Publication - Consultation analysis

Reducing health harms of foods high in fat, sugar, or salt: consultation analysis

Published: 13 Sep 2019

Independent analysis of the responses to the consultation on proposals to restrict the promotion and marketing of foods high in fat, sugar, or salt, and have little to no nutritional benefit.

106 page PDF

1.9 MB

106 page PDF

1.9 MB

Contents
Reducing health harms of foods high in fat, sugar, or salt: consultation analysis
Footnotes

106 page PDF

1.9 MB

Footnotes

1. Scottish Government (2018) Reducing Health Harms of Foods High in Fat, Sugar or Salt: Consultation Paper https://www.gov.scot/publications/reducing-health-harms-foods-high-fat-sugar-salt/

2. Close to three-fifths agreed with the exemption to positioning restrictions where there is no reasonable alternative; and close to two-fifths agreed with the close to expiry exemptions.

3. Including concerns about the impact of the proposals on: the elderly; ethnic minorities; those with disabilities; those with special dietary requirements; those with medical conditions that are managed via the consumption of discretionary foods; and those who consume discretionary foods at celebration times or in relation to religious beliefs.

4. Scottish Government (2018) A Healthier Future – Scotland’s Diet and Healthy Weight Delivery Plan https://www.gov.scot/publications/healthier-future-scotlands-diet-healthy-weight-delivery-plan/

5. Scottish Government (2018) The Scottish Health Survey 2017 edition | volume 1 | main report https://www.gov.scot/publications/scottish-health-survey-2017-volume-1-main-report/

6. 2-15 year olds

7. Foods Standards Scotland (2018 update) Situation Report: The Scottish Diet: It needs to Change https://www.foodstandards.gov.scot/downloads/Final_Report.pdf

8. Katrina F Brown et al (2018) The fraction of cancer attributable to modifiable risk factors in England, Wales, Scotland, Northern Ireland, and the United Kingdom in 2015 http://www.nature.com/articles/s41416-018-0029-6

9. Hauner H (2010) Obesity and diabetes. in Holt R.I.G, Cockram C.S., Flyvbjerg A et al (ed.) Textbook of diabetes. 4th edition.

10. Guh et al (2009) The incidence of co-morbidities related to obesity and overweight: A systematic review and meta-analysis
https://bmcpublichealth.biomedcentral.com/articles/10.1186/1471-2458-9-88

11. A Castle (2015) Obesity in Scotland. SPICe Briefing, 15/01. 7 Jan 2015. http://www.parliament.scot/ResearchBriengsAndFactsheets/S4/SB_15-01_Obesity_in_Scotland.pdf

12. NHS Health Scotland (2017) Public attitudes to reducing levels of overweight and obesity in Scotland http://www.healthscotland.scot/media/1705/public-attitudes-to-reducing-obesity-in-scotland.pdf

13. Scottish Government (2017) Diet and Healthy Weight Delivery Plan https://www.gov.scot/publications/healthier-future-scotlands-diet-healthy-weight-delivery-plan/

14. This refers to places that serve food and drink outside of the home such as restaurants, cafes, pubs, coffee shops and takeaways.

15. However please see para 1.20 below with regard to the generalisability of the findings.

16. Including individuals, organisations and organisation type.

17. It should be noted that in some instances the percentage total will not add up to 100% due to rounding error.

18. i.e. whether those with a pro-restriction stance tended to agree or disagree with the specific proposals put forward and whether those with an anti-restriction stance tended to disagree with all proposals or whether they saw merit in some aspects.

19. (1) One blank response and one duplicate response were removed. (2) There were no campaign responses. (3) There were low numbers where it was evident that respondents had ‘conferred’ and submitted similar response wording. These responses were kept on the basis that they were submitted to represent different organisations and it was deemed reasonable for different organisations with similar interests to submit consistent responses. (4) For missing answers to closed questions, the written comments provided were used to interpret the answer to the closed question where possible. (5) It was apparent that at times a small number of respondents found elements of the wording for the closed questions difficult to understand, as their written explanation did not match the answer option selected. In these cases, the written comments provided by the respondent were used to interpret their intended response and corrections were made. 

20. While the views of respondents are discussed, the accuracy/evidence on which they are based has not been assessed (as this is beyond the scope of the analysis).

21. At times responses were complex and it was not always clear which aspect of the proposals for a given question was being referred to. Additionally, as some questions are inter-related, at times the same point was covered across a number of questions. To facilitate the interpretation of the findings, efforts were made to minimise duplication by integrating duplicated views within the question that most closely relates to that issue. 

22. Consequently, the amount of information presented regarding disagreement with the proposals is generally greater. This should not be interpreted as disagreement being more prevalent than agreement – the frequency of responses presented for each question should also be kept in mind when interpreting the findings.

23. The main reason respondents did so was to enable them to provide citations for references included in their online response.

24. This category included a variety of organisations such as professional bodies, a consumer organisation and a regulator.

25. For example: restaurant, fast food outlet, coffee shop

26. Questions 11, 14, 15 and 16 invited input/suggestions and, therefore, only direct/informative responses were considered.

27. The respondent selected ‘Strongly disagree’ but based on their written comments they may have meant ‘agree’ or ‘strongly agree’. However the wording of their comments was not sufficiently clear to enable correction of their tick box answer.

28. In addition to the responses shown in Table 4.1, 9 respondents (8 individuals and 1 organisation) selected the answer option ‘other’ in addition to one of the main answer options. Table 4.1 shows their main answer option, but not the additional ‘other’ answer selected. Of these 9 respondents, 5 provided an explanation. Those explanations have been included within ‘other considerations’ (para 4.13) below.

29. See para 4.15.

30. The list comprises of products listed by both individuals and organisations, however, not all organisations that indicated that ‘additional foods should be included’ went on to list specific foods – few described the approach to categorising foods that they felt should be taken without listing specific foods.

31. The Nutrient Profile Model was “developed by the Food Standards Agency in 2004-2005 to provide Ofcom, the broadcast regulator, with a tool to differentiate foods on the basis of their nutritional composition in the context of television advertising foods to children. The model uses a simple scoring system where points are allocated on the basis of the nutrient content of 100g of a food or drink.” See Department of Health (2011) Nutrient Profiling Technical Guidance, Online, Available from: https://www.gov.uk/government/publications/the-nutrient-profiling-model (accessed 30/04/19)

32. The comments submitted by these respondents conflicted with the original tick box answer option that they selected, but were not sufficiently clear to enable correction. Please see Annex 2, Table A2.3 for a more detailed breakdown of the conflicting answers.

33. Proportion of responses by respondent type closely mirrors the overall response rate to the consultation. In total 455 individuals (85%) and 78 organisations (15%). Within the organisations (59%) were from non-industry and 32 (41%) from industry.

34. It should be noted that this includes both those that disagree with mandatory restrictions of this nature as well as those that favoured restrictions but felt the categorisation was limited.

35. This is made up of two groups – 1) conflicting answers - the comments submitted by these respondents conflicted with the original tick box answer option that they selected, but were not sufficiently clear to enable correction; 2) possible conflicting answers - no comment was submitted but the tick box answer option selected conflicts with the viewpoint expressed in responses to other questions. Please see Annex 2, Table A2.4 for a more detailed breakdown of conflicting and possible conflicting answers.

36. This respondent did not submit a comment but the tick box answer option selected conflicts with the viewpoint expressed in responses to other questions. Please see Annex 2, Table A2.5 for a more detailed breakdown.

37. This is made up of two groups – 1) conflicting answers - the comments submitted by these respondents conflicted with the original tick box answer option that they selected, but were not sufficiently clear to enable correction; 2) possible conflicting answers - no comment was submitted but the tick box answer option selected conflicts with the viewpoint expressed in responses to other questions. Please see Annex 2, Table A2.6 for a more detailed breakdown of conflicting and possible conflicting answers.

38. This is made up of two groups – 1) conflicting answers - the comments submitted by these respondents conflicted with the original tick box answer option that they selected, but were not sufficiently clear to enable correction; 2) possible conflicting answers - no comment was submitted but the tick box answer option selected conflicts with the viewpoint expressed in responses to other questions. Please see Annex 2, Table A2.7 for a more detailed breakdown of conflicting and possible conflicting answers.

39. Numbers varied across the four types of promotion. Of those who agreed with restricting and offered an explanation in relation to the type of promotion, either some or few respondents expressed these reasons for agreement.

40. Numbers varied across the four types of promotion. Of those who disagreed with restricting and offered an explanation in relation to the type of promotion, generally few respondents expressed these reasons for agreement.

41. The comments submitted by these respondents conflicted with the original tick box answer option that they selected, but were not sufficiently clear to enable correction. Please see Annex 2, Table A2.8 for a more detailed breakdown of the conflicting answers.

42. This is made up of two groups – 1) conflicting answers - the comments submitted by these respondents conflicted with the original tick box answer option that they selected, but were not sufficiently clear to enable correction; 2) possible conflicting answers - no comment was submitted but the tick box answer option selected conflicts with the viewpoint expressed in responses to other questions. Please see Annex 2, Table A2.9 for a more detailed breakdown of conflicting and possible conflicting answers.

43. This is made up of two groups – 1) conflicting answers - the comments submitted by these respondents conflicted with the original tick box answer option that they selected, but were not sufficiently clear to enable correction; 2) possible conflicting answers - no comment was submitted but the tick box answer option selected conflicts with the viewpoint expressed in responses to other questions. Please see Annex 2, Table A2.10 for a more detailed breakdown of conflicting and possible conflicting answers.

44. This is made up of two groups – 1) conflicting answers - the comments submitted by these respondents conflicted with the original tick box answer option that they selected, but were not sufficiently clear to enable correction; 2) possible conflicting answers - no comment was submitted but the tick box answer option selected conflicts with the viewpoint expressed in responses to other questions. Please see Annex 2, Table A2.11 for a more detailed breakdown of conflicting and possible conflicting answers.

45. Responses to this question were received from all organisation types except Out of Home providers.

46. Responses to this question were received from all organisation respondent types except the Out of Home sector.

47. Responses to this question were received from all organisation types except Out of Home providers.

48. Although this programme sits within an industry representative body, the perspective provided was that of a public health interest and therefore this programme is categorised as public sector for the purposes of the consultation. A separate response from the Scottish Grocers Federation was also submitted which represents industry interests and is categorised under industry representative body.


Contact

Email: Leigh.Edwardson@gov.scot