1 The Royal Society for Public Health Response to UK Government consultation on restricting promotions of products high in fat, sugar and salt by location and price Questions for Consultation Businesses and products affected 1. Do you think that the restrictions suggested in this consultation should apply to all retail businesses in England that sell food and drink products, including franchises? Yes/No. Please explain your answer. Yes, the restrictions in this consultation should apply to all retail businesses in England that sell food and drink products, including franchises. No matter their size or speciality, all businesses should take steps towards fulfilling the government’s ambition to halve rates of childhood obesity by 2030 1 . This should include all out-of-home businesses that use price promotions on HFSS products, such as fast food takeaway outlets (see Question 30 for more detail). 2. Do you think there are any other retailers that the restrictions suggested in this consultation should apply to? Yes/No. If yes, please explain which retailers and why. The suggested restrictions in this consultation should apply to all retailers that sell food and drink, including those whose primary focus is not food and drink. This should include supermarkets (both large and small stores), convenience stores, newsagents, clothes shops, household goods shops and any other retailers that stock food or drink without it being their primary product. In addition, it should include businesses in the out-of-home sector that sell food and drink, including cafes, restaurants and fast food chains. It is crucial to have a level playing field across all businesses and retailers. 3. Do you think there are any retailers that the restrictions suggested in this consultation should not apply to? Yes/No. If yes, please explain which retailers and why. All retailers should follow the restrictions. We recognise that it may be harder for smaller businesses to do this, and they may need a longer implementation period, but they should strive to meet the restrictions. 4. Do you think that the restrictions should also apply to retailers that do not primarily sell food and drink, for example, clothes retailers and newsagents? Yes/No. Please explain your answer. Clothes retailers and newsagents should also be included, as these types of shop particularly promote high sugar confectionary products around the checkout area 2 . A new report from the UK 1 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/718903/ childhood-obesity-a-plan-for-action-chapter-2.pdf 2 http://ukhealthforum.org.uk/wp-content/uploads/2019/03/Strand-1-High-Street-Food-Placement-Project- Strand-One-Final-Report-March-2019.pdf
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1
The Royal Society for Public Health
Response to UK Government consultation on restricting promotions of products high in fat, sugar
and salt by location and price
Questions for Consultation
Businesses and products affected
1. Do you think that the restrictions suggested in this consultation should apply to all retail
businesses in England that sell food and drink products, including franchises? Yes/No. Please
explain your answer.
Yes, the restrictions in this consultation should apply to all retail businesses in England that sell food
and drink products, including franchises. No matter their size or speciality, all businesses should take
steps towards fulfilling the government’s ambition to halve rates of childhood obesity by 20301. This
should include all out-of-home businesses that use price promotions on HFSS products, such as fast
food takeaway outlets (see Question 30 for more detail).
2. Do you think there are any other retailers that the restrictions suggested in this consultation
should apply to? Yes/No. If yes, please explain which retailers and why.
The suggested restrictions in this consultation should apply to all retailers that sell food and drink,
including those whose primary focus is not food and drink. This should include supermarkets (both
large and small stores), convenience stores, newsagents, clothes shops, household goods shops and
any other retailers that stock food or drink without it being their primary product. In addition, it
should include businesses in the out-of-home sector that sell food and drink, including cafes,
restaurants and fast food chains. It is crucial to have a level playing field across all businesses and
retailers.
3. Do you think there are any retailers that the restrictions suggested in this consultation should
not apply to? Yes/No. If yes, please explain which retailers and why.
All retailers should follow the restrictions. We recognise that it may be harder for smaller businesses
to do this, and they may need a longer implementation period, but they should strive to meet the
restrictions.
4. Do you think that the restrictions should also apply to retailers that do not primarily sell food
and drink, for example, clothes retailers and newsagents? Yes/No. Please explain your answer.
Clothes retailers and newsagents should also be included, as these types of shop particularly
promote high sugar confectionary products around the checkout area2. A new report from the UK
Manufacturers and retailers should both be responsible for following location restrictions.
Manufacturers should not be allowed to pay retailers to place restricted products in prominent
locations, and equally retailers should introduce policies to ensure the restrictions are adhered to.
Price promotion restrictions
10. Which of the following options do you think is the most appropriate for achieving the aims of
this policy:
Option 1 - Require retailers to ensure that all their volume based price promotions on food and
drink are on healthier products.
Option 2 - We are open to alternative suggestions from stakeholders as to how this policy could be
implemented in order to reduce overconsumption of HFSS products but also to encourage
businesses to promote healthier products and to further incentivise reformulation. For example,
we have explored the possible impact of requiring retailers to ensure that at least 80% of their
sales from volume based price promotions on all food and drink per year are on healthier
products.
Neither
Please explain your answer.
Option 1 is most appropriate for achieving the aims of this policy. For this policy to be effective, it
must cover restrictions on all HFSS products, and only allow volume based price promotions of
healthier products. Recent research by Cancer Research UK found that shoppers who buy more on
promotion are more likely to be overweight or obese7. Option 2 is not clear enough to consumers
and would rely on retailers sharing their sales data to work.
11. If you are proposing an alternative option, please explain how your preferred option would
better deliver the aims of this policy, how it would be delivered and whether there would be any
practical and/or implementation issues that we should be aware of.
NA
12. Do you think that the price restrictions should apply to ‘multibuy’ promotions and ‘extra free’
promotions of pre-packaged HFSS products (see Annex 5)? Yes/No. Please explain your answer.
Yes, the price restrictions should apply to promotions that result in purchasing more to take
advantage of the discount. These types of promotion encourage over-purchasing and therefore
over-consumption, so they do not save the consumer money in the long term, but they do
contribute to weight gain8. Our report, The Child’s Obesity Strategy, revealed that 47% of young
people thought there should be limits on buy one get one free offers for junk food9. Polling
commissioned by RSPH and Slimming World for our report, Size Matters, found that 60% of the
public have experienced upselling of unhealthy, high calorie food and drink in supermarkets10.
7 Paying the price: New evidence on the link between price promotions, purchasing of less healthy food and drink, and overweight and obesity in Great Britain. Timothy Coker, Harriet Rumgay, Emily Whiteside, Gillian Rosenberg, Jyotsna Vohra. 2019. 8 https://academic.oup.com/nutritionreviews/article-abstract/67/6/333/1812231 9 https://www.rsph.org.uk/uploads/assets/uploaded/403f6527-dd7a-4b7e-8ad62dab7bef33fd.pdf 10 https://www.rsph.org.uk/uploads/assets/uploaded/055c2d87-c3ab-4dfb-ba4aa44b9488c88f.pdf
19. For food and drink consumed outside of the home, are there other types of price promotion
that should be restricted? Yes/No. If yes, please explain which promotions we should consider and
why.
Meal deals should be considered for restriction. Many meal deals include HFSS products, so there
should be further research into the impact of meal deals on purchasing and consumption.
Seasonal products should also be considered for restriction. Retailers should look at limiting how
early they promote seasonal HFSS products. With three weeks to go until Easter, RSPH
commissioned polling that revealed 23% of those surveyed had already bought and consumed at
least one full sized Easter egg in 201913. 77% of respondents thought that supermarkets start selling
Easter eggs and other Easter related treats too early.
Location restrictions
20. Which of the following options do you think is the most appropriate to achieve the aims of this
policy:
Option 1 - We propose that the location restrictions should apply to the following locations: store
entrances, ends of aisles and checkout areas (see Annex 2).
Option 2 - We are open to alternative suggestions from stakeholders as to how this policy could be
implemented. If you are proposing an alternative option, please explain how your preferred
option would better deliver the aims of this policy, how it would be delivered and whether there
would be any practical and/or implementation issues that we should be aware of.
Neither
Option 1 is preferred, as data from the Obesity Health Alliance showed that the majority of food and
drink products in store entrances, end of aisles and checkout areas are food and drinks that
contribute to children’s excess sugar and calorie intake14. We may be open to further restrictions in
the future if evidence emerges about other locations contributing to high sales of HFSS products.
21. Do you think that the location restrictions should apply to all of the following locations: store
entrances, ends of aisles and checkout areas? Yes/No. Please explain your answer.
Yes, the location restrictions should apply to store entrances, ends of aisles and checkout areas.
Products in these areas sell well because they are more visible15, so if the products in these areas are
HFSS they contribute further to the obesity problem16.
22. Do you currently use or do you know about any official definitions for these locations? Yes/No.
If yes, please provide them below.
No
13 https://www.rsph.org.uk/about-us/news/retailers-urged-to-crack-down-on-early-easter-egg-sales-to-tackle-obesity.html 14 http://obesityhealthalliance.org.uk/wp-content/uploads/2018/11/Out-of-Place-Obesity-Health-Alliance-2.pdf 15 Wilson A, Buckley E, Buckley J and Bogomolva S. Nudging healthier food and beverage choices through salience and priming: Evidence from a systematic review. Food Quality and Preference 2016. 51:47–64. 16 Cohen D and Lesser L. Obesity prevention at the point of purchase. Obesity Reviews 2016. 17:389–396