Reminder to Liquor Primary and Food Primary Licensees: Off-Site Alcohol Sales Must be made with Purchase of a Meal

Dear ABLE BC Members and Industry Colleagues,

Last year, ABLE BC, the BCRFA, and other partner associations advocated for LP and FP licensees to be able to sell liquor for offsite consumption with the purchase of a meal. The Liquor Control and Licensing Regulation Branch (LCRB) granted this authorization on October 29, 2022 with Policy Directive 21-21.

We have heard concerning reports that during recent inspections to test licensee compliance, every establishment inspected by the LCRB sold single-serving drinks without any food at all.

The disregard for this policy is deeply troubling to ABLE BC. We fought hard to find ways for LP and FP licensees to have realistic options to recover from the pandemic, and we want to ensure that this new revenue stream remains in place.

If non-compliance continues, it is possible that the LCRB will make a recommendation to government that this permission be removed. We expect industry to respect this policy and immediately stop the sale of offsite liquor without food.

For clarity, if you are selling liquor for takeout or delivery, it must be sold with a meal. This authorization is not intended to allow LP and FP licensees to operate like liquor stores, but rather to have an additional revenue stream and offer more options to customers.

The LCRB has not defined what constitutes a meal. This has been intentional, to provide licensees with flexibility while expecting that they operate in good faith.

To help establishments be compliant, the LCRB offers this guidance:

  • If the order includes liquor, the focus of the transaction or order should be the food.

  • Consider what is commonly understood to be a meal. Cheese and crackers, chips, or a plate of French fries is not a meal. 

  • Refer to your own menu and how you’ve categorized food options for your patrons. For example, meals are not found in the ‘appetizer’ section of a menu, so one appetizer does not satisfy the requirement. However, it is not uncommon for someone to order two or more appetizers to make a meal. That would satisfy the requirement. For establishments that do not define their menu items in this way, use the first two considerations.  

At the end of the day, it is the responsibility of the licensee to ensure staff are only selling liquor for off-site consumption in conjunction with the sale of a meal. Staff need to be prepared to demonstrate to a liquor inspector how they are meeting this requirement. 

If you have questions about this policy, please contact ABLE BC's Executive Director Jeff Guignard at jeff@ablebc.ca.

Ann Brydle