Food (Promotion and Placement) (Scotland) Regulations 2025: island communities impact assessment

Evidence review

The regulations to restrict the location and price promotion of targeted HFSS food and non-alcoholic drinks are expected to have a positive impact across all population groups, including those in island communities. Potential differential impacts on island communities are most likely where there are differences in sales of food compared to mainland communities and were considered to potentially be:

• reduced food availability
• higher prices
• less access to dietary diversity
• greater reliance on local and traditional foods
• less frequent but larger shops per trip (i.e. bulk buying).

The above would have a differential impact if they affected consumption patterns of HFSS foods, shopping behaviours (thus exposure to promotions) and responsiveness to promotions.

There is little evidence to inform whether island communities in Scotland eat more or less HFSS or generally have different diets from mainland Scotland. The limited evidence available suggests this is not likely to be a key differential factor. Island communities are generally in better health than on the mainland, for example female healthy life expectancy in 2019-2021 was higher or no different to Scottish average (Scotland 61.1yrs; NHS Western Isles 64yrs; NHS Shetland 71.6yrs; and NHS Orkney 76.4yrs). Male life expectancy was no different between the same four areas.

A multi-national study (that included data from England and Scotland surveys) concluded that BMI tended to be marginally higher in rural populations compared to urban populations in high-income western countries, although evidence suggests that the difference is minimal. It is not expected that this policy will lead to differential impacts on island and rural communities given population level BMI averages.

Availability of food, particularly fresh food, has been one of the differences raised in relation to island communities. The regulations are not intended to or expected to affect food availability, especially of fresh food.

Due to island communities tending to make less individual shopping trips than the Scotland average, with larger purchases on average for each of these shopping trips^[1], island communities may be more likely to take advantage of multi-buy and bulk buy promotions.

During periods of adverse weather, some island communities may experience shortages of certain products. Island communities may therefore be more likely to rely on bulk purchasing of certain products to ensure access to certain foods during these periods. However, these regulations will not prevent this strategy and instead seek to shift the balance of promotions to healthier options. The policy does not restrict availability or access to food, and does not limit the promotion of healthier, non-HFSS foods.

However, economic modelling showed no difference by rural urban classification (with rural as a proxy for island) in purchasing via volume promotions^[2]. Food Standards Scotland have found that the average spend on price promotion was greater (£2.19 per kilogram) than the average spend off promotion (£1.67 per kg) in 2022. This suggests that, on average, it was more expensive to purchase food and drink on a price promotion (including temporary price reductions and volume promotions), compared to those without a promotion, with the gap widening in 2022 compared to 2019. The restrictions on promotions are therefore not expected to have a differential impact on island communities.