ALLIANCE responds to consultation on Restricting Promotions of HFSS Food and Drink regulations

Read the ALLIANCE's response to the Restricting promotions of food and drink high in fat, sugar or salt (HFSS) regulations consultation.

The ALLIANCE broadly supports the Scottish Government’s proposed regulations. We expect that the regulations will positively affect the whole population, especially the health inequalities of people living in socioeconomically deprived areas.

We know that food is more than a nutritional need and is inherently important to realising other human rights such as the right to health, the right to an adequate standard of living and the right to social and medical assistance as found in our responses to the Scottish Government consultations on the Good Food Nation Bill and, more recently, the Good Food Nation Plan.

Consumption of HFSS products is a cause of non-communicable diseases (NCDs) and a driver of health inequalities in Scotland. These outcomes are entirely preventable. Unhealthy Commodity Industries (UCI) continue to pose a significant barrier to progress in this area. If the Scottish Government is to address NCDs and health inequalities, then it must also address and tackle all commercial determinants of health on an equal footing to the social determinants of health.

There is wide-ranging evidence on the benefits of restricting price promotions on unhealthy food and drink both in-store and on digital platforms. Such regulations would contribute to the Scottish Government’s commitments contained within the Diet and Healthy Weight Plan and work towards eradicating food and child poverty. Without the implementation of regulation on HFSS promotions, the Scottish Government will miss its target of reducing childhood obesity by at least 50% by 2030.

Whilst we agree that there are positives to being consistent with the rest of UK policy, we feel that Scotland can go further and suggest that if the Nutrient Profiling Model (NPM) is applied then the most up-to-date version must be used within the regulations when possible. The current UK NPM
was introduced in 2004-2005. As it is ten years out of date, it no longer reflects UK dietary recommendations especially those for free sugars and fibres.

The ALLIANCE does not agree that non-pre-packaged food or businesses with under 50 employees should be excluded from the scope of the regulations. Many businesses such as fast food
outlets, takeaways and other similar OOH businesses would still be able to promote unhealthy HFSS products. The ALLIANCE believes that this would allow for loopholes to be created, where significant impacts on the health inequalities of people from lower socio-economic backgrounds and those living in deprived areas continue.

If enacted the regulations must be accompanied by awareness raising and training for local authorities, businesses and individuals. A duty should also be placed on local authorities to routinely collect
disaggregated and intersectional data to monitor the regulations impact and effectiveness.

You can read our response in full by clicking the links below.

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