1. INTRODUCTION AND SUMMARY

1.1 Introduction

1.1.1 This submission on the Sale and Supply of Alcohol (Improving Alcohol Regulation)Amendment Bill is made by The New Zealand Initiative (the Initiative), a Wellingtonbased think tank supported primarily by major New Zealand businesses. In combination, our members employ more than 150,000 people.

1.1.2 The Initiative undertakes research that contributes to the development of sound public policies in New Zealand, advocating for a competitive, open, and dynamic economy and a free, prosperous, fair, and cohesive society.

1.1.3 The Initiative’s members span the breadth of the New Zealand economy. The views expressed in this submission are those of the author rather than the Initiative’s members.

1.1.4 We support the role of the Sale and Supply of Alcohol Act 2012 in ensuring that alcohol is sold and supplied responsibly. Licensing can help ensure that alcohol is supplied by suitable people, from suitable premises, under conditions that reduce risks associated with irresponsible sale or supply. Licensing is also well-suited to dealing with licensees who sell to minors, sell to intoxicated people, repeatedly breach licence conditions, or
otherwise fail to meet the standards expected of responsible suppliers.

1.1.5 However, licensing is not well-suited to addressing every harm associated with alcohol, including many of those harms listed in the Act. Some of the most serious harms attributed to alcohol are likely to be better addressed primarily through more targeted tools, with licensing playing at most a supporting role where a clear causal pathway can be shown. Where the problem is repeat alcohol-related offending, offender-focused
interventions are likely to be better targeted than general restrictions on licensed premises. Where the problem is disorderly conduct, direct enforcement of disorder and public-order laws may be more cost-effective than broad restrictions on trading hours or outlet location. Where the problem is fetal alcohol spectrum disorder, targeted prevention, diagnosis, support, and treatment measures are much more closely connected to the harm than controls on the placement of beer and wine displays or restrictions on ordinary licensed premises.

1.1.6 The Bill’s general policy statement recognises that alcohol regulation should strike a balance between minimising the potential for alcohol-related harm and avoiding unnecessary constraints on legitimate businesses. It also recognises that the sale and supply of alcohol provide economic and social benefits, while also contributing to social and health harm. That framing is appropriate. But the Bill should go further in ensuring that licensing decisions, official reports, objections, conditions, and local alcohol policy processes are directed toward cost-effective harm reduction.

1.1.7 The Act should not be treated as the only or default instrument for reducing every harm associated with alcohol. The Act should focus on the harms that can reasonably and cost-effectively be reduced through controls on sale and supply. Other harms should be addressed through better-targeted measures.