Category: News

On the 20^th year anniversary of the landmark court decision in Granholm v. Heald, it is appropriate to contrast the progress that has been made regarding direct to consumer (DTC) sales of wine within both Canada and the USA. This issue is unique to federal jurisdictions where alcohol is regulated by their states/provinces using post-Prohibition ideology. In most countries, there is no legacy of Prohibition and thus no patchwork of arcane legal restrictions surrounding alcohol sales and shipment within the country.

The Granholm decision was the impetus for a ‘landslide’ of progress south of the border. The Granholm court ruled that if a state permitted DTC sales within its borders (i.e. from a winery direct to customers within that state) then it could not prohibit DTC sales to those same customers from wineries outside the state. In other words, the court held that a state could not provide preferential treatment for its own wineries by using restrictive laws that prevented out of state wineries from making the same type of sales.

The eventual effect of this was that nearly all U.S. states now permit DTC sales from other states. This summary from the California Wine Institute shows that only 5 states still prohibit DTC sales. 

In contrast, Canada, now seems to have the worst of all possible worlds. We still have a patchwork quilt of alcohol regulation with differing standards and rules from province to province. There is still no national (or even close to national) standard for DTC and little to no thought given to consumer selection or competition. We have many provincial regulators that are still rooted in post-Prohibition ideology. As a stakeholder once said to me “the folks that currently regulate alcohol here were not around during Prohibition but they were trained by people who were”.  

Unfortunately, this is still true in some provinces. The mentality is still fiercely protective of provincial liquor fiefdoms and their ability to generate tax revenue for their political masters. It appears fearful of any attempt to eliminate hurdles at provincial borders or to transfer control or policy-making to anyone other than the liquor bureaucracy (which doesn’t even exist in most other countries).

As such, we have made little progress on DTC in Canada. Only one province (Manitoba) is fully open (and importantly has had zero problems as a result). BC and Nova Scotia permit sales of Canadian wine direct from the winery without fees. Saskatchewan and Alberta permit such sales but only using complex permit and fee payment systems, the latter of which is now almost completely unworkable given its recent hike in markup rates. The two largest provinces still remain closed.

There have been recent pronouncements of good intentions by various governments including a proud proclamation from the federal government that we would get this solved by Canada Day. However, I am doubtful that this will get solved in a sensible way. For example, last week the Ontario government signed a memorandum of understanding with Manitoba which included mutual commitments to address the DTC problem. The preamble to the memo states “Manitoba is a leader on direct-to-consumer (DTC) sales of alcohol and is currently fully open”. The governments then agree to “develop a bilateral DTC agreement by June 30, 2025, to enhance market opportunities for producers and increase consumer choice for Manitobans and Ontarians”.

This is a solution in search of a problem. As the memo states, Manitoba is currently “fully open” to Ontario producers making DTC shipments (without charging any fees). It also has virtually no wine industry or production. So why would Ontario be concerned at all about DTC shipments from Manitoba into Ontario? Is there any reason why they would not immediately emulate Manitoba’s ‘leadership’ … and become “fully open” to DTC from Manitoba?

On a larger level, there would appear to be some obvious solutions to all of this. Many (or most) provinces could easily become “fully open” to other provinces without any significant consequences. DTC shipments from wineries have constituted and will constitute such a tiny part of the overall liquor marketplace that the liquor bureaucracy will barely even notice – and would not take any meaningful hit to their revenue. As noted above, Manitoba has experienced no issues and has been “fully open” since 2012. 

The only real issue with “fully open” DTC is for those provinces that might permit DTC from both wineries and retailers and which have significantly different liquor markup structures. In those cases the price differences between provinces could be sufficient for some consumers to pay for shipping and to wait for an inter-provincial purchase … but this is already happening in the grey market. And I would suggest that any province in such a position might wish to rethink its approach to markup and to adopt something more reasonable. 

Another approach which could work would be one that my colleague, Anthony Gismondi, recently suggested in the Vancouver Sun … whereby the provinces agree on a sensible ‘flat rate’ markup amount that would be collected on all inter-provincial sales which amount would be submitted to the liquor bureaucracy in the receiving province. The key to this is to make the amount reasonable and easy to collect. As Anthony suggested, $2-3 per 750 ml bottle would likely work (i.e. a national volume-based flat tax) … but higher amounts would make the scheme unworkable.

Finally, and failing reasonable provincial solutions, I would suggest that we adopt a solution that is better than the U.S. and one that is more befitting a real country: the federal government should exercise its exclusive jurisdiction over interprovincial trade and legislate a national personal exemption amount for DTC sales. We already have ‘duty-free’ exemptions for international alcohol purchases. If the provinces are going to treat each other as if they are separate countries, then let’s get the federal government to intervene and become the adult in the room. Would Canadian civilization collapse if we permitted 1 or 2 cases of wine per month per person to travel ‘duty-free’ between provinces?

I think a little competition between liquor monopolies would be a good thing. Long suffering Canadian wine drinkers deserve at least this much latitude within their own country and from their federal government.

A tariff is a tax imposed by one country’s government on products that are imported from a foreign country. This makes the imported products more expensive as opposed to local alternatives.

Tariffs that are imposed on wine imported from another country will almost certainly increase the end consumer price. Here is an example of a Canadian wine being sold into the U.S. market assuming a 25% tariff (current conditions). The same principles would apply for wines from other countries if the US imposes tariffs as they may do this coming week (although the threatened tariff on European wines is 200% not 25%!).

For example:

	With Tariff	Without Tariff
A Canadian winery sells a bottle of wine to a U.S. importer for $10	$10	$10
AT USA BORDER Tariff of 25% imposed by US Govt on Canadian products	+$2.50	+$0
USA BORDER	———————-	———————-
US importer pays tariff to get the wine released from customs. So the $10 cost for the wine increases to $12.50.	$12.50	$10.00
US importer must add $ to cover its expenses and profit (to generate a wholesale price). Assume 20% added. Wine is then sold to a retailer at that price.	$15 wholesale	$12 wholesale
US retailer adds $ to cover its expenses and profit (to generate a retail price). Assume 30% added.	$19.50 retail	$15.60 retail
	+$3.90 with tariff

The end consumer will almost certainly pay more for the bottle of wine when tariffs are applied because the US-based importer had to pay the tariff, increasing its costs. In some rare circumstances, the US importer might absorb the increased costs or the Canadian exporter (winery) might lower its prices but this would be unusual.

As a result, tariffs are essentially hidden government taxes that are applied prior to the wholesale level of distribution, thus increasing the cost of goods throughout the supply chain.

Yesterday (March 5^th), the federal government issued a first ministers’ statement indicating that significant changes will be made shortly to eliminate or reduce internal trade barriers in Canada: see First Ministers’ Statement on Eliminating Trade Barriers in Canada. Specifically, the announcement states the following regarding barriers that restrict the alcohol trade:

“Launching pan-Canadian direct-to-consumer alcohol sales for Canadian products: The Governments of British Columbia, Alberta, Saskatchewan, Manitoba, Ontario, Quebec, New Brunswick, Nova Scotia, and Canada have committed to improving the trade of alcohol products between participating jurisdictions by advancing direct-to-consumer sales for Canadian products. Currently, British Columbia allows for direct-to-consumer sales for wine, while Manitoba is already open to direct-to-consumer sales on all alcoholic beverages. The Yukon is exploring options for direct-to-consumer alcohol sales within the territory.”

Media organizations have subsequently reported on this positively. See Ottawa, Provinces Agree to Open the Tab on Booze.

I am encouraged to see that progress may be happening on this issue. However, I have been working on this issue for a decade and a half. During that time, there have been many grand statements of intention with only a few practical and workable results. On this issue, like many areas of liquor policy, the “devil is in the details”. Particularly, I wait to see for those details and to see whether the announced changes address the following two major issues.

Will There Be Realistic and Workable Tax Expectations? 

The major stumbling block over the years has been provincial concerns that if they loosen their control over their respective provincial liquor monopolies by removing interprovincial restrictions, they will lose sales tax and liquor markup revenue from liquor sales. The latter amounts are the ‘hidden taxes’ that are applied by the government liquor monopolies at the wholesale level as part of their statutory monopolies over liquor distribution. Generally, the provinces have asserted that they need to collect all of the tax and liquor markup from out of province sales in order to ‘remain whole’. In my view, this concern is exaggerated. 

The liquor markup fulfills two functions. Partly, it covers the costs of operating the wholesale liquor distribution system (i.e. importing, warehousing, shipping … and sometimes also retail costs). And partly, it is ‘pure tax’ that goes to general revenue. There are very different approaches to the application of these fees in each province. Sales taxes vary considerably with Alberta having none. There is similar variation for liquor markup with varying amounts charged. Some provinces exempt their own producers from markup entirely (BC) or apply reduced charges (Ontario). 

In respect of an interprovincial sale where the wine is shipped directly from a producer to a customer, there are zero liquor distribution system costs to be covered. The destination province incurs no costs at all because the producer or customer pays for the shipping and costs of sale. As such, the provinces should only be worried about the ‘pure tax’ component.

And even on that part, would interprovincial sales make any appreciable difference? Manitoba has had open borders for alcohol sales since 2012 … and has not experienced any meaningful drop in provincial liquor revenue. BC has permitted DTC sales of Canadian wine from other provinces for years (without collecting any fees) … and has not seen any significant adverse effects. Same for Nova Scotia. The reality is that if a province has reasonable tax and markup levels, it will not see any substantial change … because it is much easier for a customer to buy wine locally than to order it from another province, pay for shipping, and wait for delivery. DTC generally only happens in respect of product that is difficult to find and for that small segment of the wine consumer marketplace that is willing to seek out those wines. 

For any system that permits the interprovincial sale of alcohol, there needs to be realistic and workable expectations about how much sales tax and liquor markup are being collected, if any. If the system is too expensive or administratively cumbersome, it simply will not work … and may price Canadian wines out of reach of normal consumers.

The recently introduced Alberta DTC system provides an instructive example. When introduced, this system required producers to pay a simply flat fee amount (about $3) on each bottle. This was easy for producers to charge and reasonable enough that consumers would likely pay it. However, Alberta has recently indicated that it is changing its markup structure … and it is not yet clear how much fees will increase or whether the fee calculation will become overly complicated (see Alberta Hikes Liquor Markups).

Consequently, I await the details associated with our new ‘open borders’ for alcohol. It may be too much to hope for truly ‘free’ sales and shipment but I am hopeful that the provinces may at least introduce a sensible system that will work for both producers and customers.  

Will Consumers Have Both Producer and Retail Choice?

A secondary concern is whether the new system will apply so that customers can buy wine from both producers and retailers in other provinces. To date, the only province that openly permits both is Manitoba. The reforms in BC and Nova Scotia only apply to Canadian wine purchased directly from a winery. If Canada wants to join the rest of the world, it should let wine lovers shop for wine in other provinces without such limitations … and simply let consumers find, buy and love any wine that they can find within their own country. 

This morning, the Trump administration announced that it will proceed with blanket 25% tariffs on almost all Canadian and Mexican products entering the U.S. In retaliation, the Canadian and Mexican governments announced reciprocal tariffs. The Canadian response includes matching 25% tariffs on U.S. alcohol products, including wine, that enter the Canadian marketplace. I discuss the effects of these developments below.

What Wine Does the Tariffs Apply To? The Canadian tariffs will apply to all U.S. produced wine that enters Canada as described above. The tariffs would not apply to non-U.S. wine (e.g. French or Italian wine) that enters Canada from the U.S. or from other countries.

When Will the Tariffs Take Effect? The Canadian tariffs take effect as of 12:01 am today (Tuesday March 4th). However, they will not apply to goods that were already in transit to Canada today. As such, these tariffs will apply to all U.S. wine arriving at the border which is shipped today or later. The tariffs are imposed when the product enters Canada so wine that is already within Canada will not be subject to the tariffs. For example, U.S. wine that is already in Canadian stores or is already in the Canadian distribution system will not be subject to the tariffs.

Will Wine Prices Rise Because of the Tariffs? U.S. Wine prices should not rise immediately because wine that is already here will not be subject to the tariffs. Wine importers will likely exhaust their existing stocks of U.S. wine at existing prices so they should be able to supply retailers and restaurants/bars for some time depending upon their stock levels in Canada. Importers will hope that the tariff disputes are resolved before they have to import new stock. If an importer brings in new stock from the U.S., that stock would be subject to the tariffs and the importer would likely have to raise consumer prices (see below).

How Much Could Prices Rise? If an importer brings in new stock from the U.S., there would likely be considerable price hikes. The 25% tariff would be added to the supplier’s cost before the imposition of other taxes and liquor board markups. The cumulative effect creates a multiplier of “tax on tax” which would significantly increase costs for the importer and make it very difficult for them to ‘absorb the cost increase’. For example, using rough calculations, I believe that a U.S. bottle of wine currently retailing for $20 would increase by about $5-6. All price points would be affected with greater dollar price increases at higher price points. I note that the effect in Alberta will be compounded with the recent change in AGLC liquor markup rates.

Will U.S. Wines Still Be Available? What Will be the Effect on Sales? The reciprocal tariffs are an action of Canada’s federal government. However, liquor distribution is controlled by the individual provinces, all of which have government monopolies on distribution at the wholesale level and most of which also have government retail stores. Some provinces have either entirely removed or selectively removed U.S. alcohol products from distribution by their provincial liquor monopolies (update: most Canadian provinces have now entirely removed U.S. alcohol from government monopoly distribution). These actions will obviously have severe marketplace effects. Even in those provinces which continue to permit sales, the effect on consumer purchasing of U.S. wines will likely be significant if this dispute drags on. Some consumers may choose to avoid purchasing U.S. wines due to the politics of the situation. But even for those that don’t, all U.S. wines would become less price competitive as compared to Canadian wines and wines imported from other countries. There would likely be a significant loss of market share from the U.S. in favour of Canada and other countries.

What About Bringing Wine Back After a Trip? The tariffs will not apply for accompanied imports of wine that are within an individual’s duty-free limit. However, they would apply for any amount of wine that is outside the limit. As such, the importation of U.S. wine by a traveller that is not duty-free will become considerably more expensive.

What About Selling Canadian Wine in the U.S.? The American tariffs would affect the price of Canadian wine in the U.S. marketplace in a similar way to that described above (although the U.S. does not import much Canadian wine). As a result, any new shipments of Canadian wine (or other alcohol) into the U.S. would be subject to tariffs with resulting eventual price increases and eventual erosion of market share. This issue would be more significant for Canadian spirits manufacturers.

Yesterday, the Alberta Gaming, Liquor and Cannabis Commission (AGLC) announced that liquor markups in Alberta will increase as of April 1st 2025 for “high-value wine”. Liquor markups are government imposed fees applied at the wholesale level as a result of the statutory government monopoly over wholesale liquor distribution. Essentially, they are ‘hidden’ taxes on liquor. Previously, AGLC had applied a volume-based markup on wine, which now increases slightly to $4.11 per litre ($3.08 per 750 ml bottle). This fee remains constant regardless of the value of the wine. This system was often referred to as the ‘flat tax’ and was preferred by many in the industry as being relatively simple. It resulted in prices for wine that were relatively low by Canadian standards.

A new system has now been introduced that is more complicated and imposes additional fees on “high value” wines that are based on the value of the wine (sometimes referred to as ‘ad valorem’ taxes). The flat tax described above still applies for wines that have a “reference invoice price” up to $15 per litre ($11.25 per 750 ml bottle) (I call this “Supplier Cost” below) . Using approximate calculations that would translate to about $20 per 750 ml bottle at retail once the various fees are added in. So wines at or below that consumer price point should be relatively unaffected.

However, for wines above the $15 per litre reference point, there are new additional percentage based fees that are shown in the table below:

As you will note, this system is fairly complicated imposing 3 levels of additional fees, based on the wine’s value. The fees are 5% for value between $15-20 per litre. Then 10% for any value between $20-25 per litre. Then 15% for any value above $25 per litre. Again, using approximate calculations, this would have the following effects. Retail margins vary considerably so the numbers would change accordingly (examples below use a retail ‘markup’ of 38%).

Supplier Cost inc. excise/duty (750 ml)	Flat Tax Markup	Additional ‘High Value’ Markup	Approx Wholesale Price	Approx End-Consumer Price	Approx Price Increase
11.25	3.08	0	14.33	19.78	0
15.00	3.08	0.19	18.27	25.21	0.26
18.75	3.08	0.57	22.40	30.91	0.79
30.00	3.08	2.26	35.34	48.77	3.12
75	3.08	9.01	87.09	120.18	12.43

The new system will create end-consumer price increases as noted and which are more significant as the value of the wine increases. Any value (supplier cost) above $18.75 per bottle will be ‘taxed’ at 15% so the largest increases will occur for expensive wines (above approx. $30 retail). Effectively, Alberta has now introduced a new hidden ‘tax’ of 15% on expensive wine.

The new system becomes effective on April 1st, 2025. I note that it remains unclear how these changes will apply to the recently announced DTC registration system under which BC wineries can sell directly to consumers in Alberta.

The last couple of weeks have been tumultuous for Canada with on again/off again threats of tariffs from the U.S. President. However, the turbulence has also shone a light on our own internal problems, and particularly upon those related to the persistence of internal trade barriers such as the inability of most Canadian consumers to legally purchase alcohol from producers and retailers in other provinces. 

As most Canadians will remember, there was a hope that this specific problem would be solved in 2018 when the Supreme Court of Canada considered the issue in the case of R. v. Comeau, in which Gerard Comeau was charged after purchasing alcohol in Quebec and bringing it back to his home province of New Brunswick. His legal counsel argued that the restrictive provincial laws were invalid because the Constitution guarantees that products produced in one province “shall be admitted free into each of the other Provinces”. Mr. Comeau won the case at the trial level. Unfortunately, (and tragically in hindsight) the Supreme Court overruled the trial court. They declined to recognize the plain meaning of these words and, instead, upheld provincial restrictions that prevented Mr. Comeau (and other Canadians) from shopping for alcohol in another province.

At the time, Andrew Coyne (who was then writing for the National Post) called out the Supreme Court’s “baffling” decision and asked what was the worst part of it: was it “the shoddy reasoning, the tendentious reading of simple declarative statements, the selective approach to history, the willful naivete?”. I commend anyone interested to read his full analysis here: “Supreme Court beer ruling ties the constitution in knots, and the economy with it”. It’s hard to disagree with any of Mr. Coyne’s criticisms. Indeed, many of them are prescient of the situation we now find ourselves in. 

The bottom line is that this was an awful decision on many levels. Canada now desperately needs to rid itself of this ruling and escape the economic straightjacket that it creates for us. Federal and provincial governments alike have professed to take action on this issue for years but very little progress has been made – mostly because the provinces like their absolute control over the money that liquor sales generates for them. It is far past time to fix things and throw these silly restrictions into the dustbin of embarrassing regulatory trash that has burdened us for so long. 

The federal minister responsible for internal trade, Anita Anand, commented last week that we could possibly see the end of these restrictions “in 30 days” … with meetings scheduled between the various levels of government to address this. I remain optimistic but am not holding my breath due to the long history of much talk and no action. The feds and provinces need to deliver on this … please get it done. Let us join the rest of the world and eliminate all barriers to the interprovincial alcohol market. 

Also … see my discussion with Tania Tomaszewska on this issue here: Blocking Our Own Wine – What Happened to Free Trade

Last week, the U.S. Surgeon General issued an advisory entitled “Alcohol and Cancer Risk 2025” which garnered a significant amount of media attention since it concludes that the consumption of alcohol is so risky that all alcohol sold in the U.S. should contain warning labels to alert consumers about the cancer risks caused by alcohol consumption. It includes some worrying statements such as that the risks of alcohol related cancer “may start to increase around one or fewer drinks per day”.

In many places, it emphasizes the risks related to low levels of consumption including by stating that “17% of the estimated 20,000 U.S. alcohol-related cancer deaths per year occur at [consumption] levels” within the U.S. recommended drinking guidelines of 2 drinks per day for men and 1 drink per day for women. It also asserts that the majority of the public is uninformed about the extent of such risks.

The end of the advisory concludes with a call to action for “reducing alcohol-related cancers in the U.S.” that includes a reassessment of recommended consumption levels as well as advocating for the inclusion of warning labels “about the risk of cancer associated with alcohol consumption”. Here is an excerpt:

I am not convinced that this advisory is correct or that it even provides useful information for the general public. Here’s why I think that.

A major part of the advisory, and one that is of interest to the public, is an explanation of the risks related to alcohol consumption … and specifically how those translate into the likelihood of poor health. While there is some reference in the advisory’s discussion to other sources, the most “hard-hitting” part of it (and the easiest to understand) is an infographic (shown below, from p.13 of the advisory) which concludes that more alcohol consumption (even at relatively low levels) increases the risk of cancer in both men and women. 

It states that the lifetime risk (up to age 80) of being diagnosed with an alcohol-related cancer is 16.5% for women and 10% for men if they drink less than 1 drink per week (i.e. this is the chance of getting one of these types of cancer even if you drink basically nothing). It then asserts that these risks increase to 19% for women and 11.4% for men at a consumption level of 7 drinks per week (the current U.S. recommended level for women). The risk further increases to 21.8% for women and 13.1% for men at a consumption level of 14 drinks per week (the current U.S. recommended level for men). 

The infographic further explains that these increases in risk would translate to “about 5 more women out of 100” and “about 3 more men out of 100” developing alcohol related cancer (up to age 80) if they consumed two drinks per day (i.e. about a 5% increase for women and 3% increase for men in absolute risk). 

All of these infographic explanations of risk are based on a single study from Australia that was published in 2021. Here is the link to the study if you are interested. After reading through the study, I am having considerable difficulty in understanding both how the Surgeon General came to the conclusions that he did … and how the conclusions regarding risk were generated. 

The authors of the study generated conclusions of risk related to alcohol consumption that are similar to the ones contained in the advisory. These are tabulated by age and gender and by alcohol consumption groups (see excerpt from table below which highlights the important parts, the complete Table 3 can be reviewed as part of the supplementary material to the study which can be found at the link above.

If one reviews the actual assessments of risk calculated in the study up to age 80 (table 3 above – in red), one can see that the study determined the following:

• The lifetime risk for alcohol related cancer for those in the group who drink less than 1 drink per week (i.e. almost nothing) is 9.96% for men and 16.53% for women. These numbers are the same as those in the advisory infographic (above) and indicate the chance of being diagnosed with an alcohol related cancer even if you drink next to nothing. 

• The lifetime risk for alcohol related cancer for those in the group who drink amounts between 1 and 14 drinks per week (median/average of 6 drinks for men and 5 for women) is 10.86% for men and 17.6% for women. This is an increase of about 1% in the absolute risk to the first set of numbers (i.e. little difference in risk to drinking almost nothing). The advisory infographic provides a different set of higher risk numbers (11.4% and 19%) for consumption at 7 drinks per week which it is claimed is based on the same data.

• The real problem lies in the final set of numbers. Here the lifetime risk for alcohol related cancer for those in the group who drink more than 14 drinks per week is calculated for everyone in that group who declared above this consumption level and for all greater consumption amounts (some of whom would be heavy drinkers … the median/average consumption in this group was 21 drinks per week for men and 20 drinks per week for women – see red text above). The lifetime risk to age 80 for this group is stated as 13.46% for men and 21.17% for women. These risk percentages are almost the same as those quoted in the advisory infographic (13.1% and 21.8%) for a consumption level of 14 drinks per week. This makes no sense. How can the analysis from the actual study indicate a risk level for a group with a median consumption of 20-21 drinks per week that is quoted by the advisory as being essentially the same as one for 14 drinks per week. One set of numbers appears to be incorrect … and that is more likely to be those in the advisory infographic.

This is potentially serious because the infographic is claiming a particular level of increased risk at 14 drinks per week (which are the current U.S. drinking guidelines for men) which does not appear to be justified by the study upon which it relies. According to the study, that same level of increased risk is not reached until (on average) men drink 50% more than the guidelines and women drink 185% more than the guidelines.  

As such, I question the propriety of the conclusions in the advisory. In addition, and since the advisory relies so much on the Australian study, it is worth noting the following:

• The study group consisted of individuals over 45 years of age. Persons living in rural and remote areas were over-represented in the group. These factors raise questions related to the transferability of the conclusions to other demographic groups in other places such as the U.S. The authors note that the study’s conclusions regarding risk are higher than other studies, particularly a British one.
• Vital information related to lifestyle and alcohol consumption was obtained from the group by self-reporting via postal questionnaires. This raises questions about the accuracy of the data including the likelihood of under-reporting of alcohol consumption.
• The authors of the study note that 2.8% of cancer cases in Australia are attributed to alcohol consumption. Conversely, this means that 97.2% of cases are NOT attributable to alcohol.
• The authors note many limitations of the study including the possibility of under-reporting of consumption by participants and an inability to fully track consumption patterns or alcohol types.

In summary, I have the following questions about this advisory that raise issues about its utility: 

• Why is the Surgeon General using a single Australian study to provide risk justifications for alcohol policy interventions at the federal level for all of the United States? This particular study may not be applicable to the U.S. and/or could later be proved to be inaccurate.
• Policy decisions that are based on science should have broad scientific support. In contrast, the recent National Academies Review of Evidence on Alcohol and Health came to dramatically different (basically opposite) conclusions regarding moderate consumption and appears to be broader based.
• Why is the Surgeon General’s advisory using risk calculations that do not seem to be supported by the actual data in the study that it is relying upon?
• Why is the Surgeon General’s advisory narrowly focused on the health risks related to alcohol and cancer, particularly when the vast majority of cancer cases (97% according to the Australian study) are not attributable to alcohol consumption? Should the Surgeon General more properly be taking a broader look at alcohol and health … as the National Academies Review did?
• Why would relatively small increases in risk justify a conclusion that alcohol “causes” cancer (a more accurate statement might be that “alcohol can contribute to the development of cancer” at specified consumption levels)? Why would this lead to calls to reassess the existing drinking guidelines? And why would this lead to advocacy for warning labels that could be very misleading in respect of the actual risks involved?

Note: my discussions of risk above refer to absolute risk which is the primary discussion in both the advisory and the study … and, in my view, the most transparent way to discuss risks relating to health. I do not refer to relative risk (i.e. the % difference between two levels of absolute risk) because I think that is often misleading, particularly in situations where the absolute risk is small.

There continues to be a great deal of media coverage of anti-alcohol advocates who claim that there is “no safe level” of alcohol consumption. This series of blog posts provides 3 reasons why I will continue to ignore these assertions.

Reason #3 – Individuals Should Make Their Own Choices

The third reason that I am not paying much attention to anti-alcohol advocates is that their conclusions and recommendations are wholly incompatible with the notion that individuals are likely to have both different health outcomes from similar behaviours and different risk tolerances. The conclusion that there is “no safe level” of alcohol consumption is a prime example of this. 

Individuals have vastly different health histories, genetic predispositions to illness, diets and lifestyles. Even if it were true that there is an increased average health risk across a population related to a certain level of alcohol consumption, that does not mean that it is true that any one individual has the same level of risk. There could well be groups of individuals who have higher risks related to family health history, diet, exercise or susceptibility to problem consumption. It may well be appropriate to advise some of those individuals that the safest level of consumption for them is low or even none. But that does not mean that other individuals have the same risk factors. Someone who drinks moderately, who is fit, who has no problematic health history, and who eats well may have little to no risk from the same level of consumption. For that individual the blanket recommendation of “no safe level” is completely wrong. 

Any set of recommendations (and particularly the blanket “no safe level” statement) is simply not accurate on an individual level unless it takes into account all of the unique personal factors that apply to that individual. As such, public health guidance that creates blanket recommendations is inappropriate and bordering on the reckless. Unfortunately, I suspect that such guidance is being created to deliberately “scare” people into reducing consumption, even when there is no scientific basis to do so.

In a similar vein, individuals will likely have very different levels of risk acceptance when it comes to health and alcohol consumption, particularly when the absolute risk related to certain health outcomes is very small. This applies to all aspects of life including driving, playing sports and engaging in other lifestyle choices. Some people are risk adverse when it comes to health, others not so much. The anti-alcohol advocates assume in their calculations that almost any level of increased risk is unacceptable even if it is very minimal. They also mostly ignore the proven health benefits of certain levels of consumption on heart disease … and completely ignore the health benefits of consumption that is related to social interaction and community. 

It remains a fact (which is inconvenient to the anti-alcohol folks) that if you look at all-cause mortality … in other words, general life expectancy … that people who consume in moderation are on average, likely to live longer than those who abstain completely (as well as longer than heavy drinkers). Life insurance calculations do not penalize people who drink for a reason … there is simply no basis to conclude that moderate drinkers will have shorter lives. As a result, I will continue to drink wine in moderation, as I have for the past few decades and as civilized society has for thousands of years.

Reason #1 is here: Only Pay Attention to Good Science

Reason #2 – Don’t Listen to Biased Sources

There continues to be a great deal of media coverage of anti-alcohol advocates who claim that there is “no safe level” of alcohol consumption. This series of blog posts provides 3 reasons why I will continue to ignore these assertions.

Reason #2 – Don’t Listen to Biased Sources

The second reason that I am not paying much attention to the anti-alcohol advocates is that I generally only give credence to scientists and other experts that I believe are looking at the issues with a proper unbiased perspective and who are neutral. In other words, I pay attention to who is making the claims and what their motivations might be. I need to trust the source. I think that much of the work coming from the anti-alcohol camp is not neutral science … rather it is advocacy cloaked in scientific language. Most of the anti-alcohol crowd derive from one of two camps: they are either public health professionals or are academics whose research interests are devoted to anti-alcohol work.

In terms of the public health group, I believe that for the most part, this group is well-intentioned but often becomes misguided. On many contemporary public policy issues, public health has focused their analysis far too narrowly, often using a metric of mortality reduction related to a single disease without considering the wider effects on society or even on properly targeting the actual problem. In addition, they have sometimes demonstrated a propensity to not provide the whole truth if they believe that a “white lie” will accomplish their policy objectives. The World Health Organization has become, sadly, a prime example of this.

The results can be problematic … as was demonstrated during Covid regarding the contradictory messaging regarding the effectiveness of masks.  In my home province of British Columbia, this approach also caused serious political repercussions when a “harm reduction” policy of drug decriminalization was accepted at the behest of public health. This resulted in rampant social disorder, out-of-control public drug use and continued increases in overdose deaths. The province had to reverse the policy to stem the damage.

Many of these same experts have also advocated for various anti-alcohol policies such as hefty tax increases and sales restrictions, arguing that an overall reduction in alcohol consumption will reduce alcohol-related harms. That blunt and over-reaching approach rarely works as Scotland recently discovered when increases to its minimum alcohol pricing had little to no effect on problem drinkers (while increasing the costs for everyone else). See Minimum Pricing, Miserable Results.

The reality is that simple solutions to complex problems rarely work … and that if you want to actually reduce alcohol-related harms, you should target the people who are drinking too much … not those who are drinking wine in moderation with dinner.  

In terms of the other group of academics, I also don’t believe that most of them are truly neutral. Decades of scientific analysis has shown that moderate alcohol consumption is either fine or confers some small health benefits. Some recent studies have argued that the earlier work was wrong and that there is “no safe level” of alcohol consumption. However, the science behind such a change in conclusions is dubious at best and probably wrong. See Has the WHO lost its way regarding alcohol? 

Many of the proponents of these claims have built careers on anti-alcohol advocacy and are enjoying a moment in the sun, supported by unquestioning media. I believe that it is appropriate to question whether someone who gains all or nearly all of their income from anti-alcohol research is ideologically biased. Some of these folks also have long established connections and working relationships with avowed temperance organizations such as Movendi (formerly the International Order of Good Templars) which requires a lifetime pledge of abstinence to be a member. It’s a bit like asking your vegan cousin to organize the food choices for the family picnic … don’t be surprised when there are no meat options.

Reputable studies and institutions continue to publish studies that provide balanced analysis and continue to show certain benefits from moderate consumption. These are reviewed nicely in this excellent article by Dr. Laura Catena, a physician who is also a winemaker. There is also a good analysis by Dr. Ken Mukamal from Harvard here: Is Alcohol Good or Bad for You? Yes. As such, I recommend being careful who you listen to on these issues – and consider tuning out if you suspect that the “scientist” is someone who is motivated by anti-alcohol bias and/or is someone whose career has been defined by that type of work.

Who should you trust? An accomplished researcher from Harvard and an experienced physician? Or a social science professor with a long history of anti-alcohol work? I know who has my trust and confidence. As a result, I will continue to drink wine in moderation, as I have for the past few decades and as civilized society has for thousands of years.

Reason #1 is here: Only Pay Attention to Good Science

Reason #3 is here: Make Your Own Choices

There continues to be a great deal of media coverage of anti-alcohol advocates who claim that there is “no safe level” of alcohol consumption. This series of blog posts provides 3 reasons why I will continue to ignore these assertions.

Reason #1 – Only Pay Attention to Good Science

I studied the history and philosophy of science as an undergraduate. While I have great respect for scientists and their accomplishments over the centuries, I am also keenly aware of what can go wrong. Science often has an aura of both truth and infallibility, which is perpetuated by the media. In reality, science and its conclusions are only as good as the scientific method that is used for any particular analysis. Unfortunately, some science is either poorly done or extremely difficult to do … and the conclusions are often dubious or incorrect. 

The science behind the “no safe level” alcohol claims is part of a branch of science known as “nutritional epidemiology”. It is based on observations of the lifestyles and health of people which are almost always compiled from questionnaires (i.e. data which can be inherently unreliable due to inaccurate responses and/or bias). This branch of science has serious structural issues which should prevent sweeping conclusions or, at the very least, any conclusions should be subject to extensive caveats and warnings. 

John Ioannidis is a professor at Stanford University and an acknowledged expert on the validity of scientific studies and conclusions. In 2018, he wrote that “the emerging picture of nutritional epidemiology is difficult to reconcile with good scientific principles. The field needs radical reform.” There is a good analysis of the overarching problems in this book by Stuart Ritchie: Science Fictions: How Fraud, Bias, Negligence and Hype Undermine the Search for Truth (at p.164 onward). And there is more specific analysis regarding the “no safe level” claim in this fine article by David Morrison: Has the WHO lost its way regarding alcohol?  

For further background on the science related to alcohol and health, you might want to take a look at these recent books: The Very Good News About Wine by Tony Edwards and Wine & Health by Richard Baxter, MD.

At a most basic level, and after carefully looking at all the evidence, I do not believe that there is any reliable scientific evidence that the moderate consumption of alcohol poses any significant risk to most individuals … and I am strongly of the view that the “no safe level” conclusion has almost zero scientific merit. As such, I will continue to drink wine in moderation, as I have for the past few decades and as civilized society has for thousands of years.

Reason #2 – Don’t Listen to Biased Sources

Reason #3 is here: Make Your Own Choices