Spirits Canada strongly encourages that adults who choose to consume beverage alcohol do so responsibly. Low-Risk Drinking Guidelines (LRDGs) can be an effective guide for Canadians who choose to drink and help them evaluate their personal risk.

Canada’s current low-risk drinking guidelines were developed in 2011 and based on a comprehensive analysis of medical literature available, recommended that women consume no more than 2 drinks per day, and men no more than 3 drinks per day. The Canadian analysis of LRDGs was examined and adopted by several peer countries including the UK, the US, and Australia, and they remain in place today.

In 2020, CCSA was engaged by Health Canada to analyze the 2011 LRDGs and in August 2022, the agency released an interim draft of a meta-analysis of medical studies and constructed behavioural risks associated with the consumption of beverage alcohol. The meta-analysis was restricted to 16 out of 75 potential studies that could have been included in the study but 59 of the studies were disregarded.

The August draft drastically revised the 2011 recommendations and concluded that Canadian adults should have no more than 2 drinks per week in order to minimize the associated risks of consuming alcohol. In CCSA’s view, those consuming more than 2 drinks per week are problem drinkers.

Because this is a radical departure from the widely accepted 2011 LRDGs, prior to considering these recommendations, Spirits Canada encourages Health Canada to undertake an independent third-party review of the selective meta-analysis that was conducted by the CCSA. This would help ensure that Canadian adults who choose to consume beverage alcohol base their consumption decisions on an unbiased, thorough examination of risk factors that are individually and collectively appropriate for the Canadian public.

Spirits Canada is concerned that based on the CCSA’s draft recommendation; many Canadians who currently enjoy beverage alcohol safely will be considered to be “problem drinkers” for consuming more than two drinks a week (two drinks per week is the equivalent of 25 millilitres of spirit alcohol, or less than one teaspoon per day from Monday to Friday, but not on weekends). In any other market such consumers would be well within standard recommended guidelines for beverage alcohol.

If you would like to support the efforts of Spirits Canada, please consider sending a letter to your Member of Parliament. A suggested text can be found HERE.

40%Federal Taxes

Finance Canada implemented an automatic escalating excise tax in 2017. This tax is indexed to increases in the Consumer Price Index and automatically rises each year, without having to pass through budgetary approval in parliament. Canadian taxpayers already pay more in taxes for spirits than most consumers around the world; between 60% and 140% depending on the province. Continuing to add more tax onto distilled spirits when other substances such as cannabis enjoy a flat tax rate unjustly targets the category and sends a confusing message to consumers.

Consumers contribute a significant amount in federal excise tax through their purchases of distilled spirits on an annual basis. Spirits are taxed at a higher rate than beer or wine, even though standard drinks each contain about the same amount of alcohol. Differentiated tax rates were introduced at the end of prohibition, to encourage Canadian consumers to moderate their consumption of beverage alcohol that had higher levels of alcohol.  Studies have shown, however, (The Effect of Changes in Alcohol Tax Differentials on Alcohol Consumption, Markus Geheritz, Department of Economics, Strathclyde University), that when prices rise, consumers who choose to drink beverage alcohol switch their product choice from a more expensive to a less expensive option when prices increase, but do not actually consume less ethanol. This indicates that current excise design does not actually discourage consumption of alcohol and instead unfairly favours some categories of beverage alcohol over others.

Spirits Canada favours an equitable excise tax on beverage alcohol that does not distinguish between categories. This would allow many consumers to access and enjoy a wider variety of products, and would encourage the diversification and premiumization of products that are currently available to Canadian consumers.

Due to increasing market demand, the Canadian whisky distilling industry has launched efforts to premiumize many of their brands, and they are releasing some very special blends and single malts. This is exciting news for Canadian whisky lovers, but many of these products are only available in the US and other export markets because the tax regime and other limitations in the Canadian marketplace make these whiskies too expensive for Canadian consumers to purchase, and they only do so in limited quantities. In recognition of this highly valuable segment of the market, Canada’s fiscal policies could encourage distillers to leave their products to age for longer periods of time, and increase the local availability of these very special whiskies. States such as Kentucky have adopted a fiscal credit to encourage the premiumization of its aged bourbon, allowing producers to leave their product in barrels as inventory as long as it takes to produce these very special aged products, without being penalized for not bringing them to market.

Provincial Taxes

Spirits Canada works closely with provincial liquor boards, who are both customers and regulators of the beverage alcohol industry. Alberta, British Columbia, and Saskatchewan have opted to allow private retail stores to sell alcoholic beverages to consumers in those regions. Other provinces and territories use provincial liquor stores to distribute alcoholic beverages. In all cases, however, the wholesale purchase and distribution of beverage alcohol is managed through local liquor boards at the provincial level.

Liquor boards charge a mark-up on the price of alcohol that they sell. Similar to the federal excise tax, mark-ups differ depending on the category of beverage alcohol, and ranges depending on the province. Consumers also pay GST, HST, volume tax, bottle deposits, and an environmental tax on each bottle of alcohol that they consume.

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