FOOD LABELLING LAW AND POLICY REVIEW:
A Submission by the National Drug Research Institute on
Alcohol Warning Labels
Professor Steve Allsop, Associate Professor Tanya Chikritzhs
and Mr Vic Rechichi
National Drug Research Institute Tier 1 Research Centre
Curtin University of Technology, Perth
Contact Details
Professor Steve Allsop
Director
National Drug Research Institute
P: 08 9266 1600
F: 08 9266 1611
E: S.Allsop@curtin.edu.au
Postal:
National Drug Research Institute
Curtin University of Technology
Health Research Campus
GPO Box U1987
Perth WA 6845
Introduction
The National Drug Research Institute’s (NDRI) mission is to conduct and disseminate
high quality research that contributes to the primary prevention of harmful drug use
and the reduction of drug related harm. The Institute has an internationallyrecognised reputation for providing evidence-based research to inform policy and
practice, particularly in regards to alcohol policy.
NDRI therefore welcomes the review of food labelling laws and the opportunity to
provide input into the potential introduction of alcohol warning and advisory labels
(referred to as warning labels in this submission) as a new strategy to help reduce
the harm caused by alcohol in Australia.
In this submission, NDRI will focus only on warning labels and not the myriad other
food labelling laws the review panel is considering. NDRI will endeavour to present
the research evidence that outlines the effectiveness or otherwise of alcohol warning
labels. NDRI acknowledges that, in 2009, key staff members involved in the
preparation of this submission also produced two reports on the impact of alcohol
warning labels for Food Standards Australia New Zealand.
Background and Context
More than 20 countries have adopted alcohol warning labels. Those labels vary, both
in terms of their presentation – from image only to written warnings – and their focus
– from alcohol use during pregnancy to drink driving.
Despite this there is, unfortunately, a limited research base to inform our
understanding of the effectiveness of warning labels. Most publications have come
from the U.S. and are based on data from that country, and the current research
base does not for example allow an accurate comparison between potential impacts
of voluntary versus mandated alcohol warning labels. This submission, and indeed
the considerations of the review panel, should be viewed within this context.
However, that is not to say that there is no evidence regarding the effectiveness of
warning labels, nor that there is evidence that they are ineffective or have no impact.
Effectiveness of Warning Labels
The research evidence that is available indicates that:
 Consumers are able to recall the presence of warning labels even though
often most are not particularly noticeable and do not stand out from their
background;
 A substantial proportion of alcohol consumers, including younger people, who
have reported that they had seen an alcohol warning label could recall the
message;
 Younger women and heavier drinkers may be more likely to notice warning
labels; and
 Over time, and thus increased exposure, more people will become aware of
the existence of warning labels.
A small body of research indicates that warning labels have some impact on
judgements about risks associated with alcohol consumption. In terms of translating
that into the impact of warning labels on behaviour, some research indicates that the
introduction of warning labels in the U.S. was associated with a self-reported
increase in the likelihood of respondents discussing the risks of alcohol.
There is also some limited evidence that warning labels prompted pregnant women
to discuss alcohol consumption and the more types of warnings consumers are
exposed to – on advertisements, point of sale promotions etc – the more likely they
were to discuss alcohol-associated risks. These are important findings. Information
included in warning labels appears to have resulted in consumers being more
informed about risks.
In considering the effectiveness of warning labels, it may be instructive to consider
some theoretical perspectives in understanding the influence of health
communications, including warning labels.
General health information research indicates that providing information about the
risks of a particular behaviour may not result in behaviour change. These health
communication models predict that a warning label, or other media, communicating
messages about health risks may be noticed and understood in general but might not
be interpreted by an individual as having personal relevance. For example, selfserving optimism may increase the sense that the risks are only pertinent for others.
Health information in a warning label may then be recognised by an individual but
other strategies, such as interpersonal discussion about risk and the individual
having access to strategies to help them change their behaviour, will be required.
This suggests that while warning labels may be worthwhile as a means to inform
people about risk, on their own they will probably not be sufficient to ensure
behaviour change – other strategies will also be required.
What other Strategies have Impact – the Evidence
The body of evidence about effective alcohol interventions has been summarised by
various groups (e.g. Babor et al 2003; Loxley et al 2004, Chikritzhs 2007). Effective
interventions include: controls on availability through price mechanisms (e.g.
Waagenar et al 2009); controls on physical access through hours of sale, number of
outlets, and age restrictions; enforcement of liquor licence laws; ensuring low risk
drinking contexts; interventions aimed at specific risks (e.g. random breath testing);
and brief and more intensive treatment options. More recently, attention has
focussed on the potential of sustained and well-resourced social marketing initiatives
in combination with the above measures and changes to alcohol promotion efforts
adopted by the alcohol industry. Strategies to more effectively communicate health
messages, for example via warning labels, should be considered in the broader
context of, and in combination with, other effective interventions This suggests that if
warning labels are adopted, they should be consistent with, and where possible
linked to, other alcohol policy and related strategies.
For example, warning labels conveying messages about the risks of drinking for
women of childbearing age and drinking while pregnant would be complemented by
other strategies and activities, such as controls on alcohol availability, advice by
primary health care staff and increased screening of alcohol use before and during
pregnancy.
Lessons from other Domains – Tobacco
While, as indicated, the evidence surrounding the effectiveness of alcohol warning
labels is limited, there is a stronger evidence base regarding the impact of tobacco
warning labels. Acknowledging distinctions between tobacco and alcohol, tobacco
still provides important lessons for alcohol interventions.
Evidence from Australia and overseas indicates that to have impact, tobacco warning
labels need to be prominent, graphic and incorporate images as well as text.
Evidence from the tobacco arena also indicates that messages are most effective
when they are mandatory and when messages and images are frequently changed
and alternated. The content, style and presentation of tobacco warnings can
markedly affect how noticeable and memorable they are, and influence their impact.
It is important to note that tobacco warning labels have constituted one component of
an overall, complementary, tobacco strategy.
Summary and discussion
The need for a multi-faceted approach
Approaches to responding to alcohol problems are likely to be most effective when
multi-faceted and evidence-based. Strategies such as social marketing campaigns,
school drug education, brief interventions and, in all likelihood, warning labels should
be accompanied by other approaches that address the influence of factors such as
alcohol availability, enforcement of drinking laws, alcohol promotion, family dynamics
and resources and parenting skills on people’s drinking behaviour.
The need to build the evidence base
As indicated, the research base is limited, mostly from the U.S. and observed effects
have largely been on information recall. There is little to suggest any impact on
behaviour and much of the research has been short-term – six months or less. Such
a brief period of time may not be sufficient for individuals to act on the information
contained in warning labels.
Furthermore, label content has focussed primarily on a narrow band of messages,
such as pregnancy/birth defects, drinking and driving, operating machinery and
information about alcohol content/standard drinks. Much of the research has been on
warning labels that, compared to tobacco warning labels, have not been particularly
graphic, have not used prominent visual images and text, and have not been rotated.
Rather than claiming that they have no impact (which is contrary to the evidence on
their impact on message recall) we might perhaps be surprised that, in their current
form, they have had any impact at all. However, it is important that any step to
embrace alcohol warning labels include quality evaluation to ensure they are
consistent with and complement other strategies and to assess their individual and
combined impact on knowledge of risks and behaviour.
Conclusion
The National Drug Research Institute believes there is merit in considering the
introduction of alcohol warning labels in Australia.
However, as the tobacco arena indicates, effective alcohol warning labels are most
likely to be those which are prominent, graphic and incorporate images as well as
text.
Any introduction of alcohol warning labels should also be coupled with adequate
investment in properly evaluating their impact. This will include identifying their
benefits in the contexts of any costs for the community, governments and industry.
The key consideration is that warning labels should be considered as one aspect of a
comprehensive strategy to minimise the harm caused by alcohol in Australia.
While it may be challenging in some cases to attribute changes in behaviour solely to
alcohol warning labels, we concur with other reviewers, such as Wilkinson and Room
(2008a; 2008b) and Anderson (DHS, 2008), who have concluded that warning labels
are warranted as part of a multi-faceted comprehensive strategy:
“…adding warning labels to alcohol containers has a longer term social utility in
helping to establish social understanding that alcohol is a special and hazardous
commodity.” (Wilkinson and Room 2008a, p.19).
REFERENCES
 Babor, T., Caetano, R., Casswell, S., Edwards, G., Giesbrecht, N., Hill, L.,
Holder, H., Homel, R., Osterberg, E., Rehm, J., Room, R., and Rossow, I.
(2003). Alcohol: No ordinary commodity – research and public policy. Oxford:
Oxford University Press.
 Chikritzhs, T.N., Gray, D., Lyons, Z. and Saggers, S. (2007). Restrictions on
the sale and supply of alcohol: Evidence and outcomes. National Drug
Research Institute. Curtin University of Technology, Perth, Western Australia.
 Deutsche Hauptstelle fur Suchtfragen e.V. (DHS). (2008). Consumer labelling
and alcoholic drinks. Hamm: DHS.
 Loxley, W., Toumbourou, J.W., Stockwell, T., Haines, B., Scott, K., Godfrey,
C., Waters, E., Patton, G., Fordham, R., Gray, D., Marshall, J., Saggers, S.,
Sanci, L. and Williams, J. (2004). The Prevention of Substance Use, Risk and
Harm in Australia: A Review of the Evidence. Canberra: Australian
Government Department of Health and Ageing.
 Wilkinson, C., and Room, R. (2008a). Warnings on alcohol containers and
advertisements: International experience and evidence on effects. Drug and
Alcohol Review, 28; 4, p426-435.
 Wilkinson, C., and Room, R. (2008b). Informational and warning labels on
alcohol containers, sales places and advertisements: Experience
internationally and evidence on effects. Report for the Victorian Department of
Human Services.