Mandatory Health Warnings for Alcohol Products sold in Ireland

Ireland is set to become the first country to introduce mandatory health warnings on alcohol products.

The Minister for Health has recently signed into law regulations which will have the effect of introducing onerous health labelling requirements on alcohol products sold in Ireland.

The Public Health (Alcohol) (Labelling) Regulations 2023 (the Regulations) will require the labels of alcohol products to state the calorie content and grams of alcohol in the product. Labels will need to include a warning about the risk of consuming alcohol when pregnant, the risk of liver disease and the risk of fatal cancers from alcohol consumption. The labels will also have to direct the consumer to the Health Service Executive’s website, for further information in relation to alcohol consumption. This information must also be displayed in a licensed premises and on websites where alcohol products are sold online.

There is a three-year lead-in time to provide the industry with time to prepare for and implement the changes that will be required to add the detailed warnings to labels. The rules will come into effect from 22 May 2026 and will only apply to products on sale in Ireland. They will not apply to alcohol products being exported.

The Public Health (Alcohol) Act 2018 (2018 Act) which has not yet been fully commenced, was enacted with the objective of reducing the consumption of alcohol in Ireland. The main provisions of the 2018 Act provide for the following:

1. minimum unit pricing for the retailing of alcohol products;
2. regulation of the marketing and advertising of alcohol;
3. regulation of sports sponsorship;
4. structural separation of alcohol from other products; and
5. health labelling of alcohol products.

The provisions relating to labelling of alcohol products are amongst the most radical changes introduced by the 2018 Act.

Another provision of the 2018 Act that is yet to be commenced relates to the content of advertisements for alcohol products with fines and other penalties for non-compliance. Once commenced, it will have a significant impact on the way alcohol is advertised in Ireland. An advertisement for an alcohol product will not be able to contain anything other than the warnings in relation to the dangers of consuming alcohol or any of the following details:

1. an image of, or reference to, one or more alcohol products (whether of the same or different kinds) either in a container or containers (which may be opened or unopened) or in a glass or glasses;
2. details of whether the product is intended to be diluted with a non-alcoholic beverage and where it is intended to be diluted, an image of or reference to the non-alcoholic beverage;
3. an image of, or reference to, the country and region of origin of the product , the method of production, or the premises where the product was manufactured;
4. the price of the product;
5. a brand name or variant, trade-mark and brand emblem of the product;
6. a corporate name and corporate emblem of the product;
7. an objective description of the flavour, colour and smell of the product;
8. the name and address of the manufacturer (or his or her agent);
9. the alcoholic strength by volume of the product;
10. the quantity in grams of alcohol contained in the product; and
11. the energy value expressed in kilojoules and kilocalories of the product.

Despite fielding concerns from winemakers, brewers and distillers worldwide, the trade and competition authorities at EU and WTO level declined to block the proposed measure on competition or other grounds.

However, the Regulations remain the subject of criticism from alcohol industry lobbyists and other EU member states who have raised concerns about Ireland’s decision to press ahead with national legislation when a harmonised approach is being considered at EU level.

Health-conscious consumerism is a growing trend, and this focus on health and well-being will continue to have a significant impact on the food and beverage industry. Although it will be important to monitor developments in this space we are also working with clients and colleagues internationally to fully understand the various applicable regulatory requirements and prohibitions as clients plan their advertising and labelling claims.

Learn more about these regulatory requirements and prohibitions and their implications for your business by contacting any of the authors.