Calorie labelling in the out of home sector: consultation analysis

11. Additional Comments (Q22)

Question 22 - Please outline any other comments you wish to make on this consultation.

In total, 261 individuals and 52 organisations provided a response to question 22.

The responses to this question were largely negative with key themes related to eating disorders, business costs, mental health, perceived performative nature of the policy, etc. being reiterated. Many personal eating disorder stories were shared, with explicit begging by sufferers and their families that this policy not go ahead.

Many respondents suggested other ways to deal with obesity. These were wide ranging, but suggestions consistently raised included education on nutrition from a young age, policies targeting poverty and inequality as the root causes of obesity and efforts to make healthy food cheaper rather than unhealthy food more expensive. As in questions above, various respondents also argued that other nutritional information that could be more beneficial for consumers, such as protein and salt labelling, or for the presentation of nutritional information in more nuanced ways.

Businesses and industry representative bodies also set out their concerns in more detail in this part of the consultation. The majority of these concerns repeated themes outlined in prior sections of this consultation, such as emphasising the difficulties faced by out of home food providers as a result of the cost of living crisis and the pandemic and sentiments that this policy would only add more challenges.

A minority of organisations discussed specific implementation details if the policy is put in place. For instance a manufacturer and an industry representative body suggested that if this policy is implemented, the same 20% tolerance on calorie analysis used in England is applied in Scotland. Additionally, a third sector organisation opposed to MCL put forward that in the event the policy is implemented the impact of MCL on those with eating disorders, their families, and the development of new eating disorders should be monitored and evaluated.

A minority stated that they hoped the policy went ahead and expressed hopes that the government would not be bullied by the food industry into allowing obesity to continue.

Finally, many respondents expressed distrust with the consultation process due to the design of the consultation questions. Paragraph 4.27 discusses technical issues with question 4 which may have contributed to this. Additionally, comments on the consultation overall argued that it was excessively long and detailed making it, in the view of these respondents, deliberately inaccessible. Finally there were criticisms of the phrasing of some questions as assuming calorie labelling will go ahead.