Policy responses and statements

Name of organisation:

Scottish Government

Name of policy document:

Choosing the Right Ingredients: The Future for Food in Scotland - Discussion Paper

Deadline for response:

25 April 2008

Background: This discussion paper was intended to stimulate thought and debate about food in Scotland. The Scottish Government invited views to help identify the issues which are important to respondents, and how we can best work together to achieve the Government's vision of a future food industry that is fully joined-up throughout the whole supply chain, and that plays an integral part in a healthier, wealthier, safer and stronger, greener and smarter Scotland.

The Scottish Government invited comments on these issues and any other general views on the future of food and drink in Scotland.

COMMENTS ON
SCOTTISH GOVERNMENT
CHOOSING THE RIGHT INGREDIENTS: THE FUTURE FOR FOOD IN SCOTLAND - DISCUSSION PAPER

The Royal College of Physicians of Edinburgh is pleased to respond to the Scottish Government on its discussion paper on Choosing the Right Ingredients: The Future for Food in Scotland.

We are delighted that the Scottish Government is addressing this extremely important issue, and would like to support any initiative that addresses the problems of obesity and nutrition.  This is a major public health problem that is adversely affecting the health of people in Scotland.  This document, “Choosing the right ingredients”, is an excellent starting point to help improve nutrition and health in Scotland. 

There are a number of general issues and specific issues which are worth raising and considering within the context of policy development.

General Issues

1. To improve the nutritional quality of the Scottish Diet we need to (a) produce (b) sell more, and (c) consume more quality food.  This means the focus needs to be marketing and selling as well as production of quality food.  In particular, there is a need for a reduction in total fat and in saturated fat, a reduction in salt and an increase in the provision and consumption of fruits and vegetables.

2. Changes will only occur when changes occur within the food industry.  They need to be involved and mentioned in the document.

3. The evidence suggests that the changes required are not huge.  For instance, a reduction in the total fat consumption in the diet from 38% to below 35% is targeted.  Unfortunately, all these percentages are going in the wrong direction currently.

4. “Safe” food as described in on page 5 can be considered as (a) short-term safety ie microbiological safety, and (b) long-term safety ie nutritional.

5. None of the five main supermarkets are based in Scotland.  This means that the trade and economic links are weaker than in other areas.  This provides great opportunity as these companies may have less influence on strategic policy in Scotland.

6. Alcohol is a major nutritional issue (as well as a social issue), especially in Scotland.  This document would benefit to focus more on some of the alcohol related issues.

7. Scotland is well placed, as many (but not all) of its traditional industries are involved in the production of healthy foods.  This includes a thriving offshore and onshore fishing industry, as well as a strong arable/vegetable farming and berry farming sector.

Specific Opportunities for Action

The general philosophy of the document is excellent.  However, there could be more focus on specific action points.  We appreciate that there may have been a deliberate attempt to avoid being too specific until after the consultation period.  However, there is a definite need to create specific action points, otherwise many of the ideals outlined in this document will not be realised.  We thought it would be useful to raise a number of possible action points which may help in delivering change.  For instance, many of the initiatives outlined on page 11 should be evaluated to see what real change they have effected.

1. As well as supporting vegetable and fruit producers, support is required for marketing and advertising of these products.  For example the “Scottish Berry Project” obtained funding from the Health Department and SEERAD, but lacked adequate funding for adequate marketing, and as a result did not succeed.

2. There could be a tax on advertising high energy foods – 70% of food adverts on children’s TV are for high fat foods.

3. Cost is one of the main drivers of food consumption.  We tax smoking and alcohol, and a tax on poor quality foods should be considered, possibly by:

   1. Taxing foods with more than a certain amount of fat, or saturated fat.

   2. A corporation tax on companies producing foods with high levels of fat, salt and sugar.

   These revenues can be used to subsidise fruit and vegetable production and marketing.

4. Convenience is the other main drivers of food consumption.  Any revenues which subsidise local provision and sales of fruit and vegetables would be welcome.  For instance the Scottish Grocers’ Federation Healthy Living Campaign which promotes healthier food in convenience stores in low-income areas has been successful, but would benefit from further support.

5. Anything which makes it easier for consumers to identify and choose healthy options would be advantageous.  Such initiatives could include:

   1. “traffic lights” coding on food – red for unhealthy, yellow for moderately healthy and green for healthy.  This has been started in some areas but to a very minor degree, and it could be made obligatory for supermarkets to code their food.

   2. Establishing standards for meals and snacks.   It could be agreed or stipulated that all meals sold as “meals” should contain a maximum of 700 calories.

   3. Meals in restaurants could be standardised in a similar way.

6. There should be explicit support for the need for more research into nutrition and food choices.

7. One significant barrier to the efficiency by which producers can operate, and hence the price of the product, is the extent of bureaucracy within the food supply chain from regulatory authorities, supermarkets and food marketing groups.  This could be streamlined, which would encourage more suppliers to be involved and could lower the price of fruit and vegetables.

8. Although there is a tax on alcohol, in real terms it has become cheaper over the years.  There should be consideration of raising tax on alcohol further, especially on alcohols where the consumption has increased significantly over the last 10-20 years, and especially where that is in the young.

9. It may be worth extending the punishments on alcohol related crime.  This could include:

   1. a lower alcohol limit for driving in Scotland (as occurs in most EU countries).

   2. more severe penalties eg immediate driving ban for drink driving - similar to Norway.

   3. Since alcohol-related street crime reflects antisocial behaviour and irresponsibility, it could be linked to points on a driving licence or other broader consequences

A National Food Policy is very much welcomed.  We have indicated a number in which we think this document and future policy could be developed.  We appreciate that these ideas are just a few of many possible approaches.  We have deliberately been specific with some of our ideas so that they could be considered.  We would very much like to engage in any future developments and we believe these issues to be crucial to the health of people in Scotland.

We wish the Scottish Government success with taking forward this initiative.

Copies of this response are available from:

Lesley Lockhart,
Royal College of Physicians of Edinburgh,
9 Queen Street,
Edinburgh,
EH2 1JQ.

Tel: 0131 225 7324 ext 608
Fax: 0131 220 3939

[25 April 2008]