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

The consultation closes on 23 September 2022. If you are unable to respond by then, please contact us and complete and send the respondent information form (see supporting documents) to Responses received up to 30 September will be accepted and included in the analysis of this consultation.

Evidence summary

Poor diet and over consumption of high fat, sugar and salt food

44. Improving the nation's diet and promoting healthy weight is important to improve people's overall health and reduce the risk of diet and weight-related ill health.

45. The association between poor diet, excess weight and health outcomes such as heart disease, type 2 diabetes and certain cancers has been established for some time. The COVID-19 pandemic has further emphasised the risks associated with being overweight. Evidence indicates excess weight is associated with an increased risk of serious COVID-19 outcomes.

46. There is also evidence that there has been a widening of inequalities with respect to dietary health outcomes as a result of the COVID-19 pandemic. For example, recent data found that the proportion of primary 1 children at risk of overweight or obesity increased by 8.4% among children living in the most deprived areas between 2019/20 and 2020/21, compared to a 3.6% increase in the least deprived areas.

47. Approximately two out of three adults in Scotland are living with overweight or obesity, and around 30% of children are at risk of overweight (including obesity). A range of inequalities exist, for example, 70% of adults in the most deprived areas of Scotland were living with overweight or obesity, compared to 60% of adults in the least deprived areas; 22% of children in the least deprived areas are at risk of overweight or obesity compared to 35% in the most deprived areas. A higher prevalence of excess weight is also seen in some minority ethnic groups, with the health risks of obesity arising at a lower BMI in these groups.

48. The Scottish diet is too low in fruit, vegetables and fibre and too high in calories, saturated fat, salt and sugar. For example, in 2018, the average energy density of the diet in Scotland was 172 calories per 100g of food compared to the population level goal of 125 calories per 100g of food. The average intake of fruit and vegetables is around 265g per person per day compared to the dietary goal of 400g. Additionally, discretionary foods (foods not required for a healthy balanced diet, such as confectionery, sweet biscuits, savoury snacks, cakes, pastries, puddings and sugar containing soft drinks) account for around 20% of calories and fat in our diet, and more than half of free sugars[12] intake.

Challenge of the food environment and promotions activity

49. Everyone needs to eat to provide us with the energy and nutrients we need to remain healthy. Food is available all around us in shops, from takeaways, restaurants, cafes and canteens as well as online. The food environment includes all aspects of where we buy and produce food and has a key influence on our dietary choices. At present, the food environment heavily incentivises and promotes low cost foods which contribute disproportionately to energy, fat, saturated fat, free sugar and salt intakes.

50. In 2020, around 27% of the food and drink we bought from shops and supermarkets was on price promotion. The majority of these were on temporary price reductions and Y for £X style offers. In Scotland, in the out of home environment, around 9% of visits included a price promotion, the majority (6.4% of visits) being meal deals or multi-buys[13].

51. Marketing of food that contributes to unhealthy diets is persuasive. Promotions encourage us to buy more than we would otherwise have done, encouraging increased intake of calories[14],[15],[16]. This increase in calories remains even when storing purchases to consume at a later date or swapping to other brands or products is taken into account.

52. Research has also shown that less healthy food and drink is more likely to be promoted and with a greater discount or cost saving compared to 'healthier' ones. Other evidence shows that as food prices increase, shoppers adapt their behaviour by purchasing more products on promotion. This is concerning in light of the current context of the rising cost of living, including rising food prices and further underpins the need to regulate promotion of HFSS products. Addressing our exposure to promotions of unhealthy food is one way to help support diet, healthy weight and overall health improvement as part of wide ranging actions.

53. Economic modelling has estimated that removal of price promotions such as temporary price reductions, multi-buy and 'Y for £X', just on discretionary foods such as cakes, biscuits, confectionary, crisps, etc., has the potential to reduce calorie intake by 613 calories per person per week. The impact is expected to be even greater if a wider range of high fat, sugar and salt food categories is included.

54. Restricting promotions is also regarded as more effective to help reduce inequalities than other approaches such as education and reliance on individual behaviour change.



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