Alcohol Policies in the Northern Dimension Countries - ndphs

 
Alcohol Policies in the Northern Dimension Countries - ndphs
Northern Dimension
                                            Partnership in Public Health
                                               and Social Well-being

 NDPHS Expert Group on Alcohol and Substance Abuse
                          Thematic Report

                Alcohol Policies in
        the Northern Dimension Countries

NDPHS Series No. 1/2011
Alcohol Policies in the Northern Dimension Countries - ndphs
Northern Dimension Partnership in Public
Health and Social Well-being (NDPHS)
NDPHS thematic report: Alcohol Policies

The views reflected in this paper are those of
the members of the NDPHS Expert Group on
Alcohol and Substance Abuse who have
developed it and should not, therefore, be
interpreted otherwise. If specific country data
are not available in this report, this is because
the authors were either unable to obtain it or
did not receive permission to publish this data.

Editor: Mariliis Tael, Bernt Bull, Zaza Tsere-
teli

Reference Group for the preparation of the
report:
Triinu Täht, Estonia
Matilda Wrede-Jäntti, Finland
Katariina Warpenius, Finland
Inga Liepina, Latvia
Gelena Kriveliene, Lithuania
Janusz Sierosławski, Poland
Eugenia Koshkina, Russia
Karin Nilsson Kelly, Sweden
Maria Renström, Sweden

This paper may be freely reproduced and
reprinted, provided that the source is cited.

It is also available on-line in the Papers‟
section of the NDPHS Database at
www.ndphs.org........................................

View our website at www.ndphs.org and keep
an eye on policy developments and explore the
world of the NDPHS – a partnership
committed to achieving tangible results!

Further information:

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Phone (switchboard): +46 8 440 1920
Fax: +46 8 440 1944
E-mail: secretariat@ndphs.org
Alcohol Policies in the Northern Dimension Countries - ndphs
Contents
ABBREVIATIONS .................................................................................................................... 4
1. INTRODUCTION .................................................................................................................. 5
   1.1 Background ....................................................................................................................... 5

   1.2 Alcohol consumption in Northern Dimension area .......................................................... 5

   1.3 Methodology ..................................................................................................................... 7

2. OVERVIEW OF EUROPEAN AND GLOBAL STRATEGY TO REDUCE THE
HARMFUL USE OF ALCOHOL.............................................................................................. 8
3. PROFILES ........................................................................................................................... 11
   3.1 Estonia ............................................................................................................................ 11

   3.2 Finland ............................................................................................................................ 17

   3.3 Latvia .............................................................................................................................. 23

   3.4 Lithuania ......................................................................................................................... 29

   3.5 Norway ........................................................................................................................... 37

   3.6 Poland ............................................................................................................................. 43

   3.7 Russia.............................................................................................................................. 48

   3.8 Sweden............................................................................................................................ 52

   3.9 Local interventions to prevent and reduce alcohol consumption ................................... 58

   3.10 Research and monitoring .............................................................................................. 61

   3.11 Treatment ...................................................................................................................... 63

4. CONCLUSIONS .................................................................................................................. 64
5. LIST OF REFERENCES ..................................................................................................... 65
ANNEX I.................................................................................................................................. 74
   Research and monitoring in the NDPHS partner countries .................................................. 74

   Outcomes of alcohol consumption in the NDPHS partner countries ................................... 81

   Summary of selected measures to reduce alcohol availability and drunk-driving in the
   NDPHS partner countries ..................................................................................................... 84

ANNEX II ................................................................................................................................ 85
   Questionnaire ........................................................................................................................ 85

                                                                                                                                             3
Alcohol Policies in the Northern Dimension Countries - ndphs
ABBREVIATIONS

ACL       Law on Alcohol Control
ALKO      State Alcohol Monopoly
ANDT      National Strategy for Alcohol, Illicit Drugs, Doping and Tobacco
ASA EG    Expert Group on Alcohol and Substance Abuse
BAC       blood alcohol content
CAN       Swedish Council for Information on Alcohol and Other Drugs
DTACD     Drug Tobacco and Alcohol Control Department
ECAD      European Cities Against Drugs
ESPAD     European School Survey Project on Alcohol and Other Drugs
EWA       European workplace and alcohol project
FAS       Swedish Council for working life and social research
FSRAM     Federal Service for the Regulation of the Alcohol Market
HBSC      Health Behavior of School-aged Children
IST       Interdisciplinary Specialized Treatment
ND        Northern Dimension
NDPHS     Northern Dimension Partnership in Public Health and Social Well-being
NGO       non-governmental organization
NIHD      National Institute for Health Development
PARPA     State Agency for Prevention of Alcohol Related Problems
SoRAD     Centre for Social Research on Alcohol and Drugs
STAD      Stockholm Alcohol Prevention Programme
UFAIS     Unified Federal Automated Information System
Valvira   National Supervisory Authority for Welfare and Health
VAT       Value added tax
WHO       World Health Organization

                                                                                  4
1. INTRODUCTION
This report is a thematic report on alcohol policies in the Northern Dimension Countries
within the framework activities of the Northern Dimension Partnership in Public Health and
Social Well-being (NDPHS). The countries covered in the report include Estonia, Finland,
Latvia, Lithuania, Norway, Poland, Russia and Sweden.

1.1 Background
Harmful use of alcohol, illicit drugs, tobacco and other psychoactive substances is one of the
major public health concerns within the Northern Dimension (ND) area and has severe impact
on public health systems. The burden of psychoactive substance use is enormous not only for
the affected individuals, but for the whole society.
     The mission of the NDPHS is to promote the sustainable development of the ND area by
improving people‟s health and social well-being. The Partnership aims to contribute to this
process by intensifying cooperation, assisting the Partners and Participants in capacity
building, and by enhancing the extent of coordination between international activities within
the ND area.
     NDPHS Expert Group on Alcohol and Substance Abuse (ASA EG) objective is to
promote sustainable development of comprehensive policies and actions in the entire region
to prevent and minimize harm from tobacco smoking, alcohol and drug-use to individuals,
families and society (especially children and young people).
     This report gives an overview of alcohol policies in eight countries in the ND area.
Alcohol policy can be defined as all national strategies and programmes that are directed to
influence alcohol availability, demand and consumption behavior of people. Therefore
alcohol policy consists of different fields, e.g. regulations of availability and marketing,
license system for production and sale, education policy, research and prevention. Depending
on a country, the range and strictness of measures differ widely. At the end of the report the
detailed data on outcomes of alcohol consumption in the NDPHS partner countries, and a
brief summary of selected measures (minimum age, opening hours of off-premise alcohol
sale, maximum blood alcohol content) that reduce alcohol availability and drunk-driving
(Table 18), is also available.

1.2 Alcohol consumption in Northern Dimension area

Worldwide consumption in 2005 was equal to 6.13 litres of pure alcohol consumption per
capita (age 15+). Europe has been the continent with the highest per capita alcohol
consumption levels.
     The levels of recorded alcohol consumption vary across EU, for example recorded
alcohol consumption per capita in Luxembourg was in 2005 2.5 times higher than in Malta. In
France same indicator was approximately 1.5 times higher than in Greece. Besides Nordic
countries such as Norway and Sweden that are well-known for their low consumption levels,
same trend was prevalent also in Turkey. Unrecorded consumption is by its nature difficult to
measure. In 2003–2005 the average per capita unrecorded consumption was estimated quite

                                                                                            5
low in Sweden, Romania, Poland and Hungary (approximately 4 litres). (WHO Regional
Office for Europe 2010)
     Over years alcohol consumption patterns in Europe have been divided into two: the
northern dry area, where beer consumption is relatively high due to consumption on weekends
and outside meals, and the southern, or Mediterranean, wet area, where wine is usually
consumed at meals. Dry area consists typically of Sweden, Finland and the United Kingdom
and wet areas of France and Italy. (Grant 1985; Gual, Colom 1997) In the dry context alcohol
consumption is related more to mind affection, control loose situations and possibilities of
new relationships. In the wet context alcohol has the meaning of positive and tasty liquid that
is associated with food. (Allamani et al 2000)
     Iontchev (1998) used similar approach, but divided alcohol consumption to three
different patterns: the Mediterranean pattern, the Central European pattern and the Northern
European pattern (also includes Baltic countries, Russia and Ukraine). The Central European
pattern is more oriented on beer consumption and the Northern European pattern on spirits
consumption. Last pattern is also characterized by non-daily drinking, irregular binge drinking
episodes and the acceptance of drunkenness in public.
     Based on previous described patterns, European ND area countries can be divided as
follows: the Central European pattern – Germany and Poland; the Northern European pattern
– Estonia, Finland, Iceland, Latvia, Lithuania, Norway, Russia and Sweden. According to the
data on World Health Organization‟s (WHO) Health For All Database (World Health
Organization 2011a), there are significant differences between and inside the patterns.
Recorded adult per capita consumption has increased in most of the ND area countries over
the period of 2000–2009 (Figure 1). Bigger increase of consumption has been reported in
Estonia, Lithuania and Poland. Consumption has stayed quite stable in the Nordic countries
and in Canada over the period.

Figure 1. Recorded adult per capita consumption in general population (age 15+) in Northern
Dimension area, 2000–2009. (World Health Organization 2011a)

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Comparing the overall alcohol consumption prevalence rates between men and women, and
between countries, it can be seen that the consumption pattern is quite homogeneous. Only in
Sweden the prevalence rate was much higher among men – 90%, among women it was 81%
(Figure 2). Poland and Canada are the only countries where the overall prevalence rate is
below 85%. (World Health Organization 2011a)

Figure 2. Proportion of alcohol consumers in the general population in Northern Dimension
area – Canada 2004, Estonia 2006, Germany 2006, Latvia 2007, Lithuania 2007, Finland
2007, Norway 2004, Poland 2005, Sweden 2007 (World Health Organization 2011a)*.

Globally, the highest rates of morbidity and mortality due to alcohol occur within the WHO
European Region. Curtailed life expectancy as a result of alcohol varies greatly across
Europe. Approximately 25% of the difference in life expectancy between western and eastern
European men aged 20–64 years in 2002 has been attributed to alcohol. (WHO Regional
Office for Europe 2010)

1.3 Methodology
Information presented in country profiles is derived from the questionnaire (see Annex II) that
is based on the answers from the ASA EG members. The questionnaire was developed by the
Chair and International Technical Advisor of the ASA EG. It consists of main fields that are
covered to implement an effective alcohol policy. Additional information has been gathered
from WHO‟s Health For All database, Acts, policy papers, science articles, summaries,
databases, presentations and web pages.

*No information on Poland‟s men and women alcohol consumption and Lithuanian total alcohol consumption. Russia was
not presented under this indicator.

                                                                                                                7
2. OVERVIEW OF EUROPEAN AND GLOBAL STRATEGY TO
REDUCE THE HARMFUL USE OF ALCOHOL
Harmful alcohol consumption affects public health extensively and it is considered to be one
of the main risk factors for poor health globally. Due to contribution to the global burden of
disease harmful alcohol consumption is listed as the third leading risk factor for premature
deaths and disabilities in the world. Alcohol consumption does not have effect only on those,
who drink alcohol, but also on their family members and friends and on populations that are at
particular risk from harmful use of alcohol, such as children, adolescents, women of child-
bearing age, pregnant and breastfeeding women, indigenous peoples and other minority
groups or groups with low socioeconomic status. (World Health Organization 2010)
     Reduction of harmful alcohol consumption is a good opportunity to improve health and
social well-being. However, there are considerable challenges that have to be taken into
account in global national initiatives and programmes:
    - increasing global action and international cooperation in order to support and
        complement regional and national actions;
    - ensuring intersectional action;
    - proper attention to prevention, because availability and affordability of alcoholic
        beverages are problems in many countries;
    - balancing different interests; production, distribution, marketing and sales of alcohol
        create employment and generate considerable income for economic operators and tax
        revenue for governments at different levels;
    - focusing on equity, to reduce social disparities and to disseminate new knowledge
        about harmful alcohol consumption and social inequity;
    - in case of developing alcohol-related policy interventions, it should be taken into
        account that interventions in high-income countries may not be transferrable to other
        settings; and
    - although there have been developed systems for collecting, analyzing and
        disseminating data on alcohol consumption, alcohol-related harm and policy responses
        by Member States, the WHO Secretariat, and some other stakeholders, there are still
        gaps in knowledge. (World Health Organization 2010)
The “European action plan to reduce the harmful use of alcohol 2012–2020” gives a
comprehensive overview of the problem and provides policy options proven to reduce
alcohol-related harm. Policies such as regulating alcohol pricing, targeting drunk–driving and
restricting alcohol marketing are known to be effective. The five main objectives of the plan
build on previous European plans, and align with the WHO global strategy on alcohol, to:
    - raise awareness of the magnitude and nature of the health, social and economic
         burdens due to alcohol;
    - strengthen and disseminate the knowledge base;
    - enhance capacity to manage and treat alcohol-related disorders;
    - increase mobilization of resources for concerted action; and
    - improve surveillance and advocacy. (WHO Regional Office for Europe 2011)
“The European Action Plan is closely linked to the interventions in the action plan for
implementation of the European strategy for the prevention and control of non-communicable
                                                                                            8
diseases (2012–2016) but is more detailed in its targets and action. The Action Plan is also
closely linked to the new European health policy, Health 2020, where non-communicable
diseases and the risk factors behind them are a priority for WHO during 2012–2020.” (WHO
Regional Office for Europe 2011)
     The reduction of harmful alcohol use is a way to protect populations. Effective measures
should be put into practice by countries to ensure that. Member States have a primary
responsibility for formulating, implementing, monitoring and evaluating public policies to
reduce the harmful use of alcohol. Such policies require a wide range of public health-
oriented strategies for prevention and treatment. Many decision-making authorities should be
involved in the formulation and implementation of alcohol policies. Health ministries have a
crucial role in bringing together the other ministries as a national alcohol council, comprising
senior representatives of many ministries and other partners, in order to ensure a coherent
approach to alcohol policies and a proper balance between policy goals in relation to harmful
use of alcohol and other policy goals. (World Health Organization 2010)
     According to the “Global Strategy to Reduce the Harmful Use of Alcohol” the policy
options and interventions available for national action can be grouped into 10 recommended
target areas which are:
         - leadership, awareness and commitment;
         - health services‟ response;
         - community action;
         - drunk-driving policies and countermeasures;
         - availability of alcohol;
         - marketing of alcoholic beverages;
         - pricing policies;
         - reducing the negative consequences of drinking and alcohol intoxication;
         - reducing the public health impact of illicit alcohol and informally produced
             alcohol; and
         - monitoring and surveillance. (World Health Organization 2010)
“Most Member States have taken actions to reduce alcohol-related harm, and many of them
have extensive policies in this field. This highlights the need for further actions and
cooperation at EU and national level.” (Commission of the European Communities 2006)
      “The EU Alcohol Strategy supports multi-stakeholder and multi-sector action at the EU,
Member State and local level, as well as internationally alongside the WHO. Within the EU,
the central actors are the Member States, where the major competence in alcohol policy lies.
In addition, the EU Alcohol Strategy emphasises the fundamental importance of involving all
stakeholders if widespread public health benefits are to be achieved. This is based on the
rationale that alcohol related harm is a multi-faceted problem that needs a concerted societal
response. An important early task in Strategy implementation was therefore to put in place the
appropriate structures and mechanisms through which diverse actors can meet, develop trust
and agree on actions in a co-ordinated way.” (European Commission 2009)

                                                                                              9
“Structure put in place by the Commission to implement the strategy is based on four main
pillars:
         - strengthened coordination and policy development between Member States and
            the European Union level, through the Committee on National Alcohol Policy
            and Action;
         - stimulation of concrete stakeholder-driven action on the ground, through the
            European Alcohol and Health Forum;
         - development of reliable, comparable and regularly updated data on alcohol
            consumption, drinking patterns and alcohol-related harm, as well as on common
            indicators and definitions, through the Committee on Data Collection, Indicators
            and Definitions.
         - mainstreaming the reduction of alcohol-related harm into other Community
            policies.” (European Commission 2009)
“Successful implementation of the strategy will require concerted action by Member States,
effective global governance and appropriate engagement of all relevant stakeholders. All
actions listed in the strategy are proposed to support the achievement of the five objectives.”
(World Health Organization 2010)
     As a response to the current situation with „Harmful use of alcohol in Europe“, 60% of
countries have a written national alcohol policy; 6.7% do not have a national policy but have a
subnational policy; 28.9% do not have either a national nor subnational policy in writing and
4.4% have an alcohol policy in draft form only. Of the 27 countries with national alcohol
policies, two thirds have revised their policies since 2005 and 90% were described as
multisectoral and 81% of the policies are coordinated by the health sector. In the majority of
countries surveyed, alcohol policies are formulated at the national level only, whereas
national, subnational and municipal levels carry out implementation, alone or in
combinations. (WHO Regional Office for Europe 2010)

                                                                                            10
3. PROFILES

3.1 Estonia
Total population: 1.34 million inhabitants (46% men; 54% women)*
Population 15+... years: 85%*
Population in urban areas: 69%*
* as of 25.04.2011 (Statistics Estonia 2011)

Alcohol is defined as an alcoholic beverage which means beer with an ethanol content of
more than 0.5% by volume and other liquids intended for human consumption with ethanol
content of more than 1.2% by volume (Alcohol Act 2011).

Alcohol policy
Estonia does not have a written national alcohol policy. There is a draft on it, which has been
discussed by the government, but no legal status has been given to the document.
     In September 2011 it was announced that the Ministry of Social Affairs is in charge of
developing the Green Book by the end of 2012 (Rikken 2011).
     Requirements on alcohol management, restrictions on alcoholic beverage consumption,
liability for breach of law and supervisory behest on compliance over special requirements
and restrictions are regulated by Alcohol Act, which came into force on 01.09.2002 (Alcohol
Act 2011).

Governmental control on production and sale and regulation of alcohol control
Alcohol Act (2011) regulates the production, processing, bottling, possessing, import, export
and sale of alcohol. All alcohol – produced or imported, has to be registered in Alcohol
registry, strong alcohol (over 22%) must be equipped with revenue stamp.
     In order to produce, store, sell or otherwise handle alcohol one must submit an
application for adding a corresponding notation to their registration form in the register of
economic activities (often translated as commercial register). The application can be denied
on the grounds of previous violations of Alcohol Act by the applicant. (Alcohol Act 2011)
     As of 21.07.2010 the total number of sale points (retail, wholesale, restaurants, pubs,
cafes etc.) in Estonia was 5963 (4.4 sale points per 1000 inhabitants) (Estonian Institute of
Economic Research 2010a).
     Retail trade in alcoholic beverages is prohibited on the premises and in the territories of
the following institutions: children and educational institutions, health care providers, social
welfare and custodial institutions, Defense Forces, in excise warehouses, in motor vehicles or
on peddling vehicles, from stands or at street or in market, at the location of events for
children during the time of such events. The off-premises sale of alcohol is permitted from
10:00 until 22:00. (Alcohol Act 2011)
     Local municipalities have legal right to set supplementary restrictions on alcohol outlets,
assortment and the modes of retail sales of alcohol. Some of the local municipalities have
forbidden alcohol beverages sale on the last day of April (Walpurgis Night), more precisely
from 14:00 to 10:00. The ban stands for shops, tea gardens and events that occur outside.

                                                                                             11
The minimum age to purchase, own and consume alcoholic beverages is 18. It is
prohibited to offer and sell alcohol to underage person. (Alcohol Act 2011)
     In 2007–2009 there were 32 289 registered cases of consumption or purchase of
alcoholic beverages by minors (Estonian Institute of Economic Research 2010a).
     In the interests of ensuring public order, the right of retail trade of alcoholic beverages
may be suspended until circumstances which cause the suspension cease to exist: 1) by the
Government of the Republic, throughout the state; 2) by county governors, throughout the
corresponding county; 3) by rural municipality and city governments, throughout the
administrative territories thereof or with regard to particular places of business or to one place
of business. (Alcohol Act 2011)
     For violations of alcohol act the enforcement measures consist of fines and losing the
notation in the commercial registry (the right to handle alcohol), confiscating illegal alcohol,
imprisonment (Alcohol Act 2011).
     It is prohibited to drink alcohol on streets, in stadiums, parks, public transport or in other
public places (Alcohol Act 2011).
     In 2007–2009 there were 598 cases of acquisition, possession and distribution of alcohol
which was not permitted to be handled and 61 974 cases of consumption of alcoholic
beverages in public places or appearance in public places while intoxicated (Estonian Institute
of Economic Research 2010a).

Alcohol taxation system
Alcohol taxing is regulated with Alcohol, Tobacco, Fuel and Electricity Excise Duty Act
(2010), which came into force on 01.04.2003. Alcoholic beverages are taxed with value added
tax (VAT) (20%) and excise duty. In order to secure the safety of product and to avoid tax
fraud, all alcohol is registered, strong alcohol is also marked by special tax labels.
     The rates of excise duty in Estonia and minimum rates in European Union for different
types of alcohol are presented in table 1.
Table 1. The rates of excise duty for different types of alcohol (European Commission 2011)
Product                 Unit                      Excise duty rates in     EU minimum excise
                                                  euros*                   duty rates*
Beer                    1% of ethanol content        5.43                   1.87
                        by volume in hectolitre      2.721

Fermented beverage      Hectolitre                  31.70                    0.00
or wine < 6.0%
Fermented beverage
or wine > 6.0%          Hectolitre                  73.12                    0.00

Intermediate product    Hectolitre                 156.20                   45.00
Ethyl alcohol           1.0% ethanol in          1418.00                  550.00
                        hectolitre
* as 01.07.2011; 1yearly production up to 3000hectolitre, independent small breweries, yearly
production limited to 20000 hectolitre

The comparison of the rates calculated by percentage of alcohol are presented in table 2.

                                                                                                12
Table 2. Comparison of the rates calculated by percentage of alcohol
Product             Excise rate       Excise per 1%   Average ethanol      Excise amount per
                                      of ethanol in   content of product   litre of product
                                      litre
Wine and
fermented           11.44             0.95 (wine)     12 % (wine)          11.44
beverage
(per litre)          4.96 (≤ 6.0 %)   0.99 (cider)     5% (cider)          11.44
Beer
(per 1.0% of         0.85             0.85             5%                   4.25
ethanol in litre)
Intermediate
product             24.44             1.36            18 %                 24.44
(per litre)
Ethyl alcohol
(per 1.0 % of        2.22             2.22            40 %                 88.80
ethanol in litre)

Advertising regulations
Advertising of alcohol is regulated by Advertising Act (2011). Present policy on marketing
focuses mainly on reducing the impact of marketing to minors and preventing injuries. There
is an alcohol advertising ban from 7:00 to 21:00 in television and radio. It is prohibited to
target youth directly in advertisements, there are also some restrictions on the content of
marketing of alcoholic beverages, i.e. it is not allowed to show minors in advertisements. Also
alcohol promotions in connection with activities targeting young people are banned. The
advertisement has to have a warning “Attention! It is alcohol. Alcohol might harm your
health”. For violation of advertising act a violator can be warned or fined.

Drunk driving
Legal limit of blood alcohol content (BAC) is 0.02% (Traffic Act 2011). Police carry out
random breath tests (Police and Border Guard Board 2011). Awareness campaigns are
regularly carried out by Estonian Road Administration (Estonian Road Administration
2011a). Also Estonian Road Administration and Police forces are conducting preventive
educative programmes in schools (Estonian Road Administration 2011b; Traffic Act 2011).
     Drunk driving registered by the police per 10000 inhabitants has decreased in recent
years more than two times (in 2007 133.5 and in 2009 59.0). Number of accidents involving
drunken motor vehicle drivers per 10000 inhabitants has also decreased since 2007 (3.9 in
2007, 1.8 in 2009). Altogether from 2007 until 2009 145 people were killed and 1640 injured
in alcohol-related traffic accidents. (Estonian Institute of Economic Research 2010a)

Illicit alcohol production and smuggling
The obligation to register all produced and imported alcohol, also to document any change of
location, possession or ownership of alcohol is enforced to tackle the problem of illegal

                                                                                            13
alcohol and smuggling. It is prohibited not only to produce unregistered, illegal alcohol, but
also to own or possess an appliance for the distillation of spirits. Police is responsible for
implementing these restrictions. (Alcohol Act 2011)
     The regulation on alcohol import is coherent with these of European Union and it is
implemented by Border Guard Force, Police and Border Guard Board and Tax and Custom
Administration (Alcohol Act 2011).
     Typical illegal alcohol consumers are low income inhabitants and people who live near
Russian border. People who are more price-sensitive choose often illegal alcohol instead of
legal alcohol. According to recent study, in 2010 9% of consumers still bought illegal alcohol.
During recent decade the share has been substantially decreased, for example in 1999 the
share was 28%. (Estonian Institute of Economic Research 2010b)

Alcohol consumption and outcomes

The results of the Health Behavior among School-aged Children Study (HBSC) 2009/2010
(Aasvee, Minossenko 2011) show that in Estonia the consumption prevalence differs among
adolescents – lower rates among younger ones and higher rates among older ones. It is
possible to see from figure 3 that alcohol consumption patterns are quite similar among 15-
year old boys and girls. Almost 60% of boys and 70% of girls consumed alcohol every month
or seldom. Every fifth 15-year old boy and sixth 15-year old girl consumed alcohol weekly.

Figure 3. Alcohol consumption distribution among 15-year old boys and girls, 2009/2010
(Aasvee, Minossenko 2011).
The most preferred drinks among 15-year old adolescents were beer and light alcoholic
beverages. 35% of boys consumed beer and 30% of boys and 37% of girls consumed light
alcoholic beverages at least once a month (Aasvee, Minossenko 2011).
     Among 15-year old schoolchildren, 42% of girls and 32% of boys had never been drunk
(Figure 4). About 20% of respondents had been drunk once. Almost 50% of boys and 40% of
girls had been drunk 2 or more times. (Aasvee, Minossernko 2011)

                                                                                            14
Figure 4. Drunkenness distribution among 15-year old boys and girls, 2009/2010 (Aasvee,
Minossenko 2011).
According to the Health Behavior among Estonian Adult Population 2010 study (Tekkel,
Veideman 2011), approximately 8% of 15–64-year old men and 13% of women had not
consumed alcohol in last 12 months (Figure 5). If 36% of women consumed alcohol few
times a year, then among males the rate was 13%. On the other hand compared to women,
more men consumed alcohol weekly – 14% vs. 43%.

Figure 5. Distribution of alcohol consumption in last 12 months among 16–64-year old
respondents, 2010 (Tekkel, Veideman 2011).

Consuming six or more portions of alcohol at once is considered to be hazardous for health
(one portion equals a bottle of 0.5 litre beer, glas of wine or shot of spirits). Almost 70% of
15–64-year old women had not consumed alcohol hazardously, while among men the
prevalence rate was only a bit higher than 30% (Figure 6). Approximately 25% of men
consumed alcohol hazardously at least once a week, among women the prevalence rate was
below 5%. (Tekkel, Veideman 2011)

                                                                                            15
Figure 6. Distribution of consuming six or more portions of alcohol at once among 16–64-
year old respondents, 2010 (Tekkel, Veideman 2011).

Alcohol consumption leads to different outcomes. The death rates of alcohol related diseases
decreased from 2008 to 2010 (Statistics Estonia 2011). The biggest decrease occurred among
men. For example in 2008 almost every 20th man and 5th woman out of 100 000 inhabitants
died due to mental and behavioral disorder related to alcohol consumption, in 2010 the rates
were significantly lower – 11.5 and 2.4. Accidental poisoning by alcohol and exposure to
alcohol caused 16.5 deaths per 100 000 men in 2008 and in 2010 the rate was 10.2. Among
women the death rate increased from 3.7 in 2008 to 4.2 in 2010. The death rates of diseases
partly related to alcohol consumption have increased among men and decreased among
women in case of malignant neoplasms. Cirrhosis death rate has decreased almost two times
among men, from 11.2 in 2008 to 5.8 in 2010. Among women the decrease was smaller.
Additional information is presented in Annex I in tables 10 and 11.

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3.2 Finland

Total population: 5.38 million inhabitants (49% men; 51% women)*
Population 15+... years: 84%*
Population in urban areas: 68%*
* as of 18.03.2011 (Statistics Finland)

“Alcoholic substance means a substance or product which contains more than 2.8% by
volume ethyl alcohol. Alcoholic beverage means a beverage which contains a maximum of
80% by volume ethyl alcohol.” (Alcohol Act 2009)

Alcohol policy
Finland has Alcohol Act since 1932, when it gave the country a system of alcohol control
based on a state alcohol monopoly (Österberg 1985). The Act has been renewed twice – in
1969, when Act on alcoholic beverages and medium beer came to force and in 1994, when
Finland became a member of the European Union (Österberg 1985; Karlsson 2009).
     “Alcohol Act (2009) applies to alcoholic substances, their production, importation,
exportation, sale and other delivery, use, possession and transport, as well as to advertising
alcoholic beverages. Its purpose is to prevent detrimental societal, social and health effects
caused by alcoholic substances by controlling the consumption of alcohol.”
     National Supervisory Authority for Welfare and Health (Valvira) is responsible of
implementing the Alcohol Act at regional and local level (European Commission 2010).
     Finland has a written national policy on alcohol, formally adopted by the National
Government (Ministry of Social Affairs 2004).
     The main objective of the policy is to reduce alcohol-related harm. To accomplish the
main objective there has to be reduction in alcohol induced harm to the wellbeing of children
and families, in hazardous consumption and related problems and change in the course of the
overall consumption of alcoholic beverages. The Alcohol Programme 2004–2007, that was
co-ordinated by the Ministry of Social Affairs and Health targeted to prevent and reduce
alcohol related harms by influencing consumption habits and the level of consumption.
Finnish Government decided to continue implementation of the Alcohol Programme and the
National Institute for Health and Welfare is coordinating implementation of the Alcohol
Programme 2008–2011. (Jääskeläinen et al 2010)

Governmental control on production and sale and regulation of alcohol control
 “The production license for alcoholic beverages or spirits may be granted by the Product
Control Agency to a person who is considered to have the qualifications and the reliability
required for the activity. The Product Control Agency may append to the production license
restrictions which concern the volume of the production or the alcoholic beverages to be
produced as well as lay down such conditions for the production and the storage or transport
of the alcoholic beverages produced as are necessary for the supervision. Alcoholic beverages
and spirits may be produced only on premises approved of by the Product Control Agency
where the production and storage has been arranged so as to facilitate efficient supervision.
The Product Control Agency and the State Provincial Offices keep an alcohol trade register

                                                                                           17
for processing and supervision of the license issues referred to in Alcohol Act and for
compiling alcohol statistics of the traders that have been granted a license referred to in
Alcohol Act or that have applied for such a license.” (Alcohol Act 2009)
      “Retail trade of alcoholic beverages may be carried on only in a municipality where the
municipal council has given its consent to it. Retail trade of alcoholic beverages containing a
maximum of 4.7% by volume ethyl alcohol which are prepared through fermentation, may be
carried on, besides by the State Alcohol Monopoly (ALKO), by whoever the licensing
authority has granted a retail license. Retail trade of alcoholic beverages containing more than
4.7% of alcohol can only be purchased in state monopoly stores. Licensed premises shall have
a sufficient assortment of mild alcoholic beverages and moderate-price non-alcoholic
beverages.” (Alcohol Act 2009)
      A license is required for on-premise sales of all alcoholic beverages (National
Supervisory Authority for Welfare and Health 2010). As of 2009 the total number of retail
sales in Finland was 6455 (1.2 retail sales per 1000 inhabitants). 92% of retail sales were
retail outlets which were allowed to sell alcoholic beverages with alcohol content equal or
lower than 4.7%. The total number of serving licenses in 2009 was 8352 (1.6 retail sales per
1000 inhabitants). (Jääskeläinen et al 2010)
      It is allowed to sell alcoholic beverages containing over 4.7% alcohol by volume off-
premise from 09:00–20:00 on weekdays and from 09:00–18:00 on Saturdays. Alcohol, made
by fermentation and containing below 4.7% alcohol by volume can be sold off-premise every
day 9:00–21:00. Selling alcoholic beverages containing over 4.7% alcohol by volume on
Sundays is prohibited. (Jääskeläinen et al 2010).
      „Alcoholic beverages shall not be sold in a retail shop or sales premises for alcoholic
beverages: 1) to persons who are under twenty years of age, however so that mild alcoholic
beverages may be sold to those aged eighteen and over; 2) to persons who behave disturbingly
or are clearly intoxicated, or 3) if there is reason to suspect illegal use of alcoholic beverages
or their illegal delivery or procurement for other persons.“ (Alcohol Act 2009)
      “The Product Control Agency may withdraw the production license without
compensation either for a certain period or permanently or prohibit production in a production
place, unless the prescribed provisions, regulations, restrictions or conditions are observed, or
if the license-holder is considered to no more fulfill the conditions for granting the license or
to have lost his/her reliability.” (Alcohol Act 2009)
      “The licensing authority may issue the license holder an admonition or a written warning,
set conditions necessary for the supervision of serving of alcoholic beverages or without
compensation restrict the license which it has granted by limiting the serving hours, the
serving area, the kinds of alcoholic beverages to be served, or without compensation withdraw
the license it has granted either for a certain period or permanently.” (Alcohol Act 2009)
      “It is prohibited to drink alcoholic beverages on premises for retail trade of alcoholic
beverages or in other open shops, in restaurants and other places where food and refreshments
are available to the public against payment and in apartments or other places where public
gatherings or events are arranged.” (Alcohol Act 2009)
      “Regional State Administrative Agencies supervise the licensed premises. The police
may, where maintaining public order requires so, prohibit drinking of alcoholic beverages in
public places. The owner of the premises or the organizer of the event or the doorkeeper may

                                                                                               18
not allow drinking of alcoholic beverages or serve them without license on premises.”
(Alcohol Act 2009)
     The police have the right to confiscate alcohol from under-aged people in public places.
From 2007–2009 there were approximately 280 000 cases of drunken people taken into police
custody (Jääskeläinen et al 2009; Jääskeläinen et al 2010).

Alcohol taxation system
The excise duty on alcohol and alcoholic beverages is regulated in accordance with the
provisions in the Act on Excise Duty (2010). The duty is not levied on products that have
been denatured and are not intended for ingestion.
     Alcoholic beverages are taxed at the national level with excise duties on beer, wine,
intermediate products and spirits. The excise duties for spirits and beer are calculated by
alcohol volume/weight and by beverage type for wine and intermediate products. The levels
of excise duty tax for alcoholic beverages are not adjusted for inflation. The VAT is 22%.
(Österberg, Karlsson 2003a) Table 3 presents the rates of excise duty for different types of
alcohol.

Table 3. The rates of excise duty for different types of alcohol (European Commission 2011)
Product                          Unit                Excise duty rates in   EU minimum excise
                                                     euros*                 duty rates*
Beer 0.5%–2.8%                   Per hectolitre of     2.70                  1.87
                                 alcohol of
                                 finished product
Beer >2.8%                                            26.00
                                 Per hectolitre of
                                 alcohol of
                                 finished product
                                                     Yearly production up
                                                     to1:
                                                     2000 hl – 13.00
                                                     30000 hl – 18.20
                                                     55000 hl – 20.80
                                                     100000 hl – 23.40
Fermented beverage or wine       Hectolitre          283.00                  0.00
Fermented beverage or wine
>1.2% 2.8% 5.5% 1.2% 2.8% + others)
                                 1% ethanol in       3940.00
                                 hectolitre
* as 01.07.2011; 1independent small breweries, yearly production limited to 20000 hectolitre
                                                                                            19
Advertising regulations
There are legally binding regulations on alcohol advertising at the national level. There is a
total ban on advertising for spirits and partial statutory restrictions for wine and beer
advertisements. (Alcohol Act 2009)
     It is prohibited to advertise alcohol on television before 21:00. Advertising is prohibited
in shows in cinemas where minors can attend. (Karlsson 2009)
     Alcohol advertisement supervision is conducted by Valvira together with the Regional
State Administrative Agencies (National Supervisory Authority for Welfare and Health 2011).
There are three types of penalties for advertising violations: a written order to stop, a warning
and revoking of the license (Alcohol Act 2009).

Control measures of drunk driving
The BAC limit is 0.05%. For aggravated drunk-driving it is 0.12%. BAC is measured by
breath analyzer tests and blood/urine analysis. The police perform random breath testing, and
citizens actively inform the police of suspects. The penalties for drunk driving are fines,
imprisonment and temporary backing of the driver‟s license. (Österberg, Karlsson 2003a)
     From 2007–2009 there were 35 498 cases of driving while under the influence of alcohol
or drugs. The cases per 1000 inhabitants aged 18 or over have decreased slightly from 6.6 in
2007 to 5.4 in 2009. In that period there have been altogether 2302 accidents (90% were non-
fatal injuries). (Jääskeläinen et al 2009; Jääskeläinen et al 2010)

Illicit alcohol production and smuggling
“In order to prevent illegal production of alcoholic beverages and spirits it can be laid down
by Government decree that the importers, manufacturers and traders of appliances or their
components suitable for such production shall submit a notice of that activity to the
Supervisory Authority for Welfare and Health and to keep a record of it.” (Alcohol Act 2009)
     Undocumented consumption consists of alcoholic imports by passengers, home prepa-
ration illegal distillation, smuggling, surrogates and alcohol consumed by Finns abroad. In
2009, undocumented consumption of alcohol was estimated to amount to 1.9 litres of pure
alcohol per capita. It accounted for 19% of total alcohol consumption in 2009, illegal
preparation and smuggling accounted for 3% of it. Alcohol smuggling and illegal home
preparation have been decreasing since 2004. (Jääskeläinen et al 2010)
     The penalties for illicit alcohol production are specified by Criminal code (2011), i.e.
fines and/or imprisonment.

Alcohol consumption and outcomes
According to the Adolescent Health and Lifestyle Survey 2009 (Rainio et al 2009), almost
half of the schoolchildren had consumed alcohol at age 14 (Figure 7). Among 16-year olds the
prevalence rate was almost 80% and among 18-year olds 90%. Compared to boys the rate was
slightly higher among girls. 42% of 18-year old boys and 33% of same aged girls consumed
alcohol weekly. Among 16-year olds the prevalence rate was around 15%.

                                                                                              20
Figure 7. Prevalence of alcohol consumption among 14-, 16- and 18-year old boys and girls,
2009 (Rainio et al 2009).

About 5% of 14-year old schoolchildren had been drunk at least once a month (Figure 8).
Among 16-year olds the rate was much higher – 19% among boys and 21% among girls. 36%
of girls and 43% of 18-year old boys had been drunk at least once a month.

Figure 8. Prevalence of at least once a month drunkenness among 14-, 16- and 18-year old
boys and girls, 2009 (Rainio et al 2009).

According to the Health Behavior Monitoring among the Finnish Adult Population Study
2009 (Helakorpi et al 2010), about 10% of 15–64-year old respondents had never consumed
alcohol (Figure 9). Approximately 25% of women and 20% of men consumed alcohol few
times a year. There were more weekly drinkers among men compared to women, respectively
48% and 38%.

                                                                                           21
Figure 9. Distribution of alcohol consumption among 15–64-year old respondents, 2009
(Helakorpi et al 2010).

70% of 15–64-year old women and 25% of men had never consumed six or more portions of
alcohol at once (Figure 10). Almost 25% of men and 15% of women consumed alcohol
hazardously at least once a week. (Helakorpi et al 2010)

Figure 10. Distribution of consuming six or more portions of alcohol at once among 15–64-
year old respondents, 2009 (Helakorpi et al 2010).

According to Statistics Finland (2011), alcohol related diseases and accidental poisoning by
alcohol caused about 55 deaths per 100 000 men aged 15–64 in 2007. The death rate was
approximately 4 times lower among women – 14.5. In 2009 the rate had decreased among
men and women, respectively 53.0 and 5.0. Additional information is presented in Annex I in
table 12.

                                                                                         22
3.3 Latvia
Total population: 2.21 million inhabitants (47% men; 54% women)*
Population 15+... years: 87%*
Population in urban areas: 69%*
* as of 30.05.2011 (Central Statistical Bureau of Latvia 2011)

The Latvian legislation does not provide an overall definition on what an alcoholic beverage
is. The Law on Excise Duties (2011), which was adopted on 25.11.1999, gives definition of
specific alcoholic beverages – beverages whose ethyl alcohol strength by volume exceeds
1.2% (in respect of beer – exceeds 0.5%). (Law on Excise Duties 2011)

Alcohol policy
“Programme for Reduction of Alcohol Consumption and Restriction of Alcohol Addiction for
2005–2008” (2007) was approved by the Cabinet of Ministers (Order No 40) on 19.01.2005
and it was the national document on alcohol policy in the country in 2005–2008.
     Until 2010 the alcohol policy in the country was also regulated by the “Public Health
Strategy for 2001–2010” (2001) and its Implementation Programme for 2004–2010 (both
approved by the Cabinet of Ministers) where the target No 12 of the policy document aimed
to decrease the harm caused by alcohol, illicit drugs, psychoactive substances and tobacco.
     The Ministry of Health has developed a new policy document – “Public Health Strategy
for 2011–2017” (2011), which was approved by the Cabinet of Ministers on 05.10.2011. The
Public Health Strategy plans to prepare a new action Plan for Reduction of Alcohol
Consumption and Restriction of Alcohol Addiction for 2012–2014. The goal of the plan will
be to reduce alcohol consumption per capita and to restrict the harmful effect caused by
alcohol to the individual and to society at large. The goal will be achieved by implementing 4
objectives: 1) reduction of inquiry of alcoholic beverages; 2) reduction of supply of alcoholic
beverages; 3) reduction of hazardous and harmful alcohol consumption; 4) maintenance of
alcohol consumption and alcohol-related harm information system.

Governmental control on production and sale and regulation of alcohol control
Handling of Alcoholic Beverages Law (2010), which came into force on 22.04.2004,
regulates “any activities with alcoholic beverages (preparation for processing, processing,
production, filling in packaging (pre-packaging), labeling, storage, loading, disembarkation,
transfer, transportation, importation, exportation, distribution, purchase, marketing,
elimination and similar), as well as the advertising of alcoholic beverages.”
     “A special permit (licence)” is “necessary for wholesale trade in alcoholic beverages and
retail trade in alcoholic beverages. If retail traders of alcoholic beverages sell only beer, a
license for retail trade in beer is necessary for them. Any type of license is issued by the
licensing commission of the State Revenue Service for an indefinite period.” (Handling of
Alcoholic Beverages Law 2010)

                                                                                            23
According to the Handling of Alcoholic Beverages Law (2010) the retail trade of alcoholic
beverages is prohibited:
    on the premises and territory of educational institutions and medical treatment
       institutions, the police, armed forces and other military bodies;
    in booths;
    in kiosks that have no sales rooms, as well as on premises that have not been put into
       exploitation;
    on premises where a sales room is smaller than 20m2 (the prohibition specified in does
       not apply to retail trade in industrially produced alcoholic beverages in which the
       amount of absolute alcohol does not exceed 6% by volume and which are intended for
       off-premises consumption, as well as to such retail trade in self-produced wines,
       fermented beverages or other alcoholic beverages which is performed by the merchant
       specified in Handling of Alcoholic Beverages Law);
    at a sales point which is situated in an apartment building, if the common stairs or
       premises shall be utilized for the entrance to such sales point;
    from 22:00 to 8:00, except such retail trade points in which alcoholic beverages are
       sold on tap and the consumption thereof is ensured on the spot, as well as duty-free
       shops;
    in automatic vending machines;
    from vehicles, except specialized mobile shops.
It is prohibited to sell alcoholic beverages to persons under 18 years. “It is prohibited to offer
alcoholic beverages free of charge (except the tasting thereof), as a gift or as compensation for
the purchase of other goods or for the receipt of services.” (Handling of Alcoholic Beverages
Law 2010)
      “Persons who are dealing with the acceptance (purchase) of packaging are prohibited to
receive (purchase), store and carry out other activities with glass, plastic and other kinds of
packaging of alcoholic beverages, from which the excise duty stamp has not been disposed of,
as well as to perform activities with it.” (Handling of Alcoholic Beverages Law 2004)
      The responsibility for violation of the law related to excise duty and taxes is stipulated by
Law on Excise Duties (2011) and Law on Taxes and Fees (2011). The State Revenue Service
is responsible for controlling the implementation and compliance with the law.
      Penalties for illegal circulation of alcohol are defined by the Law on Latvian
Administrative Violations Code (2011) and the Criminal Law (2011).

Alcohol taxation system
Alcoholic beverages are taxed with VAT (22%) and excise duty. Excise tax for alcoholic
beverages in Latvia is a subject of the Law on Excise Duties (2011) which defines tax rates of
alcoholic beverages, excise tax labels and labeling, licensing, terms of tax calculation and
payment. It is prohibited to produce, use, process, store, move and market alcoholic beverages
for which excise duty has not been paid and that have not been labeled with excise duty
stamps.
The rates of excise duty in Latvia and minimum rates in European Union for different types of
alcohol are presented in table 4, all rates are in euros (1 EUR = LVL 0.71).

                                                                                                24
Table 4. The rates of excise duty for different types of alcohol (European Commission 2011)
Product                   Unit                   Excise duty rates in    EU minimum excise
                                                 euros*                  duty rates*
Beer                      1.0% of ethanol            3.071                1.87
                          content by             (yearly production up
                          volume in hectoliter   to 10000 hl2): 1.09
Fermented beverage or     Hectolitre               63.40
wine < 6.0%
Intermediate product      Hectolitre               98.62                  45.00
15.0%
3) they may not claim that alcohol has therapeutic qualities or that it has the effect of a
stimulant or a sedative or that it helps to resolve personal problems;
4) they may not encourage immoderate consumption of alcohol or present abstinence or
moderation in the use of alcohol in a negative light;
5) they may not emphasize the alcoholic content of alcoholic beverages; and
6) they may not create the impression that the consumption of alcoholic beverages ensures
success socially or sexually.

Drunk driving
Ban on drunk driving is defined by the Road Traffic Law (2011) and the Law on Latvian
Administrative Violations Code (2011). To ensure safe road traffic and to eradicate drunk
driving, the State The police perform driver controls by determination of the level of alcohol
in the drivers expiration. These controls are performed on a regular basis by traffic raids and
they are intensified during holidays. (Road Traffic Law 2011)
     According to the Road Traffic Law (2011), the legal blood alcohol concentration and the
air exhaled by the driver can not exceed 0.05%; for drivers with driving experience under 2
years it can not exceed 0.02%. Breath tests are carried out by the State Police and the State
Border Guard (on the State border) or if a driver is delivered to the medical authority for the
performance of such a test, if there is a cause for suspicion, that the driver is under the
influence of alcohol, but it is not possible to perform the test of the exhaled air or a driver
does not agree with the results thereof. The Ministry of Interior is in charge of control
measures for vehicle drivers.
     From 2001 until 2006 the number of alcohol related traffic accidents has decreased from
2341 accidents in 2001 to 1247 in 2006 (Koroleva 2008a).

Illicit alcohol production and smuggling
“Alcoholic beverages which do not comply with mandatory harmlessness and quality
requirements or have been produced illegally or imported illegally, are considered as
dangerous to human health and life.” (Handling of Alcoholic Beverages Law 2010)
     “In case of the illegal manufacture (production), storage or transport of illegal alcoholic
beverages – a fine shall be imposed on natural persons in an amount from LVL 250 (353
EUR) up to LVL 500 (706 EUR) or an administrative arrest shall be imposed for a period up
to 15 days, with confiscation of the alcoholic beverages and the vehicles utilized to transport
them or without the confiscation of the vehicles, but for legal persons – from LVL 1000 (1410
EUR) up to LVL 10 000 (14 100 EUR), with confiscation of the alcoholic beverages and the
vehicles used to transport them or without confiscation of the vehicles.” (Law on Latvian
Administrative Violations Code 2011)
     The action plan against smuggling was developed in 2010. Based on this plan the State
Police, Security Police, State Revenue Service Customs Department, Border Control, State
Revenue Service Excise Department, Corruption Prevention and Combating Bureau and the
State Revenue Service Finance Police Department performed various activities to restrict
smuggling of illegal alcohol. Border control and raids on illegal points of sales are intensified
and adjustments of the relevant jurisdiction are performed to restrict circulation of illegal

                                                                                              26
alcohol and smuggling. Institutions involved in interdiction of contraband are informing the
society on the harm caused by alcohol use with help of the media. (Vilks 2011)

Alcohol consumption and outcomes
According to the unpublished HBSC Latvia 2009/2010 results, approximately 16% of 15-year
old boys and 12% of 15-year old girls had never consumed alcohol. Almost 70% of 15-year
old girls consumed alcohol every month or seldom, compared to boys 56% (Figure 11). The
prevalence rate was also higher among boys, when it came to weekly drinking, 22% vs. 19%,
and daily drinking 6% vs. 1%.

Figure 11. Alcohol consumption distribution among 15-year old boys and girls, 2009/2010.
The most preferrable drinks among Latvian adolescents were beer and alcopops. 42% of girls
and 29% of boys consumed alcopops and 37% of boys consumed beer at least once a month.
    34% of 15-year old girls and 29% of same aged boys had never been drunk (Figure 12).
Almost 50% of girls had been drunk 1–3 times, the prevalence rate among boys was lower
(43%). About 20% of boys had been drunk more than ten times, compared to girls, the
prevalence rate was almost three times higher.

Figure 12. Drunkenness distribution among 15-year old boys and girls in 2009/2010.
According to the Health Behavior among Latvian Adult Population 2008 study (Pudule et al
2010), about 10% of 15–64-year old men and women had never consumed alcohol (Figure

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