The position of the Union of Brewing Industry Employers in Poland – “Polish Breweries” regarding the proposed amendments limiting beer advertising

The Union of Brewing Industry Employers in Poland – “Polish Breweries” expresses its deep concern regarding amendments to the Alcohol Abuse and Alcoholism Prevention Act proposed by the Ministry of Health which strive to drastically reduce legal air time for beer advertising. In our view, this regulation will not contribute to achievement of targets identified by the Ministry of Health, while its major after-effect will be deterioration of conditions for doing business by the brewing industry and related sectors.

The reduced time limit for beer advertising proposed by the Ministry of Health is a superficial solution, relatively easy to implement, which yet fails to solve problems related to excessive and harmful consumption of alcohol that affects a portion of the Polish society. The overwhelming majority of Poles use alcohol reasonably and moderately.  Alcohol abuse is an issue which refers to merely several percent of adult population which mainly consumes spirits, not beer. We do agree that special preventive schemes should be addressed to this group, but we cannot assume that moving beer advertising to a later time slot will effectively solve this issue.

The Union of the Brewery Industry Employers “Polish Breweries” is convinced that beer advertising should not be linked with the consumption level. Despite an increase in total air time, which has also been prompted by a rise in the number of TV channels, for many years beer consumption has been stable in Poland at 97-99 litres per capita. The Polish beer market is saturated, mature and highly competitive. Producers use advertising to build the competitive advantage of their brands and communicate their latest products to the market; it is thus not a vehicle deployed to expand the market itself which has been stable and demonstrated no growth for the past five years. Meanwhile, beer advertising is a driver of positive beer culture and moderate consumption. It contributes to development of a positive trend to replace strong beer with alcohol-free beer or beer with lower alcohol content.

Polish legislation relevant to beer advertising is among the most restrictive ones in the European Union. Most EU states impose no restrictions in this respect, or introduce fewer constraints than those implemented in Poland. Constraints to beer advertising in Poland include both the time slot in which commercials may be aired (from 8pm until 6am) and limitations concerning the content of commercials. Moreover, the brewing industry in Poland has introduced a number of voluntary self-regulations, mainly to boost the protection of minors and prevent irresponsible alcohol consumption by pregnant females and drivers. Further restrictions are groundless and will not deliver expected outcomes. In reality, moving beer commercial to a later time slot beyond 11pm stands for the ultimate ban on beer commercials.

Withdrawal of advertising budgets of beer manufacturers from television networks may lead to a number of consequences that go beyond the media and marketing sector. A substantial loss in revenue will be declared by television networks, including public television, what will threaten jobs in sectors related to production of commercials. Negative fallout may also affect fiscal revenue: The Student Sport and Recreation Fund whose beneficiaries include more than 90,000 children will be actually wound up.

Comprehensive prevention of negative phenomena related to alcohol abuse must take into consideration consumption patterns relevant to different categories of alcohol and their actual impact on harmful alcohol consumption. The proposal which further reduces the legal time limit for beer advertising will boost the appeal of spirits, and especially small and ready-to-drink spirit drinks (bottles up to 200 ml).

It should, however, be stressed here that legal beer advertising was greenlighted by the policy adopted in the 90-ties which strove to shift consumption from liquor to beverages with lower alcohol content (Art. 10 of the Alcohol Abuse and Alcohol Prevention Act). Over the last dozen years, this policy managed to effectively modify the structure of consumption of alcoholic beverages and the drinking culture.  Working towards elimination of beer advertising is tantamount to implementation of proposals of the spirit industry, what marks an attempt at reversing this trend. Meanwhile, data of The World Health Organisation reveal that not only the consumption of alcohol per capita in Poland has gone down to become lower than in countries where spirits dominate, but also dropped below figures for the Czech Republic, Belgium, Slovakia or the United Kingdom.

The Union of Brewing Industry Employers in Poland – “Polish Breweries” stresses that the prerequisite to the successful economic growth of the industry and related sectors is stable legislation conductive to investments and stable employment.

We share your concern about public health and agree that it is essential to launch measures that prevent such practices like underage sale of alcohol or alcohol consumption in public places.  However, we are determined to reinforce the role of the state in solving social and health issues, but in the most effective manner that is adequately addressed to the audience in need. We are open to cooperation in this area. Being a socially responsible sector, for many years we have been implementing numerous educational programmes to limit such negative practices like underage sale of alcohol, alcohol use by expectant mothers or driving under influence. We have been advocating responsible and moderate consumption on many occasions. The brewing sector in Poland is voluntarily communicating ingredients, the nutritional characteristics and energy value to consumers, or information the amendment drafted by the Ministry of Health plans to regulate.

We appeal to public authorities to thoroughly analyse all consequences of proposed regulations and initiate a dialogue that embraces all aspects of the advocated act.

Warsaw, 2 October 2017