The consultation, which opened this weekend and will close at the beginning of April, asks stakeholders to comment on the restriction of volume-based promotions, such as ‘buy one, get one free’ offers and free refills. These price promotions “encourage people to buy more than they need”, the DHSC suggested.
The Department is also examining whether restrictions should be introduced on the placement of HFSS products at “main selling locations” in-store, such as checkouts, aisle ends and store entrances.
The consultation asks which businesses, products and promotion types should be included in the restrictions and seeks to develop definitions of HFSS products, prices promotion mechanisms and locations in-store. The DHSC is inviting businesses to share feedback on how they will be able to put these measures into practices and whether any difficulties will arise.
Fighting obesity and NCDs
The consultation follows on from the second chapter of UK’s strategy to tackle childhood obesity, published last summer. A key plank of the strategy was restricting promotions of unhealthy food to tackle the UK's growing childhood obesity problem.
Nearly one in four children are overweight or obese by the time they start primary school. By the time they leave, at age 11, this ratio rises to one in three children.
The health department highlighted the negative consequences that this has for the health of the nation, including higher risks of non-communicable diseases such as type 2 diabetes, heart disease, fatty liver disease and various cancers. It is estimated that obesity related diseases cost the UK £6.1 billion each year. The total cost to society, according to figures quoted by DHSC, is estimated at £27-46 billion per year.
“Our aim is to reduce excessive eating and drinking of HFSS products that can lead to children becoming overweight and obese. We also want businesses to promote healthier food and drink, to help people make healthier choices,” DHSC said.
DHSC will consider the responses to the consultation before setting out next steps and publishing a response paper.
FDF hits out at 'grossly insensitive’ move
Representatives of the food industry reacted angrily to the launch of the consultation, which Tim Rycroft, Food and Drink Federation chief operating officer, said was “grossly insensitive”.
Rycroft said that the DHSC’s move was tone deaf to the concerns of UK food businesses and a “monumental distraction” from the “abyss of a no-deal Brexit”.
“It looks like the Department of Health and Social Care is out of touch with economic realities and with the rest of government, whose sole focus now is preventing the catastrophe of no-deal. This consultation – already late – should have waited until the uncertainty we face is resolved.”
‘Wrong-headed and muddled’
Moreover, Rycroft argued, a ban on promotions is both “wrong-headed and muddled” with the result that it would make shopping more expensive and reduce consumer choice.
“Shoppers love the UK’s, vibrant, good-value, innovative food and drink market, and promotions underpin that. They allow new products and brands to win space on supermarket shelves and help new products to get shoppers’ attention. Limiting the effectiveness of these mechanisms would stifle innovation and lock-in the positions of dominant brands. It would make it harder for challenger brands and start-ups to break into the market,” he insisted.
Promotions also play a role in making food more affordable, Rycroft added. Citing Public Health England data, he suggested people would have to pay an extra £634 per year for the same food if grocery promotions were banned.
He also stressed that food makers have collectively taken on responsibility for making foods healthier through reformulation efforts.
“For more than ten years the food and drink industry has risen to the UK’s significant obesity challenge. Favourite products have been reformulated to reduce sugar, calories, fat and salt. Portion sizes have been limited. Some of these principals have now been adopted as part of Public Health England’s own reformulation programmes.
“Preventing companies from promoting these reformulated, healthier options to consumers would be mad; but that’s what the government wants to do. This is a bizarre and contradictory public health policy.”
Health campaigners dismiss concerns
Health campaigners remained unmoved by the concerns expressed by the food industry, dismissing out of hand the suggestion that promotions will push up grocery costs and potentially hit the poorest consumers hardest.
"Chocolate and sweet confectionery are among the highest contributors of sugar in the British diet, providing together 10% of the total sugar in diets of children (4-10 year olds) and 11% in teenagers (11-18 years). Chocolate confectionery is also among the highest contributor to saturated fat intake, providing 5% of total saturated fat intake in children’s diets (4-10 year olds) and 7% in teenagers (11-18 years), yet they contain little or no nutritional value and contribute to tooth decay and excess calorie intake. These types of products are often on price promotion and widely available, encouraging over-consumption," Kawther Hashem, a nutritionist from Action on Sugar, told FoodNavigator.
Hashem also refuted the suggestion that restrictions on promotions will discourage food makers from reformulating and offering consumers better-for-you products. "If companies do decide to reformulate to healthy (non-HFSS) products, then these products would be allowed to be put on promotion including price promotions such as meal deals, multi-buy and extra-free deals – potentially generating more revenue for them," she argued.
Action on Sugar wants a total ban on the marketing of HFSS products across all platforms, including TV, digital and print marketing.
"HFSS products are heavily promoted in British supermarkets as well as in the out-of-home sector, and it has been found that such promotions increase the amount of unhealthy food and drink people buy by at least 6% of total sugar purchases (i.e. 30kcal per person, per day). This could be prevented if promotions on high-sugar products did not occur. The food industry spends very large amounts promoting, marketing and advertising their unhealthy products. This huge amount of spending dwarfs the £5.2 million annual spent of the government’s healthy eating campaign. Research shows that marketing greatly influences the food children choose to eat," Hashem said.
Promote healthy food, industry urged
Dan Parker, founder of health campaign group Living Loud, acknowledged that limiting BOGOFs could have a detrimental impact on consumers on low incomes - but he argued that price promotions should instead be used as a tool to promote healthy eating.
"Many families on low incomes rely on price promotions to feed their family. If we want to make the healthy choice the easy choice, they need to make the cheapest choice - and price promotions have an important role to play," he told FoodNavigator. "Four million children in the UK live in families which cannot afford healthy food and we work with people with type 2 diabetes who simply cannot afford the low carb diet they need to put diabetes into remission. The government needs to encourage promotions on healthy food, increase access to schemes such as Healthy Start and Alexander Rose vouchers and look at prescribing healthy food to people with type 2 diabetes and other life style related conditions."
Parker argued that the government's current plans don't go far enough to tackle the influence makers of HFSS food wield over buying decisions. "BOGOFS and other price promotions are but one promotional mechanic. The government should also be targeting promotions run on pack by food manufacturers and in restaurants. Prize draws, other competitions, free gifts with purchase and token collection mechanics are designed to normalise increased portion sizes and frequency of consumption.
"We think it is essentially marketing and promotions that drive food choice. We need to use marketing to inspire people to make healthier choices and promotions to encourage people to try new healthy alternatives."
A spokesperson for DHSC told FoodNavigator that the government wants to encourage the use of promotions on healthy products to support its efforts to tackle obesity.
A Department of Health and Social Care spokesperson said:
“Families doing their weekly shop face a barrage of promotions for sugary and fatty foods that make it very hard to make healthier choices – which is why we are consulting on options to put restrictions in place. We want to encourage businesses to promote healthier products like fruit and vegetables instead as part of our commitment to halving child obesity by 2030.”
Positive promotions: Veg Power launches ad campaign
With much attention in the UK focused on the role of marketing and promotions in the obesity epidemic, healthy eating coalition Veg Power, is launching its own initiative to encourage people to up their consumption of fruit and vegetables.
Veg Power is spear-headed by Peas Please, a collaboration between think tank the Food Foundation, Nourish Scotland, Food Cardiff and the WWF. It has secured a broad cross section of support, including the backing of celebrity chefs Jamie Oliver and Hugh Fearnley-Whittingstall as well as advertising executive and founder of Bartle Bogle Hegarty Sir John Hegarty.
Working with television broadcaster ITV, Veg Power is launching a £2 million TV advertising campaign, which will kick off next week (25 January) and focus on promoting higher vegetable consumption.
The campaign has also secured the backing of nine supermarket groups, who have agreed to offer promotions and position in store on fruit and vegetable items.