Alcohol Labelling Bill [HL]

Thank you. It would be sensible to lose Clauses 2, 3 and 4, and it would not damage or reduce the overall impact of the Bill to do so. As they stand, the clauses are over-restrictive, inflexible and not helpful. Clause 2 is superfluous given that the food labelling regulations, which also cover alcoholic drinks, already prescribe for clarity and legibility. The relevant parts of the Food Labelling Regulations 1996 state that any information on labels, "““shall be easy to understand, clearly legible and indelible and, when a food””—" or, in this case, a drink— "““is sold to the ultimate consumer, the said particulars shall be marked in a conspicuous place in such a way as to be easily visible … Such particulars shall not in any way be hidden, obscured or interrupted by any other written or pictorial matter””." I cannot see any reason to go any further than that, in the interests of consistency—which, after all, is one of the five principles of better regulation, an agenda enthusiastically endorsed by the Government. I shall read a couple of sentences from the guidance on the consistency principle produced by the former Better Regulation Commission, on which body I used to sit: "““Regulators should be consistent with each other, and work together in a joined-up way … New regulations should take account of other existing or proposed regulations””." It is really not in producers’ interests to put consumer information on labels that is illegible. Retailers would reject it, and so would consumers. The value and importance of reputational risk should not be underestimated. Many of the same arguments apply to Clause 3, where the over-prescriptiveness could end up being counterproductive, partly because of the design of labels—if the label were black and/or red, the impact of the requirement here could be completely lost—but partly because if pregnancy advice is being included as part of the wider sensible drinking message, as in the voluntary agreement, the design and positioning of the package as a whole needs to be addressed by the producer companies. It is too restrictive and illogical to compel them to observe particular requirements for one aspect only out of the five-point plan. Industry needs flexibility to research and introduce improved logos or pictograms as well. We have been talking about the French logo and heard a description of it, but producers need the freedom to investigate consumer insights so that they could possibly offer improved variations on that in future. I am aware of consumer research recently done in Japan that showed that consumers on the whole assumed that that particular logo meant that alcoholic drinks had contraceptive properties, and it would be a bit of a disaster if that happened here. We cannot assume that logos will be set in stone or that the prescriptive way in which the clause is currently framed is the best way to do it. There is a short and simple reason for Clause 4 not to stand part: it is not necessary. It is already a legal requirement under food safety legislation, which covers alcoholic drinks, that manageable product recalls should be facilitated. The Food (Lot Marking) Regulations 1996 require containers to be marked in order to identify the batch to which the container belongs. Many of those markings are actually minute codes, providing precise information on the time of packaging and the line number on which the product was packaged. I simply cannot see what additional reasons relating to alcohol and pregnancy would require anything further, or for the existing law to be restated.