A healthier future: Scotland's diet and healthy weight delivery plan

Outcome 2: The food environment supports healthier choices

Achieving Scotland's dietary goals and our ambition to halve childhood obesity, demands action to transform the food environment - that is the environment that influences what we buy and eat - to support healthier choices and reduce the excessive consumption of food and drink high in fat, sugar or salt ( HFSS).

It is increasingly hard for many of us to eat well and maintain a healthy weight. Not only is food much more energy dense and readily available, but we also live increasingly sedentary lifestyles and are bombarded with seemingly ever-present messages and triggers that encourage consumption.

Relying solely on individual action is not always sufficient. We are all susceptible to temptation, but children are especially impressionable. We need to make it easier for us all to make positive dietary choices.

Measures to transform the food environment, such as restricting the promotion and marketing of less healthy foods and reducing the energy density of food, are also more likely to be effective in reducing health inequality than measures aimed at encouraging individuals to change their behaviours. ^[27]

Restricting HFSS promotion and marketing within premises

As a nation, we consume too much food and drink that has little to no nutritional value, but which contribute calories or salt to our diet. These "discretionary foods" account for, on average, 379 calories per person per day - that is about one fifth of total calories. They similarly account for about one fifth of total fat and saturated fats and for over half of daily free sugars consumption. ^[28] For good health, we should eat such food and drink less often and in smaller amounts.

Food Standards Scotland ( FSS) advise that we reduce our intake of discretionary foods by at least half. ^[29] To help to achieve this and Scotland's dietary goals, we intend to restrict the promotion and marketing, within premises where these foods are sold, by removing triggers that may encourage their purchase.

Source: Food Standard Scotland

Action 2.1 The Scottish Government will in autumn 2018 consult on detailed plans to restrict the promotion and marketing of targeted HFSS foods, within premises where these foods are sold to the public, to inform impact assessments and consideration of legislation to reduce associated health harms.

Some progress has been made through voluntary action, such as some removal of confectionery from some checkouts. However, to deliver the scale and pace of change needed and maintain a level competitive playing field, mandatory measures are required.

The consultation will include seeking views on our intention to focus on food and drink:

• high in fat, sugar or salt
• frequently consumed
• add calories or salt
• but have little or no essential nutrients.

In particular: confectionery, sweet biscuits, crisps, savoury snacks, cakes, pastries, puddings, and sugar containing soft drinks. Views will also be sought on whether to also include ice-creams and dairy desserts.

It will also seek views on restricting their promotion and marketing, including:

• multi-buys: buying a set number of products for a set price, e.g. 2 for £2. Meal deals are a form of this. It would also include buy one get one free and e.g. 3 for 2 offers
• free or free samples
• sale of unlimited amounts for a fixed charge, e.g. unlimited refills
• upselling
• coupons (whether physical or electronic) being accepted (10p/20% off etc.)
• purchase rewards ( e.g. toys, vouchers, loyalty card points, reduced price for another product, competition entry)
• displays at checkouts, end-of-aisle, front of store, island/bin displays, etc.
• promotion of value.

The Scottish Government will explore the scope for relevant restrictions online.

Restricting HFSS advertising

Advertisements for HFSS foods appear more than twice as often in broadcast media as any other type of food and drink adverts, ^[30] and it is clear that the food industry believes that advertising drives sales - the top 18 spending crisp, confectionery and sugary drinks brands put over £143 million a year into advertising in the UK. ^[31]

Advertising has a significant impact in normalising what is acceptable for children in society to eat, fostering habits about:

• what we eat (discretionary foods are the norm);
• when we eat it (snacking culture is the norm); and
• how much we eat (larger portion sizes are the norm).

SGF Healthy Living Programme (Big Breakfast Event Hawick, March 2017)

The Scottish Government recognises that most choices are shaped by our environment and are almost entirely emotional and sub-conscious decisions. We need our society to shift advertising towards healthier options to empower people to make choices in-store that support their wellbeing and that of their family.

In our October 2017 consultation paper, we outlined that as broadcast advertising is currently reserved, we would strongly press the UK Government to ban the broadcast advertising of HFSS foods before the 9pm watershed. We welcome that the UK Government has announced that it will consult on introducing a 9pm watershed on TV advertising of HFSS products and similar protection for children viewing adverts online.

Action 2.2 The Scottish Government strongly advocates that the UK Government, following its consultation, moves quickly to ban the broadcast advertising of HFSS foods before the 9pm watershed.

Action 2.3 The Scottish Government will in 2019 explore the scope for strengthening the Committee of Advertising Practice ( CAP) regulations on advertising HFSS foods online, taking account of the Advertising Standards Authority ( ASA) review due to conclude at the end of 2018.

Action 2.4 The Scottish Government urges the UK Government to work with it and the devolved administrations in considering the right approach to the regulation of online advertising of HFSS foods.

Action 2.5 The Scottish Government will engage with local authorities, transport companies and media agencies to develop a code of practice in 2019, to restrict advertising HFSS foods on sites they manage such as bus shelters, stations and inside buses and trains.

Action 2.6 We will consider the ASA's review of the implementation and impact of the CAP code on non-broadcast advertising of HFSS foods and, if insufficient progress has been made, will consider what action we can take to protect children from exposure to HFSS food and drink advertising. The Scottish Government will continue to call for the CAP to adopt PHE's forthcoming nutrient profile model, revised in line with the latest scientific evidence.

Action 2.7 The Scottish Government requests that the ASA strengthen the implementation of its CAP code by removing advertising of HFSS foods within a radius of 800 metres of any site with 25% or more footfall by under 16 year olds, including schools.

Restricting the use of licensed characters, brand equity characters and celebrities

Despite a welcome strengthening of the UK's advertising codes, we still see characters from the latest movie blockbuster appearing on children's chocolate and brand equity characters ^[32] advertising cereals high in sugar.

It is clear that current restrictions do not go far enough. Restrictions on packaging and in-store are inconsistent with those for advertising. And for those advertising restrictions, there exists a discrepancy between licensed ^[33] and unlicensed (or equity) characters, creating a loophole that allows brands to use cartoon characters to market HFSS products.

Action 2.8 The Scottish Government urges the UK Government to pursue measures to restrict the use of licensed characters, brand equity characters ^[34] and celebrities to promote HFSS foods to children.

Developing and implementing an Out of Home Strategy to support healthier choices

It has never been more convenient to eat food out of the home. In 2015 alone, there were 948 million visits to out of home establishments in Scotland – up 3% on the previous year. ^[35] But is it too easy to buy cheap, fast food? 91% of consumers think so. ^[36] Many of the top food and beverages consumed out of home in Scotland tend to be less healthy, including chips/french fries, burgers and regular cola. Children between 0-12 yrs consume these types of foods more often than adults in out of home settings. ^[37]

Source: Food Standards Scotland Situation Report 2018

Bridgend Inspiring Growth

With more than 30,000 ^[38] out of home food outlets in Scotland, the role that the out of home sector can play should not be underestimated. Establishments that embrace healthier options with fewer calories, provide clear nutrition information and offer a greater proportion of smaller portion sizes will help Scotland to progress towards its dietary goals.

Action 2.9 FSS will in autumn 2018 consult on an Out of Home ^[39] ( OoH) strategy, in parallel with the Scottish Government consultation on the promotion and marketing of targeted HFSS foods. The OoH consultation will focus on how to encourage calorie reduction and measures to encourage food outlets to provide better information to customers, including calorie information on menus. It will also include the role the public sector can play as an exemplar in healthier food provision.

Helping our understanding of nutrition labelling

Action to drive the purchase of healthier food options in shops and catering outlets relies on consumers making informed choices. The Scottish Government, in concert with other UK administrations, launched the voluntary Front of Pack colour-coded nutrition labelling scheme in 2013, enabling consumers to easily see whether a product is high in fat, salt or sugar. Around two-thirds of packaged foods in supermarkets display the Front of Pack label ^[40] but that leaves many products, including many discretionary foods high in fat, salt and sugar, without this consumer-friendly information.

Action 2.10 The Scottish Government will urge the UK Government to push for mandatory Front of Pack labelling that would help consumers easily identify healthier and unhealthier foods.

Action 2.11 To support people to better understand nutrition labelling, FSS will in 2019/20: (i) conduct research among consumers with a view to running a consumer education marketing campaign on nutrition labelling; and (ii) engage with health and education networks to support relevant professionals to encourage consumers to use nutrition labels to make healthier choices.

Controls over food outlets near schools

As set out in the Scottish Government's Public Health Priorities, we want the places and spaces where people live to support them to lead healthy lives. The area around schools is an environment where we want to make a positive change in the habits of young people at lunchtimes and on the way to and from school. One possible lever available to us is planning policy. We will continue to explore how it could be used alongside other measures to encourage healthier choices and discourage unhealthy ones.

Action 2.12 As part of its forthcoming review of Scottish Planning Policy, the Scottish Government will take into account its commissioned research, to be published this summer, on the relationship between the food environment and the planning system, including how food outlets near schools can be better controlled. The next version of Scottish Planning Policy is expected to be published in 2020.

Source: Public attitudes towards reducing levels of overweight and obesity in Scotland

Reformulation of products to reduce risks of public health harm

The Scottish Government welcomes the steps taken by Public Health England to encourage larger companies to reformulate their products. However, given that 95% of Scottish companies in the food and drink manufacturing sector are small and medium-sized enterprises ( SMEs) ^[41] , it is important that this sector also plays its part, not just for the health of our nation but to enhance our reputation as a producer of healthier quality produce using the latest innovative practice. Consistent with the aims for responsible growth for the Scottish food and drink sector set out in Ambition 2030, the Scottish Government will work with partners over the next three years and invest £200,000 to support SMEs reformulate commonly consumed products.

Action 2.13 A dedicated Reformulation Connector will be embedded within the Make Innovation Happen Programme to link companies to existing support, such as academia through the Scottish Funding Council and wider business support through the Scotland Food and Drink Partnership.

Action 2.14 The Scottish Government will lead a Ministerial summit in late 2018, to raise awareness of the commercial benefits and costs associated with reformulating. The summit will feature new research from Food and Drink Federation Scotland who will revisit companies that have already reformulated products, and fresh market insights from the Make Innovation Happen Insights Programme. ^[42]

Restricting the sale of energy drinks to young people under the age of sixteen

The Scottish Government recognises that consumption of energy drinks is a significant concern to parents, teachers and young people. These concerns go beyond the high sugar content that most of these drinks have. Teaching unions report issues with behaviour ^[43] and the last European Food Safety Authority study indicates significantly higher consumption in the UK than our European neighbours. ^[44]

Action 2.15 The Scottish Government welcomes the leadership shown by many retailers in restricting the sale of energy drinks to young people under the age of 16 and urges those who have not yet taken this action, to do so. We will work with Sporta, the co-ordinating body for leisure trusts on whether similar measures can be taken in the 1,300 facilities their members manage in Scotland.

Action 2.16 The Scottish Government will consult on restricting the sale of energy drinks to young people under the age of 16.

Fiscal measures that encourage healthier choices

The Soft Drinks Industry Levy ( SDIL) provides an exemption for milk-based drinks containing more than 75% milk. While milk and milk-based drinks can play an important role in a child's diet, for some products that nutritional benefit can come with a significant increase in sugar consumption. This has been partially addressed by the addition of a milk-based drinks category to the PHE's voluntary reformulation programme, however, the Scottish Government remains concerned that this will not sufficiently address the high levels of sugar currently being consumed through these products.

The SDIL has led to a welcome price differentiation between drinks subject to the levy and those that are not, providing consumers with an economic driver to make healthier choices.

Action 2.17 The Scottish Government urges the UK Government to extend the SDIL to include sugary milk-based drinks, including dissolvable powders containing less than 95% milk, if these drinks do not meet their 20% Public Health England ( PHE) Reformulation Programme sugar reduction target by 2020.

Action 2.18 The Scottish Government urges the UK Government to take appropriate action if it becomes clear that industry will not meet the PHE reformulation targets set for both sugar and calorie reduction.

Action 2.19 The Scottish Government urges the UK Government to further use the tax system to make healthy food cheaper and to reduce the purchase of HFSS foods, and to devolve the necessary competences to the Scottish Parliament in this area to ensure a fuller range of levers are open for consideration.