In its detailed submission, the Association focused heavily on Section 7 (Alcohol Drinks) of the Code.
For example the Association suggests that alcohol should not be advertised in terms of price, quantity or alcohol strength in any marketing communications but should be confined to product differentiation only.
NOffLA would also like to limit alcohol advertising and promotion to a structurally separated licensed area of that premises and not placed beside or in proximity to any products that appeal to children.
“Currently alcohol can be positioned next to non-food and household products such as toys, birthday cards, DVDS and games – products which could be attractive or of interest to young and/or under-age people,” states the submission, “This product placement is then augmented by cleverly-designed alcohol advertising in many mixed trading outlets.”
NOfflA also suggests that alcohol not be linked to any promotional deals that may include food items (meal deals, chocolate and wine deals etc).
“These offers send the wrong signals to under-age people because they immediately create a link between alcohol and certain products,” states the submission which also argues that volume deals of alcohol advertised for sale in the off-trade are the equivalent of depicting the buying of large rounds of alcohol in a pub and should therefore not be permitted under the Code.
A significant number of mixed trading outlets undertake widespread advertising of sales promotions which encourage individuals to purchase excessive amounts of alcohol, states the submission.