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Publication - Consultation analysis

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

Published
17 June 2025
From
Minister for Public Health and Women's Health
Directorate
Population Health Directorate
Topic
Business, industry and innovation, Economy, Health and social care
ISBN
9781836910893

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.

Consultation

View supporting documents Supporting documents

Appendix 1 – Tables

The table below shows the number of responses to each question by respondent type. It is worth noting that this is the aggregate response, across both closed and open elements where applicable (e.g., Question 1). Some respondents may have only responded to one element of the question which explains any discrepancies between the figures in this table, and the figures in the subsequent individual question tables.

Table A: Number of responses to each question by respondent type (Number)
Individual Industry Non-industry Total
Question 1 270 29 38 337
Question 2 269 28 38 335
Question 3* 171 22 37 230
Question 4** 268 29 38 335
Question 5 268 30 37 335
Question 6* 205 24 35 264
Question 7 261 29 38 328
Question 8 263 31 39 333
Question 9* 165 28 35 228
Question 10** 265 30 36 331
Question 11 264 23 35 322
Question 12 261 25 35 321
Question 13* 79 19 26 124
Question 14** 256 26 36 318
Question 15 252 25 36 313
Question 16* 72 18 27 117
Question 17 253 28 37 318
Question 18 250 26 35 311
Question 19 250 22 37 309
Question 20 248 27 35 310
Question 21* 60 19 21 100
Question 22 246 25 36 307
Question 23 245 26 33 304
Question 24* 63 10 16 89
Question 25 256 28 36 320
Question 26 256 28 34 318
Question 27** 258 30 38 326
Question 28* 205 25 39 269

Notes

  • * These questions only comprised an open element
  • ** These questions comprised multiple closed questions and an open element

Question 1

Table A1: Do you agree with the proposal to be consistent with the category descriptors set out in Schedule 1 of the UK Government regulations for England? (Consultation question 1)
Individual Industry Non-industry Total
No. % No. % No. % No. %
Yes 88 33% 28 100% 28 74% 144 43%
No 165 62% - - 8 21% 173 52%
Don’t know 15 6% - - 2 5% 17 5%
Total 268 100% 28 100% 38 100% 334 100%

There were 334 responses (268 from individuals, 28 from industry and 38 non-industry respondents).

  • All (100%) of these industry respondents and three-quarters (74%) of the non-industry respondents said they agreed, while just a third (33%) of the individuals agreed.
  • Around a fifth (21%) of the non-industry respondents and nearly two-thirds (62%) of the individuals disagreed with the proposal – as noted in the introduction, however, for individuals this tended to reflect a disagreement with the proposals overall rather than a specific concern with this element of the legislation.

Question 2

Table A2: Do the food category descriptors set out in Schedule 1 (and included in Annex D of the consultation paper) sufficiently describe the food categories within scope of regulations? (Consultation question 2)
Individual Industry Non-industry Total
No. % No. % No. % No. %
Yes 142 53% 25 93% 25 68% 192 58%
No 83 31% 2 7% 10 27% 95 29%
Don’t know 43 16% - - 2 5% 45 14%
Total 268 100% 27 100% 37 100% 332 100%

There were 332 responses to this question (268 from individuals, 27 from industry and 37 from non-industry).

  • Most (93%) of the industry respondents, two-thirds (68%) of the non-industry respondents and half of the individual (53%) said they agreed with the descriptions.
  • Just 7% of industry respondents, together with around a quarter of non-industry (27%) and a third (31%) of individuals, disagreed.

Question 4

Table A3: Q4. Is the proposed description of the following sufficiently clear for the purpose of implementation and enforcement: first for Multibuys, second for Extra free? (Consultation question 4)
Individual Industry Non-industry Total
a. Multibuy No. % No. % No. % No. %
Yes 177 67% 25 96% 34 92% 236 72%
No 74 28% - - 1 3% 75 23%
Don’t know 13 5% 1 4% 2 5% 16 5%
Total 264 100% 26 100% 37 100% 327 100%
b. Extra free No. % No. % No. % No. %
Yes 170 65% 26 96% 22 59% 218 67%
No 77 29% - - 11 30% 88 27%
Don’t know 16 6% 1 4% 4 11% 21 6%
Total 263 100% 27 100% 37 100% 327 100%

There were 327 responses to Question 4. To the multibuy element of this question, 264 responses were from individuals, 26 were from industry respondents, and 37 were from non-industry respondents. To the extra-free element of this question, 263 responses were from individuals, 27 were from industry respondents, and 37 were from non-industry respondents.

  • For multi-buy, almost all (96%) of the industry respondents, the vast majority (92%) of the non-industry respondents, and two-thirds (67%) of the individuals said the proposed description was clear.
  • Most of these respondents also considered the extra-free sufficiently clear: 96% of industry respondents, 59% of non-industry respondents and 65% of individuals.

Question 5

Table A4: Is the proposed timescale of 12 months sufficient to allow price promotions on packaging to be phased out? (Consultation question 5)
Individual Industry Non-industry Total
No. % No. % No. % No. %
Yes 63 24% 10 40% 25 68% 98 30%
No 168 63% 10 40% 3 8% 181 55%
Don’t know 34 13% 5 20% 9 24% 48 15%
Total 265 100% 25 100% 37 100% 327 100%

There were 327 responses to Question 5 (265 individuals, 25 industry and 37 non-industry).

  • Industry respondents to this question were evenly split, with 40% saying the timescale is sufficient and 40% saying it isn’t (with 20% unsure).
  • Non-industry respondents tended to say the timescale is adequate (68%), with 8% saying the timescale is insufficient and around a quarter (24%) unsure.
  • Individuals tended to say the timescale was not sufficient (63%) with a quarter (24%) saying the timescale was sufficient and 13% unsure.

Question 7

Table A5: If meal deals are included within scope of the policy, which would be your preferred option for targeting them? (Consultation question 7)

There are three options:

Option 1 - Meal deals cannot contain HFSS targeted foods.

Option 2 - Meal deals can contain up to one HFSS targeted food.

Option 3 - Meal deals cannot contain targeted HFSS discretionary foods.

Individual Industry Non-industry Total
No. % No. % No. % No. %
Option 1 30 16% 2 13% 17 52% 49 21%
Option 2 129 70% 12 75% 2 6% 143 61%
Option 3 25 14% 1 6% 14 42% 40 17%
Don’t know - - 1 6% - - 1 0%
Total 184 100% 16 100% 33 100% 233 100%

There were 233 responses to Question 7 (184 individuals, 16 industry and 33 non-industry).

  • Of those that selected one of the options, Option 2 (meal deals can contain up to one HFSS targeted food) was the preferred option for both the industry respondents (selected by 75%) and individuals (selected by 70%). Less than one in 10 (6%) of non-industry respondents selected this option.
  • Non-industry respondents were fairly split between Option 1 (meal deals cannot contain HFSS targeted foods), selected by 52%, and Option 3 (meal deals cannot contain targeted HFSS discretionary foods), selected by 42%. Neither of these options were popular with industry respondents: 6% selected Option 3 and 13% selected Option 1 (one and two respondents respectively).

Question 8

Table A6: If temporary price reductions (TPRs) are included within scope of the policy, is the proposed broad definition sufficient for implementation and enforcement? (Consultation question 8)
Individual Industry Non-industry Total
No. % No. % No. % No. %
Yes 88 34% 6 23% 27 77% 121 38%
No 114 45% 17 65% 1 3% 132 42%
Don’t know 54 21% 3 12% 7 20% 64 20%
Total 256 100% 26 100% 35 100% 317 100%

There were 317 responses to Question 8 (256 individuals, 26 industry and 35 non-industry).

  • Industry respondents generally considered the definition was not sufficient (65% vs 23% who thought it was).
  • Most (77%) non-industry respondents said they thought the definition was sufficient, with just 3% saying it wasn’t.
  • Individuals were more evenly split: 45% saying it wasn’t and 34% saying it was.

Question 10

Table A7: Are the proposed descriptions of the following prominent in-store locations sufficiently clear for implementation and enforcement: checkouts, end of aisle, store entrances, covered external areas and free-standing displays? (Consultation question 10)
Individual Industry Non-industry Total
Checkout No. % No. % No. % No. %
Yes 157 62% 20 83% 22 61% 199 63%
No 77 30% 2 8% 11 31% 90 29%
Don’t know 21 8% 2 8% 3 8% 26 8%
Total 255 100% 24 100% 36 100% 315 100%
End of aisle No. % No. % No. % No. %
Yes 152 61% 15 65% 29 81% 196 63%
No 78 31% 4 17% 3 8% 85 27%
Don’t know 21 8% 4 17% 4 11% 29 9%
Total 251 100% 23 100% 36 100% 310 100%
Store entrances No. % No. % No. % No. %
Yes 152 60% 16 70% 27 77% 195 63%
No 78 31% 4 17% 4 11% 86 28%
Don’t know 23 9% 3 13% 4 11% 30 10%
Total 253 100% 23 100% 35 100% 311 100%
Covered external area No. % No. % No. % No. %
Yes 147 59% 20 87% 22 63% 189 61%
No 78 31% 1 4% 2 6% 81 26%
Don’t know 25 10% 2 9% 11 31% 38 12%
Total 250 100% 23 100% 35 100% 308 100%
Free standing displays No. % No. % No. % No. %
Yes 152 60% 5 21% 29 85% 186 60%
No 77 31% 16 67% 2 6% 95 31%
Don’t know 23 9% 3 13% 6 3% 29 9%
Total 252 100% 24 100% 34 100% 310 100%

There were between 308 and 315 responses to each of the parts of Question 10 (from between 250 and 255 individuals, 23 and 24 industry respondents, and 34 and 36 non-industry respondents). Generally, respondents in all three categories considered the descriptions to be sufficiently clear.

  • Industry respondents were especially likely to consider the descriptions for checkouts (83%) and covered external areas (87%) to be clear. Notably just one fifth (21%) considered the description of free-standing displays to be clear, while two-thirds (67%) said it was not clear.
  • At least three-fifths (>60%) of non-industry respondents said each of the location descriptions were clear, this rose to four-fifths for those relating to end of aisle (81%) and free-standing displays (85%).
  • Views from individuals were broadly constant across all the locations: around three-fifths (c.60%) said they felt the descriptions were clear and three in ten (c.30%) said they were not.

Question 11

Table A8: Do you agree with the proposed approach to applying store entrance criteria to dedicated food areas within stores? (Consultation question 11)
Individual Industry Non-industry Total
No. % No. % No. % No. %
Yes 56 21% 9 45% 29 85% 94 30%
No 176 67% 4 20% 1 3% 181 57%
Don’t know 29 11% 7 35% 4 12% 40 13%
Total 261 100% 20 100% 34 100% 315 100%

There were 315 responses to Question 11 (261 individuals, 20 industry and 34 non-industry).

  • Just under half (45%) of industry respondents agreed with the proposed approach, while a third (35%) said they didn’t know and a fifth (20%) did not agree.
  • Most (85%) non-industry respondents said they agreed with the approach, while around one in ten (12%) didn’t know.
  • Most (67%) individuals did not agree, while around a fifth (21%) agreed and around one in ten (11%) didn’t know.

Question 12

Table A9: Do you agree with the proposed description for relevant floor area? Consultation question 12)
Individual Industry Non-industry Total
No. % No. % No. % No. %
Yes 70 27% 12 63% 30 86% 112 36%
No 149 58% 5 26% 2 6% 156 50%
Don’t know 40 15% 2 11% 3 9% 45 14%
Total 259 100% 19 100% 35 100% 313 100%

There were 313 responses to Question 12 (259 individuals, 19 industry and 35 non-industry).

  • Around two-thirds (63%) of these industry respondents agreed with the proposed description, while a quarter (26%) said they didn’t agree and a tenth (11%) didn’t know.
  • Most (86%) non-industry respondents also said they agreed with the description, while around one in ten (9%) didn’t know.
  • Conversely, most (58%) individuals did not agree with the description, while around a quarter (27%) agreed and 15% didn’t know.

Question 14

Table A10: Are the proposed descriptions of the following online equivalent in-store locations sufficiently clear for implementation and enforcement: covering home page, favourites page, pages not opened intentionally by the consumer and checkout pages (Consultation question 14)
Individual Industry Non-industry Total
a. Home page No. % No. % No. % No. %
Yes 137 55% 19 86% 33 94% 189 61%
No 81 32% - - - - 81 26%
Don’t know 33 13% 3 14% 2 6% 38 12%
Total 251 100% 22 100% 35 100% 308 100%
b. Favourites page No. % No. % No. % No. %
Yes 128 52% 18 82% 24 67% 170 56%
No 88 35% 1 5% 10 28% 99 32%
Don’t know 32 13% 3 14% 2 6% 37 12%
Total 248 100% 22 100% 36 100% 306 100%
c. Pages not opened by consumer No. % No. % No. % No. %
Yes 127 51% 19 86% 33 94% 179 58%
No 84 34% - - - - 84 27%
Don’t know 38 15% 3 14% 2 6% 43 14%
Total 249 100% 22 100% 35 100% 306 100%
d. Checkout pages No. % No. % No. % No. %
Yes 131 53% 18 82% 32 91% 181 59%
No 83 33% 1 5% 1 3% 85 28%
Don’t know 34 14% 3 14% 2 6% 39 13%
Total 248 100% 22 100% 35 100% 305 100%

There were between 305-308 responses to the different elements of Question 14 (248-251 individuals, 22 industry and 35-36 non-industry). Generally, the respondents from all three categories considered the descriptions sufficiently clear, although as indicated below, the responses from individuals were more varied.

  • Most (82%-86%) of these industry respondents considered the descriptions for online locations clear. Around one tenth (14%) said they didn’t know.
  • Almost all (91%-94%) of non-industry respondents said the online location descriptions were clear. The exception to this was for favourites pages – just two-thirds (67%) said the description was sufficiently clear.
  • Around half (51%-55%) of individuals agreed that the online location descriptions were clear, while around a third (32%-35%) said they were not.

Question 15

Table A11: Are there any other equivalent online locations that should be within scope of the policy? (Consultation question 15)
Individual Industry Non-industry Total
No. % No. % No. % No. %
Yes 12 5% - - 24 67% 36 12%
No 163 66% 16 76% 2 6% 181 60%
Don’t know 71 29% 5 24% 10 28% 86 28%
Total 246 100% 21 100% 36 100% 303 100%

There were 303 responses to Question 15 (246 individuals, 21 industry and 36 non-industry).

  • None of the industry respondents said there were other online locations that should be included.
  • Two-thirds (67%) of the non-industry respondents and one in twenty individuals (5%) thought other online locations should be included (a total of 36 respondents).

Question 17

Table A12: Are the types of business within the scope of the policy sufficiently described for the purpose of implementation and enforcement? (Consultation question 17)
Individual Industry Non-industry Total
No. % No. % No. % No. %
Yes 105 42% 9 36% 25 69% 139 45%
No 91 36% 12 48% 5 14% 108 35%
Don’t know 55 22% 4 16% 6 17% 65 21%
Total 251 100% 25 100% 36 100% 312 100%

There were 312 responses to the closed question element of Question 17 (251 individuals, 25 industry and 36 non-industry).

  • Around one-third (36%) of these industry respondents said they agreed with the proposed description, while nearly half (48%) said they didn’t agree and 16% didn’t know.
  • Two-thirds (69%) of non-industry respondents agreed, while 14% said they didn’t, and a similar proportion (17%) didn’t know.
  • Views of individuals were mixed: around two-fifths (42%) agreed, around a third (36%) did not and a fifth (22%) didn’t know.

Question 18

Table A13: Is the proposed extension of restrictions to online sales, including through online aggregator sites and apps, sufficiently described for the purpose of implementation and enforcement? (Consultation question 18)
Individual Industry Non-industry Total
No. % No. % No. % No. %
Yes 100 41% 9 45% 22 65% 131 44%
No 86 35% 3 15% 4 12% 93 31%
Don’t know 60 24% 8 40% 8 24% 76 25%
Total 246 100% 20 100% 34 100% 300 100%

There were 300 responses to the closed question element of Question 18 (246 individuals, 20 industry and 34 non-industry).

  • Just under half (45%) of these industry respondents agreed the proposed extension of restrictions is sufficiently described, 15% disagreed, and two-fifths (40%) didn’t know.
  • Most (65%) non-industry respondents agreed, one-tenth (12%) disagreed, and a quarter (24%) didn’t know.
  • Views from individuals were mixed: two-fifths (41%) agreed, around a third (35%) disagreed, and a quarter (25%) didn’t know.

Question 19

Table A14: Are the arrangements for franchises and symbol groups sufficiently described for the purpose of implementation and enforcement? (Consultation question 19)
Individual Industry Non-industry Total
No. % No. % No. % No. %
Yes 96 39% 6 32% 28 78% 130 43%
No 90 37% 7 37% 4 11% 101 34%
Don’t know 60 24% 6 32% 4 11% 70 23%
Total 246 100% 19 100% 36 100% 301 100%

There were 301 responses to the closed question element of Question 19 (246 individuals, 19 industry and 36 non-industry).

  • Views from these industry respondents were mixed: a third (32%) agreed, a third (37%) disagreed, and a third (32%) didn’t know.
  • Most (78%) non-industry respondents agreed, while just one-tenth (11%) disagreed, and a further tenth (11%) didn’t know.
  • Views from individuals were also mixed: two-fifths (39%) agreed, a third (37%) disagreed, and a quarter (24%) didn’t know.

Question 20

Table A15: Do you foresee any impacts on the ability of businesses to trade either within the UK market or internationally from any of the proposed measures? (Consultation question 20)
Individual Industry Non-industry Total
No. % No. % No. % No. %
Yes 140 60% 14 56% 6 18% 160 55%
No 42 18% 6 24% 12 36% 60 20%
Don’t know 53 23% 5 20% 15 45% 73 25%
Total 235 100% 25 100% 33 100% 293 100%

There were 293 responses to the closed question element of Question 20 (235 individuals, 25 industry and 33 non-industry).

  • Just over half (56%) of these industry respondents said yes, while a quarter (24%) said no, and a fifth (20%) said they didn’t know.
  • Few (18%) non-industry respondents said yes, around a third (36%) said no, and nearly half (45%) didn’t know.
  • Views from individuals were similar to those of industry: most (60%) said yes, around a fifth (18%) said no, and a quarter (23%) didn’t know.

Question 22

Table A16: Are the proposed exemptions from location restrictions based on business type clear and sufficiently defined to enable implementation and enforcement? (Consultation question 22)
Individual Industry Non-industry Total
No. % No. % No. % No. %
Yes 104 43% 11 48% 24 67% 139 46%
No 89 36% 8 35% 7 19% 104 34%
Don’t know 51 21% 4 17% 5 14% 60 20%
Total 244 100% 23 100% 36 100% 303 100%

There were 303 responses to the closed element of Question 22 (244 individuals, 23 industry and 36 non-industry).

  • Just under half (48%) of these industry respondents agreed the proposed exemptions based on business type are clear and sufficiently defined, a third (35%) disagreed, and a fifth (17%) didn’t know
  • Two-thirds (67%) of non-industry respondents agreed, around a fifth (19%) disagreed, and 14% didn’t know.
  • Views from individuals were mixed: two-fifths (43%) agreed, around a third (36%) disagreed, and a fifth (21%) didn’t know.

Question 23

Table A17: Are the exemptions from location restrictions based on individual store relevant floor area clear and sufficiently defined to enable implementation and enforcement? (Consultation question 23)
Individual Industry Non-industry Total
No. % No. % No. % No. %
Yes 99 41% 14 61% 22 71% 135 45%
No 92 38% 5 22% 4 13% 101 34%
Don’t know 52 21% 4 17% 5 16% 61 21%
Total 243 100% 23 100% 31 100% 297 100%

There were 297 responses to the closed element of Question 23 (243 individuals, 23 industry and 31 non-industry).

  • Three-fifths (61%) of these industry respondents agreed the proposed exemptions based on individual store relevant floor area are clear and sufficiently defined, a fifth (22%) disagreed, and a fifth (17%) didn’t know
  • Just over two-thirds (71%) of non-industry respondents agreed, 13% disagreed, and 16% didn’t know
  • Views from individuals were mixed: two-fifths (41%) agreed, a similar proportion (38%) disagreed, and a fifth (21%) didn’t know.

Question 25

Table A18: Do you agree with the proposed use of administrative sanctions for enforcement of the policy? (Consultation
Individual Industry Non-industry Total
No. % No. % No. % No. %
Yes 42 16% 15 60% 22 67% 79 25%
No 198 78% 1 4% 4 12% 203 65%
Don’t know 15 6% 9 36% 7 21% 31 10%
Total 255 100% 25 100% 33 100% 313 100%

There were 313 responses to the closed element of Question 25 (255 individuals, 25 industry and 33 non-industry).

  • Three-fifths (60%) of these industry respondents agreed with the proposed use of administrative sanctions for enforcement of the policy, while 4% disagreed, and over a third (36%) didn’t know.
  • Two-thirds (67%) of non-industry respondents agreed, a tenth (12%) disagreed and two-fifths (21%) didn’t know.
  • Most (78%) individuals disagreed, 16% agreed and 6% said they didn’t know.

Question 26

Table A19: Do you agree with the maximum penalties proposed for the offences in relation to enforcement of the policy? (Consultation question 26)
Individual Industry Non-industry Total
No. % No. % No. % No. %
Yes 28 11% 15 58% 17 53% 60 19%
No 205 80% - 4 13% 209 67%
Don’t know 22 9% 11 42% 11 34% 44 14%
Total 255 100% 26 100% 32 100% 313 100%

There were 313 responses to the closed element of Question 26 (255 individuals, 26 industry and 32 non-industry).

  • Three-fifths (58%) of these industry respondents agreed with the maximum penalties proposed for the offences in relation to enforcement of the policy, none disagreed, and two-fifths (42%) didn’t know.
  • Just over half (53%) of non-industry respondents agreed, a tenth (13%) disagreed, and a third (34%) didn’t know.
  • Most (80%) individuals disagreed, a tenth (11%) agreed and a tenth (9%) didn’t know.

Question 27

Table A20: Is the proposed 12 month period following the introduction of regulations sufficient to prepare for implementation and enforcement? (Consultation question 27)
Individual Industry Non-industry Total
Implementation No. % No. % No. % No. %
Yes 56 22% 5 19% 25 68% 86 27%
No 176 68% 16 59% 5 14% 197 61%
Don’t know 25 10% 6 22% 7 19% 38 12%
Total 257 100% 27 100% 37 100% 321 100%
Enforcement No. % No. % No. % No. %
Yes 44 17% 5 21% 22 61% 71 23%
No 180 71% 9 38% 5 14% 194 62%
Don’t know 30 12% 10 42% 9 25% 49 16%
Total 254 100% 24 100% 36 100% 314 100%

There were 321 responses to the closed element of this question on implementation (257 from individuals, 27 from industry and 37 from non-industry) and there were 314 responses for the enforcement element (254 from individuals, 24 from industry and 36 from non-industry).

  • Just a fifth of industry respondents considered the time to prepare for implementation and enforcement sufficient (19% and 21%, respectively). Most (59%) industry respondents said that there is not enough time to prepare for implementation, while around a fifth (22%) said don’t know. Views were more mixed with respect to enforcement: two-fifths (38%) said that there is not enough time to prepare for enforcement, while two-fifths (42%) said don’t know.
  • Non-industry respondents tended to agree that there is time to prepare: 68% say there is time to prepare for implementation, and 61% regarding enforcement. In both cases, 14% said there is insufficient time, and around a fifth (19%) and a quarter (25%) respectively said they were unsure.
  • Individuals tended to say there was not enough time to prepare: 68% with respect to implementation and 71% regarding enforcement.

Contact

Email: DietPolicy@gov.scot

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