Implementation and enforcement of mandatory calorie labelling regulations for the out-of-home sector in England: qualitative study of the experiences of business implementers and regulatory enforcers

Background Mandatory calorie labelling on menus of large out-of-home food outlets was implemented in England on 6 April 2022. Barriers and facilitators that were unforeseen before implementation may modify policy impacts. As part of a process evaluation of the policy, we studied the implementation process, examining business experiences and enforcement by local authorities (LAs) to identify barriers and facilitators in achieving the policy goals. Methods Using purposive sampling, we recruited 11 employees of large food businesses (implementers) and 9 employees of LA environmental health or trading standards departments (enforcers). Post-implementation semi-structured interviews were conducted by video conference. Interviews were audio recorded, transcribed verbatim and analysed using the Framework Method. Results Both groups of participants described a decentralised approach to delivery and enforcement, and resource constraints meant LAs were unable to assist with all business inquiries. Enforcement activity was limited because complaints about labelling from the public were rare, and enforcers prioritized acute food safety issues. Pre-implementation discussions created the presumption among enforcers that most businesses were compliant. Businesses complied to safeguard their reputation and maintain customer trust. While participants supported calorie labelling, potential barriers to policy impact included a presumed lack of customer interest. Financial pressure during implementation strained business resources, and businesses suggested that customers may prioritise financial over health concerns in their decision-making. Conclusions These findings underscore the need for central guidance, verification of adherence, and sufficient enforcement resources. To optimize policy success, future developments should consider economic contexts, customer expectations, and policy refinement, while recognizing common industry arguments against policy implementation. ### Competing Interest Statement The authors have declared no competing interest. ### Funding Statement This independent research was commissioned and funded by the NIHR (NIHR200689, Policy Research Programme). The views expressed in this publication are those of the author(s) and not necessarily those of the NIHR or Department of Health and Social Care. This work was supported by the MRC Epidemiology Unit, University of Cambridge (grant number MC/UU/00006/7). Funders had no role in study design; collection, analysis and interpretation of data; writing the report; and the decision to submit the report for publication. ### Author Declarations I confirm all relevant ethical guidelines have been followed, and any necessary IRB and/or ethics committee approvals have been obtained. Yes The details of the IRB/oversight body that provided approval or exemption for the research described are given below: The Humanities and Social Sciences Research Ethics Committee of the University of Cambridge gave ethical approval for this work. I confirm that all necessary patient/participant consent has been obtained and the appropriate institutional forms have been archived, and that any patient/participant/sample identifiers included were not known to anyone (e.g., hospital staff, patients or participants themselves) outside the research group so cannot be used to identify individuals. Yes I understand that all clinical trials and any other prospective interventional studies must be registered with an ICMJE-approved registry, such as ClinicalTrials.gov. I confirm that any such study reported in the manuscript has been registered and the trial registration ID is provided (note: if posting a prospective study registered retrospectively, please provide a statement in the trial ID field explaining why the study was not registered in advance). Yes I have followed all appropriate research reporting guidelines, such as any relevant EQUATOR Network research reporting checklist(s) and other pertinent material, if applicable. Yes All data produced in the present study are available upon reasonable request to the authors.