The Climate Change, Environment and Rural Affairs Committee has launched a consultation as part of its inquiry into the management of Marine Protected Areas in Wales. Objectives of the inquiry:
The deadline for responses is 10 February 2017.
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Well… 2016 has left some pretty firm memories and legacies for 2017 and beyond! It is probably inappropriate to attempt to forecast just how 2017 and beyond will perform; suffice to say that one thing I have learned during my term at Wales Tourism Alliance is just how resilient, passionate and tenacious our members are which bodes well for whatever the next 12 months throws at us. I thank you for your support and engagement during 2016 and look forward to building from the sound platform we have created to successfully represent your members and wish you all the very best for 2017. Adrian Barsby, WTA Chair. December 2016 Three organisations representing the tourism industry in Wales have joined forces to urge the Welsh Assembly Members to urgently investigate the issue of rising business rates which they say are a disincentive to future investment. Tourism businesses across Wales are faced with business rate increases of between 40 and 100 per cent next year, putting extreme pressure on them.
The Wales Tourism Alliance (WTA), Wales Association of Self Catering Operators (WASCO) and British Hospitality Association (BHA) are calling on the AMs to support some form of tax exemption for businesses that invest in tourism enterprises. At a recent National Assembly for Wales’ Cross-party Group on Tourism representatives from WTA including Adrian Barsby, Chair, the BHA Chief Executive, David Chapman and WASCO secretary, Jan Meulendijk, former chair of WASCO and its advisor on business rates met with AMs to discuss the issue. Mr Meulendijk gave an in-depth presentation highlighting the escalation of business rates from three per cent of revenue in 2000 to between 12 and 15 per cent. Proposals for 2017 will see his own rates almost double. Self-catering operators will be under even greater pressure to make money during their peak season to compensate for months of lower revenue, just to cover the extra business rates. This should be seen in light of the fact that – unfortunately – out-of-season business has already suffered year on year after the 2008 recession, and even peak-time business has taken serious hits. “It seems many tourism businesses are seeing proposed increases of 40 to 70 per cent, with some exceptional cases more than 100 per cent,” said Mr Barsby. “For larger businesses, this represents many thousands of pounds. Since the business rates were last assessed in 2010, the income of many businesses has not kept pace with cost base increases”. “I think it’s very positive that the three main tourism bodies representing tourism businesses in Wales are in unison on this issue.” The Cross-party Group on Tourism is chaired by Suzy Davies, Conservative AM for South Wales West with Secretariat provided by WTA. Tourism company elects new chairman as five directors join the board A new chairman and five new directors were elected at the annual meeting of an independent organisation that represents 600 tourism and hospitality businesses across Mid Wales. Rowland Rees-Evans, managing director of Penrhos Park at Llanrhystud, near Aberystwyth, steps up from vice chairman to take over the reins of MWT Cymru from Anne Lloyd-Jones, of Tywyn, who stood down after 15 years as chairman. The new directors are Sharon Peake-Jones, co-owner of Pandy Isaf, Dolgellau, Meurig Jones, estate manager at Portmeirion Ltd, Portmeirion, Owen James, owner of holiday cottage 2, Mill Street, Crickhowell, Dylan Roberts, joint managing director of Salop Leisure who lives in Bow Street, Aberystwyth and Louise Lloyd, managing director of Harry’s Hotel, Aberystwyth. They join Ian Rutherford, managing director of King Arthur’s Labyrinth, Corris Craft Centre and Corris Mine Explorers at Corris, near Machynlleth, Paul Boland, manager of Llanerchaeron, a National Trust property near Aberaeron, Neil Bale, of Cyfie Farm, Llanfihangel, near Llanfyllin. Retiring from the board with Mrs Lloyd-Jones are Tony Bywater, chairman of Salop Leisure and William Moeran, general manager of the Trefeddian Hotel, Aberdyfi. “I am really looking forward to the next few months working with the new board members,” Mr Rees-Evans told members meeting at Plas Talgarth Resort, Pennal, near Machynlleth. “We are here to help and learn from each other and to share good ideas.” He emphasised the importance of digital technology to tourism businesses, as a growing number of customers now use mobile phones and tablets to search and book accommodation. “We have to be smart and engage with our customers or they will look elsewhere,” he said. Brexit would create opportunities as well as challenges for tourism businesses and austerity measures would continue to take money out of the local economy, he added. However, with interest rates at a record low, in was an opportunity for business investment to raise quality standards. He pledged to focus on growing MWT Cymru’s membership and to continue the company’s lobbying work to ensure that Assembly Members and MPs were updated on important tourism issues. Val Hawkins, MWT Cymru’s chief executive, highlighted developments during the year and focused on plans for 2017. The Show Me Wales website had recently been updated and a new Visit Mid Wales website would be launched early in the new year with additional features and a wealth of destination information about the region. The new year would see a drive to highlight the great value for money membership benefits, local member meetings and a review of the FairBooking Wales initiative. “Our continual programme of investment in the latest digital marketing technology helps to attract visitors to the region and provides a showcase for our member businesses to gain and maintain competitive advantage in the marketplace,” said Mrs Hawkins. “As we approach our 26th year of trading, our primary focus is to assist members to meet future challenges and opportunities and to work in partnership with other tourism organisations to help develop the tourism economy of Mid Wales and beyond. “Working together makes sense and I support collaboration between the private and public sectors. It is good for individual businesses and for the tourism industry as a whole.” Picture caption: The five new directors of MWT Cymru (from left) Meurig Jones, Sharon Peake-Jones, Owen James, Louise Lloyd and Dylan Roberts. New chairman Rowland Rees-Evans. Nations Brand Index: The headline finding is that the UK suffered the biggest overall fall in perception of any of the top 10 countries. It turns out that the biggest contributor to that fall was the decrease in how overseas countries viewed the UK’s Governance, which was down 4 places from 6th to 10th.
The news is somewhat better for the tourism-related aspects of the report. While the UK is down 2 places to 7th in terms of how welcoming the people of the UK are perceived, the perception of the UK as a tourism destination is only down one place (from 4th to 5th) and this is only because the perception of the UK being “Rich in natural beauty” has fallen six places (It should be noted that this small sounds more dramatic than it actually is due to a number of countries having very similar scores in terms of natural beauty). And there is even some good news in that the UK has risen one place (from 6th to 5th) in terms of the destination that visitors would like to visit if money was no object, which bodes well for the 2017 booking season. A consultation has been launched on changing the name of the National Assembly. The Commission is very keen to hear from a diverse range of people. You can find more information on the Assembly’s website. The link below directs you to the consultation document and explains how you can respond. www.Assembly.wales/name Tourism businesses have been urged to capitalise on the international publicity generated by the Cambrian Coast Railway being name in the world’s top 10 epic train journeys. The recognition came from The Guardian newspaper who picked the Machynlleth to Pwllheli line, also known as the Cambrian Coast Railway line as one of the world’s most spectacular railway trips. This fantastic publicity followed hot on the heels of Lonely Planet naming North Wales in the world’s top 10 regions to visit in 2017. Now Rhydian Mason, Rail Development Officer for the Cambrian Railways Partnership, is calling on everybody connected with tourism in the region to work together to use the publicity as a springboard to attract more tourists to visit attractions and book accommodation along the rail routes in Mid Wales. “It’s great news for tourism attractions and accommodation providers along the line in the region, which relies heavily on the tourism industry. The real challenge now for the industry is to work together to respond to the challenge that has been set by The Guardian recognition. Mr Mason said the region has so many attractions, including the Wales Coastal Path, the magnificent castle at Harlech, the spectacular Snowdonia National Park as well as a host of renowned TV and film locations for Hollywood Blockbusters, cult 60s dramas and the multi-award winning Hinterland series. MWT Cymru, which represents around 600 tourism businesses across Mid Wales, has developed ‘Moving Adventures’, a project to promote sustainable transport options and car free adventures in the region. “We want to persuade more visitors to consider alternative modes of travel, including trains, to be the start their adventure when visiting Mid Wales,” said Val Hawkins, MWT Cymru’s chief executive. “MWT Cymru has developed a range of itineraries to give visitors ideas how to travel to and explore the region.” WTA Response Addressing the Questions posed by the Committee:
What are the fundamental outcomes we want to see from agriculture, land management and rural development policies? In a nutshell, the WTA wants to see the ongoing development of successful tourism businesses which offer employment opportunities helping to sustain the well being of our rural communities and their culture. A Holistic Approach To achieve the above what is needed is for Government (Westminster, Cardiff and local authority) to follow policies conducive to the sustainable development of the tourism industry, working with the industry in the development of those policies. This has many aspects (see below) but fundamentally the approach to rural development must be holistic. Thus the development of policy for agriculture post Brexit must not be considered in isolation, but as an integral part of policy for the sustainable development of rural areas. And likewise the development of policy in relation to tourism. A Level Playing Field One of the outcomes the WTA seeks is that of a ‘level playing field’ to enable the tourism industry in Wales to be competitive, nationally and internationally. Thus together with tourism organisations in the rest of the UK we have long argued for a reduction in the rate of VAT on tourism accommodation to levels which prevail elsewhere in Europe. We look to the Welsh Government to press this argument upon Westminster. On the part of the Welsh Government, we look to an outcome where the industry in Wales is not put at a disadvantage, Vis a Vis competitor destinations in the UK by the introduction of any fiscal measures which impose additional costs on the industry or regulations which might impose additional administrative costs. It is imperative that a business friendly approach is created and maintained. A Conducive Planning Framework On the planning front we look to the Welsh Government for a framework which is conducive to helping sustainable tourism development in rural areas, and to local planning authorities to be pro-active in their dealings with would- be developers to bring about the right development in the right place. Towards these ends we would urge the Welsh Government to introduce legislation, as recommended in the Marsden Report, so that the planning authorities responsible for National Parks and AONBs have a statutory purpose to ’promote sustainable forms of economic and community development based on the management of natural resources and the cultural heritage of the area’. This would set the tone for a pro-active approach to sustainable tourism development. Support to Businesses for Capital Investment The level of government support for capital investment in tourism businesses has always been modest compared with support for other industries. Currently, for example, one of the Welsh Government’s support schemes is linked to development of export markets. Yet in balance of payments terms, developments in the tourism industry geared towards overseas visitors have the same impact. The immediate priority for the Westminster and Welsh Governments is to ensure that in the transition out of the EU, the resources which have been earmarked for rural development programmes, including tourism related, should be made available. In the post Brexit situation the WTA would look to the Welsh Government to allocate sufficient resources to support a vibrant rural economy and its constituent elements. As far as the tourism industry is concerned, bearing in mind its contribution to GVA and its potential for growth, Government support for capital investment over and above existing levels would be justified. A Strong Marketing Presence Another outcome we would look for is a strong marketing presence for Wales and its rural areas in its key tourism markets in the UK and selected overseas markets. Given the predominance of small businesses which make up the industry in Wales, the role of visit Wales in marketing is vital. In the past it has benefitted from EU funding, but it is noticeable that in comparison with other countries we have not been able to sustain a significant presence in the market. We would argue for a significant increase in the Marketing budget of Visit Wales so that it can sustain profile building national marketing campaigns on an ongoing basis and contribute to industry promoted campaigns for rural tourism products. There should be a significant increase in marketing in selected overseas markets to capitalise on the fall in the exchange rate and to match the £40 million Discover England campaign launched by Visit England. In this context the merger of Visit England and visit Britain raises doubts about the focus that Visit Britain will be able to give to Wales. Tourism Infrastructure Top of the concerns is the need for reliable Superfast Broadband. Superfast Cymru began the roll-out in 2013, but over a fifth of rural businesses have concerns about reliability. The programme has benefitted from EU funding, but it needs to be completed before Brexit takes place and resources subsequently put in place for regular updating. The commitment to electrify the train connection between London and Cardiff is to be welcomed but the extension to Swansea and improvements in connectivity in North Wales will help bring rural Wales that much nearer tourism markets. The latter is particularly important for Mid and North Wales to realise the potential of the hubs of Birmingham and Manchester airports for incoming overseas visitors. Both of these have extensive and well established inbound services. When allocating the new Wales and Borders Rail Franchise to start in 2018, the WTA would urge the Welsh Government to pay particular attention to proposals by the applicants to provide services which will develop the tourism industry into rural Wales, including frequency and timing of services, the quality of the rolling stock and the provision of adequate space for luggage and bicycles. Representatives of the WTA have met with some of the companies bidding for the franchise and have emphasised the importance of these requirements. The infrastructure services provided by local authorities are a vital part of the visitor experience. Authorities are under huge financial pressures, with some rural counties having faced the largest cuts in resources, and as a result some key facilities, notably public toilets, have been closed. If the tourism potential of our rural communities is to be realised, then the key part played by local authorities in the provision of these facilities must be realised and ways found to ensure their provision. The way forward may lie in discussion at local level between tourism businesses and representatives of the local authority and the local community about alternative ways of providing the facilities. Investing in People and Quality Standards Tourism businesses in Wales have a reputation for high standards, but if this reputation is to be maintained, there has to be ongoing emphasis on training and acquiring and updating the necessary skills. Our FE colleges and Universities provide a range of full time courses, but many of our businesses are run by owner managers who need tailor made training at the sort of times they can accommodate alongside their day to day work. This is an area which needs development by the colleges and local tourism organisations. In common with many industries, tourism suffers from a shortage of labour with the necessary skills. Hence the number of EU nationals who have been attracted to work in the industry. For the UK as a whole it amounts to 15% to 20% of the total workforce, a far higher proportion than some other industries. For some tourism businesses in Wales they are an essential part of the workforce. There is no doubt that they currently feel very unsettled and urgent confirmation is needed that they will be allowed to continue in their jobs post Brexit. This needs to be supported by more vigorous promotion of the skilled jobs and careers available in the tourism industry and regular up-skilling of those working in the industry. Our prospective visitors will be reassured of the standards they can expect in Wales by quality assurance schemes. Visit Wales has traditionally set much store by the development of appropriate schemes for the main sectors of the industry. These have been particularly useful for small businesses in rural areas. However the emergence of on line reviews in recent years has to be taken into account. The WTA considers there now needs to be an industry wide debate about their future. The Future of EU Regulation as they bears on the Tourism Industry The Tourism Industry Council in England, in its evidence to the Inquiry being undertaken by Parliamentary Committee on Culture, Tourism and Sport, has identified some of the EU Regulations which bear on the tourism industry. The Welsh Government in conjunction with appropriate representatives of the industry will wish to join with the Westminster Government in considering the future of these Regulations. They will have relevance to all of Wales including to greater or lesser degree its rural areas. The regulations relate to: The Single Aviation Market to which it is vitally important that the UK maintains access and the EU’s multilateral aviation agreements. This is important for Wales because it will facilitate the development of tourism flights top Cardiff Wales airport and the continuation of services into other airports giving access to Wales. Regulations governing Aviation Safety and Security including the Passenger Name Record Directive Regulations governing Coach and Bus Services and Rail Services. The regulation covering bus and coach services covers international coach tours. Passenger rights for air, bus and coach travel. European Driving License allowing for mutual recognition of different license styles. European Health Insurance Card Mutual Recognition of Qualifications Directive which will bear on activity holidays. Employment EU funding programmes Border Controls requiring EU visitors to enter through EEA lanes which take, currently, almost twice as long as EU lanes. Visas Customs Union-events industry. If this was not covered by single market arrangements, there would be considerable additional costs in moving equipment between EU countries. Domestic Air Passenger Duty Passenger Travel Directive Aviation State Aid Guidelines What lessons can we learn from current and previous policies and from policies elsewhere? We need to keep constantly in mind the inter relationship of the various policy areas involved in considering the future of our rural communities. There must be a holistic approach otherwise the law of unintended consequences may have unfortunate repercussions. The classic example already mentioned was the way in the action taken to deal with the 2002 foot and mouth outbreak impacted adversely on the tourism industry. A better understanding of the symbiotic relationship between the two industries and more sensitive handling of the necessary actions which had to be taken might have avoided this. In the past when there was more flexibility in ways of supporting the tourism industry, it proved possible for the Welsh Government and its agencies to be innovative in the steps it took. Frequently these were schemes originating in suggestions from the industry. Brexit opens up the possibility for more innovative approaches and Visit Wales with closer connections with the industry can be the ‘eyes and ears’ in bringing this about. Just observing our competitor destinations in the UK, certainly Scotland and Northern Ireland, and also the Republic of Ireland, it does seem that they have had more resources devoted to the promotion and development of tourism than Wales. Their presence in the market place testifies to this. England too with its £40 million Discover England Development Fund has been given the opportunity to cut a dash. Arguably then the opportunity to put Wales on a level footing ought now to be taken, given the potential of the development potential of the industry particularly in rural areas, by a step change increase in the resources afforded to the industry. To what extent should Wales develop its own agricultural, land management and rural development policies or should it be part of a broader UK-wide policy and financial framework. The short answer is that it needs to do both. The rationale of devolution is that it should be possible for the Welsh Government to devise policies suited to the ‘unique’ circumstances of Wales. This has been reflected both in policy developments and legislation passed by the National Assembly. However that we are part of the wider UK economic and social dimension which is also affected by broader international considerations, and this cannot be ignored. These have to be taken into account in the development of policy by the Welsh Government. Hence the need for close involvement by the two Governments on the transition out of the EU and into the future. There will be some issues on which Wales can be a trail blazer, as in the levy on plastic bags, to be subsequently copied elsewhere. There will be others, for example the objective of being GM free, which it will be extraordinarily difficult to achieve because of the nature of international trade. Within the framework which will be created by the Wales Bill, the WTA would encourage the Welsh Government to follow policies as outlined previously in this evidence which will support the sustainable development of the tourism industry in Wales generally and in rural Wales in particular. While the transition from the EU will be done on a UK basis, we look to see that the post Brexit settlement will fairly reflect the needs of Wales and its tourism industry. This will enable Wales to confirm its brand image as a distinctive destination within the UK offering something unique and distinctive.. To reinforce that distinctiveness, Tourism should be given equal status alongside agriculture, in all considerations relating to rural development. Secondly, that symbiotic relationship should be held up as an exemplar of sustainable living. Which other countries might seek to emulate in a rapidly changing post-industrial world. Following our call for evidence the Wales Tourism Alliance has now responded to the All Party Parliamentary Group for Tourism and the Hospitality inquiry into the impact of the sharing economy on the UK tourism industry.
As part of this inquiry, respondents are asked to provide evidence related to seven specific questions. The objective is, quite rightly to gain some factual substance to the issue. However, there are currently no resources dedicated to establishing how much impact there has been in Wales, from the growth of the sharing economy. Without this research it is still fair to say this growth been the biggest single issue to hit our businesses in the last five to ten years. It is therefore worthy of research spend and we will be raising the lack of research undertaken with Welsh AMs at the next Tourism Cross Party Group of Assembly Members in the Senedd on the 29th November 2016. Unfortunately, until there is a commitment to undertake such a piece of work we can only respond to the questions, with anecdotal, but professionally grounded knowledge from the tourism industry in Wales and draw on the experience of the tourism industry from other destinations. What has been the overall impact of the sharing economy on the UK tourism industry – to what extent has it increased the size of the total market in terms of revenue and employment? Is this growth different between the inbound and domestic tourism sectors? If you take the number of overseas visitors to Wales as one measure, volume increased 15% in the first 6 months of 2016 compared to the first 6 months of 2015 and expenditure by overseas visitors in Wales has increased by more than 8%. Of course you cannot place this growth entirely down to the ‘Sharing economy’ however it can deducted that there has been some contribution. Therefore it can only be that total market size has increased. Although we also suspect the actual size of growth attributable is less than it actually is as many customers will simply be market ‘channel’ hopping to find the cheapest deal. I.e. looking at the site or agency then using a sharing channel to book. The bigger issue is growing industry concern that while these new peer to peer channels may have opened up a new budget market, it has also have attracted others away to property that is being let ‘below the radar’ and which both undercuts the legitimate tax paying business. Will the growth in the tourism-related sharing economy continue or is it approaching a natural limit in terms of market share? How will the sharing economy develop in future? We suspect it has probably reached a natural limit in mature domestic UK markets. Less so from short haul visitors, particularly the EU. With regard to the developing long haul BRIC nations, then no. Although we are aware many of the nationals from these nations are not confident about self-packaging. Research has shown that the Chinese in particular, prefer the security of group travel, so the growth of these markets via the sharing economy coupled to other barriers to international tourism growth (Visa restrictions; APD) means it may take some time to develop. Do sharing economy platforms provide any benefits or opportunities for existing tourism accommodation businesses in terms of gaining access to new customers? The obvious benefit is the fee base substantially cheaper (at least at the outset) than the cost of reaching the market would be, or have been, via more traditional agency. For example Airbnb top slices around 3 to 4%; whereas HOSEASONS (Wyndham Group) is closer to 15%. Benefits of each vary. In terms of opportunities, they do potentially offer a far greater, almost global reach, than the more traditional travel agent/marketing companies. Niche marketing is also made easier. What evidence is there that people operating a tourism accommodation business marketing through a sharing economy platform are less likely to comply with regulations than other tourism accommodation SMEs? If so, what steps should be taken to ensure that there is a level playing field in terms of regulatory compliance? - Forbes recent article citing that ‘Airbnb Could Wipe Out 70% Of Its South Korea Listings by next month’, due to regulatory issues. That would mean 7 out of 10 of their listings in the destination could be removed. Amongst a host of non-compliance issues, the hosting of a home for a tourist is illegal as regulators require hosts to be living in the same accommodation. - Similarly in New York City, new legislation has been introduced targeting those using Social media to rent property to tourists, so that people advertising rentals of less than 30 days can be fined up to $7,500 if it is found that the host is not on the premises during the rental. Interestingly, Airbnb is now looking to extend its offer by incorporating product beyond accommodation, for example ticketing for attractions. In the UK as small operators we have struggled with EU package travel legislation enacted in UK law. Obviously changes are afoot on this front, however, could it be possible that an offshore company could eventually trump (excuse the pun) domestic legislation whilst the ‘legitimate’ micro and small business community cannot. The sharing economy operates on trust, whereby both the buyer and the seller are able to moderate the activities of the other by providing feedback, which enables poor performers to be excluded from the community. However, this model does not take into account the views of neighbours that are impacted by the operation of such businesses. What can be done to make sure that the external impacts of these businesses are fully taken into account? Greater regulation of ‘invisible’ and/or unscrupulous operators through legislation that targets the rogue operator (as outlined above in the case examples). However in a UK environment of deregulation, much of which we support, and diminishing public funds with which to regulate - this would appear extremely unlikely. Introducing new legislation to combat this situation is difficult, but with the cost of enforcement this option does not seem possible anytime soon. Unless of course an economic assessment can prove otherwise! We note the move in the Chancellors Autumn statement that the Budget 2017 will set out further details for making access to licences or services for businesses conditional on them being registered for tax. In conclusion: In more general terms beyond the questions above - whilst the UK Government has suggested measures to help to build consumers’ trust in online transactions in the sharing economy’ (Independent review of the sharing economy Government response; March 2015) our concern is with the micro and small tourism operator: - There is simply not the protection afforded to the micro or small business as there is for the consumer. Our industry is dominated by micro businesses supporting many livelihoods’ across Wales. Whilst we largely operate as businesses, most are self-employed, often struggling to hold up their end of a business transaction via a faceless off-shore on-line travel agency (OTA). Granted there are advantages too, but there is a misguided assumption by both the consumer and the operator that the OTA offers protection for both, when in reality they offer little when things go wrong. - On-line reviews are a serious concern to the micro operator. Where there are serious flaws in the product on offer, which need to be rectified, a bad review is understandable. However removing a malicious or incorrect review is extremely difficult. - Whilst, we appreciate we cannot turn back time, online travel agencies, such as Airbnb, have the potential to provide opportunities, but also hold risk of monopolisation with a few off shore companies that are difficult to regulate or be enforced upon to pay UK tax. We have great concern that our legitimate small businesses, paying UK rates of tax and abiding by our often stringent legislation in relation to a range of consumer protection issues such as food hygiene; fire safety; PA testing, etc. are being penalised by an unregulated sub-industry who can undercut on pricing and destroy viability. Is this really a sharing economy or simply a legitimised underground economy that in reality the Government can do little to control? Rules requiring takeaways to promote food hygiene ratings on leaflets, came into force this week (28/11/2016] requiring takeaway food businesses to promote their food hygiene ratings on leaflets and menus which enable customers to order by phone or online.
Latest figures show that over 94% of food businesses in Wales now have a generally satisfactory rating or higher (3 or above), with 62.5% of Welsh food businesses having the highest 5 rating (Very Good). From this month, if a takeaway leaflet or menu shows food for sale, the price and a way of ordering the food without visiting the premises, it will also have to include a bilingual statement encouraging customers to check the food hygiene rating of the business on the food hygiene ratings website. The statement will also remind customers that they have a legal right to ask the food business for their food hygiene rating when they order over the phone. The legislation also enables food businesses to voluntarily display their valid food hygiene rating on this type of publicity material, but if they do so the rating must be valid and in the specified format so it can be clearly seen. |