LICENSING bosses are to ask the government to think carefully before restricting advertising for the area's breweries and distilleries.
The Scottish Government put out questions in November on potential restrictions on alcohol advertising and promotion across the country.
In their draft reply, West Dunbartonshire Licensing Board raises a number of questions about how new rules would be enforced and how they would impact businesses, as well as the public.
They particularly raised concerns for West Dubartonshire's alcohol production sites, part of the tourist trade and where advertising the site is entirely tied to booze.
They will tell the government: "In the Board's experience, breweries or distilleries may have ancillary off-sales or sales facilities, and premises catering for tourists may rely on a link to alcohol products produced in Scotland.
"This will extend to their exterior branding and appearance. Such premises may struggle to comply with a restriction on alcohol marketing, i.e. the premises’ name and branding will align with their alcohol product."
The consultation looks at marketing in outdoor and public spaces, in-store marketing, and enforcement.
Licensed premises could potentially be forced to change how they present themselves to the public.
Meanwhile, the Board is currently required to grant approval for an application outlining where booze is sold on premises'. If there were rules about where in a shop alcohol was sold, that would need much more clarity and guidance.
The Board will consider their draft response in their January 10 meeting.
Their reply states: "The Scottish government may also consider potential issues flowing from the use of outdoor spaces as licensed areas.
"The use of licensed outdoor drinking areas has increased recently (accelerated by restrictions due to the covid-19 pandemic). Such areas may be visible from the public spaces and may form part of the public space.
"The Board is, of course, supportive of evidence-based measures that will promote
and improve public health. It does, however, have a concern as to how such measures will be implemented and enforced.
"The Board does have a concern that it may be difficult to implement a framework
that prescriptively manages the location of alcohol in a retail environment. For
example, any framework would need to consider all possible settings for the display
of alcohol and this may be complex given the diverse range of retail type premises
and the potential for rapid changes owing to changes in shopping habits or
technological advances."
And the Board asked how the proposed rules will apply - just to new premises, or to existing ones? And would that require new applications to meet the rules, and considerably more work for the Board to assess.
The draft response adds: "The Board anticipates that many existing licensed premises may struggle to comply with any restrictions, e.g. restricting the use of mixed alcohol and non-alcohol aisles or moving alcohol behind the till. This may be due to the physical layout of the
premises or a lack of funds to implement the changes. What would happen should
the licence holder say changes are not practical?"
Consultation from the government closes on March 7, 2023.
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