Health Action Campaign – Written evidence (FPO0046)



1. Health Action Campaign is a public health charity, whose guiding principle is that prevention is better than cure. In this submission we draw on our health economics research into the role of food and the food industry and our follow up research into how best to reduce childhood obesity.


What are some of the key ways in which diet (including food insecurity) impacts on public health?

2. Food high in sugar, salt and saturated fat is now implicated in a range of health problems, from obesity and type 2 diabetes to heart attack, stroke, several types of cancer and dental decay1. For instance, eating too much of this kind of food is the main cause of obesity

and there’s a seven times greater risk of type 2 diabetes in people who are obese.

3. So, action by the food industry to produce food that is lower in sugar, salt and saturated fat is important for public health.

Has sufficient progress been made on tackling childhood obesity and, if not, why not?

4. Childhood obesity rates remain worryingly high. The main reason for the lack of progress is that government action has been too little, too late. For instance:

Do you have any comment to make on how the food industry might be encouraged to do more to support or promote healthy and sustainable diets? Is Government regulation an effective driver of change in this respect?

5. Three important points here are:

6. Food companies who want to produce healthier food now have a range of options. For instance, they can:




7. We have no commercial relationship with or interest in any of the organisations mentioned above and simply provide the examples to illustrate that the food industry now has a range of healthier food production options available to it,

8. We accept that reformulation can be a complex process. Companies may need to consider the impact not only on taste but also on shelf life, food safety and processes such as baking. However, reformulation is a core skill for food companies, who can already vary the formulation of the ‘same’ product for different parts of the world (to cater for different regional tastes or different regulatory requirements). They can also call on the expertise of external organisations to help with reformulation, including an increasing number of universities - and have access to an element of corporation tax relief for R & D.

9. Evidence that healthier food is good for business comes from a range of sources. This includes consumer research organisations like Kantar World Panel, Leatherhead Food Research, Nielsen and Canadean. It also comes from sales figures. For example, both globally and in the UK, sales of bottled water have now overtaken sales of sugary drinks3. Again, here in the UK dunnhumby, who track supermarket sales, report that more health-conscious consumers spend more. It is reasonable to assume they will also tend to live longer in good health – meaning greater lifetime value for the companies whose products they purchase.

10. Health concerns don’t represent an existential threat to the food industry. People will always need to eat and drink. And consumer behaviour is sometimes nuanced. For example, people may want their everyday foods to be healthy, but feel treats (like chocolates or eating out) may be treated more as indulgences, with less need to be healthy. So we will always need a food industry. However, our analysis suggests that producing healthier food and being seen to do so, isn’t just good for public health, potentially reducing pressure on the NHS. It should have positive commercial benefits for food companies, enabling them to increase market share and profits amongst the country’s (and the world’s) increasingly better educated, more health-conscious consumers. With increasing public and political pressure for healthier food it makes sense for food companies to be seen as part of the solution, rather than part of the problem.

11. Government regulation to achieve progress is now widely supported. This includes support from the British Retail Consortium and its big supermarket members, which has called on the government to take tougher action to ensure more companies produce healthier food.

12. The government should take into account that most big companies which are serious about staying in business undertake scenario planning. They consciously seek to identify potential threats and opportunities and then make contingency plans to prepare for them. It is reasonable to assume that most major food and drink companies have identified that regulation to ensure healthier products may be introduced at some stage and already have plans in place to rapidly introduce healthier alternatives as and when required. They may not introduce such healthier alternatives until required but will be ready to do so when needed. The ease with which so many companies introduced lower sugar versions of their soft drinks before the government levy was introduced is a good example of this in practice4.

A Public Health England report has concluded that “considerable and largely unprecedented” dietary shifts are required to meet Government guidance on healthy diets.2 What policy approaches (for example, fiscal or regulatory measures, voluntary guidelines, or attempts to change individual or population behaviour through information and education) would most effectively enable this? What role could public procurement play in improving dietary behaviours?

13. Seeking to change individual or population behavior through information and education is often popular with governments, as it avoids them having to tackle the root causes of problems - in this case the over production and marketing of cheap food high in sugar, salt and saturated fat relative to the cost, availability and advertising of healthier food like vegetables and fruit. 

14. Unfortunately, as research in England tells us, between 43% and 61% of working age adults routinely don’t understand health information5. In practice therefore, health information tends to be understood and acted on by those who are most literate and health conscious - effectively increasing health inequalities.

15. As we have seen with action on public health issues from smoking to car seat belts over the years, fiscal and regulatory measures are needed if real and lasting progress is to be achieved.

16. To put this in a wider context, upstream initiatives (which make healthy choices the easy and/or legal choices) are almost always more effective than downstream initiatives (which don’t tackle the underlying causes and instead rely on trying to persuade millions of individuals to change the ingrained habits of a lifetime).

17. Health information and education will usually also be competing with much larger advertising budgets and more sophisticated and evidence-free approaches promoting unhealthy products. For example, the budget the government allocated to Change4Life to promote healthy snacks in 2018 was £4.5 million6. This sounds impressive until it is placed in context e.g. it is less than the advertising budget for the chocolate bar Kit Kat in a typical year, which in turn is just one of a wide range of products high in sugar, salt and/or saturated fats being promoted that year7.











Michael Baber, Director, Health Action Campaign.

12 September 2019