Industry responses to unhealthy food retail promotion restrictions: a thematic analysis of two public consultations in Scotland

Objective: Governments are increasingly implementing policies to improve population diets, despite food industry resistance to regulation that may reduce their profits from sales of unhealthy foods. However, retail food environments remain an important target for policy action. This study analysed publicly available responses of industry actors to two public consultations on regulatory options for restricting unhealthy food price and placement promotions in retail outlets in Scotland.

Design: We conducted a qualitative content analysis guided by the Policy Dystopia Model to identify the discursive (argument-based) and instrumental (tactic-based) strategies used by industry actors to counter the proposed food retail policies.

Setting: Scotland, UK, 2017–2019.

Results: Most food and retail industry responses opposed the policy proposals. Discursive strategies employed by these actors commonly highlighted the potential costs to the economy, their industries and the public in the context of a financial crisis and disputed the potential health benefits of the proposals. They claimed that existing efforts to improve population diets, such as nutritional reformulation, would be undermined. Instrumental strategies included using unsubstantiated and misleading claims, building a coordinated narrative focused on key opposing arguments and seeking further involvement in policy decision-making.

Conclusions: These findings can be used by public health actors to anticipate and prepare for industry opposition when developing policies targeted at reducing the promotion of unhealthy food in retail settings. Government action should ensure robust management of conflicts of interest and establishment of guidance for the use of supporting evidence as part of the public health policy process.