Submissions

Includes SPECTRUM responses to consultations and other inquiries

SPECTRUM makes a number of submissions to government, parliamentary committees and other inquiries and consultations related to unhealthy commodities, the commercial determinants of health and health inequalities.

Our responses are developed collaboratively across the consortium and can include submissions led by a particular researcher or research group from SPECTRUM, as well as joint submissions with our partners.

2022

SPECTRUM and Action on Smoking and Health (ASH) submitted a response to the Department of Health and Social Care consultation on mental health and wellbeing, ahead of the development of a new 10-year plan for England. Our response highlights the bi-directional link between mental ill-health and smoking: mental ill-health can lead to people smoking, smoking more and becoming addicted, whilst smoking can also lead to poor/worsening mental health. The 10 Year Mental Health Strategy can contribute to wider efforts to reduce smoking rates by setting aspiration for lower smoking among people with mental health conditions and noting the action needed to achieve this.

Responding to a consultation by the UK Government Department for Digital, Culture, Media and Sport, SPECTRUM provided comments on the online advertising programme. The marketing of alcohol and HFSS products has far-reaching implications. It is fundamental that all forms of brand marketing are explicitly covered by new online advertising regulations. The response highlights that the current self-regulation system is not effective, and statutory regulation is necessary to ensure codes are complied with.

A SPECTRUM response was submitted to the Department of Health Northern Ireland Consultation on Minimum Unit Pricing (MUP) of Alcohol in Northern Ireland. Our response highlights evidence from the ongoing evaluation of MUP in Scotland by Public Health Scotland. To deliver greater impact, MUP should form part of a comprehensive alcohol harm reduction strategy. For long-term effectiveness, MUP level should be linked to inflation or affordability.

Responding to a consultation launched by the Welsh Government, SPECTRUM provided comments on the draft long term tobacco control strategy and delivery plan, which aims to achieve a smoke-free Wales by 2030. The consultation response recommends closer consideration of Article 5.3 of the WHO Framework Convention on Tobacco Control, and recognition of the role inequalities and disparities play in driving tobacco use.

A SPECTRUM response was submitted to a Scottish Parliament Health, Social Care and Sport Committee inquiry into health inequalities in Scotland. The submission recognises that despite bold policy action taken by Scotland over the past 20 years to address the burden of harm from NCDs, such as smoke-free legislation and minimum unit pricing for alcohol, much more needs to be done in light of the agenda to build back better after the COVID-19 pandemic.

Responding to a Scottish Government consultation on the draft National Planning Framework 4, the SPECTRUM submission highlights a significant opportunity for place-based policies to help address public health challenges in Scotland.

2021

Action on Smoking and Health (ASH) and SPECTRUM submitted a joint representation to HM Treasury’s Spending Review (SR21) and Budget. The representation is organised around three key areas: strengthening the UK’s tax base, sustainable long-term funding for enhanced public health, and maintaining the UK’s position as a global leader in tobacco control.

Read the response on the ASH website

Action on Smoking and Health (ASH) and SPECTRUM responded to the Office for Product Safety and Standards consultation on the UK’s overarching product safety regulations, so that any prospective reform results in a product safety framework that is fit for the future – protecting people and supporting both growth and investment. Our response focused on concerns about the lack of appropriate regulation of novel nicotine products, in particular nicotine pouches.

Read the response on the ASH website

In May 2021, Action on Smoking and Health (ASH) in collaboration with the Royal College of Physicians and SPECTRUM submitted a response to the New Zealand Government’s consultation on proposed actions to achieve the Smokefree 2025 goal, which will inform the development of the Smokefree Aotearoa 2025 Action Plan.

Read the response on the ASH website

SPECTRUM submitted a response to the DHSC consultation on “Transforming the public health system: reforming the public health system for the challenges of our times” – a paper detailing reforms to the public health system in England.

Action on Smoking and Health (ASH) and SPECTRUM submitted a joint response to the DHSC consultation reviewing the effectiveness of the tobacco and related products legislation introduced between 2015 to 2016. The submission, which concluded that the legislation had been effective but could be strengthened, was underpinned by peer reviewed research carried out by SPECTRUM members. Set out in Appendix 1 of the document is a full list of the 32 recommendations made by ASH and SPECTRUM about how the regulations could be strengthened.

Read the response on the ASH website

Action on Smoking and Health (ASH) and SPECTRUM submitted a joint response to HM Treasury’s consultation ahead of the 2021 Budget. The response’s recommendations focus on strengthening the UK’s tax base, securing greater investment in public health and strengthening the UK’s place in the world as a global leader on tobacco control.

Read the response on the ASH website

2020

Led by Dr Lauren Carters-White, SPECTRUM and the Institute of Social Marketing and Health at the University of Stirling submitted a response to the DHSC consultation on their proposal for a total online advertising restriction for HFSS products to reduce the amount of HFSS advertising children are exposed to online.

SPECTRUM submitted a response to the DHSC consultation on front-of-pack nutrition labelling in the UK. The response includes comments on existing measures, such as the Multiple Traffic Light label, and highlights the influence of child-friendly characters, celebrities and sports stars on packaging.

Action on Smoking and Health (ASH) and SPECTRUM submitted a joint representation to HM Treasury’s Comprehensive Spending Review. The representation is organised around three key areas: strengthening the UK’s tax base, sustainable long-term funding for enhanced public health, and maintaining the UK’s position as a global leader in tobacco control.

Read the response on the ASH website

Led by the Tobacco Control Research Group at the University of Bath, a response was submitted to HM Treasury’s consultation on the potential approach to duty- and tax-free goods arising from the UK’s new relationship with the EU.

SPECTRUM submitted a response to a Scottish Government consultation on the size of no-smoking areas outside hospital buildings, the wording on no-smoking notices and whether specific areas of land or specific buildings should be exempted.