Restricting promotions of food and drink high in fat, sugar or salt: business and regulatory impact assessment - partial

Partial business and regulatory impact assessment of proposals to restrict promotions of food and drink high in fat sugar or salt (HFSS).


Footnotes

1 Please note that we use the term “foods” to mean food or drink, excluding alcoholic drinks. Alcoholic drinks have little/no essential nutrients and those high in sugar could be considered to be within the category of ‘high in fat, sugar or salt’. However, alcohol has its own regulatory regime.

2 Equality, opportunity, community: New leadership - A fresh start - gov.scot (www.gov.scot)

3 McGill et al (2015) Are interventions to promote healthy eating equally effective for all? Systematic review of socioeconomic inequalities in impact

4 Scottish Dietary Goals, March 2016 (gov.scot)

5 The Scottish Diet - It needs to change 2020 update | Food Standards Scotland

6 World Obesity: Addressing weight stigma and misconceptions about obesity in Europe

7 Brown, K. F. et al. The fraction of cancer attributable to modifiable risk factors in England, Wales, Scotland, Northern Ireland, and the United Kingdom in 2015. Br. J. Cancer 118, 1130–1141 (2018). (nature.com)

8 Abdelaal M, le Roux, C and Docherty, N (2017). Morbidity and mortality associated with obesity. Annals of Translational Medicine; 5(7): 101: p.1 (ncbi.nih.gov).

9 Global burden of 87 risk factors in 204 countries and territories, 1990-2019: a systematic analysis for the Global Burden of Disease Study 2019 (thelancet.com))

10 Sahoo, K, Sahoo, B, Choudhury, AK, Sofi, NY, Kumar, R, Bhadoria, AS (2015). Childhood obesity: causes and consequences. J Family Med Prim Care. 2015 Apr-Jun; 4(2): 187–192

11 The Scottish Health Survey 2022: summary report - gov.scot (www.gov.scot)

12 Diet, nutrition and the prevention of excess weight gain and obesity - PubMed (nih.gov) (2004); Tackling obesities: future choices - mid-term review (publishing.service.gov.uk) (2007)

13 Leigh Sparks and Steve Burt, University of Stirling for Food Standards Scotland, Identifying and Understanding the Factors that can Transform the Retail Environment to Enable Healthier Purchasing by Consumers (2017) (foodstandards.gov.scot)

14 Consumption of discretionary foods and drinks and other categories of dietary concern in adults (16+ years) | Food Standards Scotland

15 Rapid Evidence Review - Restriction of Price Promotions (healthscotland.scot) (2017); Food marketing exposure and power and their associations with food-related attitudes, beliefs and behaviours: a narrative review (who.int) (2022)

16 Restricting promotions of food and drink high in fat, sugar or salt: consultation - gov.scot (www.gov.scot)

17 McGill et al (2015) Are interventions to promote healthy eating equally effective for all? Systematic review of socioeconomic inequalities in impact. BMC Public Health. 2015 September 15; 15: 894

18 Food Standards update (2016) Diet and nutrition: proposals for setting the right direction of the Scottish diet

19 Scottish Government, October 2017 A healthier future - action and ambitions on diet, activity, and healthy weight: consultation - gov.scot (www.gov.scot)

20 Scottish Government, April 2018 A Healthier Future: analysis of consultation responses - gov.scot (www.gov.scot)

21 Scottish Government, October 2018 Reducing health harms of foods high in fat, sugar or salt: consultation - gov.scot (www.gov.scot)

22 Discretionary foods are those that provide little or no nutritional benefit and are not necessary for a healthy diet. Examples include confectionary, crisps, pastries, cakes, sweet biscuits and soft drinks with added sugar.

23 Scottish Government, September 2019 Reducing health harms of foods high in fat, sugar, or salt: consultation analysis - gov.scot (www.gov.scot)

24 Restricting promotions of food and drink high in fat, sugar, or salt: consultation analysis - gov.scot (www.gov.scot)

25 Briefing paper on Discretionary foods (foodstandards.gov.scot)

26 Reducing Health Harms of Foods High in Fat, Sugar or Salt: Consultation Paper (www.gov.scot)

27 IBDR extract provided by Scottish Government business statistics team

28 Sourced from report in preparation from Food Standards Scotland

29 Food Standards Scotland, Analysis of data from Kantar Worldpanel, Purchase Panel, Scotland 2022 (report in preparation)

30 Weighing the impact of HFSS laws (kantar.com)

31 Extracted from Nomis - Official Census and Labour Market Statistics (nomisweb.co.uk) on 30 November 2023

32 Earnings and working hours - Office for National Statistics (ons.gov.uk)

33 Earnings and hours worked, occupation by four-digit SOC: ASHE Table 14 - Office for National Statistics (ons.gov.uk)

34 Reducing health harms of foods high in fat, sugar or salt: economic modelling – final report - gov.scot (www.gov.scot)

35 Food Standards Scotland, Analysis of data from Kantar Worldpanel, Purchase Panel, Scotland 2022 (report in preparation)

36 Scotland's Census 2022 - Rounded population estimates | Scotland's Census (scotlandscensus.gov.uk)

37 Food Standards Scotland, Analysis of data from Kantar Worldpanel, Purchase Panel, Scotland 2022 (report in preparation)

38 Foods failing a NPM test from Table 9 of Annex A -The 2018 review of the UK nutrient profiling model (publishing.service.gov.uk)

39 Non-weighted average of chocolate confectionery and sugar confectionery

40 Non-weighted average of all soft drink categories excluding water, still/sparking and flavoured

41 Non-weighted average of breakfast cereal high fibre and breakfast cereal other

42 Assumptions taken from UK Government impact assessment, which in turn was based on 2017 IGD study of German supermarkets. The impact assessment notes the lack of UK specific information.

43 Sales impact of displaying alcoholic and non-alcoholic beverages in end-of-aisle locations: an observational study - PubMed (nih.gov)

44 Hollands G.J. et al. Altering the availability or proximity of food, alcohol and tobacco products to change their selection and consumption (core.ac.uk)

45 Supermarket policies on less-healthy food at checkouts: Natural experimental evaluation using interrupted time series analyses of purchases | PLOS Medicine

46 Impact assessment of restricting checkout, end-of-aisle, and store entrance sales of food and drinks high in fat, salt, and sugar (HFSS) (publishing.service.gov.uk)

47 Microsoft Word - FSS - NSP - OOH 2021 Briefing summary word document - Embargoed pdf - 29th November 2022 (foodstandards.gov.scot)

48 This is assumed to be 20% for the lower scenario and 40% for the upper scenario to provide a an illustrative of sensitivity of the estimates.

49 The UK Government impact assessment notes this assumption is uncertain. “We therefore assume that HFSS items removed from checkouts continue to generate 30% of their sales in aisle locations. This is an unevidenced assumption, chosen to be roughly double the figure provided by the German study which was thought to be an under-estimate. No additional evidence or data on how much sales these products will continue to generate within aisles was submitted through the consultation, and due to the commercial sensitive nature of the data, we were not able to gather it through further stakeholder engagement. This assumption was further tested with stakeholders, but received no responses.” Impact assessment of restricting checkout, end-of-aisle, and store entrance sales of food and drinks high in fat, salt, and sugar (HFSS) (publishing.service.gov.uk)

50 Including meal deals and Temporary Price Reductions

51 Earnings and hours worked, region by occupation by four-digit SOC: ASHE Table 15 - Office for National Statistics (ons.gov.uk)

52 Scottish Authority Food Enforcement Re-Build paper from FSS Board meeting 25 October 2022 (foodstandards.gov.scot)

53 Final Business and Regulatory Impact Assessment, Alcohol (Minimum Pricing) (Scotland) Act 2012, The Alcohol (Minimum Price per Unit) (Scotland) Order 2018 Final Business and Regulatory Impact Assessment (BRIA) (www.gov.scot)

54 The model is only quantifying the benefits of reduced calories and not any of the other potential nutritional benefits from the policy

55 Reducing health harms of foods high in fat, sugar or salt: economic modelling – final report - gov.scot (www.gov.scot)

56 Estimation of food and nutrient intakes from food purchase data in Scotland between 2001 and 2018 | Food Standards Scotland

57 Executive summary - Reducing health harms of foods high in fat, sugar or salt: economic modelling – final report - gov.scot (www.gov.scot)

58 the term “policy measure” or “measure” refers to any proposed or existing policy, regulation, law or other government intervention

59 ONS, DBR extract for March 2021. Includes registered private sector businesses only for selected SIC codes identified by SG officials.

60 Industry Sector - Businesses in Scotland: 2022 - gov.scot (www.gov.scot)

61 Situation Report - The Scottish Diet: It Needs to Change (2020 update) (foodstandards.gov.scot)

62 Evidence summary - Restricting promotions of food and drink high in fat, sugar or salt: consultation - gov.scot (www.gov.scot)

63 Consultation on Restricting Promotions of Food and Drink High in Fat, Sugar or Salt (www.gov.scot)

64 Global, regional, and national comparative risk assessment of 84 behavioural, environmental and occupational, and metabolic risks or clusters of risks, 1990–2016: a systematic analysis for the Global Burden of Disease Study 2016 - The Lancet

65 Discount rates and the monetised value of a QALY are given in the HMT green book.

66 Based on DHSC Calorie Model 3.1.2, Evidence note - GOV.UK (www.gov.uk), used with assistance and permission gratefully received from the UK Department of Health and Social Care (DHSC)

Contact

Email: dietpolicy@gov.scot

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