COVID-19: What counts as a substantial meal? How rules on pub drinking could work in Tier 2

England will head into a new tiered system of coronavirus restrictions next week, with millions living under stricter rules on drinking at hospitality venues.

On Wednesday around 32 million people will be in Tier 2, which means pubs and restaurants can only sell alcohol with a “substantial meal”.

They must stop serving by 10pm and close by 11pm.

The prime minister acknowledged the coronavirus rules would bring a “great deal of heartache and frustration” for the hospitality sector.

But what do the rules say? And how will they be enforced in the run up to Christmas?

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What counts as a substantial meal?

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The government’s advice is rather vague and open to interpretation.

According to its COVID-19 winter plan: “Venues that serve alcohol can only remain open where they operate as if they were a restaurant, which means serving substantial meals (and accompanying drinks).”

The guidelines define “substantial meals” as “a full breakfast, main lunchtime or evening meal”.

Communities Secretary Robert Jenrick also previously defined it as one “you would expect to have as a midday meal or an evening meal” – and appeared to rule out traditional pub snacks like a packet of crisps or a side of fries.

He suggested a Cornish pasty on its own would not constitute a substantial meal, unless it came on a plate, to a table, with a side of chips or salad.

He told LBC in October: “It would be like a main course, rather than, say, a packet of crisps or a plate of chips.”

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Under the old tiered system, guidance stated that “a table meal is a meal eaten by a person seated at a table, or at a counter or other structure which serves the purposes of a table”.

However, the Local Government Association (LGA) said this was “open to interpretation” and there was “a degree of flexibility”.

The LGA added: “It would be difficult to argue that a single sausage roll or a snack pork pie constitutes a main meal, whereas if it was served plated with accompaniments such as vegetables, salad, potatoes it could be considered substantial.”

Can I share a meal and still order alcohol?

The winter plan guidelines don’t offer much clarity – but it could depend on how many people are sharing it.

One household can have a meal together indoors, but the rule of six applies to those eating outdoors.

However, for the old tiered system, the LGA advised that sharing a meal among a large group probably wouldn’t meet the standard.

It said: “Whereas a platter or dishes designed to be shared could constitute a meal for a couple of people, sharing a single meal or plate of food between a group would be unlikely to be deemed a substantial meal.”

People in a pub in Liverpool, parts of the North of England are bracing themselves for the most stringent Tier 3 controls, with Merseyside expected to have its pubs, gyms and casinos closed in a bid to suppress its infection rate.
Image: Pubs in Tier 3 areas are restricted to a takeaway or delivery service

How many drinks can I order with food and how long can I drink for?

The guidelines only state that alcoholic drinks must be served with food.

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There isn’t any detail on how many drinks you can have, or if you can drink before or after eating.

Trade body Hospitality UK previously suggested it be left up to each venue to decide what was reasonable.

It said government guidance did not set out any rules on when the service of alcohol with a meal should begin and end.

How does the curfew work and can I order multiple drinks before last orders?

The previous 10pm closing time for Tiers 1 and 2 has been changed to 10pm last orders with an 11pm closing time.

But venues must still “operate as if they were a restaurant” and serve food along with drinks.

The new rules pose “more questions than answers”, Alastair Kerr, from The Campaign For Pubs, told Sky News.

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He said publicans had not received any extra guidance but there was a “resounding feeling” that the rules are “catastrophic” – particularly as pubs “rely on the December trade to survive”.

Questions also remain on how many drinks can be ordered at once, and if multiple drinks can be purchased before last orders.

Mr Kerr said landlords would “operate a common sense policy” but that the extra hour “doesn’t bring much benefit” because they have to keep the pub open and the lights on without any takings.

He said publicans would not “endorse unsociable drinking” but that some could allow a customer to order multiple drinks to help cover this cost.


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