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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 .
We welcome the opportunity to comment on the proposed 50 pence per unit minimum price set out in the draft SI. Whilst we do not think it is appropriate for us to recommend a particular floor price for alcohol we would urge the Scottish Government to bear in mind the following points as part of its final decision on what is an untested and major policy intervention. • The likely cross-border effects and loss of sales for Scottish companies and retailers as consumers seek alcohol from elsewhere. The higher the MUP the larger this impact will be. • Likewise the potential for Illicit sales / sales and consumption outside of the licensing regime, including to minors for example which was prevalent at the height of the ‘booze-cruise’ boom to France in the mid/late 1990’s. • An Institute of Fiscal Studies paper issued in December highlighted that average alcohol prices in England, Wales and Scotland are currently very similar, with 68.2% of products off-trade alcohol in Great Britain sold below 50p pence per unit, with the figure at 68.7% in Scotland. The average price of those products sold in Scotland below 50p was 11p below this (39p). For categories such as Cider this rises to more than 20p lower (GB as a whole). • This means that at 50p per unit there will be some very significant price rises for alcohol brands in Scotland with some products diverging very significantly from England • According to National Statistics alcohol prices in the off-trade have remained broadly flat since 2011 • The price set should remain fixed throughout the five-year period to allow a meaningful evaluation of the impacts • As well as the public health impacts it is important that the evaluation takes a holistic approach including: cross-border and illicit impacts; overall consumption as well as sales in Scotland; product, category and channel switching (e.g. off-trade and on-trade impacts); as well as any employment impacts and impacts on those on low incomes. • It is important that retailers and consumers are aware of the changes and the reasons why products have increased in price, some quite significantly. We believe this requires some standard text to be developed by the Scottish Government that can be displayed in store and shared with customers as required.

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Paul Togneri

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Scottish Beer and Pub Association