G/TBT/N/IRL/4  
6 February 2023  
(23-0791) Page: 1/3 
Committee on Technical Barriers to Trade  Original:  English  
 
  
NOTIFICATION  
The following notification is being circulated in accordance with Article 10.6  
 
1. Notifying Member:  IRELAND  
If applicable, name of local government involved (Article 3.2 and 7.2):   
2. Agency responsible:   
Department of Health  
Block 1 Miesian Plaza  
50 – 58 Lower Baggot Street  
Dublin 2  
D02 XW14  
Email: tobacco_and_alcohol_control_unit@health.gov.ie  
Website: http://www.gov.ie/health  
Name and address (including telephone and fax numbers , email and website 
addresses, if available) of agency or authority designated to handle comments 
regarding the notification shall be indicated if different from above:   
3. Notified under Article 2.9.2 [X], 2.10.1 [  ], 5.6.2 [  ], 5.7.1 [  ], 3.2 [  ], 7.2 [  ], 
other :  
4. Products covered (HS or CCCN where applicable, otherwise national tariff 
heading. ICS numbers may be provided in addition, where applicable):   
The Act relates to the sale, labelling, advertising, marketing, and display of alcohol 
products. Beer made from malt (HS code(s): 2203); Wine of fresh grapes, incl. fortified 
wines; grape must, partly fermented and of an actual alcoholic strength of > 0,5% vol or 
grape must with added alcohol of an actual alcoholic strength of > 0,5% vol (HS code(s): 
2204); Vermouth and other wine of fresh grapes, flavoured with plants or aromatic 
substances (HS code(s): 2205); Cider, perry, mead and other fermented beverages and 
mixtures of fermented beverages and non -alcoholic beverages, n.e.s. (excl. beer, wine or 
fresh grapes, grape must, vermouth and other wine of fresh grapes flavoured with plants 
or aromatic substances) (HS code(s): 2206); Undenatured ethyl alcohol of an alcoholic 
strength of < 80%; spirits, liqueurs and other spirituous beverages (excl. compound  
alcoholic preparations of a kind used for the manufacture of beverages) (HS code(s): 
2208)  
5. Title, number of pages and language(s) of the notified document:   
Public Health (Alcohol) (Labelling) Regulations 2022 (18 pages, in English).  
6. Description of content:   
The Public Health (Alcohol) Bill was notified to the WTO Committee on Technical Barriers 
to Trade in 2016. Section 12 of that Bill contained the obligation to provide health 
information and health warnings on the labels of alcohol products and in other settings. 
The Public Health (Alcohol) Bill was subsequently enacted in 2018. Draft Regulations 
under Section 12 of the Public Health (Alcohol) Act 2018 are currently being notified to 
the TBT Committee of the WTO. These draft regulati ons provide the detail in relation to G/TBT/N/IRL/4  
 
- 2 - 
 
  the health warnings and health information. The draft regulations do not contain the 
requirement for such warnings as this is contained in section 12 and this was enacted in 
2018.  
The consumption of alcohol has been id entified as causing significant public health harm 
in Ireland. In response to this threat, the Irish Government enacted the Public Health 
(Alcohol) Act 2018 for the protection of human health.  
Under Section 12 of the Public Health (Alcohol) Act, the Minist er for Health is empowered 
to make regulations to require that the labels of alcohol products should contain:  
i. A warning to inform people of the danger of alcohol consumption.  
ii. A warning to inform people of the danger of alcohol consumption when pregnant.  
iii. A warning to inform people of the direct link between alcohol and fatal cancers.  
iv. The quantity of grams of alcohol contained in the product.  
v. The number of calories contained in the alcohol product.  
vi. A link to a health website which gives information on alcohol  and related harms.  
In addition, section 12 provides that those selling alcohol in on -licenced premises will be 
required to display a notice containing the same health warnings, a link to the public 
health website and an indication to the customer that the  alcohol and calorie content of 
alcohol products for all 'poured drinks' is available in a document on request.  
The draft labelling regulations apply to all alcohol products sold in Ireland, whether 
produced locally or imported into the State.  
The draft re gulations notified to the WTO, TBT provide the detail for the obligation under 
section 12. In relation to the requirements for health warnings, the requirement under 
12(i) to provide for a warning to inform people of the danger of alcohol consumption has 
been specified as a warning on the risk of liver disease. In addition, the requirement for 
a pregnancy warning under 12(ii) can be fulfilled through using a specified pictogram. 
The health website required at 12(vi) is www.askaboutalcohol.ie . 
The draft regulations also provide that for alcohol products which have a small surface 
area the health warnings and information can be of a smaller size or a flag label can be 
used. Finally, the regulations specify that web sites which sell alcohol products must 
display the same information as would be available to the consumer in a physical shop so 
that the online consumer has all the information at the point of purchase.  
The purpose of this provision is to ensure that impor tant and necessary public health 
information is communicated to the Irish consumer at the point of purchase so that the 
consumer can make an informed choice about their alcohol consumption. In addition, 
evidence shows that health information on the labels of alcohol products leads to a 
reduction in alcohol consumption and therefore in the health harms caused by alcohol.  
Currently, there is no regulatory requirement for the display of health warnings or health 
information on alcohol products sold in Ireland. This is despite the well settled scientific 
evidence that alcohol causes conditions such as alcoholic liver disease and alcohol induced 
pancreatitis as well as cancers, cardiovascular disease and other conditions being 
attributable to alcohol. Ire land's objective is to reduce the disease and death caused by 
the way alcohol is currently consumed here and to do so using methods that do not exceed 
what is necessary to achieve that objective. In the case of labelling, Ireland is taking the 
minimal acti on of requiring the risks associated with the product to be stated for the 
benefit of the consumer.  
7. Objective and rationale, including the nature of urgent problems where 
applicable:   
The high volumes and harmful patterns of alcohol consumption in Ireland are responsible 
for an enormous burden of public health harms and healthcare costs. The proposed 
regulations submitted here form part of a suite of measures under the Public Health 
(Alcohol) Act that are designed to reduce these harm s and costs for the protection of the 
health of Irish citizens.  G/TBT/N/IRL/4  
 
- 3 - 
 
  In accordance  with Article 2.2 of the WTO TBT Agreement and in pursuit of the protection 
of human safety and health, these regulations are aimed at protecting human health.  
The draft labelling  regulations apply to all alcohol products sold in Ireland, whether 
produced locally or imported into the State. Therefore, in accordance with Article 2.1 of 
the WTO TBT Agreement, products imported from the territory of any member will be 
accorded treatme nt no less favourable than that accorded to like products of national 
origin and to like products originating in any other country.  
Alcohol consumption levels in Ireland have remained extremely high in recent years 
despite extended closures of on -licensed premises due to COVID -19. 50% of Irish drinkers 
drink to a hazardous level and one in five drinkers have an alcohol use disorder.  
Alcohol consumption creates an enormous burden on public health in Ireland causing an 
estimated 4.8% of all deaths and 5.2% of  disability adjusted life years. Alcohol 
attributable morbidity is trending upward with hospitalisations doubling since the mid -
1990s and illnesses becoming more complex. 4% of total health expenditure will be on 
alcohol related disease for the next 30 yea rs unless Ireland changes its populations 
understanding of and relationship with alcohol.  
The data shows that the Irish population is not aware of the health risks of alcohol. Despite 
the public health burden caused by alcohol consumption here, awareness o f the health 
harms remains low also among younger age groups. 16% do not know if it is safe to 
consume alcohol while pregnant, 79% do not know of the breast cancer risk and those 
aged 15 -24 were typically less aware of the risks than others. There is a dem and to know 
more; 78% believe that the government has a responsibility to implement public health 
measures to address high alcohol consumption and 95% support including details of 
alcohol -related harms on labels.  
In order to empower Irish consumers to make  healthier choices about their alcohol 
consumption, the draft regulations are designed to ensure that consumers are directly 
informed of the risks associated with alcohol products at the point of purchase and at the 
point of consumption.  
The draft regulati ons are designed to be effective in accordance with international best 
practice and are a proportionate response to the serious threat to health posed by alcohol 
consumption in Ireland.  
The draft regulations provide for a very long lead -in time (3 years) w hich will not begin 
until the regulations have been finalised and provide options for businesses to minimise 
the impact on their processes. Additional provisions designed to facilitate businesses 
include reducing the minimum dimensions of the health inform ation for alcohol containers 
of a smaller size and allowing for the use of a flag label to contain the required information.  
Consumer information, labelling; Protection of human health or safety  
8. Relevant documents:   
https://dohireland.sharefile.eu/d -s0ec8009f60064cb0ba895f010568f506  
https://dohireland.s harefile.eu/d -sda24737eb8234620afe93e55130bf058  
9. Proposed date of adoption:  To be determined  
Proposed date of entry into force:  To be determined  
10. Final date for comments:  90 days from notification  
11. Texts available from:  National enquiry point [ ] or address, telephone and fax 
numbers and email and website addresses, if available , of other body:   
Contact emails:  
Siobhan_mcnamara@health.gov.ie  
Claire_gordon@health.gov.ie  
https://dohireland.sharefile.eu/d -s0ec8009f60064cb0ba895f010568f506