SOA NPM Consultation Response - June 2026

On behalf of the Scottish Obesity Alliance, we welcomed the proposal to apply the updated NPM to advertising and promotion restrictions, highlighting the importance of ensuring that policy reflects the latest evidence on diet, health and the impact of food marketing on children.

We support the updated NPM as an important step towards strengthening protections for children from the marketing of less healthy food and drink. We also highlight the need for greater consistency across UK policy, including alignment with Scottish regulations, to ensure that differences in how ‘less healthy’ products are defined do not undermine public health measures.

Key points in our response:

• We welcome the application of the updated 2018 NPM, which better reflects current dietary recommendations, including the evidence on free sugars, energy density and fibre, and will bring additional high-sugar products within the scope of restrictions.
• Reducing children’s exposure to the marketing of less healthy food and drink is important for tackling childhood obesity and wider diet-related conditions, including tooth decay, type 2 diabetes and cardiovascular disease.
• The current NPM is based on evidence and dietary guidance that is more than two decades old and contains gaps which allow some high-sugar products to fall outside existing restrictions. The updated model would help address these loopholes and reduce ‘health halo’ effects.
• We believe there is a need to go further, including bringing products such as sweet spreads and savoury pastries within scope, and addressing forms of marketing such as brand and outdoor advertising that are not currently covered.
• Children and young people are particularly vulnerable to the influence of food marketing. Strengthening restrictions has the potential to support healthier dietary behaviours from an early age and improve health outcomes across the life course.
• We are concerned that Scotland could be left behind if the updated NPM is not adopted across relevant Scottish policies. Scotland’s Food (Promotion and Placement) (Scotland) Regulations 2025 are currently based on the older NPM, creating a risk of divergence in how less healthy products are defined and regulated.
• We are calling for close collaboration between the UK and Scottish Governments and a clear roadmap for moving to the 2018 NPM across relevant policies, while ensuring implementation of the updated NPM proceeds without delay.
• We support a 12-month implementation period, provided clear technical guidance is published first, including a robust and transparent methodology for calculating free sugars.

The consultation closed on 17 June 2026.