Calorie labelling in the out of home sector: consultation analysis

Independent analysis of the responses to the consultation on mandatory calorie labelling in the out of home sector in Scotland.

Executive Summary

1. In Spring 2022, the Scottish Government undertook a public consultation, Mandatory Calorie Labelling in the Out of Home Sector in Scotland, to gather views on its proposals to make the provision of calorie information mandatory at the point of choice in Out of Home (OOH) settings. The consultation ran from 8 April 2022 until 1 July 2022. This report presents findings from an independent analysis of the responses.

2. The consultation received 660 valid responses. Responses were submitted by 574 individuals and 86 organisations or groups. Organisational responses included public sector organisations (29%), out of home providers (21%), industry representative bodies (15%), third sector organisations (12%), manufacturers (3%) and retailers (3%). The remaining 16% of organisational responses were by organisations defined as 'other'.

3. The majority of respondents opposed the introduction of mandatory calorie labelling. Some of the prevalent cross-cutting themes across responses were as follows:

  • The policy should be avoided as it has the potential to encourage and/or compound disordered eating and associated physical and mental health risks;
  • Calorie labelling alone does not provide a sufficiently robust indication of the nutritional value of food and drink items;
  • The policy could have an insignificant or unsatisfactory impact when considering the relative costs of implementation;
  • Public health messaging may be a more effective way of tackling existing health inequalities and problems. Educating people (providers and consumers) around nutrition more generally may be worthwhile (rather than focusing on calorie content alone);
  • Mandatory calorie labelling may be particularly difficult for small and micro-businesses to implement and maintain, especially those who operate flexible/regularly changing menus;
  • Lack of staff time and lack of experience/training in nutrition may be the biggest barriers to implementation, alongside costs associated with implementation; and
  • Monitoring and regulation will be challenging and should be 'soft touch' in the early days to mitigate against businesses' fears of being penalised.
  • Regulatory alignment with England was seen as desirable.

4. Among those who were in support of the policy being introduced, the following themes cut across responses to this consultation:

  • The introduction of mandatory calorie labelling may provide consumers with transparency;
  • The availability of calorie labelling to consumers may encourage customers to make healthier choices;
  • The introduction of mandatory calorie labelling could encourage out of home food providers to alter their offer to make it healthier; and
  • Mandatory calorie labelling could maximise consumer control over the choices they make.



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