PRIYA SINHA KENWARD - WRITTEN EVIDENCE (FDO0129)

 

Summary

This response to the House of Lords Select Committee Inquiry on food, diet and obesity puts forward policy proposals to address issues at three levels:

•        Systems level – proposal for design of a regulatory framework to support stable and long term policy making for a strategically important industry.

•        Policy objectives and targets – proposals for policy objectives and targets to support effective delivery across a complex food system.

•        Policy ideas – minimum viable set of policies that are designed to work synergistically to deliver meaningful change.

The following key actions are recommended:

A1. Establish independent regulatory authority to oversee the food industry and provide a long term, stable regulatory framework that helps ensure the food industry works in the interests of consumers.

The authority would follow a similar model to the independent regulation already implemented for other strategically important and competitive industries such as energy, communications, financial services etc. The FSA is well placed to take a systems based approach, expanding its existing role in food safety with a broader role across the entire food system.

Such a system would provide a robust framework to deliver the following benefits: long term stability in policy making, reduced political lobbying, systemic alignment of industry incentives to the consumer interest and a competitive level playing field, scope to impact both demand and supply sides of the market, ability to co-ordinate a whole of government approach to improving the food system.

B1. Our policy objectives and targets should focus on transitioning dietary patterns towards whole food, plants-rich diets to achieve changes needed on population health.

We should base public policy on achieving a change in dietary patterns across the population and move away from a narrow focus on calories consumed. There is consensus amongst the scientific community on nutritional benefits from eating a whole foods, plant-rich diet, with particular emphasis on consuming a variety of fruits and vegetables, fibre-rich foods and fermented foods.

B2. Adopt an overarching policy target to reduce the proportion of unhealthy foods in our diet

Adopting a policy target in the form ‘Reduce the proportion of our diet coming from unhealthy foods from [x% to y%] within [z] years’ would create a common lead indicator that helps measure progress across the entire food system. Having a common indicator helps to create momentum and a national narrative to drive cultural change in our dietary habits and ultimately our health outcomes.

B3. To deliver changes to our dietary patterns we need to ensure that making healthy choices are easy, attractive, accessible and rewarding.

To drive behaviour change healthy food choices need to be:

•        Easy - healthy choices are the default, they are visible, transparent and simple

•        Attractive - healthy choices are considered the norm and convenient

•        Accessible - healthy food is available and affordable

•        Rewarding - healthy food brings joy, is fun and/or trendy

The food industry has a critical role to play in making these changes happen, alongside government and individual citizens.

C1. Nutrition Index and Food Labelling Policies

The initial policy recommendation is to consult on revisions to the Nutrient Profiling Model and front of pack labelling regulations, including a well-developed Nutrition Index policy option.

The Nutrition Index and mandated front of pack labelling results in a single, objective score indicating the healthiness of a food and how frequently it should be consumed within a healthy whole foods, plant-rich dietary pattern. This policy proposal would also enable tracking of changes in dietary patterns by both consumers and industry.

The Nutrition Index updates the existing Nutrient Profiling Model to account for the nutrient density of the food and the level of processing. It uses the energy density and/hyper palatability of the food to determine the guidance on frequency or quantities of the food that should be consumed.

This proposal has three key objectives:

•        Create a level playing field to incentivise food manufacturers to compete on health and nutritional quality of the food they produce. This approach increases the availability of healthy food and ensures that less responsible players are not competitively advantaged during a transition to healthier dietary patterns.

•        Make it simpler and easier for consumers to choose healthier food.

•        Help create awareness and motivation to change dietary patterns by providing personalised information to consumers on their shopping receipts to track their dietary patterns.

C2. Flip the script – creating healthy defaults in the retail food environment

Adopting ‘Flip the script’ policy proposals leverages the power of defaults to help drive societal shifts in dietary patterns. The policy idea essentially separates healthy from unhealthy foods in the online and in-store retail environments. Healthy foods would be presented up front as the default with less healthy alternatives tucked away in a separate section. Healthiness of a particular food would be based on an independent, objective measure (e.g. Nutrition Index). At checkout, whether online or in-store, receipts would provide consumers with the ratio of healthy to unhealthy foods in their shopping baskets.

At this stage, the initial proposal is to conduct a retail market trial to test ‘Flip the script’ proposals generating evidence and insights to inform policy making options.

This policy is intended to achieve four key objectives:

•        At an industry level, this aligns commercial incentives with the consumer interest so that healthy food production is positively rewarded. Critically, these commercial incentives motivate industry to perform better without the need for detailed policy and reporting mechanisms.

•        Makes it easy for consumers to choose healthy foods and not be distracted by unhealthy temptations.

•        Allows for consumer choice and their ability to choose less healthy or indulgent foods

•        Encourages changes to consumer expectations and societal norms to drive the culture change needed for transition to healthy dietary patterns.

 

 

C3: Restrict advertising and marketing of unhealthy food

We want to create a more conducive food environment, reducing consumer exposure to unhealthy foods that are often normalised and promoted in society’s food culture.

The policy recommendation is to ensure that the restrictions to the promotion and advertising of junk food before the 9pm watershed, is enforced by planned date in October 2025.

C4: Public sector procurement of healthy food

Government should strengthen its procurement policies so that only healthy food is purchased by the public sector for schools, hospitals, armed forces, prisons and government offices.

The benefits of this are threefold:

C5: Health Literacy Initiative

In order to inspire future generations to look after their physical and mental health, we need to empower our children with knowledge on the science of nutrition and equip them with cooking skills to build their sense of confidence and fun in the kitchen.

Climate change is an illustrative example of the changes that can occur over time from nurturing awareness, understanding and engagement within the school curriculum from an early age.

The initial proposal is to construct a pilot study to explore the impact of a 12 week health literacy initiative and use the results to inform wider policy making on the school curriculum.

 

 

 

The pilot study is aimed at teenagers (12/13/14 years old) to assess awareness, understanding and behaviour change following a 12 week holistic health literacy programme. The holistic approach includes the following elements:

Introduction

  1. Thank you for the opportunity to respond to House of Lords Select Committee’s Call for Evidence on its Food, Diet and Obesity inquiry.

 

  1. I am a strategic advisor with 25+ years expertise in policy, regulation and economics. I have worked across a number of regulated industries within the public and private sectors, including organisations such as Ofcom, Ofgem, Ofwat and BT. I have a keen interest in public health, food and nutrition – currently, I am a steering committee member for Barnet’s Food Partnership, a Barnet health champion volunteer and a strategic advisory consultant for Qina, a personalised nutrition technology platform. I hope to add value to the House of Lords Select Committee’s inquiry by utilising my extensive experience of regulating strategically important industries and insights from working within the health and food system to help overcome the significant challenges in the UK.

 

  1. My response will predominantly focus on Q12 – “The policy tools required to prevent obesity including those focused on the role of the food and drink industry in tackling obesity.” I put forward policy ideas in my response – these are not yet fully worked up proposals but could be developed further in collaboration with Government departments or other policy focused institutions. I am open to further discussion and collaboration if that would be helpful.

 

  1. My views are set out below in three broad categories:

 

  1. I have adopted the following structure to discuss specific new policy ideas:

 

A. Systems level

A1. Establish independent regulatory authority to oversee the food industry and provide a long term, stable regulatory framework

  1. Given the strategic importance healthy food provision for the population, it is important that we evolve systems and policies whereby we can transition the food industry to a new operating model that works in the interests of consumers, whilst ensuring the financial viability of the healthy food sector.  An effective transition requires:
  1. Unlike other strategically important industries, we do not have a robust, long term regulatory framework in place to ensure that the food system delivers good consumer outcomes on health and sustainability. Political uncertainty, political lobbying, lack of a co-ordinated strategy across all of government and a financial food system that incentivises production of low quality food are challenges that a robust regulatory framework could address effectively.

 

  1. The initial policy proposal is to establish an independent regulator potentially expanding the FSA’s existing role in food safety with a broader role across the entire food system.

 

 

Objectives

  1. To establish an independent regulator with statutory authority to oversee the food industry ensuring consumer health and sustainability, whilst having regard to the overall financial viability of the food system.

 

  1.         This legislative change enables us to create the foundations for a new way of engaging with industry to drive long term positive change. This is vitally important for strategically important sectors of the economy - we need to design a system to work efficiently with the industry and help it transition to a new operational model which works in the interests of consumers.

Description

  1.         The proposed authority would be accountable to parliament. It would operate independently from government and industry, and have regard to government’s strategic priorities.

 

  1.         It would possess full information gathering, decision-making and enforcement powers, responsible for both setting and implementing policies that promote public health and environmental sustainability as it relates to the food system.

 

  1.         The authority would follow a similar model to the independent regulation already implemented for other strategically important and competitive industries such as energy, communications, financial services etc.

 

  1.         The FSA is well placed to take a systems based approach, expanding its existing role in food safety with a broader role across the entire food system.

Rationale and Benefits

  1.         Long term stability: Independence from 5 year political cycles reduces uncertainty and provides the continuity needed to support the industry’s transition to a healthier and more sustainable food system.

 

  1.         Reduced Political Lobbying: An independent regulator with strong decision making powers also reduces the extent of political lobbying, an issue many stakeholders have identified as obstructing and delaying progress in improving our food systems.

 

  1.         Aligning industry incentives to consumer interest: An independent regulator would be able to design a system of incentives – using both ‘carrot’ and ‘stick’ regulations – to help align commercial industry incentives to the consumer interest. In addition, aligning incentives and mandating changes at industry level would promote a level playing field that would help ensure less responsible providers are not competitively advantaged by their harmful actions. The systemic design of incentives enables the use of all policy tools and levers at our disposal rather than for example, being limited to a system of mandatory targets and reporting. Given widespread positive outcomes have been so difficult to achieve over the last 30 years, it is important we ensure the regulatory system we put in place has a wide range of tools at its disposal to drive positive change.

 

  1.         Scope to impact both demand and supply side of the market: The regulatory authority is able to act on both the supply and demand sides of the food system. This wide scope is necessary to achieve long-lasting change which requires not only industry regulation to alter the food environment, but also demand side approaches to support long term positive impact on consumer dietary patterns. These could include initiatives that promote health literacy in schools, cooking skills and a healthy food culture. 

 

  1.         Co-ordinate a ‘whole of government’ approach: A strong, independent regulator could champion a co-ordinated strategy and approach across government. Many stakeholders have identified complex overlapping government responsibilities as a key reason for lack of progress over the last few decades. By giving the regulator decision making powers that have traditionally has been spread across various government departments, this solution directly addresses this complexity.

 

Risks and Mitigations

  1.         Twin track approach to mitigate risk of delays due to constrained resources: Setting up a new regulatory body will require time and resources which could potentially detract resources away from policies that directly address the current issues.

 

  1.         Whilst it is true that independent statutory body will require time and resource to set up, it is likely to be an essential investment to ensure successful delivery of the range of initiatives needed to drive lasting change. There is general consensus that a key reason previous policy initiatives have failed was due to their limited nature and failure to address the system of incentives across the food system as a whole. In this context, we are unlikely to achieve the lasting changes necessary without the foundations of a strong regulatory framework. In fact, it could be argued that without a strong regulatory framework we would run a real risk of limited or no progress on policy aims and objectives.

 

  1.         To mitigate the risk of delay, government could adopt a twin track approach – continue to make progress on policies to change the food environment whilst setting a clear direction of travel for the legislative changes needed. The work on policy development will enable the new regulatory authority to hit the ground running and ensure that rapid progress can be made on policy issues.

B. Policy Objectives and Targets

B1. Our policy objectives and targets should focus on transitioning dietary patterns towards whole food, plant-rich diets to achieve changes needed on population health.

  1.         A significant proportion of our diets contains foods that are high in salt, sugar and saturated fats and/or diet high in ultra-processed foods (UPFs). For example, almost 60% of our daily calories comes from UPFs, rising to 66% for teenagers[1].

 

  1.         A number of different stakeholders have submitted studies showing that these types of foods have been strongly associated with negative health outcomes such as rising levels obesity and other non-communicable diseases.

 

  1.         There is also general consensus from scientific community on nutritional benefits from eating a whole food, plant-rich diet, with particular emphasis on consuming a variety of fruits and vegetables, fibre-rich foods and fermented foods. This helps nourish our gut biome which is essential to human health. Analysis of diets across the so called ‘blue zones’[2] have also shown these to be common characteristics of diets for people with a long and healthy lifespan.

 

  1.         However, recent government interventions have tended to focus on reducing calories instead of promoting a healthy dietary pattern e.g. requiring restaurants to set out calories for each dish on the menu. This policy may nudge people to overfocus on calorific content rather than the nutritional quality of the food – for example, calories from consuming olive oil or salmon will not have the same health effect on the body as the same amount of calories from a beef burger and chips. It is not clear that such calorie based policies have had beneficial impact on population health.

 

  1.         A narrow focus on calories consumed is unlikely to lead to the improved health outcomes we desire, if it isn’t coupled with nutritionally rich diets. I note that The National Food Strategy[3] did not focus on calories consumed but rather recommended that to meet our 2032 health, climate and nature commitments, our 2019 national diet needed to increase fruit and vegetable consumption by 30%, increase fibre intake by 50%, reduce consumption of HFSS foods by 25% and reduce meat consumption by 30%.

 

  1.         Taken together, this suggests that if we are able to transition national dietary patterns towards whole food, plant-rich diets we can improve health outcomes at a population level.

B2. Adopt an overarching policy target to reduce the proportion of unhealthy foods in our diet

  1.         Adopting a policy target in the form ‘Reduce the proportion of our diet coming from unhealthy foods from [x% to y%] within [z] years’ would create a common lead indicator that helps measure progress across the entire food system. Such a leading indicator has two vital characteristics[4]. Firstly it is predictive of successfully achieving our goal i.e. if we perform successfully against this indicator on our diets, we can be reasonably confident of achieving our health goal. Secondly and crucially this lead measure is influenceable - everyone has the capacity to influence the lead measure by actions we take. For example, different parts of the food system e.g. food manufacturers, food retailers, individual consumers etc can influence the achievement of the target by their actions. 

 

  1.         In addition, this is an indicator that can be used by every participant in the food system to measure their progress against the target, by measuring the balance of their food sales or consumption between healthy versus unhealthy foods. Having a common indicator helps to create momentum and a national narrative to drive culture change in our dietary habits and ultimately our health outcomes.

 

  1.         A common indicator may also help to drive a ‘whole of government’ approach, where each relevant government department can consider a few key priority measures it will deliver to contribute to the overarching objective e.g. HMT and tax policy; DfE on health education and school food, government procurement policies, local government planning regulations etc.

 

  1.         See section C1 below for a policy idea on the Nutrition Index and how we might establish a measure of healthy and unhealthy foods.

B3. To deliver changes to our dietary patterns we need to ensure that making healthy choices are easy, attractive, accessible and rewarding. The food environment has a critical role to play in making this happen, alongside government and individual citizens.

  1.         Changing dietary patterns will require behaviour change by businesses, government and individuals. To drive behaviour change healthy food choices need to be:

 

  1.         The food environment has a critical role to play in achieving the above objectives. Making healthy food the default, increasing visibility and availability of healthy food, producing low cost, convenient healthy foods, helping reward healthy choices through loyalty points are some areas where the food industry could make an important impact.  Coupled with this, the food industry can also support by for example, reducing exposure to the unhealthy foods they often normalise and promote, removing misleading health claims that overfocus on one favourable aspect rather than the overall healthiness of the food. These actions would support society to de-prioritise the role of unhealthy foods within our overall food system.

 

  1.         Government also has a critical role to play. This could include enabling actions, for example, creating a robust regulatory framework that aligns food industry incentives with consumer interest, and prioritising a ‘whole of government’ approach to healthy food. But it could also include more direct policies for example, requiring healthy food environments in hospitals, school, prisons and for refugees; making planning permission conditional on health related objectives being met etc..

 

  1.         In addition to supply side measures that tackle the food environment, individuals also need support to eat healthily and change their dietary patterns. Many consumers find our food labelling system confusing, misleading or too time consuming to navigate for every food. Some consumers are likely to find it too expensive to eat healthily. And as a nation, we have fewer children growing up as confident cooks. Moreover, many consumers may also not realise just how powerful long term dietary patterns are in preventing and even reversing chronic diseases. Demand side measures promote health literacy, empower consumers with cooking skills and helping them shop on a budget could support the cultural change needed to transition our nation to healthier dietary patterns.

C. Minimum viable set of policy changes to begin to deliver lasting change

  1.         We need to focus on which policies to take forward as we can’t progress them all at the same time. The priority should be on creating a minimum viable set of policies that taken together will create a system incentivised to deliver meaningful positive change.

 

  1.         The context is important when designing policies- we need to recognise that our starting point is different to some other countries. We have one of the highest penetration of UPFs and a high percentage of our diet coming from HFSS foods. So transitioning our system will require a careful trajectory that balances pace of movement of the industry while keeping up strong momentum for meaningful change.

 

  1.         Also, in common with other countries, the UK food system doesn’t financially reward providers focused on producing healthy food that promotes health and nutrition. Instead, providers are incentivised to produce low quality food in large volumes.

 

  1.         I also note that, unlike the tobacco industry, the food system is a strategically important national industry – we need to design a system and policies that enable us to work efficiently with the industry and help transition it to a new operational model which works in the interests of consumers whilst ensuring the financial viability of the sector. This increases the importance of creating incentives that positively motivates the industry to want to take actions aligned with consumer health.

 

  1.         I set out below 5 key policies that taken together would form a foundational base for creating meaningful change in the food system.

C1. Nutrition Index Policies

  1.         The initial policy recommendation is to consult on revisions to the Nutrient Profiling Model and front of pack labelling regulations, including a well-developed policy option on the Nutrition Index.

Objectives

  1.         This proposal has three key objectives:

Description

  1.         The proposal establishes a Nutrition Index that results in a single, objective score indicating the healthiness of a food and how frequently it should be consumed within a healthy whole foods, plant-rich dietary pattern.

 

  1.         Note that the proposed Nutrition Index is an objective measure allowing you to compare across categories of foods to plan a healthy diet. This is distinct from the Nutri-score system which measures the relative healthiness of foods in the same category[5] i.e. Nutri-score can help you compare two frozen pizzas but is not useful at helping you move to an overall healthier dietary pattern by comparing say a yoghurt with a custard based dessert.

 

 

  1.         This proposal has three parts that operate synergistically:

 

  1.         Mandate front of pack labelling based on the Nutrition Index, in format similar to Nutri-score. The range of scores indicate the healthiness and frequency/quantity of food to be consumed as part of a healthy whole foods, plant-rich diet. See below for some examples of scores and meanings:

 

  1.         Enable tracking of changes in dietary patterns by both consumers and industry:


Rationale and Benefits

Industry incentive effects

  1.         To deliver long lasting, effective change, the design of the regulatory framework needs to incentivise participants in the food system to want to act in a way that aligns with consumer interests, thereby mobilising industry’s efforts to be part of the solution.

 

  1.         By adopting this set of mandatory policy measures we enable a food environment where manufacturers can compete effectively on the health and nutritional quality of foods they produce. This approach helps ensure that less responsible players are not competitively advantaged during a transition to healthier dietary patterns. And it incentivises the food system to reward healthier food production.

 

  1.         The mechanisms for positive incentives arises from three key characteristics:

 

  1.         Combined impact of these effects is likely to incentivise food manufacturers to create new healthy foods, adapt existing foods to fit within the A-C scores and potentially even stop production of some foods that are unhealthy. In addition, the food industry may also be incentivised to voluntarily reduce the availability, advertising or marketing promotions of unhealthy foods to manage potentially negative reputational and brand effects.

 

  1.         Under these regulations, industry actions are likely to make healthy choices more simple and transparent for consumers. They may also be more likely to help increase the availability of healthy food. Mandating standardised labelling helps build trust in the food industry providing reputational benefits to the industry as a whole.

Consumer effects

  1.         This policy solution empowers consumers to make healthier choices and rewards them for changing their dietary patterns. These policies don’t force consumers to make a switch – it incentivises and nudges consumers to make changes over time at a pace that works for them.

 

  1.         Mandating the Nutrition Index score on front of pack makes healthy foods more visible and transparent to consumers – especially because it applies across the whole industry. Over time, this helps consumers become familiar with using the Nutrition Index and rely on it more for their decision making.

 

  1.         A single score for Nutrient Index makes it easier and less confusing for consumers to make healthy choices. For example, it might be confusing to determine how healthy the food is under the current traffic light labelling system if a food has different ratings of red, amber and green across the existing salt, sugar and fat categories.

 

  1.         The Nutrient Index score may also help counteract the harm from misleading claims that over-focus on one positive aspect of the food whilst not giving sufficient weight to other less favourable aspects of the foods.

 

  1.         Providing dietary pattern information on food shopping receipts offers consumers personalised information that helps raise awareness of their own dietary patterns and gives them a tool to track their changes over time. Loyalty reward points could further motivate behaviour changes in the right direction. Food retailers or manufacturers could even gamify these areas to make it fun for people to see how far they can shift their dietary patterns.

 

  1.         By mandating simple, clear front of pack messages and providing dietary pattern information on receipts, we are also helping to change consumer expectations and societal norms.

Risks and mitigations

  1.         There is a risk that the food industry pushes back to obstruct or delay the introduction of such measures. Responsible players may appreciate the level playing field but be wary of the commercial impact of such policies. Ensuring a sufficient time frame for implementation would help give the industry time to adapt its products and positioning in line with new regulatory requirements, whilst still ensuring progress towards better health outcomes for consumers. Less responsible players are more likely to see a new regulatory regime as a threat and we will need strong political will to see changes through, especially ahead of independent regulation being in place.

 

  1.         Another risk is that there are likely to be differing opinions on how best to update the Nutrient Profiling Model and/or to construct the Nutrition Index, leading to delay. These issues can be dealt with effectively through an open and transparent consultation process.

 

  1.         Stakeholders may object to the precautionary approach taken to protect the public from UPFs and argue that some UPFs may actually be healthy. We could mitigate the risk of wrongly categorising a specific UPF as unhealthy by allowing manufacturers to put forward high quality evidence to prove that a specific UPF is healthy and thereby categorise it differently. This enables us to continue to protect consumers against the broad range of UPFs that have been shown to be strongly correlated with poor health outcomes whilst being fair to any UPFs that are genuinely healthy.

C2. Flip the script – creating healthy defaults in the retail food environment

  1.         At this stage, the initial proposal is to conduct a retail market trial to test ‘Flip the script’ proposals generating evidence and insights to inform wider policy making.

Objectives

  1.         ‘Flip the script’ policy proposal aims to make healthy food the default for consumers. This policy is intended to achieve four key objectives:

Description

  1.         The policy idea essentially separates healthy from unhealthy foods in the online and in-store retail environments. Healthy foods would be would be presented up front as the default with less healthy alternatives tucked away in a separate section.
  1.         Healthiness of a particular food would be based on an independent, objective measure (e.g. Nutrition Index, with only A-C scored products displayed in default view). At checkout, whether online or in-store, consumers would be provided with the ratio of healthy to unhealthy foods in their shopping baskets.

Rationale and benefits

  1.         The power of defaults is well established in behavioural science and public policy, which recognises that consumers are less likely to opt out of the default or expected behaviour. For example, in May 2020 the organ donation rules in England changed to an opt out model to help more people save more lives. Ofcom banned automatically renewal contracts in 2014 following evidence which demonstrated the negative impacts on competition and switching when consumers were automatically defaulted onto new minimum contract terms when their initial contracts came to an end. 

 

  1.         A recent policy example from the UK food retail environment, relates to the 2015 introduction of regulations on Single Use Plastic Carrier Bags. This example demonstrates the significant impact of changing the default – the default was changed so that retailers did not automatically provide single use carrier bags for free at the point of sale (consumers could now choose to purchase them for a nominal 5p charge). This policy was hugely successful at reducing the consumption of single use carrier bags. Critically the policy was also important in changing consumer expectations and societal norms – many people now feel embarrassed to ask for plastic bags to the extent that some prefer to carry shopping in their arms rather than ask for single use plastic carrier bags. 

 

  1.         Adopting ‘Flip the script’ policy proposals will leverage the power of defaults to help drive societal shifts in dietary patterns to deliver the following benefits. Reducing friction is key to helping support behaviour change.


Industry level incentives:

  1.         At an industry level this shifts and aligns commercial incentives with the consumer interest so that healthy food production is positively rewarded. Critically, these commercial incentives motivate industry to perform better without the need for detailed policy and reporting mechanisms.

 

  1.         Food manufacturers: Food manufacturers (including own brand supermarket products) would have an incentive to produce more foods that fall within the A-C category so their foods appear in the default category presented to consumers. This could be through reformulation and/or increased provision of new healthy products.

 

  1.         Food Retailers: Retailers would have an incentive to stock greater number of healthy products to maximise consumers finding an agreeable choice in the default category. Over time, they may choose to de-list the less healthy products. Retailers could also encourage and promote healthy choices by offering loyalty reward points when the healthy percentage of the shopping basket is above a certain level. 

Consumer benefits: 

  1.         By presenting healthy foods as the default for consumers it helps consumers more easily access the healthy foods, saving them time and hassle of checking foods individually.

 

  1.         Consumers could still choose to access less healthy foods – either by clicking on tab that showed these options or by going to a separate section at the back of the store - but would do so with the conscious understanding that a smaller proportion of their shopping basket should come from these products if they wanted to shift to a healthier dietary pattern.

 

  1.         Consumers would be empowered to easily track their dietary patterns which could support behaviour change over time. The ratios of healthy to unhealthy could even be gamified to motivate and make it fun for people to see how far they can shift their dietary patterns.

 

  1.         This policy change could help shift consumer expectations and societal norms by raising awareness and understanding around the importance of a healthy diet.

 

 

Risks and mitigations

  1.        Food retailers may not wish to engage in trials because they are potentially concerned about negative commercial impact on their sales of unhealthy foods. However, a retail trial will generate evidence on level of impact which should allow policy to be developed taking into account commercial impact and establish a reasonable timeframe for industry to adapt to shifts in dietary patterns. Further, the commercial impact of the trial itself will be low because of the limited numbers involved in the trial. Note this proposal also generates commercial opportunities by creating a competitive opportunity to secure higher revenues from the healthy food produced by responsible food manufacturers.

C3: Restrict advertising and marketing of unhealthy food

  1.         We want to create a more conducive food environment, reducing consumer exposure to unhealthy foods that are often normalised and promoted in society’s food culture.

 

  1.         The policy recommendation is to ensure that the restrictions to the promotion and advertising of junk food before the 9pm watershed, is enforced by planned date in October 2025.

 

  1.         If healthy and unhealthy foods were separated as per policy proposal C2 above, marketing and advertising of unhealthy foods could also be restricted to the less healthy sections of the store and website. This would ensure that consumers who want to only look at healthy options are not tempted by advertising and promotions on unhealthy foods. From a behaviour change perspective, this can genuinely support consumers by enabling them to avoid as much as possible the cues and temptations that may otherwise distract them into less healthy behaviours. It would also focus policy at a critical point during their customer journey i.e. when they were making purchasing decisions, thereby reducing unhealthy impulse buys.

C4: Public sector procurement of healthy food

  1.         In addition to the supply side policies above, there are also demand side policies that are vital in building the foundation to support changes in our dietary patterns.

 

  1.         The government spends £2.4bn per annum[6] buying food for schools, hospitals armed forces, prisons and government offices, representing 5.5% of all meals eaten outside the home. Currently, only one in four state schools in England is known to me meeting school food nutritional requirements[7].

 

  1.         Government should strengthen its procurement policies so that only healthy food is purchased by the public sector.

 

  1.         The benefits of this are threefold:

C5: Health Literacy Initiative

  1.         In order to drive long term shifts in dietary patterns and inspire future generations to look after their physical and mental health, we need to empower our children with knowledge on the science of nutrition and equip them with cooking skills to build their sense of confidence and fun in the kitchen.

 

  1.         The example on climate change is illustrative of the changes that can occur over time from nurturing awareness, understanding and engagement – younger generations are far more involved and active on climate change and sustainability partly because from an early age they have been taught about climate change in academic subjects within the national school curriculum. We need to learn from this example to achieve similar understanding and activism when it comes to our physical and mental health – teaching children from an early age about the science of nutrition could help to build understanding about the importance of lifestyle factors to our health and wellbeing.

 

  1.         Although there are current mandatory requirements in the national curriculum on nutrition, it is not being prioritised by the majority of schools due to lack of resources, expertise or funds. 

 

  1.         The initial proposal is to construct a pilot study to explore the impact of a 12 week health literacy initiative and use the results to inform wider policy making on school curriculum.

Objectives

  1.         There are two key objectives of the health literacy policy idea:

 

  1.         The initial proposal is for a pilot to generate evidence on activation and engagement measures (e.g. awareness, understanding, behaviour change) that inform policy decisions on health education.

Description

  1.         The policy initiative is aimed at teenagers (12/13/14 years old) to assess awareness, understanding and behaviour following a 12 week holistic health literacy programme. This age group has been chosen for initial pilots because this is the age many children start making independent decisions around their food choices.

 

  1.         The pilot would use an adapted version of the Patient Activation Measures (PAM) – a tried and tested approach used by the NHS to establish engagement and activation in patients with long term conditions. It would test engagement, activation and behaviour change in children at the start, end and 6 months after the study. A control group would be established to measure progress via PAM measures over time.

 

  1.         The pilot adopts a holistic approach with a 12 week programme of workshops and an accompanying app to:

Rationale and benefits

  1.         This initiative seeks to build the evidence base to deliver improvements in a number of areas:

Risks and mitigations

  1.         Risks are minimal from the pilot study – key risk is that the pilot project doesn’t secure funding to proceed.

 

 

7 May 2024

[1] Chavez-Ugalde, Y et al., Manuscript title: Ultra-processed food consumption in UK adolescents: distribution, trends and sociodemographic correlates using the National Diet and Nutrition Survey 2008/9 to 2018/19, posted June 2023

[2] Geographical areas where a high percentage of people have long, healthy lives and where there are a particularly high percentage of centenarians.

[3] National Food Strategy. The Plan. Available from: https://www.nationalfoodstrategy.org/

[4] These characteristics are explained more fully in The Four Disciplines of Execution, Achieving your Wildly Important Goals 2nd edition, McChesney, Covey & Huling, 2021

[5] https://www.dw.com/en/opinion-why-europe-should-abandon-the-nutri-score/a-62922313

 

[6] National Food Strategy. The Plan. Available from: https://www.nationalfoodstrategy.org/

[7] The Food Foundation, The Broken Plate, 2023

[8] National Food Strategy. The Plan. Available from: https://www.nationalfoodstrategy.org/