Our response to Food Standards Scotland board paper on revised position on Mandatory Calorie Labelling in the out of home (OOH) sector - December 2024

In a board paper, published on 18th September 2024, FSS details their revised position on MCL for the OOH sector. The revised position advocates that mandatory calorie labelling is still required for the out of home sector, but for it to be provided on request to the consumer, rather than by default at point of choice.

In our response to the Scottish Government, we highlight our position that MCL needs to be provided at the point of choice by default, with opt-out options available for consumers. 

Our key points are:

• The out of home sector makes a significant contribution to diets and calories consumed in Scotland. Food served tends to be high in calories and in fat, salt and sugar.
• Early action is needed to improve the OOH food environment. FSS’ call for mandatory calorie information is a critical step towards improving the healthiness of the sector.
• A whole population approach is critical to ensure coherence in the delivery of dietary interventions across the life course, diseases and sectors.
• Evidence points to the potential benefits of mandatory calorie labelling/information for improving consumer awareness, encouraging product reformulation, and for population health, which warrants priority consideration.
• FSS’ paper suggests benefits from mandatory calorie information for driving change to improve healthy food content in the OOH sector. Ready access to MCL at the point of choice is critical to equip consumers to access healthier options and sustain the sector’s healthiness.
• Readily accessible mandatory calorie labelling/information at the point of choice (option 2 in the FSS paper) should be the default requirement across OOH premises and locations, with opt-out provisions to address concerns of those living with certain eating disorders.
• International evidence highlights the importance of MCL as a public health intervention, positively addressing obesity, and recognising that any costs of implementation are significantly outweighed by the public health and wider benefits.

In our response, we indicate a preference for option 2 from the three options outlined in the paper, with some adaptations, including menus without calorie information available on request, and offering nutrition information in place of calorie labelling on menu and display boards, to address concerns of those with living and lived experience of eating disorders. 

Read our response here.