Last week the Scottish government published its bold Diet and Obesity Strategy Consultation. Obesity is a complex challenge to which there is no single solution, and the consultation recognises that only a holistic approach has any chance of success.

Industry action to reformulate and reduce portion sizes has seen great success. Sugar has been reduced by 18% in soft drinks in the last five years and FDF members have introduced a 250-calorie cap on single-serve chocolate confectionery, reducing calories by 10%-15%.

David Thomson

Manufacturers are also supporting the UK government’s ambitious sugar reduction drive to reduce sugar content in products by 20% by 2020. This will significantly impact many products made and sold in Scotland.

There is a balance here - reformulating while maintaining high quality and great taste. Small businesses don’t always have the resources to meet this challenge. The Scottish government’s £200,000 commitment to help SMEs reformulate towards Scottish dietary goals is welcome support, which FDF Scotland and our partners have called for.

The Scottish government has already said it will limit promotions within retail premises in Scotland, and the Scottish parliament has the relevant powers. The consultation asks what types of promotions it should cover - multibuy, 2-for-1 or temporary price promotions - and what foods it should target - single nutrient, high calories or products high in fat, salt or sugar (HFSS). This shows how complex this is, with major implications for both consumers and businesses. Inevitably, the poorest shoppers will be hit hardest. Food and drink businesses will also be affected - promotions allow new products, brands and innovations to get shoppers’ attention in a fiercely competitive market. That’s why I’m urging the Scottish government to consult widely on the financial, practical and legal implications before seeking to change the law.

Another area affected is advertising. As a devolved government, the Scottish government only has some powers to make change. Non-broadcast advertising is mostly devolved to Holyrood, while broadcast advertising is reserved to Westminster. The Scottish government will explore restricting the non-broadcast advertising of HFSS products, in particular in areas where children may see it - eg at visitor attractions or near schools. For broadcast advertising the Scottish government calls on the UK government to ban the advertising of HFSS before 9pm.

This misses the point. Viewing habits have changed and school-aged children now spend more time online than watching TV. That’s why FDF Scotland fully supports the Committee of Advertising Practice’s rules introduced earlier this year that put an end to the advertising of HFSS food in media targeted at children, including online. We believe that putting further controls on advertising in what is already a strictly regulated marketplace would be a huge misfire.

There is a lot to be gained from the consultation and we need to see effective action across all the areas to ensure success.

David Thomson is CEO of FDF Scotland