Judith Batchelor, Sainsburys - Supplementary written evidence (FPO0091)



Thank you for inviting me to give evidence to your Committee recently and allowing me to provide Sainsbury’s perspective on the role of supermarkets in supporting healthy and environmentally sustainable diets.


I promised to write to you with some policy asks that could help to reduce obesity and to set out the areas for greater cooperation between government and industry. I have outlined these below but please do not hesitate to contact me should you have further questions.


Stimulating innovation by setting clearer guidance for industry


The grocery sector is fiercely competitive and we already have plenty of reasons to innovate and develop better, more differentiated and healthier products to help us win customers.  


However, the Government can help stimulate innovation by the private sector through welldefined metrics and methodologies that promote a level playing field and guide us in product development. A few examples here include reformulation targets, infant foods and nutrient profiles being applied to products that carry nutrition and health claims:


Reformulation targets with improved performance metrics

We welcomed the Government’s decision to set reformulation targets that provide a roadmap for product development over the next 5 years. Co-ordinated action helps provide a level playing field whilst also delivering nutritional improvements to the foods we most commonly consume. However, this process would be aided by the collection of better, more accurate data of what industry is doing, average absolute sugar reductions within relevant categories and improved performance analytics that show relative progress among companies, in order to drive competition. 


Infant foods

Current weaning regulations are ambiguous and would benefit from greater clarity regarding the regulated nutrient composition and classification of infant foods, based on the market today. For example, snack items could fall within multiple different compositional standards of the Commission Directive 2006/125/EC. 


Due to a lack of clear guidance around the development of infant foods, including appropriate portion sizes, it took us two years and work with several experts to create the appropriate nutritional criteria, portions and principles for our Little Ones brand, a range of over 60 products for infants. Greater clarity would have helped us deliver this brand to market quicker. 


I welcome Public Health England’s impending guidelines for improving the nutritional content of commercially available baby food and drinks, but more work needs to be done into the marketing and labelling of infant foods.



Restrict nutrition and health claims to healthier choices

By regulating to restrict nutrition and health claims to healthier products, the

Government could reduce the potential for consumers to be misled. In line with draft EU regulations on health claims from 2015 (which were never implemented), Sainsbury’s only makes such claims on products without red traffic light labels; otherwise, we could end up promoting a product as low in fat when it might simultaneously be high in sugar. Not all companies subscribe to these norms but tougher regulations could promote a fairer playing field, minimise consumer confusion and create better standards across industry.


Harmonise standards e.g. wholegrains

Wholegrains are encouraged as part of the carbohydrate component of the Eatwell Guide but presently "wholegrain" is an unprotected term, unlike the term wholemeal which is part of the compositional standards for bread and should only reflect breads made with 100% wholemeal. Adoption into British regulations of the EU Health Grain Forum’s (a consortium of wholegrain experts) forthcoming definition of a wholegrain food would be helpful to drive consensus across the industry.


Having a coherent view of definitions for healthier choices

There are currently multiple different nutrition standards in place to define healthier choices for hospitals, schools, reformulation and marketing to children. There is no alignment between products which pass the Ofcom Nutrient Profiling Model (NPM), CQUINN hospital retail food criteria, PHE reformulation targets for salt and sugar, regulated levels for certain nutrition claims, and traffic light criteria relating to front-ofpack labelling. Developing one product to pass all of these criteria can be a huge challenge. Yet adopting consistent nutrient profiling criteria across interventions such as advertising restrictions, labelling and reformulation would make it easier for companies such as Sainsbury’s to innovate and deliver healthier product ranges.


For me, one of the biggest opportunities available is to create a single, coherent set of nutrient standards that aid industry in developing healthier products and inform companies’ innovation roadmaps. Ideally, this would include a definition of what constitutes a 'healthier choice' within category as well as a ‘healthy choice’. 


Providing greater guidance on portion sizes

Mandating responsible portion sizes is another area of regulation that could help raise the food sector to a higher standard and encourage healthier choices among consumers. It would guide industry in the pursuit of calorie-based reformulation and, for the purposes of front-of-pack labelling, educate customers on what responsible meal sizes look like.  As mentioned previously, such reformulation criteria would benefit from being aligned with other nutrient criteria, e.g. for schools, hospital procurement, advertising to children and dietary guidelines. 


Maintaining a fair and level playing field – the shopping environment


I recognise the Government’s desire to make the shopping environment healthier and we have already engaged extensively with DHSC around proposals to restrict promotional sales of HFSS foods. Sainsbury’s was the first major grocer to stop multi-buy promotions and we accept that supermarkets should be doing more to promote healthier products in stores. 


However, there is an opportunity for the Government to use technology better in ensuring that any new regulations being adopted are applied consistently across retail channels.  For example, current exemptions being proposed would excuse non-pre-packed products from promotional restrictions but keep in scope packaged products. This could invite a situation in which a customer is not permitted to buy a multi-pack of pastries on promotion in a supermarket but is, theoretically, able to walk down the street and visit a coffee chain to purchase an unwrapped sweetened croissant in a meal deal with a high-fat coffee. 


If the Government is committed to introducing restrictions to HFSS promotions, then harnessing technology to ensure customers have access to the right nutritional information (e.g. on website or smart phone if not on front-of-pack) would ensure regulation is being applied consistently regardless of whether a product is packaged or unpackaged.  


Having already participated in some independent 'in-aisle' trials designed to nudge lessaffluent customers towards healthier choices, it is not clear to us that restricting certain products by location will necessarily reduce their rate of purchase. Our trials indicate that customers may continue to ‘roam the store’ or shop around for treats, despite interventions, and we would therefore welcome more evidence regarding location-based restrictions before a decision is made in favour of their use. 


Areas for greater cooperation between industry and government


I already shared with your Committee our exciting plans to go Net Zero by 2040 and am clear that, to hit this target and encourage customers towards healthier, more environmentallyfriendly choices, the use of data will play a big role. For example, there is huge potential for Sainsbury’s to leverage its Nectar card data to create individually tailored incentives and interventions for our customers to make healthier choices. But this is just a microcosm of a much bigger opportunity and something I am pursuing outside of Sainsbury’s in my capacity as Chair of the Innovation Working Group of the Food and Drink Sector Council. 


Indeed, sharing and integrating datasets between the private and public sectors offers a variety of applications beyond simply helping consumers make healthier choices. It could help improve the nutritional value of crops and, by extension, the nutrient density of consumers’ diets; this would be especially useful as people become older and their appetites reduce. Data trusts are one way we could unblock data sharing, making cooperation between the public and private sectors easier and creating the infrastructure necessary to truly digitise the food system. Not only would this reduce obesity; it would reduce emissions and help us get to a Net Zero economy. 


As mentioned previously, utilising data and digitising the food system is something I am passionate about and working on through my position on the Food and Drink Sector Council. Anything Parliamentarians can do to raise awareness of its potential would be most helpful. 


The National Food Strategy presents an exciting opportunity to deliver a cross-departmental plan backed by industry. The food industry is highly complex and all the individual policies referenced above need to be incorporated into a whole system approach which adds up to more than the sum of its parts.  I am confident the National Food Strategy is the right vehicle to progress this and will continue to support its development through Sainsbury’s and my role on the Food and Drink Sector Council.


Finally, the COVID-19 crisis shows us what can be achieved when the Government and industry work fast to collaborate, share data and apply their combined expertise: we are receiving records from DEFRA regarding clinically vulnerable citizens deemed most in need of food deliveries, cross-referencing that against our own data and leveraging the online grocery sector’s combined infrastructure to prioritise assistance and direct resource. This is a powerful example of what we can achieve together and I hope, when things return to normal, such ways of working can be applied to other policies such as reducing obesity. 



03 April 2020