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Restricting promotions of food and drink high in fat, sugar or salt: consultation analysis

Independent analysis of the responses to the consultation on the detail of proposed regulations to restrict promotions of food and drink high in fat, sugar, or salt.


Overview of the response

In total 362 valid responses were received to the consultation: 348 were received via the Citizen Space and 14 by email. No campaign responses were received. Some organisations did share a model text as the basis for their responses. These texts appear to have been developed by either a single organisation or jointly by a group of organisations for use by like-minded peers.

The tables below summarise the response to the consultation.

Table 1: Consultation response
Number Percentage
Individuals 279 77%
Organisations 83 23%
Total 362 100%

A wide mix of organisations responded, including, organisations representing food/commercial bodies, food manufacturers, retailers, public sector (typically local authorities and health bodies), and third sector organisations (including charities, representative organisations and lobby groups with an interest in health and poverty). The others included academic institutions, such as universities, and professional associations (typically those representing health service staff) – none of these organisations were in the food industry.

  • To support analysis and presentation within this report, respondents have been grouped into three broad categories:
  • Individuals
  • Industry respondents: industry representative bodies, manufacturers, retailers, and out-of-home
  • Non-industry respondents: public sector, third sector, other

Overall, individuals were the most common type of respondent. Among the organisations, the most common types to respond were industry representative bodies and public sector organisations (local authorities and health bodies).

Table 2: Type of organisations
Industry Number Percentage
Industry Representative Bodies 15 18%
Manufacturer 9 11%
Retailer 9 11%
Out of Home 4 5%
Non-industry Number Percentage
Public Sector 18 22%
Third Sector 13 16%
Other* 15 18%
Total 83 100%

* ‘Other’ includes educational institutes, professional associations, religious organisations. It does not include any food industry organisations.

Table 3: Summary categories
Number Percentage
Individuals 279 77%
Industry 37 10%
Non-industry 46 13%
Total 362 100%

Typically, between 300 and 330 respondents answered questions that included a closed element, and from around 100 up to around 280 for questions that were open. In line with consultation practice, respondents were free to determine which questions they answered. Not all respondents answered the quantitative questions took the opportunity to comment if they did. Equally, some who commented did not answer the quantitative questions, thus some caution is required when interpreting the quantitative results as these do not always represent the full sample of respondents. This applies throughout the questions, see Table A in Appendix 1 for a summary of the numbers responding to the questions. The following points should be taken into account.

Number of responses to closed questions: Response levels tended to be highest at the start of the questionnaire and decline slightly towards the end of the questionnaire. This may indicate that respondents became fatigued with the questionnaire so dropped out; but is more likely a reflection of the more technical nature of the questions towards the end of the consultation paper which meant the topics were of interest or relevance to fewer respondents. Notably the response to the closed part of question 7 on meal deal options achieved the lowest response (233 compared with 300-330 for the other closed questions). This was in a different format to the other closed questions in the questionnaire and required a detailed/accurate read of the relevant section of the document to respond. This is despite a reasonably high level of interest in the topic (meal deals) from respondents more generally.

Number of responses to open questions: The number of responses to each of the comment sections (Q3, Q6, Q9, Q13, Q16, Q21, Q24, Q28) is indicative. The consultation questions were often quite specific, and respondents tended to comment thematically, rather than strictly in line with the question heading. Accordingly, the reporting has been undertaken by broad section, which enables issues and themes covered across groups of questions to be collated together.

Out-of-scope responses: The consultation was designed to explore matters relating to implementation and enforcement, however, many of the consultation responses discussed more general policy issues related to HFSS foods, to restricting HFSS foods, and the impact of restricting promotion of HFSS foods. A brief summary of the issues raised is presented under question 28 ‘other issues’. Conversely, some comments raised in question 28 may also relate to specific aspects of the regulations not covered in previous sections of the report. In this instance, we have moved this analysis to the relevant question in the main body of the report.

Responses from individuals: The vast majority of the responses were very brief and to the point, with most repeating across all questions their objection to the policy to restrict promotions as a whole as they felt that government should not interfere in their personal food choices and their opportunities to purchase cheaper food. Where responses were made to the questions asked, these have been presented in this report.

Contact

Email: DietPolicy@gov.scot

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