Restricting the promotion of unhealthy food and drink products in Scotland

19 February 2021

The Restricting Food Promotions Bill was previously devised by the Scottish Government in order to restrict the promotion of unhealthy food and drink products in Scotland. In September 2019, the Scottish Government stated that they would introduce the Bill before this parliament comes to an end – as a step to tackle Scotland’s obesity epidemic. However, on June 11th 2020, it was announced that the Scottish Government would no longer be introducing this Bill due to the impact of the COVID-19 pandemic and the unknown effect of this on Scotland’s food and drink sector.

This blog considers the issues with food and drink promotions, summarises how the UK Government are planning to implement the restrictions in England (detailing which promotions are to be restricted), and why the timely introduction of such legislation is necessary in Scotland.

How do promotions affect consumer behaviour?

Price and location are highly influential factors in customers’ decision to purchase products1. Both price promotions and non-monetary promotions are employed by retailers as a successful tactic to increase the volume of food and drink products being sold2. Public Health England estimate that 34% of food and drink products are sold on promotion in the UK and Scotland.3

Public Health England’s 2020 report on the role of price promotions on the household purchases of food and drinks high in sugar highlighted that promotions are responsible for an 18% incremental increase in the volumes of food we buy in the UK.3 In other words, promotions cause us to buy 18% more food and drink products than we usually would.3 The Consumer Tracking Surveys from Food Standards Scotland have also highlighted the fact that there may be a skew towards unhealthy food being purchased through promotions in Scotland.4 In 2018, nearly half of all crisps and savoury snacks (46%), and over 40% of confectionary and soft drinks with added sugar were sold on promotion.4 In comparison, less than 30% of healthier products such as plain bread, vegetables/salad leaves, fruit, and fish were sold on promotion in each category.4

Commonly used price promotions include: temporary price reductions (TPRs), multibuy deals, and meal deals2. Common non-monetary price promotions include: placement of products in prominent positions, such as at the end of aisles and at checkouts5.

Promotions are to known to disproportionately encourage the sale of food and drinks which are high in fat, sugar and salt (HFSS)6. The promotion of these unhealthy food and drink products is contributing to the UK’s obesity epidemic7. It is estimated that, in Scotland, 32% of the calories and 36% of the fats that we purchase from supermarkets are bought on price promotion7. Further to this, promotions increase the purchase of unhealthy food and drink products most significantly in children and young people8.

Both the Scottish and UK Governments have expressed concerns surrounding food and drink promotions – due to the increased intake of unhealthy food and drink products which promotions are partly responsible for. As a result of this, both Governments have undertaken consultations and action on restricting the promotion of HFSS products, the outcomes of which are detailed below.

What is the UK Government doing to combat this?

Following consultation, the UK Government have announced in their policy paper “Tackling obesity: empowering adults and children to live healthier lives” that they intend to implement legislation to restrict the promotion of HFSS food and drink products in England by April 20229.

This legislation will restrict chosen price promotions and non-monetary promotions of HFSS products both in store and online9. The image below outlines the promotions which will be prohibited following the introduction of the legislation.

Figure 1: UK Government promotion restrictions. Source: UK Government (2020)

The restriction of these promotions of unhealthy products should help to rebalance the number of price promotions in favour of healthier food and drink products9. The implementation of these measures is expected to reduce the purchase and consumption of HFSS products and will be one of several measured needed to aim to reduce obesity levels10.

What is the Scottish Government planning?

The Scottish Government held a consultation from October 2018 - January 2019 regarding the restriction of HFSS promotions. The consultation outcome was overall in favour of the introduction of restrictions and, as a result, in September 2019 the Scottish Government announced their intention to implement these restrictions5.

The Scottish Government planned to implement restrictions on the following promotions - going further than those outlined for England5:

  • Multibuys (including ‘Buy One Get One Free’ and ‘Extra Free’)
  • The sale of unlimited amounts for a fixed charge (e.g. Unlimited refills)
  • Location promotions such as placement of HFSS products at checkouts, end of aisle displays, HFSS products at front of store, island/bin displays, shelf-edge displays
  • In-store advertising
  • Upselling
  • Coupons
  • Free samples
  • Purchase rewards
  • Branded fridges/freezers and display units in store

However, in June 2020, the Scottish Government announced that the introduction of this legislation would be put on hold due to the impact of the Covid-19 pandemic, and the unknown effect that this would have upon the Scottish food and drink retail industry11. Though, the Scottish Government have stated that they do ultimately wish to implement these restrictions in the future11. The introduction of legislation will now not be possible until after the Scottish Parliament election due to be held in May 2021.

Our thoughts on the Scottish Government proposal

Obesity Action Scotland strongly agree with the introduction of these measures to restrict the promotion of HFSS products in Scotland and urge that the legislation be introduced at the earliest opportunity. However, we also believe that the measures could be further strengthened to improve their effectiveness:

  • Firstly, Obesity Action Scotland strongly urge the Scottish Government to change their classification of which foods will be restricted by this legislation. We ask for consideration and alignment with the WHO Euro Model.12 This model classifies products into 17 categories which encompasses virtually all food and drink products.12 Certain categories of food are covered by a blanket restriction based on the category descriptor and other categories have nutrient criteria set. We feel that this would be a more appropriate way to categorise which foods will be promotionally restricted.
  • Obesity Action Scotland also believe that the restriction of temporary price reductions (TPRs) should be included in this legislation. TPRs are the most prominent form of promotion present in Scotland3 and must be addressed.
  • It is also important to note that rebalancing promotions towards healthier food and drink products will only work if the whole industry agrees to act upon this, and that these restrictions must be mandatory to achieve fairness and consistency.
  • We also ask that certain definitions and potential exemptions are strengthened such as “main meals”, multipacks, and “unavoidable” promotion locations. Clarity and strength in these areas will ensure improved food environments. 

Future Actions

In the light of the COVID-19 pandemic and the increased risk to those with obesity13, ensuring healthy weight for all is more important now than ever before.  In the reconstruction of the Scottish economy following the COVID-19 pandemic, we should strive to create a food environment which makes the healthy option the easy option. The introduction of legislation which restricts such promotion of unhealthy products is therefore an important step in transforming the food environment in Scotland and putting the health of the Scottish population first.

Obesity Action Scotland supports the introduction of legislation which restricts the promotion of HFSS products in Scotland and urges the Scottish Government to reintroduce this legislation as soon as possible.



  1. Kaur, A., Lewis, T., Lipkova, V., Fernando, S., Rayner, M., Harrington, R.A., Waterlander, W. and Scarborough, P. (2020). A systematic review, and meta-analysis, examining the prevalence of price promotions on foods and whether they are more likely to be found on less-healthy foods. Public Health Nutrition, pp.1–16.
  2. Food Standards Scotland (2020). Monitoring Retail Purchase and Price Promotions in Scotland (2014 – 2018). [online] Available at: [Accessed 26 Jan. 2021]
  3. Public Health England (2020) An analysis of the role of price promotions on the household purchases of food and drinks high in sugar, and purchases of food and drinks for out of home consumption.


  1. Food Standards Scotland (2020b) Monitoring retail purchase and price promotions in Scotland (2014 – 2018).
  2. The Scottish Government (2018). Reducing health harms of foods high in fat, sugar or salt: consultation. [online] scot. Available at: [Accessed 26 Jan. 2021].
  3. Cancer Research UK (2019). 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. [online] Cancer Research UK. Available at: [Accessed 26 Jan. 2021].
  4. The UK Government (2020). Restricting promotions of products high in fat, sugar and salt by location and price: Government response to public consultation. [online] UK. Available at: [Accessed 26 Jan. 2021].
  5. Martin, L., Angus, K., Mitchell, D., Sharp, C., Bauld, L. (2019). Rapid systematic literature review: Impact of in-premise marketing on consumer purchasing and consumption. [online] NHS Scotland. Available at: [Accessed 26 Jan. 2021].
  6. The UK Government (2020b). Tackling obesity: empowering adults and children to live healthier lives. [online] UK. Available at: [Accessed 26 Jan. 2021].
  7. Revoredo, C. (2020). What can we expect from a ban on junk food price promotions? [online] London School of Economics. Available at: [Accessed 26 Jan. 2021].
  8. The Scottish Parliament (2020). S5W29843. [online] Available at: [Accessed 26 Jan. 2021].
  9. World Health Organization. WHO Regional Office for Europe Nutrient Profile Model. Copenhagen, Denmark:
  10. NHS Inform (2020) Coronavirus (COVID-19): General advice. People at higher risk of severe illness. In: Illnesses Cond. Accessed 4 May 2020