A complex systems approach to examining stakeholders’ perspectives on the Food (Promotion and Placement) (England) Regulations

Abstract

Unhealthy dietary patterns pose a significant public health concern. The retail food environment has a key role in driving unhealthy food choices and dietary inequalities. Supermarkets and convenience stores where most households purchase their food, often use prominent locations to promote unhealthy foods. To combat these harmful marketing strategies, the UK government implemented regulations from October 2022. These regulations restrict the placement of foods and drinks high in fat, sugar, and salt (HFSS) at checkouts, aisle ends and store entrances in most retail outlets and online equivalents. These regulations aim to improve population diet and help address childhood obesity. There is, however, limited understanding of the potential effectiveness and impact of these regulations because they are a world first, without comparable regulations. This study addresses this evidence gap by adopting a systems approach to examine the perspectives of stakeholders across the system. Findings provide insights to improve the Food regulations’ implementation and enforcement.
Using a cross-sectional qualitative research design stakeholders (n=106) were interviewed. Purposive sampling and semi-structured interviewing approaches were used with women consumers (n=34), local authority enforcement officers (n=22), business representatives (n=22) and health representatives (n=28). Data were analysed using Braun and Clarke’s thematic analysis and reflexive thematic analysis methods.
Across stakeholder groups, participants were generally positive about the intent of the regulations. Many contextual factors, including the affordability of healthy foods, marketing of unhealthy foods, desire for consumer autonomy in food choice, and wide availability of unhealthy foods, however, were described as limiting the regulations’ effectiveness, evaluation, and acceptability for consumers. Enforcement efforts were considered to be influenced and undermined by limited capacity, regulatory complexity, the onerous nature of compliance assessment, and the relatively low perceived health risk of the regulations. Due to these constraints, local authority enforcement officers reported making use of a light touch approach, raising awareness, and engaging with businesses rather than issuing infringement notices. While some businesses viewed the regulations as an opportunity to invest in reformulations and layout changes, others planned to comply minimally. Businesses highlighted the complexity of the regulations, logistical considerations, and resource constraints, as obstacles to achieving a level playing field. Trade organisations helped to unify businesses’ approaches to compliance. Health representatives appreciated the symbolic shift in food policy from individual responsibility to structural determinants within the food system. Health groups, however, raised concerns about the complexity of the nutrient profiling model, the limited scope of the regulations, and potential to confuse consumers about the healthfulness of products. Concerns about unintended consequences for certain consumer groups, who might miss out on the benefits due to exemptions for out of scope stores, were also raised.
This thesis contributes to timely evidence on systems responses, adaptations, and unintended consequences on world leading regulations to address unhealthy marketing practices. Independent monitoring and evaluation of the regulations, using a comprehensive set of measures to refine the guidance, close loopholes, and ensure relevance to evolving food systems is required. Findings from this study underscore the need for a suite of policies and an appropriate enforcement infrastructure to effectively address the obesity crisis. Future research should engage broad range of stakeholders across the system to develop robust evaluation framework to assess the impact of the regulations on public health outcomes and inform development of future retail policies.

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Identifiers

ORCID for Christina Vogel: orcid.org/0000-0002-3897-3786

ORCID for Janis Baird: orcid.org/0000-0002-4039-4361

ORCID for Emma Roe: orcid.org/0000-0003-4674-2133

ORCID for Wendy Lawrence: orcid.org/0000-0003-1264-0438

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