The society, which had previously expressed concerns that the review could lead to styles such as double IPAs (DIPAs) falling foul of the new code, has rejected the notion that there should be a unit-based definition for immoderate alcohol consumption.
The Portman Group has proposed that immoderate consumption ought to be defined as four units of alcohol per non-resealable container. Beer styles such as double IPAs and imperial stouts are often sold by craft brewers in 440ml or 500ml cans.
Under the Portman Group proposals these beers would have to have an alcoholic strength of less than 9.1% (440ml) or 8% (500ml) or risk running foul of the immoderate consumption rule.
In a consultation document, seen by The Morning Advertiser, SIBA said: “We believe a much better way of determining whether a product encourages immoderate consumption is to see, following a complaint, if it is indeed being consumed immoderately and work backwards from that.”
Intended to be shared
SIBA believes that with beers such as DIPAs, imperial stouts and other strong Belgian styles, the higher quality, taste and price points of these products, and the frequency and speed of their consumption, means that they are speciality drinks that are unlikely to encourage immoderate consumption.
“Examining the quality, taste, price, sharing, decanting/pouring and resealability will give a better determination of whether or not a product is being immoderately consumed and if a product encourages this consumption rather than basing a judgment on the alcohol content alone,” it added.
The organisation also pointed out that many products on the market contain more than four units of alcohol in a single container, but are intended to be shared, and hence it “categorically cannot support this change”.
“SIBA, as a responsible trade association, is completely behind efforts to reduce the harmful consumption of alcohol across all segments of society,” it added. “We support measures that target the harmful use of alcohol where it can be proven that they do so. We also actively support measures that encourage the sensible consumption and enjoyment of alcohol, for example in licensed premises.
“However we believe that this new guidance as proposed will have unintended consequences for our members' products which need to be mitigated. If they are not, then there will be serious consequences for the industry.”
CAMRA lends its support
Responding to SIBA’s comments, Portman Group CEO John Timothy said: “Our code review process is an important opportunity to reflect on what more we can do as an industry to demonstrate our social responsibility and tackle alcohol-related harm. We’re grateful to everyone who’s responded and will be working through those submissions over the summer.
“As part of the consultation we have proposed a unit-based threshold to define immoderate consumption. This is in response to the chief medical officer’s shift to weekly rather than daily drinking guidelines. This is an important guideline for the independent complaints panel when deciding what immoderate consumption looks like and so has been a key question in this consultation."
Industry bodies the Campaign for Real Ale (CAMRA) and the British Beer & Pub Association (BBPA) have also expressed concerns over the four units definition of immoderate consumption.
In a response to the consultation, CAMRA said: "It is unacceptable that the current proposals could result in the code being unintentionally responsible for damaging the viability of some of the small UK brewers, who are producing interesting and diverse, but higher ABV beers which are vital to their businesses."