This document summarizes the key points from a presentation on alcohol labeling regulations in Ireland. It discusses the high rates of alcohol-related harm in Ireland including alcohol use disorders and deaths. It outlines Ireland's Public Health Alcohol Act of 2018 which includes provisions for minimum unit pricing and health warnings on labels. The process by which Ireland notified and finalized regulations for health warnings on labels is described, including responses from the EU and World Trade Organization. Other international developments in alcohol labeling are also mentioned.

1. APN Symposium 22 June2023
Get the facts – on the bottle
Dr Sheila Gilheany, CEO

2. AAI – independent advocate for
reducing alcohol harm
Strategic Plan 2020-2024
 Coherent and urgent implementation of Public Health (Alcohol) Act 2018 in full
 A childhood free from alcohol harm
 Services for all affected by alcohol harm
 Establishment of a state sponsored Office to lead on alcohol policy
 Main funder Health Service Executive, Ireland

3. High annual
alcohol use in Ireland

4. Alcohol impact in Ireland
15% of Irish population have an Alcohol Use Disorder
4 deaths from alcohol per day, 1460 annually –
11% of health care budget
€3.7 billion in wider costs to society, likely
twice that amount if including harm to others

5. Central provisions within the Public
Health (Alcohol) Act 2018 3
Prohibition on
advertising in
certain places
Restrictions on
advertising during
events
Children’s clothing
Advertising in
cinemas
Separation and
visibility/licenced
premises
Minimum Unit
Pricing
Regulation: sale
and supply of
alcohol products
Grant or renewal
of a licence
 Labelling alcohol products
 Broadcast watershed ❌
 Content of advertising ❌
 Adverts in publications ❌

6. Labelling

8. Why have such labels?
 One of the highest levels of FASD globally 47.5 per 1000 population (globally
7.7 per 1000)
 1000 alcohol related cancers in Ireland annually
 Half of all alcohol related breast cancers arise from low-moderate alcohol use
(1-2 drinks per day)
 Low level of awareness – only 20% aware of alcohol/breast cancer link
 Rising levels of liver disease
 261% increase from 1995-2018
 Male hospital discharges increased by 247%
 Female hospital discharges increased by 175%
 Mortality increased 400 fold since 1970
 4 alcohol-related deaths every day – 5% of all deaths
 Consumer’s right to know

9. EU policy framework
 There is no harmonising EU legislation on the use of health warnings on
alcohol
 Alcohol currently has an exemption from 2011 regulations on having to
include ingredients and nutritional info on packaging.
 Various attempts in relation to self regulation – entirely unsatisfactory
 Proposal now to amend 2011 regulations so that alcohol would have to comply
 Strenuous efforts from alcohol industry to have such info provided off-label –
ie QR Codes
 In addition, 2021 EC– Europe Beating Cancer Plan, calls for cancer warning
labelling by end of 2023

10. Ireland’s labelling regulation process
 Ireland notified the European Commission of its labelling legislation plans in
Jan 2018 and stakeholders and member states had an opportunity to
comment.
 Legislation was passed in Oct 2018
 Detailed regulations giving effect to the enacted legislation were published in
June 2022.
 These were notified to EU - standstill period until Dec 2022
 Significant campaign led by AAI – 70% of submissions in favour – in line with
public support
 13 member states issued detailed opinions or comments

11. EU Response
 No comment issued by Dec 2022 –
 Entirely consistent with EU’s 2011 regulation which provides that Member
States can also adopt national labelling measures provided the notify
Commission in advance.
 Recognition of a Member States’ competency to adopt measure on ground of
protection of public health.

12. Stella Kyriakides European Commissioner
for Health and Food Safety
In the context of the analysis under the FIC Regulation, the Commission
considered that the Irish authorities demonstrated that the notified measures
were justified on public health grounds considering the situation in Ireland and
that any resulting restrictions for the internal market that the measures may
have were proportionate to the objective pursued…….
Having analysed exclusively the draft measures notified in 2022, the Commission
decided not to issue a reaction under the SMTD.
14 March 2023

13. World Trade Organisation
 7 Feb 2023 – regulations notified to World Trade Organisation under technical
barriers to trade process
 Standstill period until 7 May
 Objections made by a number of Member States –
 16 May 2023 – ‘Minister for Health will give consideration to the
commencement of the law once all obligations have been met
 22 May 2023 – Ireland’s Minister for Health signed regulations into law –
 3 year lead in period – May 2026
 21 June WTO meeting – to be discussed. EU has a role in defending Ireland’s
position.

14. Complaint to EU
 16 May 2023 – complaint lodged with European Commission
Spirits Europe – includes Diageo, Pernod Ricard
Brewers of Europe
European Committee of Wine Companies
 Anyone can make a complaint
 2 week window for EU to acknowledge complaint
 No formal timing for any other possible action

15. Other Labelling Developments
 2017 report from Commission to European Parliament and Council – no
objective grounds that would justify absence of information on ingredients
and the nutrition information on alcoholic beverages.
 Proposed revision of Food Information to Consumers (FIC) to provide
nutritional info on alcohol products
 Industry strongly resisting on-label info – wants QR code
 No evidence for effectiveness of QR codes
 EU Beating Cancer plan – proposal to have health warnings before end of 2023
 Ireland’s regulations are in keeping with these proposals

16.  Norway – April 2022, Directorate of Health recommended cancer warnings on
alcohol products
 Canada – Jan 2023 - Canadian Centre on Substance Use and
Addiction recommends warning labels be affixed to bottles
and cans to inform consumers about serious health risks
including cancer, the number and potency of drink servings
contained and limiting consumption to two drinks a week.
 WHO Global Strategy recommends consumer information and warnings.
 EVID Action Project

17. Thank you
 Contact details
 Email: Sheila.Gilheany@alcoholactionireland.ie
 Web: alcoholireland.ie
 Twitter: @AlcoholIreland