Restrict delivery platform HFSS ‘location’ promotion restrictions on delivery platforms
Restrict 'location' promotions on digital food/ drink delivery platforms of food and drinks high in fat, salt, and sugar (HFSS)
-
Very low impact on obesity
Impact refers to the effect on obesity associated with a particular policy intervention.
-
Moderate evidence quality
Evidence refers to the effect on obesity associated with a particular policy intervention.
-
Moderate cost to governments
Cost refers to the effect on obesity associated with a particular policy intervention.
What is the policy?
This policy recommendation aims to restrict the location promotions of food and beverage products that are high in fat, sugar and salt (HFSS) on delivery platforms, by restricting their appearance in prominent locations.
This is applied to any online marketplace, where a customer can make a food and beverage delivery purchase, whether this refers to the businesses’ website if this service is provided or a third-party delivery application that they use. Locations where these restrictions may apply to, include:
- the homepage of a food retail website
- when a consumer is searching or browsing for products
- on a page not opened intentionally by the consumer, such as a pop-up page or a brand burst
- on a ‘favourite products’ page.
Online product positioning has an impact on how likely a customer is to buy them. Location-based promotions incentivise increased purchasing of products or spur impulse buys that customers might not have initially intended. This policy aims to encourage retailers to promote healthier food options online, making it easier for families to choose these healthier products.
Recent context
The legislation, introduced as a component of the National Obesity Strategy published in 2020, aims to make healthier food options more readily available and prominently displayed, with an intention of facilitating a shift from HFSS foods and beverages purchases to healthier non-HFSS alternatives. In 2019 the government initiated consultations aimed at curbing the promotion of HFSS products, both in physical stores and online. The restrictions on product placement came into effect in October 2022. This move is grounded in evidence suggesting that retail price promotions significantly influence consumer choices, and children’s sugar and calorie intake (1, 2, 3, 4). Altering the promotional patterns toward healthier options seems vital for reducing sugar and calorie intake and combating obesity. Medium and large businesses are subject to these regulations, and failure to comply may result in penalties.
In Wales, the consultation on restrictions and promotions of HFSS products also applies to online purchasing, with the intention that the legislation will mirror the location restrictions for online equivalents (for example, pop-up page prompts and at the check-out stage). Online restrictions and promotions are not within the initial legislations that followed this consultation, with the Welsh Government stating that they are reviewing the evidence.
In Scotland, the Scottish Government 2024 consultation on restricting the locations of promotion of HFSS food in retail and out-of-home settings would apply to the equivalent locations online including home pages, certain searching or browsing pages, “popup” pages, favourites pages and shopping basket or checkout pages.
Case studies
The Alcohol Act 2010 (Scotland)
The Alcohol Act in Scotland refers to legislation aimed at regulating the sale and promotion of alcoholic beverages, which came into effect in 2011. The Act bans restrictions on the price and place promotions of alcoholic beverages both in-store and online. This includes in-store placement and price promotional and licensing restrictions as well as price restrictions on online advertising and marketing. This is a minimum unit pricing (MUP) measure, where any alcohol purchases made online or over the phone must comply with the minimum price per unit of alcohol. These regulations aim to make alcohol less affordable to reduce the overall consumption of alcohol and subsequently the alcohol-related harm. The report on the MUP of alcohol in Scotland over five years (2018-2023) concluded that MUP positively impacted health outcomes, reducing alcohol-related deaths by 13.4% and hospital admissions by 4.1%.
HFSS advertising restrictions, Portugal
Portugal introduced advertising restrictions targeting child-oriented physical and digital settings, TV programming where children constitute at least 25% of the audience, and children’s cinema screenings. They also banned child-directed marketing techniques. Portugal is the first country in the European Union to introduce restrictions with a digital component. To monitor children’s exposure to online marketing of HFSS products, Portugal is piloting the CLICK framework, a tool developed by the WHO European Office for the Prevention and Control of Noncommunicable Diseases.
Analysis indicates that HFSS products continue to be advertised on television during non-peak hours and in between family-oriented programming. The findings suggest that expanding restrictions further across mixed audience programming, and adding specificity around what constitutes ‘marketing to children’, could increase effectiveness.
Considerations for implementing policy
TBD
Estimating the population reach
TBD
Cost and benefits
TBD
Costs (5-year)
Effect on inequalities
Access and digital exclusion
This policy aims to make it easier for customers to choose healthier options in online delivery platforms. Focusing on delivery platforms alone, could exacerbate inequalities in people without internet access and those who do not use or don’t know how to use technological devices, marginalising them from healthier choice promotion. It might also exacerbate socioeconomic inequalities, by avoiding the accessibility issue of individuals living in areas with limited delivery service coverage.
On the other hand, a 2019 study reported that the number of food outlets that people have access to through the leading online food delivery platform in the UK, is double in people living in the most deprived areas compared to people living in the least deprived areas. With that in mind, this policy can play an important role in improving the diets of people living in the most deprived neighbourhoods.
What works well in combination with this policy?
cards
Sources
| number of studies | Sample Size | Country (Number of studies) | Age range | Intervention and comparison | Magnitude of effect in SD (95% CI) | Magnitude of effect (calorie intake) | Quality of Evidence* |
|---|---|---|---|---|---|---|---|
| High income countries (lab and field settings); Most studies from USA | High income countries (lab and field settings); Most studies from USA | Intervention: larger-sized portions, package, individual unit or item of tableware Comparison: smaller-sized portions, package, individual unit or item of tableware | Outcome of interest: Consumption; Effect size: SMD -0.60 (95% CI -0.84 to – 0.36, P < 0.001 ) | Mean energy intake on an average snack occasion would be -38 kcal (18.9%) with lower proximity (CI: -53 kcal to -23 kcal) | |||
| High income countries (lab and field settings); Most studies from USA | High income countries (lab and field settings); Most studies from USA | Intervention: larger-sized portions, package, individual unit or item of tableware Comparison: smaller-sized portions, package, individual unit or item of tableware | Outcome of interest: Consumption; Effect size: SMD -0.60 (95% CI -0.84 to – 0.36, P < 0.001 ) | Mean energy intake on an average snack occasion would be -38 kcal (18.9%) with lower proximity (CI: -53 kcal to -23 kcal) |
References
[1] Ejlerskov, Katrine T., Stephen J. Sharp, Martine Stead, Ashley J. Adamson, Martin White, and Jean Adams. “Supermarket Policies on Less-Healthy Food at Checkouts: Natural Experimental Evaluation Using Interrupted Time Series Analyses of Purchases.” Edited by Barry M. Popkin. PLOS Medicine 15, no. 12 (December 18, 2018): e1002712. <https://doi.org/10.1371/journal.pmed.1002712.>
[2] Hollands, Gareth J, Patrice Carter, Sumayya Anwer, Sarah E King, Susan A Jebb, David Ogilvie, Ian Shemilt, Julian P T Higgins, and Theresa M Marteau. “Altering the Availability or Proximity of Food, Alcohol, and Tobacco Products to Change Their Selection and Consumption.” Edited by Cochrane Public Health Group. Cochrane Database of Systematic Reviews, August 27, 2019. <https://doi.org/10.1002/14651858.CD012573.pub2.>
[3] Liu, Peggy J., Steven K. Dallas, Matthew Harding, and Gavan J. Fitzsimons. “The Sales Impact of Featuring Healthy Foods, Indulgent Foods, or Both: Findings from a Large-Scale Retail Field Study.” Journal of the Association for Consumer Research 3, no. 3 (July 2018): 346–63. <https://doi.org/10.1086/698329.>
[4] Restricting Checkout, End-of-Aisle, and Store Entrance Sales of Food and Drinks High in Fat, Salt, and Sugar (HFSS) Impact Assessment (IA) Summary: Intervention and Options RPC Opinion: Fit for Purpose <https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1008423/impact-assessment-restricting-checkout-end-of-aisle-and-store-entrance-sales-of-HFSS.pdf>
[5] Shaw, Sarah C, Georgia Ntani, Janis Baird, and Christina A Vogel. “A Systematic Review of the Influences of Food Store Product Placement on Dietary-Related Outcomes.” Nutrition Reviews, June 1, 2020, nuaa024. <https://doi.org/10.1093/nutrit/nuaa024.>
[6] Whitehead, R., S. Greci, H Thomson, G. Armour, K. Angus, and L. Martin. “The Impact of Non-Price In-Premise Marketing on Food and Beverage Purchasing and Consumer Behaviour: A Systematic Review.” Preprint. Public and Global Health, September 16, 2021. <https://doi.org/10.1101/2021.09.13.21258115.>
Mandate health-based standards in public sector catering contracts
Mandate the inclusion of health-based standards in catering contracts that serve public spaces (e.g. hospitals, prisons, social care)