The NSW Government has sought feedback on proposed new laws for same-day alcohol deliveries. The Foundation for Alcohol Research Education (FARE) thanks the Government for taking action to improve the regulatory response to alcohol home delivery and is pleased to provide feedback on the discussion paper. As outlined in the discussion paper, the recent and projected growth in online sales and home delivery (OSHD) comes with a number of risks, and it is critical that regulatory controls keep pace with emerging market trends.
FARE is concerned that the discussion paper characterises an ideal approach as achieving balance between consumer convenience and risk mitigation. Alcohol is a harmful, addictive drug, and a group one carcinogen.1 We should not approach this drug with a bias towards convenience. It should not be treated in the same way as fast fashion or fast food. Alcohol is a unique substance; owing to its great capacity for harm to the individual and those around them its availability is regulated by governments.
Governments must recognise that in the case of alcohol, unlike fast fashion, there are public interest reasons why ‘consumer demand’ should not always be met.
Governments must also recognise that consumer demand is not organic; it is driven by marketing. Alcohol companies have expanded into this unregulated space to profit from impulsive urges to consume alcohol, and are now driving demand for these services through marketing to generate growth for their businesses. Measures to restrict marketing are part of the risk mitigation framework and must be included in the regulatory response.
The Liquor Act outlines that the Government has a responsibility to regulate the sale and supply of alcohol, while allowing the ‘balanced’ development of the liquor industry. This does not mean that every new idea and business model should be permitted simply because it has been conceived. Government must act to protect the community. Disruptive business models in OSHD present a new and unacceptable level of risk to the most vulnerable groups in the community:
children under 18
FARE’s response to this consultation outlines these additional risks and ways in which they should be mitigated.