A Healthier Future: analysis of consultation responses

Executive summary

Introduction

1. Between 26 October 2017 and 31 January 2018, the Scottish Government undertook a public consultation to gather views on its proposals for improving diet and promoting healthy weight, as outlined in A Healthier Future – Action and Ambitions on Diet, Activity and Healthy Weight. ^[1] The consultation paper contained three main sections: (i) transforming the food environment (Questions 1-6); (ii) encouraging and supporting the adoption of healthier and more active lives (Questions 7-10); and (iii) effective leadership and exemplary practice (Questions 11-13).

The respondents

2. The consultation received 362 responses comprising approximately equal numbers of responses from individuals (179) and organisations (183). Three-quarters (74%) of the organisational responses came from public health, public sector and third sector organisations. ^[2] One-fifth (20%) came from private sector and business organisations. The remaining 6% included private sector weight management organisations and regulatory bodies. In addition, four organisations (the Scottish Youth Parliament, Young Scot, Food Standards Scotland and the Scottish Public Health Network) carried out separate engagement exercises. These sessions were carried out with specific groups of interest, e.g. young people, and as part of the wider consultation to the strategy.

Overview of findings

3. In general, respondents of all types acknowledged that overweight and obesity were significant and serious public health problems. They welcomed the intention of the Scottish Government to address this issue, thought that ‘everyone should be involved’ in this agenda, and endorsed the combined focus on diet, activity and healthy weight. Two distinct perspectives emerged from: (i) public health, third sector and private weight management organisations; and (ii) food and drink industry, advertising and media organisations. The views of individual respondents were mostly aligned to the former.

4. Public health, third sector and private weight management organisations expressed support for the consultation proposals, but also repeatedly raised a range of caveats and concerns. These related mainly to the strategy: (i) needing to have a greater focus on (the root causes of) inequalities in health, (ii) not widening health inequalities, and (iii) being comprehensive, bolder, and more ‘joined-up’ across all the relevant policy areas (e.g. education, transport, economy, health, food, etc.).

5. Industry respondents generally opposed the proposals set out in Questions 1-6 and expressed concern about their potential for negative impact on industry and consumer choice. In particular they (i) opposed restrictions on price promotions of products high in fat, sugar and salt, (ii) opposed any extension of the current ( UK-wide) restrictions on broadcast and non-broadcast advertising, (iii) saw significant practical complications and competitive disadvantages for industry if arrangements diverged from those in the rest of the UK, and (iv) thought the proposals would have negative impacts on food producers, retailers and consumers. This group wanted improved consumer education, rather than legislative action.

Headline findings for each question group

Restricting price promotions of foods high in fat, sugar and salt (Questions 1-2)

6. Public health and third sector respondents generally (i) supported restricting price promotions, (ii) identified other types of promotion to restrict, and (iii) highlighted other mechanisms (both price and non-price related) to encourage healthier diets. Their main concern was the impact on people on low incomes. They suggested various ways to promote healthier food and drink and make them more affordable. In terms of the products to be targeted, respondents suggested using: (i) the nutrient profiling model (discussed in the consultation paper); (ii) the traffic light labelling system; and / or (iii) the Eatwell guide.

7. By contrast, private sector and business respondents generally (i) were opposed to price promotion restrictions, (ii) highlighted the important purposes of promotions, and (iii) raised concerns or identified negative consequences. These included: (i) a loss of business for supermarkets and small retailers, (ii) disadvantaging small food producers, (iii) placing a further burden on products or businesses already targeted for government intervention (e.g. through the Soft Drinks Industry Levy), (iv) increasing food waste, and (v) increasing prices and reducing consumer choice. They emphasised that, if promotional restrictions were introduced, there must be clear, specific and evidence-based definitions of targeted foods. This group also highlighted difficulties in using the nutrient profiling model.

Advertising (Question 3)

8. Respondents who agreed with proposals for introducing (or strengthening) restrictions on advertising generally thought that such actions would help to reduce the purchase and consumption of products high in fat, sugar and salt. This group included public health and third sector organisations, private sector weight management organisations and most individual respondents. These respondents also thought that advertising was mainly used to promote such products, and that the messages within advertising aim to normalise their consumption. Many called for a complete ban on advertising of products high in fat, sugar and salt.

9. Respondents who did not favour new or extended restrictions were mainly from industry. They argued that (i) the proposals are likely to have only a modest influence on children’s food preferences, (ii) the impact of current non-broadcast regulations should be assessed before any additional restrictions are imposed, and (iii) proposals are likely to have substantial, and far-reaching negative impacts for the food and drink industry, broadcasters, the advertising industry, public transport operators, and members of the public.

Development of a separate strategy for the out of home sector (Question 4)

10. Respondents were asked their views about a proposal to work with stakeholders to develop a sector specific strategy for out of home ( OOH) food and drink providers. In general, respondents thought that such a strategy would be appropriate and they discussed what the strategy might cover in broad terms (for example in relation to product information, planning and licensing, public sector procurement and portion control).

11. Respondents from all sectors saw the potential for an enhanced role for local authority environmental health services which was seen as a key partner in relation to this agenda. While individuals and public health / third sector respondents were generally in favour of calorie content information being available on (all) menus, representatives of the OOH catering sector said there was ‘business opposition’ to this due to the additional costs, and asked for the evidence of the impact this would have on food choices. There were also differences of opinion between the two groups in relation to (reducing) portion size.

Food labelling (Question 5)

12. Industry respondents were generally content with current labelling arrangements. However, manufacturers did not wish to see labelling arrangements diverge from other parts of the UK. They argued that market-specific packaging would be costly and wasteful, make supply chains (needlessly) more complex and result in competitive disadvantages. Individuals and public health / third sector respondents were generally positive about the current (voluntary) arrangements, but they also offered a range of suggestions for how the current system could be built on and improved – including being made mandatory, covering a wider range of products and sectors, and being standardised.

Support for reformulation and innovation (Question 6)

13. The consultation set out a commitment by the Scottish Government to invest £200k over three years to assist SMEs (small and medium-sized enterprises) to reformulate and innovate. Respondents from all groups said this sum was insufficient. Retailers, manufacturers and OOH outlets all made a positive case that much had already been achieved in relation to reformulation. Some respondents thought that specific businesses were reaching the limits of what could be achieved.

14. There was widespread agreement on the importance of advice, guidance and expertise being available to all SMEs. In general, respondents focused on the need for (i) written guidance and online materials, (ii) nutritional expertise including access to advice in the workplace, and (iii) opportunities for networking and sharing. They also talked about the need for ‘additional funding’ or ‘grant funding’ for SMEs. This could take the form of ‘tax reductions’ for rent and rates, ‘tax subsidies’ for producing healthier foods, and / or ‘advertising subsidies’ for promoting reformulated products.

Healthy weight from birth to adulthood (Question 7)

15. Respondents provided wide-ranging comments on what was required to give families and children the support they need to develop a healthy and positive relationship with food. Some – primarily public health and third sector organisations and private sector weight management organisations – discussed high-level issues in relation to policy and strategy development; others expressed views about service delivery; and others made detailed suggestions about the development and targeting of specific kinds of interventions, including better education on nutrition and cooking skills within the school curriculum.

16. The main themes in comments related to (i) addressing inequalities, (ii) tackling the obesogenic environment, (iii) framing the strategy to focus on ‘healthy weight’ (which was seen as positive), rather than ‘tackling obesity’ (which was seen as negative), (iv) ensuring joined up policy in this area, (v) workforce development, and (vi) funding.

17. Some respondents noted that focussing on individual level interventions risked widening inequalities. A range of measures were also seen to be ‘missing’ from the strategy or given insufficient attention, such as alcohol, mental health, pre-conception and pregnancy, food security, and environmental sustainability.

Supported weight management services and other interventions (Questions 8-9)

18. The consultation paper described the Scottish Government’s plan to invest £42m over five years to establish supported weight management interventions for people with – or at risk of developing – type 2 diabetes. Private sector organisations offered very few comments on this. Other respondents were unclear why interventions were to be targeted at one specific condition, rather than being made available to anyone who needs support.

19. Respondents were generally familiar with and supportive of GP referrals to weight management services. There was also support for these services to be available through self-referral and from referrals by a range of other professionals.

20. Respondents thought all programmes and services needed to take a broad and holistic view of support, and therefore should (i) cover both diet and physical activity; (ii) address self-management and behaviour change; (iii) provide psychological support if required; and (iv) include education about healthy eating, meal planning, and cookery skills. Third sector involvement and community-led programmes were thought to be vital.

Physical activity (Question 10)

21. Responses to this question came mainly from individuals and public health / third sector organisations. There was general support for proposals to develop opportunities for active travel, and to build on the Daily Mile initiative in schools. There was widespread acceptance that efforts to encourage physical activity should be part of any healthy weight strategy, but there was also acknowledgement of the barriers (e.g. stigma) facing obese people wishing to participate.

Building a ‘whole nation’ movement (Questions 11-12)

22. There was broad support for the idea that ‘everyone should be involved’ in the effort to reduce obesity. There was agreement this would require (i) good collaboration between the private, public and voluntary sectors, and (ii) clear accountability arrangements. There was also discussion about the importance of leadership across all sectors and at all levels, and the point was repeatedly made about the importance of the public sector ‘leading by example’ (e.g. by providing nutritious food in hospitals, schools, care homes, prisons, etc.).

23. Respondents believed that (i) employers should ensure that employees are able to have a good work-life balance, including proper breaks during the working day, flexible working arrangements, and opportunities to improve physical activity levels, (ii) health and environmental sustainability should be prioritised, and (iii) there should be increased investment in community food initiatives, including community gardens.

Monitoring change (Question 13)

24. Respondents were asked for their views on monitoring and evaluation. Generally they asked for a better national surveillance system for monitoring weight, particularly with a focus on improving data collection at a local level. There were three perspectives on the main outcomes to be monitored. All respondents thought that weight and weight-related measures should be monitored. However, one group thought the focus should be only on weight, while a second larger group thought that the focus of monitoring should be on health and wellbeing more generally. A third group (mainly those from the food and drink industry) called for impacts on retail sales, nutritional content, and consumption to also be measured (as well as health, wellbeing and weight-related outcomes).