Public health challenges: proposed changes to alcohol sales and promotion

Iwona Schymalla: We are going to talk about the very serious public health challenge of alcohol consumption in Poland. A few weeks ago, an affair erupted over so-called alcotubes. Not only was this product quickly withdrawn from the market, but within days a regulation was prepared to introduce restrictions on alcohol packaging. You, Minister, presented at the Health Committee and the Committee on Children and Youth Affairs - a list of planned regulatory changes, regarding the amendment of the Law on Upbringing in Sobriety. It is also worth noting that in the National Health Transformation Plan (2022-2026), alcohol was ranked sixth as a factor affecting the health of Poles and a huge threat to public health. We also have a report by the Institute for Conscious Man on alcohol initiation among young people, which indicates that this process is starting earlier and earlier. Sales, mainly of beer, and its advertising also remain a problem, which is also discussed in the report.

Minister, could I ask for a comment on the Ministry of Health's priorities in regulating alcohol availability?

Wojciech Konieczny: On the part of the Ministry of Health, we would like to see as many of these regulations as possible, so that alcohol becomes less available economically because it is too cheap, less available physically because there are too many points of sale, and so that the packaging of alcohol really does not exceed the generally accepted norms. In the amendment to the law we are proposing, there are a lot of new points. She has grown, because we initially came out with a ban on sales at gas stations from 10 p.m. to 6 a.m. However, as this law is being processed, there are more new developments. One of the very important elements affecting our actions and their success is how these regulations will be enforced. The Ministry of Health leads among other ministries in legislation, that is, in issuing laws. On the other hand, compliance with these laws does not depend only on the Ministry of Health, but on other institutions that have the legal and organizational capacity to check these regulations. I think that as a state we also have something to do, because even the best regulations, if they are not followed, will not have the desired effect.

Iwona Schymalla: In the regulations, of which there are more and more, are there also issues concerning advertising? We know that beer advertising and promotion, for example, are common.

Wojciech Konieczny: We do not touch advertising as such. On the other hand, we combine the concepts of advertising and promotion. Advertising is described, but it is not fully followed, because it should not be associated with pleasure or leisure, with such behavior that if someone drinks a beer, he feels relaxed and it is cool. This should not be the case, and it is. In addition, those who advertise will often present "zero percent" products, but in such a way that you don't know what they are. So I think that these regulations are not fully followed. In contrast, we have now put more emphasis on promotion. We believe that promotion is hidden advertising. They are now merging together. And in fact this is how the industry acts, that not being able to advertise, and already bending or exceeding these advertising laws, it does so under the guise of promotion: if you buy 6 beers, you get an extra 6. But this is also advertising, because information that there are such promotions appears in newspapers, advertisements, on TV and elsewhere. We believe that here we must intervene as strongly as possible.

Iwona Schymalla: The case of the so-called alcotubes showed that when different ministries and organizations cooperate, it is possible to act quickly. So when will the bill appear in the government and when in the parliament?

I think this law will now accelerate, because we have already been drafting it for months. She didn't have as much support as she does now. The situation has changed after the alcotube case. I think the sensitivity, both of our society and of various institutions, has increased. I think it will be easier for us to work through this change at this time. Today (editor's note: October 14), the draft we sent is due to stand at the government work programming team. If this happens and it gets an entry, it will probably be subjected to a 30-day consultation and a process that should be completed this year. There is a chance that the bill will be passed and sent to the President for signature. So this is an achievable time horizon, it just requires determination.

Iwona Schymalla: As I understand the determination in the Minister is there?

As much as possible. We see various international solutions as good solutions, reducing both economic and physical accessibility. We also need to talk about soft measures, i.e. awareness-raising, such as lessons in school, promotion of healthy lifestyles, replacing unhealthy stimulants with healthy ways of behaving. These are things that apply not only to alcohol, but also to tobacco or other stimulants. International studies say that these soft measures, which on the surface look appealing (persuading, persuading and explaining), without restrictive - rationing - measures will have limited effect.

Iwona Schymalla: How do you, Professor, as president of the Polish Public Health Association, look at the proposed changes to the regulations in the Law on Upbringing in Sobriety? What do you think should change?

Andrew Fal: The Minister said a lot of good things. I keep my fingers crossed that all of these things will come true. But I wanted to point out that delineating whether soft or hard rationing measures work better are two different things. Undoubtedly, educating the next generation is the soft thing we need to do. It's teaching, discouraging, changing awareness and emphasizing that any drink that contains even a percentage of alcohol is also alcohol. This is the soft thing, the fruits of which we will know in a generation. Which doesn't mean we shouldn't do the hard thing, which is rationing. It seems to me that we have a big problem with the inconsistent excise approach to products containing alcohol. And yet excise is a fiscal tool for public health and we should not shy away from it. I know it's not within the purview of the Ministry of Health, but that's why such a somewhat above silo and above ministerial team has always been needed - an office or public health proxy. With all due respect - but with an empowerment a little higher than any of the ministries - I have always advocated the NPRM. Because, on the one hand, it would try to develop inter-ministerial things, such as just the excise tax or the ban on presence in public spaces, and on the other hand, it would oversee the enforcement of laws that are already good and already in place, but which are not enforced. What the Minister said at least about advertising. Advertising of any product containing any amount of alcohol should be banned in public space as a rule, precisely by not creating a desire for the product. And this is quite clear. Is the issue of promotion that you mentioned. Especially from an ideological point of view, but also from a financial point of view. Selling a product for half the price, because if I sell six and add the other six, that means that I have given at least a 50 percent discount, shows the desire to create a certain demand for the product, and secondly what kind of margin I have on this product, that I can afford to do it. We see all this, we just don't enforce it. What's more, you also mentioned it, products that have zero percent alcohol content graphically, nomenclaturally or circumstantially try to harmonize or align with products with alcohol content. This is a typical action - very good in people who already drink, while it is also a typical addictive action in non-drinkers. Therefore, in my opinion, any such product that, by its graphic design, name, social allocation, resembles any product containing alcohol, should be subjected to promotion, advertising and availability restrictions, the same as an alcoholic beverage. Otherwise, we are generating generations of next users, as we can clearly see. The editor mentioned a report by the Institute for Aware Man. Year after year, we are sad to observe that the initiation period for alcohol, and unfortunately also for tobacco or cigarettes, is decreasing in Poland. Younger and younger people are reaching for these products. And this is because they are too cheap. We're talking about beer, for example, because if we can buy a beer for 2.50 zlotys, and still hit a promotion for 1.25 zlotys, it is indeed cheap. Sooner or later in the classroom at recess or in the courtyard, this beer will be found. And this can be seen in the report. Secondly, with these drinks, such as beer, we see our beloved, I say this from the point of view of young people, athletes or celebrities, some great rapper. Therefore, the number of incentives is so powerful that actually afterwards the Ministry of Finance, Health or Education is without a chance, if it does not use this first shot, to change public attitudes towards alcohol, to make people aware that it is all C2H5OH, or ethyl alcohol. Wherever it is, it is the same alcohol. If we don't explain this to each other and start enforcing it, we will have a problem, and every future generation will have the kind of discussion we are having today.

Iwona Schymalla: It's important to emphasize education among young people. Indeed, there is also a very common perception that beer, for example, is not alcohol and that it is part of a lifestyle. These are soft measures, but I think they are key here, but also influencing the advertising market. Will you have interdepartmental cooperation here?

Wojciech Konieczny: Interdepartmental cooperation is essential, because we can write a law that will be in the cloud and not where it needs to be, i.e. in schools, stores, backyards, sports facilities and discos. I know that the Finance Ministry is working on changes. There are two concepts for increasing excise taxes, one is simpler, and the other is to set a minimum price per gram of alcohol. It seems to me that this is the better concept from our point of view. And I think this is also what the Ministry of Finance is thinking about. Such work is being done. We are doing a lot in this area. Looking at previous years, there was not much going on, not to say that rather availability was increased. However, soft measures, yes, they are having an effect, because we have for the first time a very small, but nevertheless, decrease in alcohol consumption among young people. This trend should be strengthened. This is a good time to simply act, further educating, persuading, and introducing economic and accessibility incentives, which also show that the state takes this problem seriously and is fighting it. On the other hand, as for the approach that beer is not alcohol, I see this as a weak point. This attitude has somewhat penetrated us as a fashion from our neighbors: Germans, Czechs and Slovaks, where beer is treated as an accompanying drink to virtually everything. But hopefully we are just now watching this fashion come to an end.