End excessive alcohol discounts and inducements that fuel alcohol harms

Key takeaways

> Alcohol is an addictive, harmful product that harms the health of individuals and communities in many ways, including alcohol-involved suicide, family violence, drownings, and fatal road crashes.

> Alcohol retailers use excessive alcohol discounts and inducements to encourage impulsive, bulk purchases of packaged alcohol and high-risk alcohol consumption that is not in the public interest.

> As part of a comprehensive effort to reduce alcohol related harms, Victoria’s liquor laws should be amended to prohibit excessive alcohol discounts as well as the sale of alcohol being linked with any inducement (i.e. benefit, coupon, voucher or reward scheme).

More alcohol means more alcohol harms 

Alcohol-related illness and injury account for 4.5% of the disease burden in the general population and 10.5% amongst First Nations peoples.¹ As sales of alcohol have increased, so too have Victorian alcohol-related ambulance attendances (26,073 in 2022-23, up 32%, from 19,695 in 2013-14),² hospital admissions (37,586 in 2021–22, up 41% from 26,675 in 2012–13),³ and deaths (9,289 in 2021, up 25% from 7,415 in 2012).⁴ 

Alcohol causes several different types of cancer,⁵ and alcohol dependence is associated with a 223% increased risk of suicide.⁶ Alcohol is also a risk factor involved in 23–65% of all family violence incidents reported to police in Australia,⁷ and 25–60% of unintentional drownings internationally.⁸ A blood alcohol concentration above the legal limit was present in 34% of fatal crashes based on a South Australian study.⁹ 

Excessive discounts and inducements fuel high-risk alcohol consumption

Excessive discounts (e.g., price reductions of 30% or more, and deals for multi-buy, bulk purchase, and minimum spend) have an especially strong impact on young people,¹⁰ and trigger impulse purchasing, bulk buying and excessive alcohol consumption,¹¹ as people don’t want to miss out during the time limited window. In Australia, 4 out of 5 online alcohol retailers offer discounts for buying greater amounts of alcohol,¹² and large online alcohol retailers apply some kind of promotion to more than 60% of their product range at any given time.¹³ Big supermarkets also offer 2-for-1 discounts (valued at up to $19.99 in savings) on alcohol with grocery purchases as little as $0.50—a loss leader to entice new customers.¹⁴ 

Inducements such as loyalty programs and free delivery with minimum spend also incentivise the bulk purchase and consumption of alcohol at high risk levels, especially among young people including those under 18 years of age.¹⁵ 

Limiting excessive discounts and ending inducements to reduce alcohol harms

All tobacco products have been excluded from shopper and loyalty programs in Victoria since March 2013, following an amendment to the Tobacco Act 1987.¹⁶ We should do the same for alcohol as it is also a harmful, cancer-causing product. Ireland banned loyalty card programs for alcohol in 2021, alongside measures that prevent the sale of alcohol at a reduced price for a limited period, or because it’s sold with another product or service.¹⁷ Modelling in England also found a ban on all alcohol discounts would prevent 1140 deaths and reduce alcohol-related illness episodes by 15,400 per year.¹⁸

Closer to home, the Victorian Liquor Commission must give due regard to the primary object of harm minimisation in the Liquor Control Reform Act 1998 (Vic) according to the statutory definition of harm.¹⁹ The Commission has the power to ban alcohol retailers from promotions or advertising that encourage high risk consumption or are otherwise not in the public interest.²⁰ However, banning notices have rarely been used in relation to any type of advertising or promotion, can only be used retrospectively (often after an ad campaign has already finished), and there are no penalties for alcohol retailers unless they refuse to comply with a banning notice. A banning notice has never been issued in response to a liquor licensee promoting an excessive discount, despite the frequency of these promotions.

Recommendation

The Liquor Control Reform Act 1998 (Vic) and regulations should be amended so that Victorian liquor licensees are prohibited from, and penalised for, offering excessive discounts (i.e., discounts of 30% or more) and inducements (i.e., any offer or benefit that is conditional upon the purchase of alcohol, such as a voucher, product give away, discount code or free delivery).

ACV_AlcoholDiscounts_Final.pdf

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References

1 ‘Alcohol, Tobacco & Other Drugs in Australia’, Australian Institute of Health and Welfare (Web Report, 10 July 2024) <https://www.aihw.gov.au/reports/alcohol/alcohol-tobacco-other-drugs-australia/contents/about>. 

2 ‘Ambulance Attendances’, AODstats (Web Page, 19 April 2024) <https://aodstats.org.au/explore-data/ambulance-attendances/>. 

3 ‘Hospital Admissions’, AODstats (Web Page, 24 April 2024) <https://aodstats.org.au/explore-data/hospital-admissions/>. 

4 ‘Deaths’, AODstats (Web Page, 8 November 2023) <https://aodstats.org.au/explore-data/deaths/>. 

5 World Health Organisation, Alcohol and Cancer in the WHO European Region: An Appeal for Better Prevention (Report, 2020) 5. 

6 Jason Isaacs et al, ‘Alcohol Use and Death by Suicide: A Meta-Analysis of 33 Studies’ (2022) 52(4) Suicide and Life-Threatening Behavior 600, 607. 

7 Patrick Noonan, Annabel Taylor and Jackie Burke, Links Between Alcohol Consumption and Domestic and Sexual Violence Against Women: Key Findings and Future Directions (Report, No 8, November 2017) 1 <https://www.anrows.org.au/publication/links-between-alcohol-consumption-and-domestic-and-sexual-violence-against-women-key-findings-and-future-directions/>. 

8 Tuulia Pajunen et al, ‘Unintentional Drowning: Role of Medicinal Drugs and Alcohol’ (2017) 17(388) BMC Public Health 1, 1.

9 Lisa Wundersitz and Simon Raftery, Understanding the Context of Alcohol Consumption Before Driving For Crash-Involved Drivers (Case Report, No 129, November 2019) 14.

10 Sandra Jones et al, ‘The Influence of Price-Related Point-of-Sale Promotions on Bottle Shop Purchases of Young Adults’ (2015) 34(2) Drug and Alcohol Review 170, 173. 

11 Ibid. 

12 Tina Lam et al, ‘Which Alcohol Products Might Be Affected by the Introduction of a Minimum Unit Price in Western Australia? Findings From a Survey of Alcohol Retail Prices’ (2023) 42(4) Drug and Alcohol Review 915, 919.

13 Tazman Davies et al, ‘The Prevalence and Magnitude of Price Promotions in Online Alcohol Retail Outlets’ (2024) Drug and Alcohol Review 1, 2 (advance).

14 Jonathan Wardle and Sungwon Chang, ‘Cross‐Promotional Alcohol Discounting in Australia's Grocery Sector: A Barrier to Initiatives to Curb Excessive Alcohol Consumption?’ (2015) 39(2) Australian and New Zealand Journal of Public Health 124, 126. 

15 Sandra Jones and Kylie Smith, ‘The Effect of Point of Sale Promotions on the Alcohol Purchasing Behaviour of Young People in Metropolitan, Regional and Rural Australia’ (2011) 14(8) Journal of Youth Studies 885, 893-894.

16 The change prohibited “the supply of any benefit, coupon, voucher (such as fuel discounts) or any other thing under a shopper loyalty or rewards scheme operated by a retail outlet in connection with the sale of a tobacco product.” Tobacco Act 1987 (Vic) s 7; Victorian Government, Tobacco Retailer Guide (Report, July 2017) 20. 

17 Public Health (Alcohol) Act 2018 (Sale and Supply of Alcohol Products) Regulations 2020 (UK). 

18 Robin Purshouse et al, ‘Estimated Effect of Alcohol Pricing Policies on Health and Health Economic Outcomes in England: An Epidemiological Model’ (2010) 375(9723) The Lancet 1355, 1357.

19 Liquor Control Reform Act 1998 (Vic) ss 3(1), 4(2).

20 We take “high risk consumption” to mean “irresponsible consumption”. Liquor Control Reform Act 1998 (Vic) s 115A(1)(b).