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

5. Public Health Roundtable – May 2024 – Summary of discussion

09 May, 15:00-16:30

Microsoft Teams

Attendees:

• Jenni Minto, Minister for Public Health and Women’s Health Scottish Government officials
• British Heart Foundation
• Cancer Research UK
• Diabetes Scotland
• FSS
• NCD Alliance
• Nesta
• Obesity Action Scotland
• PHS

Summary of discussion

1. Welcome and introductions

• The Minister for Public Health and Women’s Health welcomed attendees to the meeting and provided an overview of the agenda.
• The lead officer for the policy gave a short presentation of the policy’s background and consultation process.
• The purpose of the roundtable was to allow for focused discussion on proposals outlined in the consultation document that were of particular interest to stakeholders, specifically promotion types, qualifying businesses and implementation.
• Briefing and questions were circulated to attendees in advance to help facilitate focused discussion.

2. Promotion types

Questions:

• We have set out our proposals for restricting price and location promotions in our consultation. How effective do you think the definitions and proposals are when considering the implementation of restrictions on the following elements:
• Meal deals: Is there a preferred option from a business perspective? Please explain the benefits and any unintended consequences of each option.
• TPRs: Do you have views on the proposed definition or how it might be improved? Is there data on the use of TPRs to support our consideration of impact?
• Free standing displays: Do you have any views on the proposed definition or how this might be improved? Is there any data on the use of these types of structures to support our considerations around impact?

Discussion

• Support expressed for restrictions on price and location promotions to be as comprehensive as possible.
• Meal deal option 1 was considered most comprehensive, though option 3 was noted as potentially more practical for business implementation. Option 2 was suggested as being a possible compromise, as it could be easier for businesses to implement while still capping calories.
• Strong agreement on the necessity to include Temporary Price Reductions (TPRs) and freestanding displays to avoid loopholes.
• Emphasis on the importance of clear definitions for different promotion types to ensure restrictions are as effective as possible.

3. Qualifying businesses

Questions:

• What are your views on implementing proposed price and location restrictions in out of home businesses?

Discussion

1. Strong consensus on including Out of Home (OOH) businesses in the restrictions, due to the significant contribution of calories they contribute to people’s diets.

2. Concerns raised that exempting smaller businesses could potentially exacerbate health inequalities due to the distribution of smaller OOH businesses in areas of higher deprivation.

3. Emphasis on the importance of monitoring and evaluation in this area.

We recently issued points of clarification on qualifying businesses and Out of Home businesses operating within the premises of a qualifying business. Do you have any comments on the points of clarification issued?

• No specific comments were provided in response to this question.

4. Public health impact

Questions:

• Do you have further evidence to support our considerations of impact from a public health perspective? In particular around areas where we propose to go further than the UK Government e.g TPRs, meal deals, out of home.
• Are you aware of any evidence around potential cost of living considerations?

Discussion

• Recognition of the importance of comprehensive evidence to support proposals, and attendees offered to share recent and forthcoming research and publications.
• Discussion on reframing language around the policy to shift focus to positive health outcomes rather than restrictions.
• Consideration of the need to balance arguments about cost of living impacts with the higher rate of dietary health issues in more deprived areas.

5. Implementation

Questions:

• Given the proposals, do you have a view on the proposed implementation period? In particular around areas of consumer messaging to support consumer understanding of measure to improve the food environment.
• Building on experience with other policies, do you have any thoughts to help shape the process for developing effective guidance and associated consumer communication?

Discussion

• Agreement for a 12-month implementation period, with the suggestion given for a phased approach to implementation and additional support for smaller businesses.
• Importance highlighted of using clear, plain language in guidance for effective public messaging.
• Emphasis on the requirement for sufficient funding, training and collaboration for enforcement bodies.
• Support reiterated for measures going further than current regulations in England to help deliver the necessary improvement in public health.

Open discussion

• Agreement that non-prepacked food should be in scope.
• Agreement that the current evidence base and expected public health benefits are enough to justify introduction of a comprehensive set of measures.
• Reiteration of importance of continuing to add to the evidence base through monitoring and evaluation of the policy, as well as ongoing research.

6. Final Comments and Close

• The Minister thanked attendees for their valuable contributions, and reiterated the importance of replying to the consultation.
• Attendees were invited to contact officials should they wish to discuss any areas of the policy in more detail before submitting their consultation response.