bill was informed by an alcohol steering group, co-chaired by Tony Holohan, that recommended restrictions on price and other measures based on the international best evidence. By the way, the coalition was opposed by an industry group and Diageo are alleged to have threatened to reduce operations in Ireland over the policy. This is one reason why I am not worried that this measure serves the interests of the pub lobby or is part of a scheme to increase the sales of alcohol.
It also needs to be said that a ban on below cost sales would mean that retailers are not allowed to sell an alcohol product at a price that is less than the cost of its manufacture. Retailers sometimes do this for strategic reasons, to undercut and drive out competitors. The policy that was proposed in the 2011 Fine Gael manifesto is different to the MUP measure that was introduced in the bill that became the 2018 Public Health (Alcohol) Act.
Another reason is that all available evidence suggests that the policy will be effective. The World Health Organisation’s draft Global alcohol action plan endorses pricing policies to control consumption and a brand new study in the Lancet has found that Scotland’s MUP policies are associated with reductions in deaths and hospitalisation. Scotland’s lessons, by the way, are the most relevant for what is possible in changing Ireland’s drinking culture. As Professor Frank Murray of the RCPI has pointed out, we can’t easily compare ourselves to the sunny beaches of the Mediterranean, as was suggested in the episode 120 because the context is just too different.
Finally, I’m not unduly concerned by the fact that the instrument used to increase alcohol prices was regulation rather than taxation. We already have taxes on alcohol products. A problem with increasing taxes on alcohol products as a standalone is that the measure can be undermined if retailers respond with a tactic called undershifting. This means that for cheap alcoholic beverages the retailer does not pass on the full cost of the tax increase to consumers. Instead, they offset their losses by increasing the cost of more expensive alcohol products. This is a ploy to keep the cheap alcohol cheap.
This highlights why MUP works. The most problematic drinkers are interested in the greatest volume of alcohol for the lowest price. This includes young people who are among the groups most impacted by MUP. From a lifecourse perspective, this measure is well suited to the mission of ensuring that young people are less likely to form a relationship with alcohol that will affect the rest of their lives. Consider also that it’s not just the total volume of alcohol consumed that determines harm, but the patterns of drinking. This makes hospitalisations, the outcome used in the Lancet study, a good outcome measure for studies of MUP. How many trips to the hospital are averted by the fact that a student was just a little bit less drunk than they might have been had their predrinks budget bought more alcohol?
It’s possible that there is a convoluted attempt to use MUP to increase alcohol sales for pubs but applying Occam’s razor to the facts leads me to the conclusion that the public health (alcohol) act of 2018 is what it says on the label.
