Tackling promotions must be next on the list

25 June 2021
We hope to see the re-emergence of the Restricting Food Promotions Bill in Scotland after it was a recent manifesto commitment for the SNP.

We hope to see the re-emergence of the Restricting Food Promotions Bill in Scotland after it was a recent manifesto commitment for the SNP.  The Bill was previously proposed by the Scottish Government in order to restrict the promotion of unhealthy food and drink products in Scotland but on June 11th 2020, it was announced that it would no longer be introduced 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 (including which promotions are to be restricted), and why the timely introduction of such legislation is also necessary in Scotland.

How do promotions affect consumer behaviour?

Price and location are highly influential factors in the likelihood of customers choosing to purchase products1. Both price promotions and non-monetary promotions are employed by retailers as a successful tactic to increase volumes 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 highlighted the fact 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 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 to healthier products such as plain bread, vegetables/salad leaves, fruit, and fish – less than 30% of which was purchased 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 buy 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 products high in fat, sugar and salt (HFSS), the outcomes of which are detailed below.

What is the UK Government doing to combat this?

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

This legislation will restrict chosen price promotions and non-monetary promotions of HFSS products both in store and online9  in businesses that have 50 employees or more. 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 consequently reduce obesity levels10.

What are the Scottish Government’s plans?

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

The Scottish Government planned to implement restrictions on the following promotions5:

  • 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. At that time the Scottish Government stated that they do ultimately wish to implement these restrictions in the future11. During the recent election a manifesto pledge to bring forward legislation to restrict the use of promotions on food and drink high in fat, sugar and salt was made by the SNP.

Our thoughts on the Scottish Government proposal

Obesity Action Scotland strongly agree with the introduction of measures to restrict the promotion of HFSS products in Scotland and urge Scottish Government to progress the introduction of the Bill as soon as possible. We would also urge the Scottish Government to consider extending the scope of the measures to ensure they effectively tackle the incessant promotions we face as follows:

  • Ensuring it includes the food types/food categories that impact on our health
  • Includes measures to tackle temporary price reductions as there are the most prominent form of promotion present in Scotland3.
  • Minimise the exemptions to this legislation and instead support the industry to progress to promote healthier alternatives

Future actions

In the light of the COVID-19 pandemic and the increased risk to those with obesity14, ensuring healthy weight for all is more important now than ever before.  As the Scottish economy recovers from the effects of the COVID-19 pandemic, we should strive to create a food environment which makes the healthy option the easy option. We have seen commitments from the UK Government for steps to tackle TV and online advertising of unhealthy foods.  Corresponding steps to tackle promotions can ensure we move even closer to healthier food environments.  The introduction of legislation which restricts such promotion of unhealthy products is an important step in 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. Find more details on this topic in our updated briefing.



  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: https://www.foodstandards.gov.scot/downloads/MONITORING_RETAIL_PURCHASE_AND_PRICE_PROMOTIONS_2014_-_2018.pdf#page=4 [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.
  4. Food Standards Scotland (2020b) Monitoring retail purchase and price promotions in Scotland (2014 – 2018).
  5. The Scottish Government (2018). Reducing health harms of foods high in fat, sugar or salt: consultation. [online] scot. Available at: https://www.gov.scot/publications/reducing-health-harms-foods-high-fat-sugar-salt/ [Accessed 26 Jan. 2021].
  6. 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: https://www.cancerresearchuk.org/sites/default/files/paying_the_price_-_exec_summary.pdf [Accessed 26 Jan. 2021].
  7. 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: https://www.gov.uk/government/consultations/restricting-promotions-of-food-and-drink-that-is-high-in-fat-sugar-and-salt/outcome/restricting-promotions-of-products-high-in-fat-sugar-and-salt-by-location-and-by-price-government-response-to-public-consultation [Accessed 26 Jan. 2021].
  8. 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: http://www.healthscotland.scot/media/2566/impact-of-in-premise-marketing-on-consumer-purchasing-and-consumption-may2019-english.pdf [Accessed 26 Jan. 2021].
  9. The UK Government (2020b). Tackling obesity: empowering adults and children to live healthier lives. [online] UK. Available at: https://www.gov.uk/government/publications/tackling-obesity-government-strategy/tackling-obesity-empowering-adults-and-children-to-live-healthier-lives [Accessed 26 Jan. 2021].
  10. Revoredo, C. (2020). What can we expect from a ban on junk food price promotions? [online] London School of Economics. Available at: https://blogs.lse.ac.uk/businessreview/2020/08/06/what-can-we-expect-from-a-ban-on-junk-food-price-promotions/ [Accessed 26 Jan. 2021].
  11. The Scottish Parliament (2020). S5W29843. [online] beta.parliament.scot. Available at: https://beta.parliament.scot/chamber-and-committees/debates-and-questions/questions/2020/06/10/s5w29843 [Accessed 26 Jan. 2021].
  12. Scottish National Party (2021), Scotland’s Future. Manifesto for Scottish Parliament Election 2021
  13. World Health Organization. WHO Regional Office for Europe Nutrient Profile Model. Copenhagen, Denmark:
  14. NHS Inform (2020) Coronavirus (COVID-19): General advice. People at higher risk of severe illness. In: Illnesses Cond. https://www.nhsinform.scot/illnesses-andconditions/infections-and-poisoning/coronavirus-covid-19/coronavirus-covid-19-general-advice. Accessed 4 May 2020