Separation and visibility of alcohol products
The Public Health (Alcohol) Act – Section 22 – contains a provision for structural separation of alcohol products in mixed retail outlets, such as supermarkets, convenience stores or neighbourhood shops, which will mean that alcohol products can no longer be displayed as routine grocery goods, and that children’s exposure to alcohol in an every day setting is limited.
This law is operational since 12th November 2020.
Retailers have three choices in relation to how it retails alcohol in-store – they can choose to store alcohol either in a separate area of the store, in a closed storage unit or cabinet, which contains only alcohol products, or in open storage units, not more than three (adjacent to each other).
Alcohol products behind check-out points must not be accessible to the public, contain no advertising, and where product is not visible to the public.
Point of sale advertising of alcohol products will now be confined to the designated separate area or the inside of the storage cabinet.
If a premises, which sells alcohol products, chooses to separate the alcohol from other products by confining the sale of alcohol to a single area in the premises, it must ensure that:
- It is separated from the rest of the premises by a physical barrier (minimum height not less than 1.2 metres), through which alcohol products and advertisements for alcohol products are not visible to members of the public
- Members of the public do not have to pass through that area in order to gain access to or purchase any products other than alcohol product, or
If a premises, which sells alcohol products, chooses to separate the alcohol from other products by confining the sale of alcohol to one or more storage units
- the maximum height of each of which shall be 2.2 metres and each of which shall, to a height of 1.5 metres, have material in place ensuring the product is not visible when the unit is closed), and which, when in use, shall remain closed, or
If a premises which sells alcohol products chooses to separate the alcohol from other products by confining the sale of alcohol to no more than three open storage units,
- the maximum width of each of which shall not exceed 1 metre and a maximum height of each shall not exceed 2.2 metres,
Restricting the ease of availability of, and access to, alcohol is a critical component of a public health approach to reducing alcohol use and the related harm.
The greater majority of alcohol, purchased in Ireland, is now accessed through the off-trade, rather than in on-trade pubs and premises.
Alcohol is not an ordinary product and this is recognised by the State’s licensing regime. Denormalising this connection is critical to reducing alcohol use to within the Low Risk Alcohol Guidelines.
The legislation replaces a previous industry led, self regulatory, voluntary code established by the Responsible Retailers of Alcohol in Ireland (RRAI), which proved unfit to advancing the objectives of public health.
The legislation is monitored and enforced by HSE Environmental Health Officers.
You will find full details of their authorised role on the HSE’s alcohol legislation webpage:
https://www.hse.ie/eng/services/list/1/environ/alcohol-legislation.html
and a full list and contact details of the nearest officers:
https://www.hse.ie/eng/services/list/1/environ/environmental-health-officers.html
Full details of an off-trade licence holder can be found on Revenue’s Register of Renewed Liquor Licences at:
You may wish to write to the store owner.
A sample letter of complaint is outlined below:
Directors
X Limited
Address 1
Address 2
Town
County
Eircode
Dear Sir
It has been brought to our attention that your store is currently not in compliance with the regulations outlined in Section 22: Separation and visibility of alcohol products and advertisements for alcohol products in specified licensed premises, of the Public Health Alcohol Act, 2018.
You will find details of the legislation at: https://www.hse.ie/eng/services/list/1/environ/alcohol-legislation.html
I/we intend to notify the HSE Environment Health Officer in your area:
and we trust that you will work to comply with the law as a matter of urgency.
Yours faithfully
X