Obesity Action Scotland: Why we need promotions regulations now

Jennifer Forsyth, Policy and Evidence Manager of Obesity Action Scotland, tells us why promotions of HFSS products need regulating now.

Last week marked the end of the Scottish Government’s latest consultation process on regulating price and location promotions of unhealthy high fat, salt and sugar (HFSS) products. This was the fourth such consultation in five years.

During this time, rates of overweight and obesity have continued to rise, and inequalities widen. Over two-thirds of adults (67%) in Scotland are living with overweight and obesity, and a third of children aged 2-15 are at risk of overweight and obesity – the highest level recorded since 2011. This trajectory is underpinned by persistent inequalities, with those living in our most deprived communities at a much greater risk of experiencing overweight and obesity than their least deprived counterparts.

Why do we need promotion restrictions?

We know that what’s around us shapes us. Promotions are a critical component of the unhealthy food environment we all experience every day. They cause us to impulse buy, spend more than we intended when shopping (on average 20% more) and are skewed towards unhealthy products. They are also ubiquitous – we experience them in shops, online, and when eating out of home.

The cost of food remains a significant concern for many people. In deprived areas, there is often less access to healthy food and, where it is available, healthier food can be up to three times more expensive. Contrary to popular narrative, promotions do not save people money due to additional unplanned spending on unhealthy food.

Discussions on regulating promotions often incorrectly argue that any regulations will ban all promotions. This is not the case. The proposed regulations would restrict promotions on only unhealthy HFSS products. Promotions could still be offered on healthier products and of course HFSS products can continue to be sold not on promotion.

Regulating promotions is essential to save people money and to ensure healthier options are the easiest and most affordable options for everyone.

A comprehensive approach is essential

At Obesity Action Scotland, we believe that to be effective and achieve improved health outcomes, any restrictions need to be comprehensive, covering as many types of price and location promotions as possible.

The consultation proposes to include temporary price reductions (TPRs) and meal deals within the regulations. This goes further than the current regulations in England, which restricts just multi-buy promotions.

TPRs and meal deals are the most common types of price promotion in Scotland. TPRs account for just under 15% of all price promotions, compared to only 0.1% for multi-buys. Meal deals make up the largest proportion of supermarket front of store offerings. Failure to include them will profoundly undermine any legislation.

Both in-store and online, a plethora of locations are used to draw attention to promotional products including aisle ends, checkout areas, and website homepages. Items promoted in these prominent locations tend to be much less healthy and encourage impulse purchases. Restrictions on HFSS promotional items location within stores have been in place in England since October 2022 and offer important lessons for Scotland. The English restrictions show that it is essential that as many locations as possible are included in store and online, otherwise retailers would simply shift promotions to locations not in scope.

The proposed regulatory process must be robust and free from industry influence.

The time for action is now

The growing levels of overweight and obesity, and worsening diet-related health inequalities, point to an urgent need for this evidence-informed, impactful policy to regulate price and location promotions of HFSS products, without further delay.

These regulations provide a real opportunity for the Scottish Government to demonstrate its commitment to population health and wellbeing, and to reducing inequalities. And it’s supported by the public. Recent polling evidence highlights that 86% of people in Scotland want greater government action to tackle health inequalities, and more than half support specific policy interventions on HFSS promotions.

Limiting the regulations to cover only a few types of promotions will not help achieve the level of public health outcomes we need to see in Scotland. We cannot afford to pass a policy that undermines its primary goal to reduce the public health harms associated with excess consumption of calories, fat, sugar and salt, including the risks of developing type 2 diabetes, various types of cancer and other conditions such as cardiovascular disease.

The need for action has never been greater, and Scotland recognises it.

We need your support

We recently submitted a joint letter to the Scottish Government with 35 signatories from across public health and civil society, showcasing the broad and far-reaching support for such regulations. But of course, this is only the beginning of the journey. We now need a concerted effort to make the regulations a reality and your support is vital. You can support by engaging with our social media content, talking to your stakeholders and contacts about the policy and how it relates to your work, and by speaking to MSPs from across the political spectrum.

Visit Obesity Action Scotland’s website to find out more.

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