Scotland’s Diet & Healthy Weight Delivery Plan. 5 years on, what has it achieved, and what is the current direction of travel?

Five years ago (2^nd July 2018), the Scottish Government published their Diet & Healthy Weight Delivery Plan.

The Plan sets out a series of actions across 5 outcomes which focus on ensuring children have the best start in life, improving the food environment, access to weight management services, ensuring leaders in all sectors promote diet and healthy weight, and reducing diet-related health inequalities.

Specific actions within the outcomes include the introduction of restrictions on promotions of discretionary high fat, salt and sugar (HFSS) products, restricting the advertising of these products – especially to children, and improving the out of home (OOH) food environment including introducing a new OOH framework.

It reflected a need for action to address the high and growing levels of overweight and obesity in Scotland, and concern of the short and long-term impact on public health. At the time of publication, 65% of adults in Scotland had overweight and obesity, and 27% of children were at risk of overweight and obesity, as recorded in the Scottish Health Survey. This has now risen to 67% for adults and 28% for children in the most recent data. Significantly, the 2021 survey reported 30% of adults living with obesity, and 18% of children at risk of obesity - both figures are the highest ever recorded by the survey. 

Prioritising child healthy weight

Improving the health and weight outcomes of children is a key focus of the Delivery Plan encapsulated in its vision to halve childhood obesity by 2030. This formally laid out the Government’s commitment to the ambition which was announced by then First Minister Nicola Sturgeon in May of the same year. We recently wrote a blog to mark the fifth anniversary of the announcement, in which we asked the question ‘5 years on are we still on track to halve childhood obesity by 2030’? Our answer was almost certainly no, with rates going in completely the wrong direction, with increasing diet and weight inequalities between our most and least deprived children.

However, despite the concerning statistics, there was hope that policy developments focused on the food environment were slowly moving forward. 

If the need for action was clear in 2018, it is even clearer now. In this blog we reflect on where we are now and the urgent need for action if we are to achieve healthy weight for all and provide our children with the healthiest start possible.

A lot can (and does) change in a short period of time

On 30^th May our new Minister for Public Health and Women’s Health, Jenni Minto, made a Ministerial Statement. We tuned into the Statement with a degree of cautious optimism about what would be announced. We hoped for bold and ambitious commitments that would reflect the public health challenge we face. Here is what we heard.

On mandatory calorie labelling, the Government announced a pause to its introduction to enable more evidence to be gathered on its impact. This was expected.

More unexpectedly it was announced they would not be progressing proposals to introduce a mandatory ban on the sale of energy drinks to children under 16 and will instead continue with the current voluntary approach, citing a lack of evidence on the impact. This is both disappointing and concerning, as evidence shows clear linkages between energy drink consumption and a range of adverse outcomes in children and young people, including physical and mental health and wellbeing impacts, lifestyle and behavioural effects, and impact on education attainment. The latest data shows that 9% of young people (ages 11, 13 &15) consume energy drinks every day, up from 5% in 2018 [1]. This is a significant rise in a short space of time and indicates that the current voluntary policy approach has not been effective in preventing children and young people from accessing and consuming energy drinks.

Lastly, the statement turned to restrictions of promotions. This is a policy we must see taken forward if we truly want to start changing the food environment for the better.

The Minister announced that restrictions on promotions will now be introduced through regulations, with a further consultation to be held in the autumn of this year. So, good news that things are progressing and that we can move straight to secondary legislation.

Frustratingly, the consultation to be launched this autumn will be the fourth one on restricting promotions since the Delivery Plan was introduced in 2018 and will be the second consultation in two years. It is also not yet a promise of being the final consultation as the Minister was questioned on this issue recently by the opposition and stated: “It is clear that, to ensure that we make the best policy—which is relatable to everybody and hits the targets and makes the changes that we intend—we have to continue to consult… I cannot promise whether that will be the final consultation, but it is absolutely key to consult in order to get the right policies" [2].

So, what now?

When the Diet and Healthy Weight Strategy was first launched in 2018 our news item at the time was clear that “urgent implementation” was key. This still remains the issue today with implementation the stumbling block on many policy commitments within the plan.

We must ensure that effective regulations are developed and enacted with the urgency that the public health challenge merits. We must also ensure that the scope of the price and location promotions that will be included remains driven by a public health need and includes the types proposed in the previous consultation and those being taken forward by Wales in their recent announcement.

Lastly, we must ensure that the public health needs of Scottish children are not derailed by industry interests.

The Ministerial Statement made multiple references to industry and, separately, Scottish Government has also established a New Deal for Business Group. One of the stated aims of the group is “improving the development and implementation of regulation – such as public health restrictions on advertising and promotions - and properly assessing its impact on particular sectors”. This is a concerning development that indicates that the food and drink industry may have direct influence on the design and development of public health policy. Whilst it is important to acknowledge the role played by industry in the food and drink sector and the need to consult them, it is critical they are not involved in any policy decision making processes, which aim to improve public health. This is a clear conflict of interest.

The first report of the group, published only in the last few weeks, gives a clear indication of the direction of travel. Among its recommendations are a “full and deep dive into the Scottish Government policy development cycle” to emphasise the need to “undertake effective engagement at all stages wherever possible – including pre-policy – particularly when regulation is a potential outcome”, as well as emphasising that voluntary regulations and codes of practice should be pursued before regulation [3]. This is concerning, as the evidence is clear that voluntary approaches to the issues we are concerned about do not work [4], [5], [6], and mandatory regulations will be required to achieve change. We need mandatory interventions to achieve the change needed to the food system that will achieve healthy weight for all.

We need Scottish Government to take urgent and bold action 

The evidence is clear. We need bold and urgent policy action from the Scottish Government to deliver on the commitments within the Diet and Healthy Weight Delivery Plan to improve child health and weight outcomes.  Industry interests cannot be allowed to take priority above children’s health.

The Scottish Government have powers and levers that can make a difference. We need the Scottish Government to act on these powers, taking urgent and bold policy decisions to address the availability, affordability, and acceptability of unhealthy HFSS products, and pursue the statutory interventions required to improve the food environment now and for future generations.

References 

[1] Findings from the HBSC 2022 Survey in Scotland. Health Behaviour in School-aged Children National Report Media_976054_smxx.pdf (gla.ac.uk)

[2] Scottish Parliament Official Report. Meeting of Parliament 15^th June 2023 https://www.parliament.scot/chamber-and-committees/official-report/search-what-was-said-in-parliament/meeting-of-parliament-15-06-2023?meeting=15371

[3] Scottish Government (2023) New Deal for Business Group Report on progress and recommendations June 2023 https://www.gov.scot/publications/new-deal-business-group-progress-report-recommendations/documents/ 

[4] World Health Organisation (2023) Policies to protect children from the harmful impact of food marketing: WHO Guidelines https://www.who.int/publications/i/item/9789240075412

[5] Boyland, E.J and Harris, J.L ‘Regulation of food marketing to children: are statutory or industry self-governed systems effective? Public Health Nutrition, 20(5); 761 -764 https://www.cambridge.org/core/services/aop-cambridge-core/content/view/CE170577FDA4E00AD9B855BFE09D28B0/S1368980017000465a.pdf/regulation-of-food-marketing-to-children-are-statutory-or-industry-self-governed-systems-effective.pdf

[6] World Health Organisation (2022) Protecting children from the harmful impact of food marketing: policy brief https://www.who.int/publications/i/item/9789240051348