Response 552294013

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Foods that would be subject to restrictions

1. Which food categories should foods promotion restrictions target?

Please select one item
Radio button: Unticked Option 1: Discretionary food categories
Radio button: Unticked Option 2: Discretionary foods + ice cream and dairy desserts
Radio button: Unticked Option 3: Categories that are of most concern to childhood obesity
Radio button: Unticked Option 4: All categories included in the UK-wide reformulation programmes
Radio button: Unticked Don’t know
Radio button: Ticked Other – please specify
Please explain your answer
I do not support restricting any items. If any are to be restricted, then option 1 is preferable. Restrictions will unfairly target lower income households for whom healthy food is more difficult to access and more expensive than less healthy items. The answer is not to make less healthy items more expensive but to make healthier ones less expensive.

2. Should nutrient profiling be used within all targeted food categories to identify non-HFSS foods?

Please select one item
Radio button: Unticked Yes
Radio button: Unticked No
Radio button: Unticked Don't know
Radio button: Ticked Other - please specify
Please explain your answer
I do not support restricting items but if any are to be restricted then I support using nutrient profiling rather than a flat ban across multiple items in a category.

3. If nutrient profiling were used, do you agree with the proposal to only target pre-packed products and non-pre-packed soft drinks with added sugar in respect of unlimited refills for a fixed charge?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Don't know
Radio button: Unticked Other - please specify

Price promotions

4. What are your views on the proposal to include the following within the scope of multi-buy restrictions?

Extra free? Agree Radio button: Not checked Agree Extra free? Disagree Radio button: Checked Disagree Extra free? Don't know Radio button: Not checked Don't know
Meal deals? Agree Radio button: Not checked Agree Meal deals? Disagree Radio button: Checked Disagree Meal deals? Don't know Radio button: Not checked Don't know
Please explain your answer
In a cost of living crisis, extra free and meal deals can be the difference between a household affording a meal and not.

5. What are your views on the proposal to restrict unlimited refills for a fixed charge on targeted soft drinks with added sugar?

Please select one item
Radio button: Ticked Agree
Radio button: Unticked Disagree
Radio button: Unticked Don't know
Radio button: Unticked Other - please specify
Please explain your answer
Unlimited refills on added sugar drinks can be replaced with no added sugar drinks without too much impact on poorer households.

6. Should other targeted foods be included in restrictions on unlimited amounts for a fixed charge?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked No
Radio button: Unticked Don’t know

7. What are your views on the proposal to restrict temporary price reductions (TPRs)?

Please select one item
Radio button: Unticked Agree
Radio button: Ticked Disagree
Radio button: Unticked Don’t know
Radio button: Unticked Other – please specify
Please explain your answer
Temporary price reductions can be the difference between households affording food and not.

8. Are there any other forms of price promotion that should be within scope of this policy?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked No
Radio button: Unticked Don’t know

Location and other non-price promotions

9. Should the location of targeted foods in-store be restricted at:

Checkout areas, including self-service Yes Radio button: Checked Yes Checkout areas, including self-service No Radio button: Not checked No Checkout areas, including self-service Don't know Radio button: Not checked Don't know
End of aisle Yes Radio button: Checked Yes End of aisle No Radio button: Not checked No End of aisle Don't know Radio button: Not checked Don't know
Front of store, including store entrances and covered areas connected to the main shopping area Yes Radio button: Checked Yes Front of store, including store entrances and covered areas connected to the main shopping area No Radio button: Not checked No Front of store, including store entrances and covered areas connected to the main shopping area Don't know Radio button: Not checked Don't know
Island/bin displays Yes Radio button: Checked Yes Island/bin displays No Radio button: Not checked No Island/bin displays Don't know Radio button: Not checked Don't know
Please explain your answers
Not prominently displaying these items can reduce impulse buying but would not remove them as an option

10. Should any other types of in-store locations be included in restrictions?

Please select one item
Radio button: Unticked Yes (please specify)
Radio button: Ticked No
Radio button: Unticked Don't know

11. If included, should the location of targeted foods online be restricted on:

Home page Yes Radio button: Checked Yes Home page No Radio button: Not checked No Home page Don't know Radio button: Not checked Don't know
Favourite products page Yes Radio button: Not checked Yes Favourite products page No Radio button: Checked No Favourite products page Don't know Radio button: Not checked Don't know
Pop-ups, and similar pages not intentionally opened by the user Yes Radio button: Checked Yes Pop-ups, and similar pages not intentionally opened by the user No Radio button: Not checked No Pop-ups, and similar pages not intentionally opened by the user Don't know Radio button: Not checked Don't know
Shopping basket Yes Radio button: Not checked Yes Shopping basket No Radio button: Checked No Shopping basket Don't know Radio button: Not checked Don't know
Checkout page Yes Radio button: Checked Yes Checkout page No Radio button: Not checked No Checkout page Don't know Radio button: Not checked Don't know
Please explain your answers
Likewise with in store, reducing impulse buying can be a good thing as long as the items are still available. Suggesting a cheaper option in a basket should be allowed as should deals on items regularly bought.

12. Should any other online locations be included in restrictions?

Please select one item
Radio button: Unticked Yes (please specify)
Radio button: Ticked No
Radio button: Unticked Don't know

13. Are there other types of promotions (in-store or online) not covered by our proposals for restricting price and location promotions that should be within scope?

Please select one item
Radio button: Unticked Yes (please specify)
Radio button: Ticked No
Radio button: Unticked Don't know

Places that would be subject to restrictions

14. Which places, where targeted foods are sold to the public, should promotions restrictions apply to:

Retail Yes Radio button: Not checked Yes Retail No Radio button: Checked No Retail Don't know Radio button: Not checked Don't know
Out of home Yes Radio button: Not checked Yes Out of home No Radio button: Checked No Out of home Don't know Radio button: Not checked Don't know
Wholesale (where sales are also made to the public) Yes Radio button: Not checked Yes Wholesale (where sales are also made to the public) No Radio button: Checked No Wholesale (where sales are also made to the public) Don't know Radio button: Not checked Don't know
Other outlets Yes Radio button: Not checked Yes Other outlets No Radio button: Checked No Other outlets Don't know Radio button: Not checked Don't know
Please explain your answer
I do not agree items should be restricted in any location.

15. Are there other places/ types of business to which the restrictions should apply?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked No
Radio button: Unticked Don't know

16. Are there other places/ types of business which should not be within the scope of the restrictions?

Please select one item
Radio button: Unticked Yes
Radio button: Unticked No
Radio button: Ticked Don't know

Exemptions to restrictions

17. Do you agree with our proposal to exempt specialist businesses that mainly sell one type of food product category, such as chocolatiers and sweet shops, from location restrictions?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Don't know

18. If exemptions are extended beyond our proposal to exempt specialist businesses that mainly sell one type of food product category, should exemptions be applied on the basis of:

Number of employees Yes Radio button: Not checked Yes Number of employees No Radio button: Not checked No Number of employees Don't know Radio button: Checked Don't know
Floor space Yes Radio button: Not checked Yes Floor space No Radio button: Not checked No Floor space Don't know Radio button: Checked Don't know
Other (please specify) Yes Radio button: Not checked Yes Other (please specify) No Radio button: Not checked No Other (please specify) Don't know Radio button: Checked Don't know
None Yes Radio button: Not checked Yes None No Radio button: Not checked No None Don't know Radio button: Checked Don't know
Don't know Yes Radio button: Not checked Yes Don't know No Radio button: Not checked No Don't know Don't know Radio button: Checked Don't know

19. If you agreed in question 18 that businesses should be exempt from location restrictions based on number of employees, what size of business should be exempt?

Please select one item
Radio button: Unticked All businesses in scope of restrictions, i.e. no exemptions based on employee number
Radio button: Unticked All in scope except businesses with fewer than 10 employees (micro)
Radio button: Unticked All in scope except businesses with fewer than 50 employees (small and micro)
Radio button: Ticked All in scope except businesses with fewer than 250 employees (medium, small and micro)
Radio button: Unticked Other – please specify
Please explain your answer.
I don’t support this for any business but if it is implemented then small businesses should be exempt.

Enforcement and implementation

22. Do you agree with the proposal that local authorities are best placed to enforce the policy?

Please select one item
Radio button: Unticked Yes
Radio button: Unticked No
Radio button: Unticked Other - please specify who
Radio button: Ticked Don't know

24. What do you think would be an appropriate lead-in time to allow preparation for enforcement and implementation of the policy?

Please select one item
Radio button: Unticked 6 months
Radio button: Unticked 12 months
Radio button: Unticked 18 months
Radio button: Ticked 24 months
Radio button: Unticked Other – please specify
Radio button: Unticked Don’t know

25. Are there any further considerations, for example as a result of the coronavirus pandemic, EU exit or rise in cost of living, that need to be taken into account in relation to enforcement?

Please explain your answer
Cost of living is a critical point. When people are struggling to eat it is not the time to remove any deals or multi buys.

Legislative framework

26. Do you agree that Scottish Ministers should be able to make provision in secondary legislation, following consultation, to regulate in relation to specified less healthy food and drink and to arrange for enforcement (including the setting of offences and the issuing of compliance notices and fixed penalty notices)?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Don't know

Impact Assessments

27 . What impacts, if any, do you think the proposed policy would have on people on the basis of their: age, sex, race, religion, sexual orientation, pregnancy and maternity, disability, gender reassignment and marriage/civil partnership?

Comment
This policy will negatively impact people in poverty. Poverty disproportionally effects disabled people and racialised people, as well as LGBTQ+ people, so this policy will negatively impact those groups.

Question 28 . What impacts, if any, do you think the proposed policy would have on people living with socio-economic disadvantage? Please consider both potentially positive and negative impacts and provide evidence where available.

Comment
Huge negative impact on people living with socio-economic disadvantage. When people may not be able to afford food for balanced meals (or not have time to cook from scratch each day due to work or caring responsibilities) taking away deals that might be the difference between affording a meal and not is not the answer.

Monitoring and Evaluation and other comments

31. Please outline any other comments you wish to make on this consultation.

Comment
This policy needs to be put on hold until the current crisis on cost of living is resolved. Only then would it be appropriate to move forwards and even then we should concentrate on making healthy foods more readily available and cheaper rather than restricting what we consider less healthy.

About you

Are you responding as an individual or an organisation?

Please select one item
(Required)
Radio button: Ticked Individual
Radio button: Unticked Organisation