Our Submissions
As the peak alcohol industry body in Australia, ABA welcomes the opportunity to lodge formal submissions and contribute to the development of government policy to reduce alcohol-related harms. Below are our recent submissions to governmental reviews and inquiries.
2021 Proposed National Obesity Prevention Strategy
ABA’s submission on the Draft National Obesity Prevention Strategy seeks to provide insight into alcoholic beverages that will help to develop an effective strategy when it comes to alcohol.
To ensure that the National Obesity Prevention Strategy provides consistent advice to governments looking to implement strategies ABA recommends that the National Obesity Prevention Strategy refers back to the National Alcohol Strategy as being the source of policy options for tackling harmful consumption of alcohol.
2021 WHO Global Alcohol Action Plan (2022 - 2030)
ABA’s feedback on the first draft of the Global Alcohol Action Plan highlights that to allow for successful implementation by Member States, the GAAP must focus on the reduction of harmful alcohol consumption and ensure that a full set of policy options are available. Without a flexible set of options that move beyond safer and a focus on harmful alcohol consumption, the Action Plan may inhibit the ability of governments to respond to the local context of many member states.
2021 Modernising the FSANZ Act: Draft Regulatory Impact Statement
ABA’s submission on the Food Standards Australia New Zealand (FSANZ) Act Review Draft RIS focuses on amendments we support in full or that require further fine-tuning; amendments we reject; and additional amendments that we believe should be included to modify the FSANZ Act to make it agile, resilient and fit for purpose.
2021 Proposed National Preventative Health Strategy
ABA welcomes the opportunity to comment on the draft National Preventive Health Strategy. Our submission recommends that the final strategy acknowledges the improvements in reducing harmful consumption and underage consumption in its key facts in the chapter on alcohol, in addition to highlighting key targets that align with the National Alcohol Strategy.
2021 FSANZ Food Regulation Reform
ABA’s submission highlights the need for the food regulatory system to remain focused on food safety, rather than expanding to incorporate broader public health and behavioural change.
2020 Review of the Food Standards Australia New Zealand Act 1991
ABA’s submission welcomes the Commonwealth Department of Health’s review of the FSANZ Act 1991 and recommends an outcome that ensures an appropriate system of food regulation is maintained, balancing both public confidence in the security and safety of food and beverages sold in Australia and New Zealand, with a cost-efficient and transparent process for industry that seeks to bring innovation and increased choice to consumers.
2020 NHMRC Draft Drinking Guidelines
ABA agrees with, and supports, the intended outcomes of the draft Guidelines to help Australian men and women make informed choices when it comes to their alcohol consumption.
However, in their current form, the draft Guidelines fail due to the risks and benefits of alcohol consumption lacking balance, with the findings not supported by evidence. In addition, the draft Guidelines have been presented in a ‘one size fits all’ approach, which does not facilitate informed choice.
2019 FSANZ P1050 Pregnancy Warning Labels
ABA’s submission draws attention to a number of significant flaws in the Decision Regulation Impact Statement which set the direction for the proposal from FSANZ. These include overstating FASD prevalence rates in Australia and understating the cost burden on industry of implementing a label change. Our submission also highlights the industry’s commitment to reducing alcohol-related harms with the use of the voluntary DrinkWise labelling scheme.
2018 WA Select Committee on Personal Choice
ABA’s submission to the Select Committee on Personal Choice and Community Safety highlights the growing trend towards responsible drinking and reduced consumption among Western Australians. New measures to reduce alcohol-related harm should be targeted towards those who consume excessive amounts of alcohol. Population-wide regulation will be less effective in reducing harms, and will also unfairly impact responsible consumers.
2018 NSW Review on Liquor Promotion Guidelines
ABA’s submission to this review presents evidence of the success of the current Guidelines and of self-regulation by means of the government approved ABAC Scheme.
2018 Draft National Alcohol Strategy 2018-2026
ABA’s submission advocates for a stronger research and evidence base to establish the NAS’s policy context, acknowledgement of key indicators of a decline in alcohol-related harms and Australia’s performance against WHO guidelines, and a focus on targeted measures over ineffective population-wide measures.
2018 ACT Drug Strategy Action Plan
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2017 NT Alcohol Policies and Legislation Review
ABA’s submission acknowledges the unique social issues affecting the Northern Territory and the need for targeted measures to reduce alcohol-related harm in the community. We outline industry’s commitment and contribution to responsible drinking, and provide a strong evidence base for the effectiveness of specific policies over population-wide regulations.
2017 NSW Inquiry into Alcoholic Beverages Advertising Prohibition Bill 2015
ABA’s submission presents a number of case studies to demonstrate the effectiveness of targeted measures and the lack of correlation between advertising restrictions and reduced consumption. Our submission highlights industry’s commitment to reducing alcohol misuse through proven methods such as Australia’s existing self-regulation system for alcohol advertising, DrinkWise’s awareness initiatives, and NSW liquor accords.
2016 VIC Review of the Liquor Control Reform Act 1998
ABA’s submission presents in-depth discussions of industry’s role in the Victorian economy and Australia’s relationship with alcohol, including an anthropological study of drinking culture in Australia and New Zealand. We discuss the most effective methods of harm minimisation and the flaws of population-wide measures such as minimum unit pricing.