Official Report (Hansard)
Date: 12 June 2013
PDF version of this report (179.65 kb)
Committee for Health, Social Services and Public Safety
Tobacco Retailers Bill: Briefing from Cancer Focus Northern Ireland/Northern Ireland Chest, Heart and Stroke
The Chairperson: Do any members need to declare an interest under this agenda item?
Ms Brown: I declare an interest as a local councillor.
Ms P Bradley: I am a local councillor and vice-chair of the all-party group on heart disease and stroke, which is involved with Northern Ireland Chest, Heart and Stroke.
Mr Brady: I am chair of the all-party group on heart disease and stroke.
Mr Beggs: I declare an interest in that my father is a local councillor. Can we have clarity about whether we need to declare an interest as a member of an all-party group? I am not aware that we do.
The Chairperson: I do not know, but it is probably better that it is done and we can check it.
OK, thanks very much. We are looking at the Tobacco Retailers Bill. We are receiving presentations from a number of groups and organisations because this is legislation. We will hand straight over to you to do your presentation and then we will open the meeting for questions and comments from members.
Ms Fidelma Carter (Northern Ireland Chest Heart and Stroke): I welcome this opportunity to address the Committee on the Tobacco Retailers Bill. My name is Fidelma Carter, and I am the director of public health for Northern Ireland Chest, Heart and Stroke. I am accompanied by my colleague Neil Johnston, public affairs adviser to Northern Ireland Chest, Heart and Stroke.
Mr Gerry McElwee (Cancer Focus Northern Ireland): I am representing Cancer Focus and am head of cancer prevention. We also welcome the Bill and see it as one element of what is needed in a comprehensive strategy for tobacco control. We have campaigned on this issue for 40 years. Progress has been good but much too slow. We need this Bill to be brought forward and strengthened, along with a number of other measures, if we are to achieve by 2020 the targets in the tobacco strategy for prevalence rates.
Ms Carter: Just to set the scene, smoking is responsible for around 2,300 deaths in Northern Ireland each year. It is a major risk factor for coronary heart disease, stroke, cancer and other diseases. Around 83% of smokers started in their teens. The latest research shows that 8% of 11- to 16-year-olds are smokers and half of those purchase tobacco from newsagents and other retailers, despite legislation that makes it illegal to sell tobacco to anyone under the age of 18.
In our view, the Bill gives the Assembly the opportunity to send out the message that it is serious about tackling smoking among young people. It also addresses premature death, preventable illness and health inequalities that exist in Northern Ireland that are contributed to mainly by smoking and tobacco. Tobacco is a legal product. However, it kills at least half of its users. The Bill will help to prevent young people from taking up smoking by making it more difficult for those who are under 18 years of age to access tobacco products.
In short, it also presents an opportunity to the Assembly to redress its own past failures. The Northern Ireland Executive's Programme for Government document entitled 'Building a Better Future 2008-2011' contained a range of ambitious targets that related to health inequalities and smoking. Those targets aimed to facilitate a 50% reduction in the life expectancy differential between the most disadvantaged areas in Northern Ireland and the average; by 2011, to reduce to 21% the proportion of adults who smoke; and, by 2011, to reduce to 25% the proportion of manual workers who smoke. In an Assembly report in June 2011, it was apparent that none of the above targets was achieved. Health inequalities continue to widen.
From the beginning of devolution, from 1999 to 2010, male life expectancy increased by 2·3 years to reach 77·1 years. It is a fact that male life expectancy in the most deprived areas had a relatively small increase of 1·6 years to reach 72·6 years, which has caused the life expectancy gap to widen from 3·9 years to 4·5 years. The gap in male life expectancy between the most and the least deprived areas was 7·6 years. Again, the main contributory factor for that gap is smoking.
Over the lifetime of the Assembly, female life expectancy in Northern Ireland has risen by 1·7 years to reach 81·5 years. A similar increase occurred in the most deprived areas, which resulted in life expectancy rising to 78·9 years. Therefore, the inequality gap, despite some fluctuations, was similar in 2010 to what it was at the beginning of that period of the Assembly. The gap is 2·6 years. That was also true about the gap in female life expectancy between the most and the least deprived areas, which stood at 4·5 years. Again, there was very little movement.
In short, if you wish to begin, after all these years, to address health inequality, you must take firm action against smoking. Specifically, you must send out a strong Act and a strong message to prevent young people from taking up smoking. I want to refer to smoking targets. In 2008, the Assembly's target was, by 2011, to reduce to 21% the proportion of adults who smoke. Currently, 25% of adults smoke, as is evidenced by the most recent health and lifestyle survey. Rather than the proportion of people who smoke being reduced from 24% to 21%, it stayed static at 24%. Indeed, it has now increased to 25%. We failed to reach the target to reduce the proportion of manual workers who smoke to 25% by 2011. It is currently 31%.
The other point that I want to raise is that we currently have the Department's 10-year tobacco control strategy, which was published last year. Again, there are some aspirational targets to be reached by 2020. I will just recap them. There is a target to reduce the proportion of 11- to 16-year-old children who smoke to 3%. It is currently 8%. Where do those young people access their tobacco? There is a target to reduce the proportion of adults who smoke to 15%. It is currently 25%. There is a target to reduce the proportion of smokers among manual workers to 20%. It is currently 31%. In reality, those new targets will be missed just as the previous ones were missed unless the Assembly takes action and sends out the message of its desire to prevent and discourage young people from taking up smoking.
We have submitted evidence to the Committee. My colleague Neil would like to highlight a couple of points in the evidence that we have already submitted. We are also happy to take any questions.
Mr Neil Johnston (Northern Ireland Chest Heart and Stroke): I welcome the Department's climbdown on the issue of illicit tobacco, and I know that many members here pushed for that. I praise the Committee for bringing that about. Indeed, the Department's original position was completely illogical, and it is great that the pressure from the Committee has already forced a rethink on that issue. Sadly, that omission seems indicative of the Department's approach to the Bill in its entirety. It appears to have looked at Scottish legislation and the legislation in other jurisdictions with a view to replicating it but then, in effect, watered it down. I have sat in on and heard all the conversations about the register, and we seem to have an issue about whether it would be a local register or a central register. We are quibbling about the fact that it might cost £50,000, although I know that Jim Wells is a bit sceptical about that. In this jurisdiction, the Department spends £119 million on hospital costs associated with smoking-related illnesses, and we are quibbling about the cost of a register.
We had all the discussions about the number of offences leading to a ban. Again, it seems to be more driven by the councils' desire not to have to increase their enforcement workload rather than any desire to deal with the issue of underselling. In the run-up to introducing their similar legislation, Scotland increased the amount of spending on enforcement by £1·5 million a year the year before and in the two years after. Therefore, there was a serious desire to deal with the issue.
I want to mention briefly two other issues. With regard to our Bill, Chairperson, you drew attention to the issue of the display of notices for those who have been convicted three times and are then subject to a banning order, but that was not mentioned. To me, the simple inclusion of a similar clause in our Bill would have been a great addition. Why the Department did not include that is beyond me.
One issue that I did not put in our written evidence and which the Committee should consider — it was raised by the tobacco manufacturers last week — is proxy buying, which is included in the Scottish Bill. Basically, it would make it an offence to buy cigarettes for someone who is under the age of 18. That is not in our Bill, although it is in the Scottish Bill. The Scottish research has shown that 55% of children get their cigarettes via proxy buying. Obviously, there is a whole issue about how you would enforce that legislation. I am not in a position to make the case for how you would do that. However, you also had a good session with representatives of the retailers — the Northern Ireland Independent Retail Trade Association (NIIRTA) and the Northern Ireland Retail Consortium (NIRC). They talked very much about Challenge 25 and about challenging people. If you were to make it an offence to proxy buy, perhaps we could have discussions with the retailers to say that, when they challenge somebody about their age, perhaps they might also be able to ask them whether they realise that it is an offence to buy for children. We all see that happening. Fidelma told me this anecdote: children stand around in their uniforms outside shops and approach adults whom they do not know, and those adults go in and buy the cigarettes. If those adults were asked for their ID and somebody was to tell them that it was an offence to buy cigarettes for those under 18 years of age, perhaps they might decide not to take the risk — the unlikely risk, perhaps — for children that they do not even know. At the moment, that is not an offence, and we are not even considering making it an offence. You wonder why the Department did not read the Scottish Bill and think that that looked quite useful and should be included in the Bill. I will leave it at that for the moment.
Mr McElwee: We would have welcomed a licensing scheme similar to that in Scotland. However, I see this as a first step. If this legislation is not effective, I think that the case will be made for a licensing scheme. The organisation has campaigned on this issue of tobacco for 40 years. I campaigned way back in 1989, 1990, 1991 and 1992, and that led to the 1992 order. Unfortunately, more than 20 years later, we are still trying to mend what was not mended then. We get too few opportunities to do this, and we need to get it right.
One of the things that we asked for then was that the maximum penalty should be raised from £2,500, which was set by Lord Melchett in 1978. It was not done in 1991 or 1992, and we need to do it now because the fixed penalties tend to be a percentage of that maximum. Therefore, if you are setting the maximum at £2,500, you are going to get a fixed penalty of a couple of hundred pounds. We recommend that it goes up to around £20,000 so that we get realistic fixed penalties for people who are selling a product that is killing half of its users. It is a lethal, addictive product.
One other major point is that we need communication and a central mechanism for recording information, so that the different penalties and offences, whether for a named individual or a store, are easily accessible to all enforcement agencies, such as councils, customs or others, so that we can quickly share information and keep an eye on where enforcement should be happening.
The Chairperson: You are well aware that this is only a draft Bill and not yet legislation. Our call for evidence is to try to get it right. We have a responsibility to listen to everybody, and we are doing that. Some presentations that we have been getting have allowed us to tease out some of the issues with the Department. The Department is listening to and watching this closely as well. I do not know of any Department that wants to start a battle with its Committee if it does not need to. Hopefully, by the time that the Department comes back to us, it will have taken on board some of the points made.
When you look at what councils are saying about the banning order — and you are well aware of this because, Neil, you said that you sat in on some of the presentations from others — they estimate that around 2,500 premises sell tobacco and that councils test-purchase visit about 15% to 20% of them each year. That means, in a three year period, 45% to 60% of premises will be subject to test purchase. To me, that shows it to be highly unlikely that a shop will commit three offences in three years because, statistically, that cannot be done. So, we have been looking at amending the legislation to three offences in five years. Have you any views on that issue?
Mr Johnston: It seems counter-intuitive to leave a longer time, but the logic is sound in that an offence that is committed will hang over them for longer and there will be more chance of their being caught. We would support that. The issue here is around the level of enforcement and the number of purchases. The environmental health people made the case that they would pay more attention to shops that fall foul and would rely on intelligence, so they may be revisited more frequently. However, there is an issue about the level of enforcement and the money devoted to that. In general, we would support the idea of acting on three offences in five years. Otherwise, it is difficult to envisage how somebody would be as unfortunate, as Mr Beggs put it, to get caught. How could somebody be unlucky enough, almost, to be caught three times in three years?
The Chairperson: Again, for your information and that of Committee members, we are looking quite closely at what Dublin and even Scotland are doing and have been talking to officials from both. My view is that we should look at and pick out the best bits from legislation throughout the world, so we end up with the best legislation on whatever issue. We are not daft to the facts of what is happening in different jurisdictions as well.
Mr Gardiner: Chair, your comments touched so closely on what I was going to say that we could marry them. The Northern Ireland Local Government Association and the environmental health officers told the Committee that they believed that the Bill needed amending to include a mechanism for one easily accessible, central body to hold all the information contained on the 26 council registers, including all the information of the relevant convictions. Do you support that view?
Mr McElwee: Yes, we completely support that view. If there are to be 26 different databases, we will not get very far in enforcing legislation. We have had two goes at legislation; its enforcement and keeping track of it all have been a problem, as has commitment to enforcement. If we commit to enforcement now, we need to quickly share that information across the 26 councils and with other agencies, so that other relevant convictions, such as selling illegal or smuggled tobacco, can be shared as well. That will show us whether a business or group of businesses are a problem and where those limited numbers of inspections can be targeted. Communication among the agencies is vital. It should not be that difficult to set up a system in which those organisations can communicate convictions very quickly. It will be vital. If we do not have that system, a lot of the other things will not succeed.
Mr Gardiner: I welcome your views. That is my impression, too. Let us hope that we are successful.
Ms Maeve McLaughlin: The submission from Chest, Heart and Stroke indicated that there will be a minimum period of three months for an order. Exploring your rationale for that timeline would be useful.
Mr Johnston: The issue is if there were no display notices. If somebody gets a ban of a month and there are no display notices, it will be almost glossed over, whereas, if there are display notices and they are there for a considerable period, the public will know that that retailer has broken the law. We hope that the public will shop accordingly. I go back to the point that getting to the stage at which somebody is subject to a banning order is, sadly, as we have established, going to be quite an unusual occurrence. Somebody would have repeatedly broken the law and would have been caught three times. The sanction needs to be substantial. A ban of a matter of weeks or a month is not going to send that signal.
Ms Maeve McLaughlin: OK. Thank you.
The Committee discussed whether the maximum period should be increased from one year to three years. The environmental health officers who spoke to us were certainly in favour of that. What are your views?
Mr McElwee: Cancer Focus supports the increase in the maximum penalty from one year to three years. On the earlier question from the Chair, we also support the period in which three breaches of the law would be considered as a conviction being extended from three years to five years.
Ms Brown: Thank you for your presentation. Obviously, you are in favour of the display notice being displayed. I have heard some of the benefits, but are there any other benefits in the display of signs advising that premises are subject to a restricted order? Do you think that that would act as a good deterrent?
Mr Johnston: The display notice is, in some ways, almost a bigger deterrent than the ban. We hope that retailers will not want to have a sign in their shops saying that they have been banned for a breach of the law because it will not go down well with their customers. We are trying to bring to bear the power of public opinion as much as that of the law.
Mr McElwee: It will increase awareness among their customers, particularly the children. It will definitely increase awareness among other retailers, at least in that geographical area and perhaps further afield. We support that. We would also support the removal of tobacco products from the premises so that there would not be any inadvertent sales. That would make enforcement easier.
Ms Brown: Do you believe that signs should be required when a restricted premises order and a restricted sales order are in use?
Mr Johnston: I think so. It is very easy to blame the staff and say that it was some student who was in. At the end of the day, it is the retailer's job to make sure that the staff are trained and understand their responsibilities. He or she will suffer the consequences if the staff let him or her down.
Ms Carter: That would send out a very strong message and would prevent it from happening again.
Mr McDevitt: I noticed that Chest, Heart and Stroke's submission expressed concern that the financial penalty of £5,000 for non-registration was too low. How much do you think it should be?
Mr Johnston: That is something on which I have been trying to seek clarification. My understanding is that, in Scotland, it is £20,000.
Mr McDevitt: Do you think that £20,000 should be on the face of the Bill?
Mr Johnston: Obviously, some of these are small corner shops, but a lot of them are quite substantial convenience stores, employing large numbers of staff, and with huge turnovers. They are substantial businesses. They are not tiny, two-man operations. A lot of them are substantial businesses, as I say, and, therefore, a substantial penalty is needed to make them conform. In the unlikely event that we get to the stage of a banning order, there would need to be a fine of some magnitude.
Mr McDevitt: I understand that that is the case for a large retailer. However, £5,000 is not an insignificant sum of money. What is your specific rationale for saying that the fine should be higher than £5,000?
Mr Johnston: I was looking at what the Scots were doing. If you look at shops — and I do not want to give examples — a lot of them, as I know from my own locality, have turnovers in the millions of pounds. They are not tiny enterprises. We want to get to the stage whereby if someone is convicted three times in the five-year period, they are going to suffer a significant financial penalty. Frankly, £5,000 is something that the larger convenience stores could wear, but £20,000 is a serious dent in anyone's finances.
Mr Beggs: Thank you for your presentation. Gerry said that there has been a £1·5 million per year increase in enforcement activity in Scotland, in conjunction with the new legislation. Given the fact that so many of our young people are smoking, it is clear that we need to do something like that. My question is this: have you any sense of where our level of test purchasing is compared to that in other regions at present? Are we doing the same level of test purchasing as elsewhere, or are we giving this a light touch?
Mr Johnston: The Scots claim that they are at 20%, whereas we claim to be at 15% to 20%. However, more resource is devoted to this in Scotland. It is something that needs to be looked at. I am not aware of comparisons between what financial resources have been put into this in Northern Ireland, for example, relative to Scotland.
Mr Beggs: Do you agree that, when the new legislation is introduced, it would be an opportune time to move the whole thing up a gear and get an effective reduction in this habit, which, ultimately, results in reduced life expectancy?
Mr Johnston: I am not sure whether Gerry mentioned this, but the Department provides money for 11 or 12 tobacco enforcement officers at the moment. The rationale for those officials, which was given to the Committee, was that, as they were now freed up because the ban on smoking in public places was so well enforced or accepted, they could be devoted to other enforcement actions. However, I do not want to comment on whether that is a sufficient resource. This is a serious public health issue. Some 8% of 11- to 16-year-olds are smoking. If we want to get that down to 3%, we are probably going to have to devote more resources to this.
Mr McElwee: I agree. Having looked at the old legislation, one of the problems was enforcement. Of course, enforcement did happen in certain areas. I remember that it seemed to be higher than average particularly in the old Western Board area. The problem was that, when cases came to court, fines were very small and were not a deterrent. I remember, at that stage, which is close to 20 years ago, Liverpool and Coventry had much stricter enforcement from trading standards and much higher penalties. That had a big impact on the number of children who were able to access tobacco.
I agree that this is a great opportunity. We now have tobacco control officers in place who have very successfully implemented the smoke-free law and who, therefore, have the experience to implement the law. However, we also need the penalties to be a deterrent. The entire system needs to communicate and work together and see the rationale for imposing those penalties rather than giving people yet another slap on the wrist.
Mr Beggs: If I may, I would like to ask a final question. Neil, you mentioned that there are a number of central tobacco control officers. Would it be better if this were regulated at a local government level, where there is local knowledge and local buy-in, or do the officers who are housed centrally in the Department provide that?
Mr Johnston: We know that the officials work with the councils. Certainly, across the UK, it is a local government issue. I think that there may be a slight difficulty because, although councils in GB tend to have a bigger public health remit, our councils have not really been involved in that to date. Sadly, it is just a bit of an add-on for our councils and is not regarded as a core activity.
Ms P Bradley: Neil, in your presentation, you mentioned proxy buying, which we all know happens. When I was a teenager, all those years ago, that happened outside the shops, and we still see it happening. I know that if you go round any of the local shops where I live at 3.30 pm or 4.00 pm, you will see a group outside and others inside. Quite often, it is their friends, older brothers or sisters, or whoever. It is usually somebody they know, and so they are quite aware of what they are doing. I am 100% behind this as well, but how would you enforce it? The person committing the crime is the buyer, and the shop assistant or owner would have to have full knowledge that they are buying for someone else. How do you imagine it working? How has it worked in Scotland?
Mr Johnston: To be honest, at the moment, it is a bit of cop-out. The Department is basically saying that the primary responsibility for selling cigarettes to under-18s rests with retailers, but, as you say, if I go in and buy cigarettes, what is the retailer to do about it? He cannot even say, "Do not sell this to the kids outside", because it is not an offence. Obviously, enforcement of this sort of legislation is difficult. As I say, I think that the idea of saying to people, "It is an offence for you to go outside the shop and sell this to children", may discourage them from doing so. Enforcement would be difficult. My understanding is that three or four test purchasers are involved in trying to witness the offence and whatnot, and to get a case prosecuted.
Ms P Bradley: You said that it is in the Scottish legislation.
Mr Johnston: Proxy buying is provided for in the Scottish legislation, so it is an offence in Scotland to proxy buy.
Ms P Bradley: You could not even put a sign up in a shop to say that it is illegal to buy on behalf of someone else because the person committing the offence is the buyer, not the seller. I would love it; it is a fantastic idea, and it should be in the legislation, but I do not know how you would do it.
Mr Johnston: In Scotland, they can put up a sign that says, "It is an offence". It is not an offence here. I do not underestimate for a moment the difficulties in trying to enforce such legislation. Again, I think that this is about trying to use public opinion to say to people that it is an offence to do it. People know that they should not do it, but I feel that the issue is about trying to increase awareness that it is an offence, although, at the moment, it is not.
Mr Brady: Thanks for the presentation. In respect of the tobacco retail legislation, I am not sure how you can introduce something without dealing with the whole issue of illicit cigarettes and tobacco. The all-party group had a very good presentation from Professor Bauld on how people can copy packaging, and all that, and how it costs only 10p to 15p for 20 cigarettes.
So, although you can enforce restrictions on sales to people who are under age — you can do your best to do that — in my constituency, illicit cigarettes are sold regularly in a huge number of shops. Most are poor quality and, because of the toxins, and so on, that they contain, are probably more damaging to children or adults who smoke. Chest, Heart and Stroke is very much in favour of this being incorporated into the legislation. Can you comment on that?
Mr Johnston: Illicit cigarettes are obviously a big issue across Northern Ireland, including here in Londonderry.
Mr Brady: One of the issues that has been raised is that it is an issue for HMRC rather than the Assembly, but, surely, it is common sense that there should be cross-departmental co-operation to ensure that, if there is legislation, it is effective and not piecemeal.
Mr Johnston: Exactly. That is why the Committee is right. The Department was essentially saying that, if someone were caught selling illicit cigarettes in their shop, it would not take that into account. That was a farcical position, and, thanks to the pressure that you brought to bear on the Department, that will, hopefully, be changed. The whole subject of illicit cigarettes is a big one, because it is widespread in Northern Ireland, and in England as well. In fact, on Channel 4 last week, a retailer said that they are under constant pressure from people coming to them suggesting that they sell illicit cigarettes. In a tough economic climate, who is to say that someone who can make a bigger markup on illicit cigarettes will not do so? Obviously, this legislation deals with legitimate retailers. There are cross-cutting issues about taking illicit sales into account, but there is another whole big issue about illicit cigarettes and how to deal with that. That is a subject for another day, perhaps.
Mr Brady: Or a couple of other days.
Mr McElwee: On that, it is very important to point out that there is no such thing as a safe cigarette. All cigarettes are damaging, and we do not know whether illicit cigarettes are any more damaging. Certainly, the damage done by legal tobacco is an absolute scourge and an epidemic. It is killing 2,300 people a year, which is half of its users. So, that is one thing that we need to keep right up front.
The second point is that although there is illicit trade, it has dropped from 21% in 2000 to 9% in 2011. This is due to effective enforcement. The tobacco front agencies will always put forward the existence of the illicit trade as an argument for not enacting any legislation across a number of fronts. They use it at the time of the Budget, when we are talking about increases in duty, but we know from looking at smuggling internationally that that is not necessarily related to the price of cigarettes in those countries but more to the level of enforcement. They also use it as an argument against standardised packs, but, again, we know that it is just as easy to forge and smuggle branded packs as it is to forge standardised packs. We have had such a big drop overall because the Border Agency and HMRC have put more effort into stopping illicit tobacco. We have also seen the effects in the north-east of England and in the north-west of England of local alliances and local public information. We had some of those organisations over recently to speak to the Minister and others on these issues to show how, if you can activate community support along with all the enforcement agencies and education and health, you can have a big impact, even in areas where smoking prevalence is very high in the north-west and north-east of England. So, we should bear all this in mind when the issue of illicit tobacco is raised.
Mr Brady: From a purely common sense point of view, fewer people will smoke if they are going to have to pay £8 for 20 cigarettes rather than £3 for illicit cigarettes.
Recently, I had a meeting with Cancer Focus, and the point was made that packaging, even of legitimate cigarettes, is being aimed at women. The packaging is very attractive. All of that is targeted, but those cigarettes are still expensive. Illicit tobacco is much cheaper — there is a difference of about £4 or £5 a packet. If people do not have access to the cheaper tobacco, surely it would go some way towards discouraging them, from an economic perspective, from buying a packet of cigarettes at £7 or £8.
Mr Johnston: Illicit cigarettes are one of a wide range of issues involved in combating tobacco. There have been a lot of improvements, and I am sure that we will be back lobbying about standardised packaging before you know it. We strongly believe that that will be another angle. We know that standardised packaging makes cigarettes less attractive to young people. The Department puts quite a lot of emphasis on smoking cessation services. This is all very well, but we have to think about prevention as much as we do in trying to get people who have already started smoking to quit.
Mr Brady: As I was travelling down this morning, I was listening to an item about e-cigarettes on the radio. The discussion was on whether they should be classified as medicinal.
The Chairperson: Let us try to stick to the Bill because we could end up going down all sorts of avenues.
This has been a very useful meeting. As I said earlier, we have a duty to listen to everybody who writes to us about legislation, but that does not mean that we agree or disagree with what they say. I just want to put that on record.
The Department listens to and takes note of some of the presentations. We will go through this over the next few weeks to decide whether we as a Committee will propose amendments. In some cases, the Department will have amendments. I take on board the point that the Department has accepted the issue with HMRC. The Department would need to decide to come to us with proposed amendments before the Bill goes back to the Floor of the Assembly as part of the process of it becoming legislation.
I know that some of you travelled some distance to be here today. On behalf of the Committee, thank you very much for coming and for the paperwork that you provided.