Restricting promotions of food and drink high in fat, sugar or salt: Stakeholder engagement summaries

3. Wholesaler and Manufacturer Roundtable – December 2023 – Summary of discussion

Monday 4 December 2023, 12:45-13:45

Microsoft Teams meeting

• John Nicholson, Deputy Director, Population Health Strategy and Improvement, Scottish Government
• Scottish Government officials
• Bestway
• Coca Cola
• Deans
• Food and Drink Federation Scotland
• Food and Drink Scotland
• JW Filshill
• Mackies
• Mars
• Mondelez
• Nestle
• Pepsi
• Scottish Wholesale Association
• Snack Nut And Crisp Manufacturer Association (SNACMA)
• Suntory
• Taylors Snacks

Apologies

• Jenni Minto MSP, Minister for Public Health and Women’s Health

Summary of discussion

1. Welcome and introduction

• Due to technical issues the Minister for Public Health and Women’s Health was unable to join the meeting. Senior Officials initiated the meeting on behalf of the Minister for Public Health and Women’s Health and introduced the agenda. Attendees confirmed they were happy to proceed in the Minister’s absence.
• The purpose of the roundtable was to allow for focused discussion on areas of the policy which have generated significant feedback from stakeholders specifically meal deals, temporary price reduction and business exemptions.
• Briefing and question were circulated to attendees in advance to help facilitate focused discussion.
• It was noted that under Competition Law, some attendees would be unable to give specific details and could provide further information following the meeting.

2. Meal Deals

Question:

There are different ways in which we could restrict meal deal promotions. What would be the preferred approach to targeting meal deals from a public health perspective and why?

Discussion

Attendees shared their views in response to the above questions. In the discussion attendee views were noted:

• The Good Food Nation initiative was a comprehensive strategy to follow instead of implementing restrictions.
• Concern about the logistical challenges of targeting specific components within meal deals (i.e. targeting pre-packed foods), and the potential for increased cost to be passed on to the consumer.
• Concern that restrictive measures could displace healthier options.
• Attendees suggested focusing on promoting healthier combinations within meal deals to address childhood obesity trends, rather than banning them outright.
• Officials confirmed the proposal was not to ban all meal deals. The proposal is to restrict less healthy meals deals with no restriction on the promotion of healthier options.

3. Temporary Price Reductions (TPRs)

Questions:

• What are your views on the public health impacts/benefits (including unintended consequences) of: i) targeting TPRs; and ii) not targeting TPRs
• We welcome any evidence stakeholder may be able to share that could contribute to the evidence base on TPRs?

Discussion

Attendees shared their views in response to the above questions. In the discussion it was noted:

• The significance of TPRs for driving sales and supporting Scottish produce. It was attendees unanimous view that restricting TPRs would significantly and negatively impact businesses.
• Concerns regarding increased costs for the consumer and potential differences in prices between Scotland and the UK.
• Attendees voiced the need for a clear understanding of targeted categories and confirmation of which Nutrition Profiling Model (NPM) would be used to identify foods high in fat, sugar or salt (HFSS).

4. Business Exemptions

Questions:

• Based on your knowledge and experience, how will the public health benefits of the policy be impacted if smaller businesses are exempt from: i) location restrictions? ii) price and location restrictions?
• Based on your knowledge and experience what would the impact on disadvantaged groups be if smaller businesses are exempt from: i) location restrictions? ii) price and location restrictions?

Discussion

Attendees shared their views in response to the above questions. In the discussion attendees noted:

• Exempting smaller stores, especially in areas of multiple deprivation, could drive up health inequalities.
• Concerns surrounding unsuccessful previous initiatives, emphasising the need for collaborative efforts and evidence-based decision-making.
• Importance of distinguishing between types of businesses, such as symbol groups and franchises, and clearly defining micro and small businesses.

5. Concluding Remarks:

• Senior officials thanked attendees for their valuable contributions, welcoming any addition written representations to officials by Wednesday 13 December. In addition attendees were invited to contact officials should they wish to have follow up discussions on any aspect of this policy.
• Senior officials noted the roundtable session is the next step in an extensive consultation process and responses would be fed into a suite of impact assessment as well as to further inform our forthcoming consultation on the detail of proposed regulations.