Response 624225670

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We invite comments on the proposed minimum price of 50 pence per unit which is set out in the draft Scottish Statutory Instrument at Annex A.

We invite comments on the proposed minimum price of 50 pence per unit which is set out in the draft Scottish Statutory Instrument at Annex A .
spiritsEUROPE is the trade association at European level representing 31 national associations as well as 8 leading multinational companies. Our mission is to represent, defend and promote the European spirits sector and help members achieve sustainable growth. We have considered carefully the consultation document published last December on Minimum Unit Pricing. We have never commented the level at which the price should be set. Nevertheless, we remain committed to be constructive and open to dialogue with authorities and stakeholders all along the process of implementation of the measure. The measure will impact many companies in Europe, large and small, who are exporting their products to Scotland and wish to operate on a level playing field. Through this response, spiritsEUROPE would like to offer some principles on the basis of which we believe the evaluation of the measure should be carried. We welcome the publication and efforts already in place to make this possible. Firstly, we believe that there are key principles for the evaluation: • Relevance • Neutrality and objectivity • Fairness and transparency • Robustness • Engagement We would hope that there will be a mechanism in place along the process for all interested parties to be able to ask questions and seek additional information. Secondly, spiritsEUROPE would very much welcome for the evaluation to assess: • If MUP will have an impact on prices of beverages that are currently sold above MUP; • If the variety of assortment of European products in Scottish retail outlets evolves following the introduction of MUP; • If the variety of assortment of products imported from outside the EU in Scottish retail outlets evolves following the introduction of MUP; • If the market share of imported, and EU products, versus UK products evolves following the introduction of MUP; • How the representation of retailers own-labels products versus branded products will evolve following the introduction of MUP; • If a statistically significant change in the trends of alcohol consumption and especially heavy alcohol use, as well as the proportion of alcoholics amongst the poorest and richest population decile, has occurred after the introduction of MUP; • If substitution effects between different beverage types (beer, wine, spirits and cider) are impacted by MUP; • How different consumer groups (light, moderate, heavy, and addictive drinkers) by income react to MUP, e.g. spending less on other food stuff, cross-border shopping, switch to the non-commercial alcohol market or if light and moderate drinkers will reduce or stop consuming alcoholic beverages; • If statistically significant changes in the trend of heart disease deaths are observed amongst the poorest population group; • If alcohol related deaths among different consumer groups by income have changed after the implementation of MUP.

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spiritsEUROPE