Formal Opposition to

Summary of Opposition

I submit this formal opposition to the Sale and Supply of Alcohol Amendment Bill on the grounds that it undermines New Zealand’s cultural integrity, erodes the symbolic sanctity of key national and religious days, and prioritises commercial gain over public wellbeing. The current restrictions — in place for just 3.5 days each year — are not arbitrary; they are woven into the national calendar as rare, respectful pauses from consumption and commerce.

This Bill, under the guise of efficiency and economic rationale, risks dissolving these deliberate moments of dignity. In doing so, it disregards historical memory, community autonomy, and public health objectives.

About Sections 47 and 48

The Bill proposes to repeal sections 47 and 48 of the Sale and Supply of Alcohol Act 2012. These sections currently prohibit alcohol sales on Good Friday, Easter Sunday, and Christmas Day, and restrict them on Anzac Day until 1pm — with limited exceptions for on-licences serving meals or accommodation. These measures are not recent inventions; they reflect longstanding public consensus that certain days should prioritise remembrance, reflection, and community ahead of commercial consumption.

1. Commercial Expansion at the Expense of Cultural Meaning

Clause: Sections 5–6 (Repeal of s47 & s48 of the Sale and Supply of Alcohol Act 2012)

The repeal of alcohol sale restrictions on Anzac Day morning, Good Friday, Easter Sunday, and Christmas Day allows ordinary trading conditions to override long-standing symbolic exceptions.

Issue: These restrictions are not regulatory burdens — they are cultural boundaries.

• Anzac Day morning is a time for solemn remembrance. Allowing alcohol sales during this time risks commercialising a sacred civic ritual.
• Good Friday and Easter Sunday hold deep religious significance for many New Zealanders.
• Christmas Day is one of the few remaining days where commercial silence still echoes a shared cultural rhythm.

Removing these protections disrespects the meaning these days hold for countless communities — veterans, churchgoers, families, and civic institutions alike.

As historian Jock Phillips noted, New Zealand’s public holidays have “held the line between civic identity and consumer culture.” This Bill walks us in the opposite direction.

2. Undermining Public Health and Social Harm Reduction

Clause: Entire Bill (especially removal of s47 & s48)

The Sale and Supply of Alcohol Act 2012 was built with harm minimisation as a central pillar. Restrictions on high-risk trading days support this aim by encouraging moderation and limiting overexposure during vulnerable times.

Issue: Relaxing restrictions on these specific days sends a clear message: alcohol availability trumps caution.

• Public health agencies like the New Zealand Medical Association and Alcohol Healthwatch have long warned of increased harms during public holidays.
• Holidays are when alcohol-related injuries, family violence, and emergency service overloads are most prevalent.

This Bill, by expanding access during high-risk periods, is not neutral. It is a net negative for public safety — and a betrayal of the Act’s original spirit.

3. Disempowering Communities and Local Control

Clause: Section 4 and related repeals

By repealing s47 and s48, the Bill removes the national default restrictions and allows unrestricted trading unless explicitly limited by local alcohol policies or licensing decisions.

Issue: This removes a national baseline of respect and places an undue burden on local councils and licensing authorities, many of which lack the resources or mandate to defend these norms against commercial pressure.

As the Law Commission’s 2010 report Alcohol in Our Lives: Curbing the Harm cautioned, “local control must be meaningful, not symbolic.” Without a national standard, communities are left to fight each case piecemeal — a recipe for uneven, inequitable outcomes.

4. Worker Exploitation and the Disappearance of True Holidays

Clause: All clauses permitting unrestricted alcohol sales on designated days

This Bill creates commercial incentives for hospitality and retail businesses to remain open on all public holidays, putting pressure on already-vulnerable workers.

Issue: Many hospitality workers will feel obligated to work on days that should be spent with family, observing faith, or resting. Forcing workers to choose between income and meaning is not freedom — it is exploitation masked as modernisation.

As noted by FIRST Union and Unite, holiday deregulation without corresponding worker protections leads to increased burnout, resentment, and absenteeism.

5. Weak Rationale and Absence of Mandate

Clause: General Policy Statement

The explanatory note justifies the Bill on the basis of efficiency and economic opportunity — citing special licences for veterans and holiday demand.

Issue: These justifications are insufficient and easily addressable without dismantling the entire framework.

• Veterans’ services can be supported through targeted licence exemptions — no need to repeal s47 or s48.
• Holiday alcohol demand is not a public right, but a business convenience. Commerce should not rewrite culture.

There is no evidence of broad public support for this change. It is a commercially driven initiative disguised as bureaucratic reform.

6. A Regressive Step in Global Context

While many countries are moving toward more restrictions on alcohol sales during holidays — to protect public health, reduce harm, and respect cultural events — this Bill does the opposite. It erodes hard-won protections and presents deregulation as modernisation. In reality, it isolates New Zealand from a growing international consensus: that alcohol harm is best mitigated through meaningful, not symbolic, limits on availability.

Conclusion

This Bill does not “modernise” alcohol law — it erodes what little is left of public, civic, and sacred space in the national calendar. The 3.5 days where commerce bows to culture are not barriers to growth — they are reminders that not every moment should be for sale.

I urge Parliament to reject the Bill in its entirety. If any change is to be made, it should involve:

• Specific carve-outs for veterans’ Anzac Day services only;
• Robust public consultation including religious, cultural, and worker organisations;
• A reaffirmation of public health and harm reduction principles at the heart of the 2012 Act.

We need less intoxication — not more. We need time to remember, rest, and reconnect — not just buy and drink.
Let the 3.5 days stand. Let them mean something.

Respectfully submitted,

Ukes Baha

Public Health Advocate | Counsellor | Policy Analyst

ukesbaha.com