Individual submissions to the Draft RIA from members of the Advertising Association, representing posters, sales promotion and direct marketing, have highlighted this effect. It is disingenuous and unreasonable of the Government blandly to assume these component parts of the supply chain can find replacement income, especially when implementation is being chosen on a minimum timeframe rather than that outlined in the Directive. One cannot take 60m per year out of particular sections of a wider business without doing substantial damage. This is not a burden evenly shared and therefore its impact is likely to be disproportionate to its size. It is a net loss.
Precise calculations are difficult.
They concluded that the implementation of such a ban would put at risk some 1,500 jobs. The Government has said that the industry has had two years to prepare. This is only partially true. The Manifesto mentioned advertising but not direct marketing, sales promotion, coupon schemes or sponsorship. These have all become incorporated into the Directive on a much shorter time-scale.