Submissions

SPECTRUM submitted a response to the Scottish Government consultation on alcohol advertising and promotion.

The Scottish Government should take action to restrict the marketing of unhealthy commodities where it can. For example, outdoor advertising (on billboards, bus stops), advertising on transport and sports and events sponsorship. Scotland should also seek to support new legislation to restrict the marketing of unhealthy products, like alcohol, at UK level, and push for the UK Government to go further wherever possible.

We recommend that a complete and comprehensive ban on alcohol marketing be introduced in Scotland. This is the simplest option for implementation and enforcement whilst protecting the majority of the population from exposure to alcohol marketing.

It is recommended that statutory regulation be implemented, as there is extensive research as to the ineffectiveness of self-regulatory and co-regulatory measures for regulating advertising of unhealthy commodities.

SPECTRUM consultation response: Alcohol advertising and promotion in Scotland

In advance of the Budget on 15th March 2023, ASH and SPECTRUM submitted a joint representation to HM Treasury backed up by a Cost Benefit and Public Finance analysis of the cost of smoking and benefits of achieving the Government’s smokefree 2030 ambition.

Key findings

• The cost of smoking to public finances (£21 bn) is nearly double the revenue raised by tobacco taxes (£11 bn)
• Spending £125 million a year to deliver a smokefree 2030 could provide a net benefit to public finances of £5.3 billion by 2030a cost-benefit analysis of this investment found a net benefit to society over 50 years of £775.7 billion.
• Four Tobacco transnationals (PMI, BAT, Imperial and JTI) are responsible for around 95% of cigarette sales in the UK and the same proportion of deaths from smoking. They should be made to pay to deliver a smokefree 2030.

Key recommendations

• Government should find the £125 million a year needed to implement the Khan review recommendations to deliver a smokefree 2030.
• HMT should implement a corporation tax surcharge on tobacco manufacturers’ profits in this Budget, which could raise ~£74 mn.
• Government should legislate to impose a ‘polluter pays’ levy on tobacco manufacturers to raise ~£700 million a year for the public purse.

Read the joint submission on the ASH website

SPECTRUM submitted a response to the Scottish Government consultation on restricting promotions of food and drink high in fat, sugar or salt (HFSS). A restriction on the promotions of HFSS products is supported by 62% of the public in the UK. To meet the Scottish Government’s target of halving childhood obesity by 2030, policy action needs to be bold and ambitious. The intention needs to be significant dietary change with a focus on creating the environments which support that change. 

SPECTRUM consultation response: Restricting HFSS promotions in Scotland

Supported by the University of Bath, SPECTRUM responded to the European Commission’s latest round of scrutiny on Ireland’s alcohol labelling legislation. 

Ireland’s Draft Regulations under Section 12 of the Public Health (Alcohol) Act 2018 supports, guides and reinforces the objectives of the European Union as a whole to reduce alcohol related harms and promote the health and safety of its citizens.

SPECTRUM response: Irish alcohol labelling notification

SPECTRUM submitted a response to the Scottish Government consultation on the Mental Health and Wellbeing Strategy. Our primary interest in the Mental Health and Wellbeing Strategy is in its potential to promote preventative action at a population level which will both support better mental health and wellbeing for all and contribute to reducing the burden of ill health from NCDs.

Our response highlights the link between smoking and mental ill-health and emphasises the need for policy coherence across the refreshed Mental Health and Wellbeing Strategy, the refreshed Tobacco Control Action Plan, other public health strategies, and the new National Planning Framework for Scotland to promote shared commitments to reducing the burden of NCDs on people’s physical and mental health and wellbeing.

SPECTRUM consultation response: mental health and wellbeing strategy Scotland

SPECTRUM submitted a response to a Welsh Government consultation, exploring proposals to make the food environment in Wales healthier. Our response highlights the importance of public health population level measures to stem the rising rates of overweight and obesity in children and adults in Wales, and across the UK. For example through restrictions on promotions, the placement of HFSS products in retail areas, and mandatory calorie labelling.

SPECTRUM consultation response: healthy food environment Wales

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.

SPECTRUM consultation response: mental health and wellbeing plan

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.

SPECTRUM consultation response: online advertising programme

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.

SPECTRUM consultation response: MUP Northern Ireland

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.

SPECTRUM consultation response: Tobacco control strategy Wales

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.

SPECTRUM consultation response: health inequalities in Scotland

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.

SPECTRUM consultation response: draft National Planning Framework

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.

SPECTRUM consultation response: transforming the public health system

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

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 products high in fat, sugar and salt (HFSS), to reduce the amount of HFSS advertising children are exposed to online.

SPECTRUM consultation response: online advertising restriction for HFSS products

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.

SPECTRUM consultation response: front-of-pack nutrition labelling in the UK

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 consultation response: approach to duty- and tax-free goods

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.

SPECTRUM consultation response: smoking outside hospital buildings