48.In PHE’s 2015 report “Sugar reduction: the evidence for action”, addressing price promotions was the first recommendation that a successful sugar reduction programme should include:
1. Reduce and rebalance the number and type of price promotions in all retail outlets including supermarkets and convenience stores and the out of home sector (including restaurants, cafes and takeaways).
49.Evidence shows that price promotions are more common in the UK than in other European countries and that they are most common for unhealthy foods and snacks. Research has indicated that promotions are the most salient form of marketing for young people. The Association of Directors of Public Health in written evidence argued
Price promotions increase the amount of food and drink people buy by one-fifth (22%) and around 6% of total sugar purchased (equivalent to 7.4g per individual per day) could be prevented if promotions on higher sugar products did not occur.
50.NHS Scotland’s 2017 rapid review paper ‘The impact of promotions on high fat, sugar and salt (HFSS) food and drink on consumer purchasing and consumption behaviour and the effectiveness of retail environment interventions’ argues that price promotions increase the volume of food or drink purchased during a single shopping trip and do not lead to a reduction in the frequency of purchasing at subsequent trips. The report also suggested that increases in the volume of food and drink purchased on promotion did not result in reductions in purchases of other high fat, salt and sugar foods and drinks.
51.Despite this, Government action on the regulation of price promotions has so far remained entirely voluntary. In its 2017 (follow-up) report, our predecessor Health Committee concluded:
We are extremely disappointed that the Government has not regulated to provide the “level playing field” on discounting and price promotions which industry representatives themselves have told us is necessary for the greatest progress. We urge the Government to follow the evidence-based advice from their chief public health advisers and to regulate to further reduce the impact of deep discounting and price promotions on sales of unhealthy food. Retailers who act responsibly on discounting and promotions should not be put at a competitive disadvantage to those who do not.
52.Evidence to this inquiry highlighted the need to distinguish between different types of promotions and their effects on health inequalities. Dan Parker of Living Loud stated in oral evidence,
Where we have to be very careful is that, generally, promotions … have different reasons. Some will be for what is called reach, which is about getting more people to eat it; some are about frequency, which is getting them to have it more often; and some are about volume, which is getting them to eat more, consume more or buy more each time they go.
The interesting thing is that some discounts are just about shifting expiring stock. We have to be exceptionally careful not to stop the shifting of expiring stock, because for our poorest people it is the lifeblood of getting food on their table and it would add to food waste.
Dan Parker summarised this argument in written evidence, stating,
A blanket ban on promotions on HFSS products would disproportionally affect those on low income who often depend on them to make ends meet. We need to stop promotions which seek to increase the frequency and volume of consumption—HFSS products should be banned from using buy-one-get- one-free and buy-one-get-one-half-price promotions.
53.We endorse the findings of our predecessor Committee in calling for Government to regulate to restrict discounting and price promotions on high fat, sugar and salt food and drinks, and particularly those that drive increased consumption, such as multi-buy discounts and ‘extra free’ promotions. Regulation ‘levels the playing field’ so that those who are doing the right thing are not disadvantaged.
54.Feature and display promotions can create a nudging effect (defined as ‘any addition to or modification of the environment that influences consumers in a predictable way without changing economic incentives’). These promotions can change which products are the most visible for consumers and impact on product choice. One audit of supermarkets’ product positioning of snack products in eight developed countries found that the UK had the highest mean total aisle length dedicated to snack food including crisps, chocolate and confectionery, with snack food at over 70% of checkouts. The UK also had the second highest ratio (1.31) of snack foods aisle length to fruit and vegetables aisle length within the supermarkets sampled. This salience of this issue to manufacturers was emphasised to us in oral evidence, where Dan Parker of Living Loud highlighted,
From that positioning—and not just gondola ends but things such as being at three quarter height or being near the check-out—Tesco makes £300 million per year from charging people for placement in store.
55.In 2015, Aldi and Lidl became the first high street retailers voluntarily to ban confectionery from their checkouts, a move subsequently followed by Tesco, Boots and Morrisons in their large stores. Confectionery and other HFSS snacks remain very prevalent at the checkouts in small outlets in a number of settings including garages and convenience stores, many with long chicanes lined by such products.
56.Sustain, a campaign group who provided written evidence to this inquiry, suggest:
The issue for food retailers has reached a tipping point and they know which way public opinion and hopefully the government are going on this.
57.In 2016 the British Dietetic Association published the results of a survey which shows that 75 per cent of the public found having junk food at checkouts ‘annoying’, 83 per cent had been pestered by their children to buy junk food at the checkouts, and 56 per cent of people would be more likely to shop at a supermarket which banned such food from their checkouts.
58.Despite all this evidence, Government action on point of sale promotions has been limited. Before our predecessor Committee in 2017, Chief Executive of Public Health England Duncan Selbie noted:
The argument was had. I have been before you and said that we can present evidence, but Parliament and the Government are there to make decisions. Being right is not sufficient; it is about what you decide to do.
59.We endorse the case made by our predecessor Committee, and by Public Health England, for removing confectionery and other unhealthy snacks from the ends of aisles and checkouts. We heard evidence that public opinion is in favour of Government action on product placement, and from retailers that they want a ‘level playing field’ on regulation. We also call on retailers to end the promotion of high calorie discounted products as impulse buys at the point of sales, particularly in the non-food retail environment. We understand that this cannot be achieved by voluntary action due to the fierce competition in the retail environment, and therefore we recommend that Government commit to regulation.
56 , PHE, 2015
58 Rapid evidence review: The impact of promotions on high fat, sugar and salt (HFSS) food and drink on consumer purchasing and consumption behaviour and the effectiveness of retail environment interventions
59 Health Committee, Childhood obesity: follow-up, Seventh Report of Session 2016–17, HC928 p.25
62 Rapid evidence review: The impact of promotions on high fat, sugar and salt (HFSS) food and drink on consumer purchasing and consumption behaviour and the effectiveness of retail environment interventions p.12
63 Ibid p.12
64 Q163, Dan Parker
65 Boots to remove sweets and chocolate from all checkouts by next month, Mail Online, 11 March 2016
67 Health Committee, Oral evidence: Childhood obesity: follow up, HC 928 (2016-17), Q87
Published: 30 May 2018