Food and Drink Federation – Written evidence (FPO0009)

 

Summary

 

This submission is made by the Food and Drink Federation (FDF), the trade association for food and drink manufacturing. Food and drink is the largest manufacturing sector in the UK (accounting for 19% of the total manufacturing sector) turning over £104bn per annum; creating GVA of £31.1bn and employing over 450,000 people.

 

  1.                                                                                                                                          Food and drink manufacturers in the UK are proud to make a wide variety of great-tasting, safe and nutritious products which are intended to be available to, and affordable by, everyone. We have long recognised the important role we can play to help people achieve healthier lives and have worked with successive Governments to play our part.

 

  1.                                                                                                                                          FDF welcomes the opportunity to respond to the House of Lords Select Committee on Food, Poverty, Health and the Environment call for evidence, to inform the inquiry into food insecurity and sustainability.

 

  1.                                                                                                                                          Our full response can be found overleaf. The key points we would like to highlight are:

 

    1. We ask that the food and drink industry is recognised as a valuable partner, that has consistently delivered against voluntary health initiatives.
    2. In addition to the extensive reformulation programmes already in place, it is imperative that targeted policy is implemented to address socio-economic inequalities in diet and health. To address this, Government should consider policies which support families on lower incomes and target initiatives in areas with the highest and increasing rates of obesity.
    3. Although sodium, sugars and fat have been the focus of dietary policy in the past two decades, evidence suggests that focusing on promoting the intake of components of diet for which current intake is less than the optimal level (e.g. wholegrains, fruit and vegetables, nuts and seeds, oily fish) might have a greater effect.
    4. Food processing/manufacturing can help extend shelf-life, avoid food waste, and maintain food safety.  Manufactured foods play an important role in supporting consumers to achieve a healthy and sustainable diet. As well as making food safe and taste good, food processing along with product reformulation and innovation, are increasingly widely applied to reduce the energy density of foods and to improve their nutritional composition.  Pre-prepared foods also have the benefit of nutritional labelling that may not be available with foods brought loose for incorporation into scratch cooked meals.
    5. Over the past three years Government has made a series of policy announcements designed to tackle childhood obesity, which have largely focussed on the food and drink industry. Government should consider a broader sweep of policy initiatives and engage with all stakeholders/settings which can play a part, such as local authorities and schools.
    6. The definition of what constitutes a ‘sustainable’ diet is at a relatively early stage of development. This is an area we are keen to understand better so that manufacturers know how to best develop positive choice. Thus far, there is clear movement towards ‘protein diversification’.
    7. Decisions on the future of sustainable food production should be evidence based. The UK could produce many crops, including fruit and vegetables currently grown abroad.  Most likely this would require technological solutions, but this production could have a greater environmental impact than the importation option, and may require heavy capital investment and harvesting by comparatively expensive labour to countries of current sourcing. Life Cycle Analysis can be a useful tool here.
    8. Key to developing a more sustainable food system is likely to be growing high quality food in smarter ways. For example, embracing and leveraging new technology.
    9. Food waste is an issue that everyone needs to own. Many food and drink manufacturers are already addressing the problem through voluntary and collective action.

 

  1. We note that the upcoming National Food Strategy due to be published in 2020 will be an important opportunity to address the issues raised within this call for evidence.

 


Questions

 

1) What are the key causes of food insecurity[1] in the UK? Can you outline any significant trends in food insecurity in the UK? To what extent (and why) have these challenges persisted over a number of years?

 

  1. FDF represent food and drink manufacturers, therefore other organisations are better placed to answer this question.

 

 

2) What are some of the key ways in which diet (including food insecurity) impacts on public health? Has sufficient progress been made on tackling childhood obesity and, if not, why not?

 

  1. A recent Lancet report[2] reviewed the health effects of different dietary risk factors. It found that in the UK the top four dietary risk factors were low intake of wholegrains, fruit, nuts and seeds, and vegetables (figure 1).

 

Figure 1 - Number of DALYs (per 100 000 population) attributable to individual dietary risks in the UK in 2017 (both sexes, all ages)

 

  1. Dietary intakes of these beneficial food groups are below the recommended amounts among the UK population, with those on lower incomes further away from meeting some dietary recommendations3. Importantly, children from poorer households have substantially lower intakes of fruit and vegetables, fibre and oily fish than other children, whereas intakes of sugar, saturated fat and salt are similar [3].

 

  1. Data from the National Child Measurement Programme[4] shows that whilst prevalence of overweight and obesity has declined in reception aged boys, prevalence has increased among reception aged girls and year 6 boys and girls from 2006/7 – 2017/18. Children living in deprived areas are more likely to be obese, and this inequality gap has increased over the last decade4.

 

  1. With respect to action the food industry can adopt to reduce childhood obesity, it is widely recognised that reformulation and portion sizing are the measures which will have the greatest impact[5]. FDF and its members are committed to voluntary reformulation and offering appropriate portion sizes and have made substantial progress to date. Over the last 4 years, the average shopping basket of our member products has reduced in calories by 12%, sugars by 13%, total fat by 12%, saturated fat by 10% and salt by 14%[6].

 

  1. The extensive reformulation programmes already in place are universal measures which will impact across society. We therefore believe that in addition to these it is imperative that targeted policy is implemented to address socio-economic inequalities in diet and health. To address this, Government should consider policies which support families on lower incomes and target initiatives in areas with the highest and increasing rates of obesity[7].

 

  1. It is essential that Government policy focuses on effective interventions with a strong evidence base. Although sodium, sugars and fat have been the focus of dietary policy in the past two decades, the evidence outlined above suggests that focusing on promoting the intake of components of diet for which current intake is less than the optimal level (e.g. wholegrains, fruit and vegetables, nuts and seeds, oily fish) might have a greater effect. The three chapters of the Government’s Childhood Obesity Plan published to date have taken minimal steps to improving these elements of the diet.

 

 

3) How accessible is healthy food? What factors or barriers affect people’s ability to consume a healthy diet? Do these factors affect populations living in rural and urban areas differently?

 

  1. In the UK, 1/3 of children are living in poverty[8]. The Food Foundation paper 'Affordability of the UK's Eatwell Guide' breaks down the cost of following a diet in line with the Eatwell Guide for different income deciles. For households in the lowest income decile nearly three quarters (73.6%) of disposable income would need to be spent, compared to only 6% for those in the highest income decile[9]. On average food budgets for more than half of UK households are insufficient to afford a diet in line with the Eatwell guide9.

 

  1. Importantly, the paper also highlights that due to rising food prices, fluctuations in the value of the pound and reduced labour availability for horticulture when the UK leaves the EU, a family would need to pay an extra £158 per year to meet the 5 A DAY guideline. This suggests we are likely to see the already widening inequalities of food security and dietary intakes accelerate further.

 

  1. Many of those in the poorer sectors of society live in substandard housing, with poor (often shared) cooking and food storage facilities.  It is important for these barriers to be considered; improving accessibility and/or affordability of healthy food may not be sufficient to support those most in need.  For such individuals, processed/ manufactured foods may well be a valuable source of nutrients.

 

  1. Only a minority of foods are grown and harvested in the format in which they are consumed, although fruits and vegetables are good examples of those that can be.  Raw materials usually require processing before they are eaten as finished products.  This processing can be as simple as washing and cutting but often involves a number of steps of preparation to turn them into the day to day foods that we recognise and purchase on a daily basis.  We have long used a wide variety of methods, such as cooking, fermentation, curing, pasteurisation, smoking and drying, to turn raw materials from the farm into the delicious food and drink products we consume every day.

 

  1. Thanks to food processing, today’s food is safer, of higher-quality, more accessible, and has a longer shelf-life than ever before. Ensuring that food is safe is non-negotiable for the food industry and is our first priority. It starts with good agricultural and animal practices and continues with the processing of raw materials, in compliance with the highest food hygiene and safety standards, delivering safe and nutritious food to citizens.  In many cases, if raw materials were not processed they would not only not taste as good, but they would be virtually indigestible and in some cases, could cause illness.  Food processing can help extend shelf-life, avoid food waste, and maintain food safety.

 

  1. Manufactured foods play an important role in supporting consumers to achieve a healthy and sustainable diet. As well as making food safe and taste good, food processing along with product reformulation and innovation, are increasingly widely applied to reduce the energy density of foods and to improve their nutritional composition.  Pre-prepared foods also have the benefit of nutritional labelling that may not be available with foods brought loose for incorporation into scratch cooked meals.

 

  1. It is vitally important that citizens understand the concept of nutritionally balanced diets and have the opportunity to make food choices to meet these.  Ideally, they should have the opportunity to learn culinary skills and have the equipment available to exercise these skills.  Where they cannot do this the opportunity presented by prepared, nutritious food and drink should not be discounted.

 

 

4) What role can local authorities play in promoting healthy eating in their local populations, especially among children and young people, and those on lower incomes? How effectively are local authorities able to fulfil their responsibilities to improve the health of people living in their areas? Are you aware of any existing local authority or education initiatives that have been particularly successful (for example, schemes around holiday hunger, providing information on healthy eating, or supporting access to sport and exercise)?

 

  1. We believe local authorities (LA’s) can play an important role in promoting healthy eating, with initiatives tailored to their local population and targeting those in need.

 

  1. Childhood Obesity Plan chapter 2 included a commitment by Government to develop resources for LA’s to use their powers to promote a healthy food environment and provide up to date guidance and training for planning inspectors. We are unsure whether this commitment has been fully actioned, however, PHE has launched Health Matters: Whole Systems Approach to Obesity, a resource to support local action on reducing obesity.

 

  1. The plan also included a commitment to develop a childhood obesity trailblazer programme with LA partners to show what works in different communities. Five LA’s have been selected – Blackburn with Darwen, Birmingham, Bradford, Lewisham, Nottinghamshire – which will receive £1.5 million of funding to trial initiatives over the next three years. 

 

  1. There are a number of initiatives implemented locally and nationally which have demonstrated a positive impact, including programmes implemented by food businesses to support local communities. Please see the below example case studies. We are also aware of a number of initiatives which support physical activity.

 

  1. Kellogg’s - Breakfast for Better Days
  2. Kellogg’s’ global initiative, Breakfast for Better Days, focuses donations of cash, food and employee time onto hunger relief programmes in the communities they operate in. In the UK Kellogg’s donates cereal to school breakfast clubs, food banks and food redistribution charities.

 

  1. Last year Kellogg’s celebrated its 20th anniversary of supporting school breakfast clubs in the UK and during this time has provided 70 million breakfasts, trained 1,600 schools and provided £4 million of investment so schools can provide the best start to the day for thousands of children. The Kellogg’s Breakfast Club Network currently supports 3,000 clubs.

 

  1. National School Breakfast Programme
  2. The National School Breakfast Programme (NSBP), delivered by Magic Breakfast and Family Action and funded by Department for Education, supports schools in disadvantaged communities to access healthy breakfasts.

 

  1. The programme aims to ensure more children have a healthy breakfast at the start of the day and improve educational outcomes for disadvantaged young people. Through the NSBP, schools receive free healthy breakfast food (cereal, porridge, low fat bagels), support from NSBP staff, a resource pack and a £500 start-up grant. Quaker and Tropicana support this programme by providing porridge and 100% fruit juice respectively to participating schools.

 

  1. In March 2019, the NSBP had been rolled out to 1775 schools, reaching an estimated 280,000 children every day. For more information please see the Family Action and Magic Breakfast websites.

 

  1. HENRY
  2. 20. Recent media coverage has highlighted the success of the HENRY programme, an education scheme which focusses on parents and carers of the youngest children and poorest families.  The programme was developed in Leeds, which has seen 6.4% decline in rates of obesity in reception children over the last 4 years[10].

 

  1. 21. The HENRY (Health, Exercise and Nutrition for the Really Young) programme aims to support families by helping parents to gain the confidence, knowledge and skills to help their families to lead healthier lives. The programme takes a holistic approach to health including supporting breast feeding, improving nutrition, emotional wellbeing, parenting skills, healthy nutrition, oral health and physical activity.

 

  1. The programme has seen great results, including 45% of children achieving their 5 A DAY by the end of the programme compared with a national average of 19.5%. More information can be found on the HENRY website. 

5) What can be learnt from food banks and other charitable responses to hunger? What role should they play?

 

  1. FDF represent food and drink manufacturers, therefore other organisations are better placed to answer this question.

 

 

6) What impact do food production processes (including product formulation, portion size, packaging and labelling) have on consumers dietary choices and does this differ across income groups?

 

  1. FDF members take their responsibility to help consumers make informed dietary choices and achieve healthier lifestyles very seriously. With respect to action industry can adopt to reduce obesity, it is widely recognised that reformulation and portion sizing are the measures which will have the greatest impact[11].

 

  1. These measures can benefit the whole population by bringing new products to market with improved nutritional profile and advertising this on the product packaging or by delivering smaller, incremental changes to formulation of food and drinks that are imperceptible to consumers.

 

  1. We are proud of our voluntary record so far: from world-leading salt reduction, virtual elimination of artificial trans fats, a sugars reduction programme, and soon a calorie reduction programme. Manufacturers are committed to this challenge and have been working towards the guidelines set by Public Health England as part of their comprehensive reduction and reformulation programme.

 

  1. FDF members’ voluntary action, reformulating products and offering appropriate portion sizes, has delivered substantial changes. Over the last 4 years, the average shopping basket of our members’ products is lower in[12]: calories by 12, sugars by 13%, total fat by 12%, saturated fat by 10%, and salt by 14%.

 

  1. Food and drink manufacturers have long recognised the importance of providing clear on-pack nutrition information to help consumers make informed choices. All pre-packed food and drink detail nutrition information on the back of pack, in line with the EU Food Information Regulations. In addition to this, most pre-packaged food and drinks voluntarily provided simple, at-a-glance nutrition information on the front of packs.

 

 

7) What impact do food outlets (including supermarkets, delivery services, or fast food outlets) have on the average UK diet? How important are factors such as advertising, packaging, or product placement in influencing consumer choice, particularly for those in lower income groups?

 

  1. Advertising and promoting food and drink to adults is a fundamental commercial freedom. It underpins the healthy, vibrant and innovative market for food and drink that shoppers enjoy.

 

  1. As part of the Childhood Obesity Plan chapter 2, the Government has undertaken several consultations to consider these areas, including:

 

  1. FDF submitted responses to these consultations.

 

  1. We believe these policy proposals will have no significant impact on childhood obesity levels. For example, the proposed extension to advertising restrictions which call for a restriction on advertising before 9pm on both TV and the internet is predicted by the Government to make a 2-calorie difference to children’s intakes. However, the proposals will have a significant impact on food companies by restricting their ability to compete, to effectively reach their adult markets and by introducing complicated and bureaucratic rules. The likely result is fewer products on the market and higher food prices.

 

  1. In addition to the above, the Government has undertaken consultations on ending the sale of energy drinks to children (closed 30th August 2018) and calorie labelling for food and drink served outside of the home (closed 7th December 2018). FDF submitted responses to these consultations and were supportive of the proposals.

 

  1. FDF members operate to a voluntary code of practice which states that high caffeine content soft drinks are not recommended for children, and specifies that this information should be clearly stated on the label of such drinks. It also states that high caffeine soft drinks should not be promoted or marketed to those under 16.

 

  1. We also support the introduction of calorie labelling for food and drink served outside of the home. Research suggests that around 20 – 25% of adults’ energy intake comes from food eaten outside of the home[13] and that the food and drinks served in these settings contain twice as many calories as equivalent manufactured products[14]. We therefore believe it is important to support consumers to make more informed choices when eating out. 

 

 

8) 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?

 

  1. As highlighted in our response to question 6, FDF and our members acknowledge our role in supporting customers to make healthier choices and are proud of our track record to date. We recognise there is more to be done and are committed to continuing our efforts in this area.

 

  1. We believe that voluntary action by industry is the fastest and most effective way of delivering change. A voluntary approach allows government to lead the agenda and focus action, whilst acknowledging that individual food companies need a certain level of flexibility to achieve change through resource intensive and challenging innovation.

 

  1. FDF members have an excellent track record in delivering on voluntary commitments through successive administrations, particularly in areas such as front-of-pack nutrition labelling and voluntary product reformulation, areas where the UK is widely acknowledged to be leading the world.

 

  1. FDF members’ voluntary action, reformulating products and offering appropriate portion sizes, is delivering substantial changes. Over the last 4 years, the average shopping basket of our members’ products is lower in[15]: calories by 12, sugars by 13%, total fat by 12%, saturated fat by 10%, and salt by 14%.

 

  1. Other examples of successful voluntary initiatives are:

 

  1. FDF members are also taking voluntary action to improve environmental performance. FDF’s environmental ambition, Ambition 2025, includes targets and other commitments on climate change, food waste, packaging, water, transport, sustainable supply chains and natural capital. Ambition 2025 case studies highlight specific actions our members have taken.

 

  1. FDF’s Sustainability Hub contains information on voluntary certifications, collaborative platforms and practical tools available to businesses looking to further their sustainability agenda. The Hub was launched to FDF members in July 2017 and to the public in January 2018. FDF update the Hub regularly and, as of August 2019, it includes 102 initiatives, many of which have some involvement from FDF members.

 

  1. As the conversation around sustainable diets grows, several FDF members have been exploring products to increase consumer choice as they diversify their diet to be flexitarian, vegetarian or vegan.  Given the definition of what constitutes a ‘sustainable’ diet is at a relatively early stage of development, in comparison to the definition of a ‘healthy’ diet, this is an area that we are keen to understand better so that manufacturers know how best to develop positive choices.  Thus far, there is clear movement towards ‘protein diversification’ where plant based dietary options are increasing, but it is important to view many factors simultaneously (e.g. carbon footprint, water usage) to ensure that unintended consequences are avoided.

 

 

9) To what extent is it possible for the UK to be self-sufficient in producing healthy, affordable food that supports good population health, in a way that is also environmentally sustainable? 

 

  1. The UK has a relatively poor climate for the production of many fruits and some vegetables that have become popular over the last few years.  In many cases the environmental impact of locally produced foods that require heating etc. may in fact have a poorer environmental footprint than those that are produce in climates for which they are best suited.  However, with modern techniques, such as solar heating, and careful and environmentally sensitive protection from the elements, such cultivation in the UK is possible, although this often requires significant capital investment and may require harvesting with comparatively expensive labour to other countries.

 

  1. It is critical with many topics, but particularly on environmental issues, to ensure that decisions are evidence based.  It can be over simplistic to assume that locally produced, seasonal produce has the best environmental footprint.  Given that the UK has (in global terms) less sun (highly relevant to crop production) and relatively poor soil, it may often be the case that fruits and vegetables transported from further afield, can in fact have a lower Carbon footprint than those produced locally.  On the other hand, horticultural products grown under glass/poly tunnels, using precision growing techniques, whilst not appearing to be ‘eco-friendly’, may in fact be more sustainable than those grown by low input (but wasteful) methods in the field.

 

  1. Similarly, assuming that an increase in self-sufficiency will result in increased food security is misguided.  The UK has long been a net importer of food, and levels of self-sufficiency are currently at typical historical low levels.  Subsidies to drive self-sufficiency are unlikely to support sustainability in the long run, and indeed it could be argued, that driving productivity and environmental factors which result in profitability probably will result in a more robust and sustainable system. The resilience of the system also needs to be considered with the ability of production systems to accommodate weather fluctuations, natural disasters and in the longer term, climate change.  Development of systems that can be termed as ‘sustainable intensification’ however are possible and should not be discounted.

 

  1. Using Life Cycle Analysis (LCA) can be a useful tool in ensuring decision making is evidence based.  For example, with packaging, focusing solely on a material’s end-of-life disposal can lead to environmental and resource benefits for the whole product/packaging system being overlooked. LCA considers the environmental impacts caused throughout the whole value chain. Often LCA is reduced to a single component, such as carbon emissions, but this can lead to misleading conclusions and is often far too simplistic.  More systematic LCA analysis might consider resource use in manufacturing, land use, greenhouse gas (GHG) emissions, release of pollutants, food waste, impacts on human health etc.   Such calculations are involved and complex but are likely to result in better evidence-based decision making.

 

  1. A number of stakeholders have advocated a Zero Carbon ambition for the UK, and indeed that concept has now been embraced by Government.  Of course, such commitments cannot be taken lightly.  Changes in agricultural practices (in particular) will be required which would not be considered evolutionary but revolutionary.  Agricultural production is likely to need to be ten times as efficient as it is now.  Logistics in food manufacture and retailing would likewise need a complete rethink.  It has been estimated that for every calorie (kcals) we eat, we burn 10 kcals of fossil fuels.  In a Zero Carbon economy, changes in the way we grow, process and retail food would need to change along with other parts of our economy.

 

  1. Key to developing a more sustainable food system is likely to be growing high quality food in smarter ways.  The use of technology in many forms will need to be embraced and leveraged.  This will certainly include the use of robotics both in the field but also much more fully in factories.  From the perspective of food and drink manufacturing we should not forget that the sector contains many SME’s, in fact 96% of businesses fall into this category.  Therefore, technology transfer can look very different for these organisations compared to the highly sophisticated multi-national organisations (many of which have research and development laboratories in the UK).  Advances in process technology will also be essential.

 

  1. Biological technology also should be encompassed in forward planning.  Modern plants and animals tailored to our future needs are available to us, but currently policy often precludes their use.  To be optimally sustainable, food production must use all the technology at our disposal (using ‘all the tools in the toolbox’) where risk assessment and risk management effectively balances any risks (as opposed to hazards) with benefit.  History also teaches us, that when citizens understand these risks in a dispassionate and balanced way, they can make well informed choices for themselves, but transparency from all stakeholders is essential.

 

 

10) Can efforts to improve food production sustainability simultaneously offer solutions to improving food insecurity and dietary health in the UK?

 

  1. See previous section. 

 

 

11) How effective are any current measures operated or assisted by Government, local authorities, or others to minimise food waste? What further action is required to minimise food waste?

 

  1. Tackling food waste wherever it occurs in the supply chain from farm to fork is a key priority for FDF members, particularly preventing waste and surpluses from occurring in the first place. FDF’s environment ambition, Ambition 2025, sets out FDF and members commitments to food waste reduction. As detailed in the Ambition 2025 Annual Progress Report 2018, FDF and several members have been supportive of a number of voluntary campaigns, such as Your Business is Food and the Food Waste Reduction Roadmap.

 

  1. Specifically, on the Food Waste Reduction roadmap FDF was pleased to support this ground-breaking initiative at its launch in September 2018. We particularly welcomed the emphasis on all businesses measuring, reporting and acting on food waste in a consistent way along with the need for collaborative working to meet both the Courtauld 2025 and UN SDG 12.3 food waste reduction targets on a whole supply chain basis. FDF has continued to work closely with WRAP on promoting uptake of the Food Waste Reduction Roadmap and particularly the Target, Measure, Act approach. For example, this year we have run exclusive webinars with WRAP for our member companies to encourage further uptake.

 

  1. In 2018, WRAP published updated estimates for UK food waste figures to ensure consistency with the Food Loss and Waste Accounting and Reporting Standard (FLWS). These new figures state that the total estimate for UK post-farm food waste is 10.2 million tonnes. Of that, 7.1 million tonnes came from the household, 260,000 tonnes from retailer, 1.85 million tonnes from manufacturers and 1 million tonnes from the hospitality and food service sector. Future action needs to fairly address food waste across all sectors, including where the overwhelming majority arises in terms of households.

 

  1. In October 2018, Government announced they would set up a pilot scheme to reduce food waste, specifically through increasing the amount of surplus food from the retail and manufacturing sectors made available for redistribution. The scheme is supported by £15 million of funding. The first £5 million opened for bids from food redistribution organisations in January 2019. The successful bids came from FareShare, Company Shop Group, The Felix Project and Food Works Sheffield to help remove barriers to food redistribution. FDF has supported this endeavour through its participation in the work of the WRAP C2025 redistribution Working Group and where FDF member company signatories along with other business signatories have committed to double food redistribution tonnage by 2020 against a 2015 baseline.

 

  1. Resources and Waste Strategy
  2. The Government published the Resources and Waste Strategy in December 2018; Chapter 5 set out the following measures to reduce food waste. Consult on regulations making it mandatory for businesses of an appropriate size to report their food surplus and waste.

 

  1. In October 2018, Government announced they would set up a pilot scheme to reduce food waste, specifically through increasing the amount of surplus food from the retail and manufacturing sectors made available for redistribution. The scheme is supported by £15 million of funding. The first £5 million opened for bids from food redistribution organisations in January 2019. The successful bids came from FareShare, Company Shop Group, The Felix Project and Food Works Sheffield to help remove barriers to food redistribution. FDF has supported this endeavour through its participation in the work of the WRAP C2025 redistribution Working Group and where FDF member company signatories along with other business signatories have committed to double food redistribution tonnage by 2020 against a 2015 baseline.

 

  1. In December 2018, Defra appointed Ben Elliot as the first Food Surplus and Waste Champion. Ben Elliot was tasked with driving governments ambition to reduce food waste from all sources. He launched Step up to the Plate in May 2019, details of which are provided below.

 

  1. Also, in December 2018, Government published new statutory guidance on the food and drink waste hierarchy. FDF’s Ambition 2025 states that we will work to the food waste hierarchy where the aim is to avoid generating food waste in the first instance.

 

  1. In February 2019, Defra launched their consultation on consistency in household and business recycling collections in England. Government proposed that all local authorities offer all households separate, weekly food waste collections from 2023. Government also proposed to legislate for business, public bodies and other organisations to segregate their recyclable waste from residual waste through three options; two of those three options would require separate, weekly food waste collection.

 

  1. Step up to the Plate
  2. In May 2019, the government launched Step up to the Plate fronted by Government’s Food Waste and Surplus Champion, Ben Elliot. Central to this is the Step up to the Plate Pledge calling on organisations and individuals to significantly cut food waste by:
  1. FDF’s CEO, Ian Wright, has signed the Pledge and FDF has given its support to the initiative. We are joined by more than 100 food organisations who have signed the Pledge to date.

 

  1. Courtauld 2025
  2. In the 25 Year Environment Plan, the Government set out their ambition to cut the greenhouse gas intensity of food and drink consumed in the UK by one-fifth through their support of the Courtauld 2025 commitment. Support was reiterated in the Resources and Waste Strategy.

 

  1. Under Ambition 2025, and as an engagement partner to Courtauld 2025, FDF has committed to contribute to the WRAP target to reduce UK food waste by 20% by 2025 per capita against a 2015 baseline.

 

  1. FDF has worked with WRAP on the previous Courtauld Commitments and between 2011 and 2014, according to WRAP analysis, food and drink manufacturers have achieved a 200,000 tonne reduction in food waste.

 

  1. FDF has also worked with our members to provide guidance on the setting of appropriate shelf lives of products and best practice on labelling.  On the latter point, we encourage members to use ‘best before’ rather than ‘use by’ dates where technically possible.  The aim is to give the consumer the best chance to use the food while it still safe to do so, by maximizing shelf life and being clear on the meaning of date marking.  We have also used a number of techniques, including social media, to help consumers understand labels better.  Some of our members also provide information on how to extend the life of products through freezing etc.  Guidance can be found here: https://www.fdf.org.uk/date-marking.aspx.

 

  1. Whilst there is much that our sector can, and is doing, we, like WRAP recognise that the responsibility for reducing food waste is one that everyone needs to own.  There is much that consumers can do in their own home to avoid waste and we are keen to understand how we can facilitate this thinking further.

 

 

12) A Public Health England report has concluded that “considerable and largely unprecedented” dietary shifts are required to meet Government guidance on healthy diets[16]. 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?

 

  1. Please see our response to question 2, where we have outlined a number of recommendations for government policy to improve diet and health outcomes. In addition, please see below our comments in relation to:

 

  1. Fiscal measures
  2. As part of the Childhood Obesity Plan, the Government implemented a soft drinks industry levy (SDIL) which came into force from April 2018. FDF opposes the SDIL as we believe it is wrong in principle to single out individual nutrients or product categories for punitive treatment.

 

  1. The soft drink sector announced in December 2015 their intention to cut calories by 20%, by 2020. Reformulation in the soft drinks industry has been ongoing for many years, resulting in reductions in sugars content of soft drinks by 30.4% since 2015[17]. It is essential that the SDIL undergoes a rigorous evaluation and the full impact of the levy closely monitored before there is any thought of extending it.
  2. We believe that interventions shown by robust evidence to present the greatest chance of being effective should be adopted. For manufacturers, that means innovating to help lower calorie intakes through product formulation and portion size.

 

  1. There is no evidence currently available which demonstrates that food taxes effect obesity rates or long-term behaviour change. In 2013, Denmark repealed its fat tax because of its negative economic impact and abandoned plans for a tax on sugar. In Mexico, the impact of a soft drinks tax saw an initial reduction of only 6 calories a day per person, in a diet of over 3,000 a day.

 

  1. The independent 2014 McKinsey Global Institute report found that a 10% tax on high-sugars and high-fat products in the UK would be ten times less effective than reducing portion sizes and eight times less effective than reformulation of products.

 

  1. Citizens make food choices based on their own personal hierarchy of needs.  For most people, the over-riding factor in decision making is price and then follow taste, health and wellness, convenience and sustainability in differing order and importance for each person.

 

  1. However, just because food prices are at a historically low point (food prices have fallen year on year for a number of years), this does not mean that food affordability has improved.  Food taxes are invariably regressive and impacts most, those who are already food insecure.  For those for whom food is least affordable (brought about by falling disposable income) taxes will have the biggest negative impact and potentially drive them further into food insecurity.

 

  1. Regulation vs Voluntary guidelines
  2. Please see our response to question 8.

 

  1. Information and education
  2. We believe that information and education play an important role in supporting people to achieve healthier diets.

 

  1. UK food and drink manufacturers have long recognised the importance of providing clear on-pack nutrition information to help consumers make informed choices. All pre-packed food and drink detail nutrition information on the back of pack, in line with the Food Information Regulations. In addition to this, most pre-packaged food and drinks voluntarily provided simple, at-a-glance nutrition information on the front of packs.

 

  1. We believe the Government should consider policies which support families on lower incomes and target initiatives in areas with the highest and increasing rates of obesity[18]. The HENRY programme (summarised on page 4) demonstrates a local initiative that takes a tailored approach to information provision and skills development with families, which has resulted in positive behaviour change.

 

  1. Public procurement
  2. The Government has undertaken a consultation to update the nutrition elements within the Government Buying Standards (GBS), which closed on 13th August 2019. The consultation sets out proposals to bring the standards up to date with the latest dietary advice and was included as a commitment within the Childhood Obesity Plan - Chapter 2.  

 

  1. We are awaiting a consultation on updating the school food standards, which was announced within Childhood Obesity Plan chapter 1 and re-announced in chapter 2.

 

13) Has sufficient research been conducted to provide a robust analysis of the links between poverty, food insecurity, health inequalities and the sustainability of food production? How well is existing research on the impact of existing food policy used to inform decision making?

 

  1.                    Several organisations and research bodies have begun to explore the link between health inequalities and the sustainability of food production. However, much of the research has been widely contested and created huge amounts of public debate.

 

  1.                    The link between a healthy sustainable diet and food insecurity and food poverty has been less explored.

 

  1.                    Eat-Lancet Commission
  2.                    The EAT-Lancet Commission is made up of 37 scientists from 16 countries working across multiple disciplines. The group was convened to develop global scientific targets for healthy diets and sustainable food production.

 

  1.                    The Commission published Food in the Anthropocene: The Eat-Lancet Commission on Healthy Diets from Sustainable Food Systems. They recommend that a planetary diet should consist of be made up predominantly of vegetables and fruits with wholegrains, plant protein sources, unsaturated plant oils, and modest amounts of animal protein. The Commission proposes boundaries for climate change (5 GT CO2 -eq yr-1), land system change (13 M Km2), freshwater use (2,500 km3 yr-1), nitrogen cycling (90 Tg N yr-1), phosphorus cycling (8 Tg P yr-1) and biodiversity loss (10E/MSY).

 

  1.                    They outline five strategies got a global food transformation: seek international and national commitment to shift toward healthy diets, reorient agricultural priorities from producing high quantities of food to producing healthy food, sustainably intensify food production to increase high-quality output, strong and coordinated governance of land and oceans and at least halve food losses and waste.

 

  1.                    However, some further study has suggested that the Eat-Lancet diet is nutritionally deficient[19].

 

  1.                    WRAP
  2.                    WRAP’s work on sustainable diets has focused on healthy sustainable eating and the reduction of food waste. Through pilot studies and surveys they have aimed to understand the behaviours underlying the causes for poor diet, unsustainable eating and food management/waste; identify potential interventions or triggers to challenge existing behaviour; explore whether existing messaging aligned with needs in encouraging health and sustainable eating; and explore which messages have most resonance.
  3.                    WRAP found that consumers did not make a connection between eating healthy and sustainable food and reducing food waste, though people who discussed their behaviours towards wasting less food also tended to have more balanced diets.

 

  1.                    Most consumers associated healthy eating with the nutritional value of foods, maintaining a healthy lifestyle and conflicting messages in the media. Sustainable eating was on the radar for only a few participants when the research took place, most consumers associated sustainable eating with where food is produced, local sourcing, seasonal produce and how food is sourced. Sustainable eating was also thought to be difficult and costly.

 

  1.                    Food Change Research Network
  2.                    The Food Change Research Network (FCRN) are based at the University of Oxford, focused on understanding and building sustainable food systems. They are currently running a project with the Food Foundation called ‘Plating up Progress?’ which aims to define a usable metric for assessing the progress of the food industry in delivering healthy sustainable diets.

 

  1.                    They have been doing work in this field since 2014, including research into the environmental impact of ruminants through the ‘Grazed and Confused’ project. This project was followed by the ‘Plates, Pyramids, Planet’ assessment which suggested a way forward for healthy sustainable diets through government owned dietary guidelines.

 

14) What can the UK learn from food policy in other countries? Are there examples of strategies which have improved access and affordability of healthy, sustainable food across income groups?

 

  1.                    There are a number of initiatives implemented internationally which have demonstrated a positive impact on health outcomes across income groups. Please see the below example case studies.

 

  1.                    Amsterdam Healthy Weight Programme
  2.                    The Amsterdam Healthy Weight Programme consists of a comprehensive range of actions to reduce the rates of obesity in the city. The programme focusses on areas of low socio-economic status and populations where need is greatest. The main risk factors for childhood obesity were identified to be: (1) families with little money, (2) non-western ethnicity, (3) parents with limited education, (4) growing up in a major city. The programme was designed, implemented and amended with these risk factors providing the foundation.

 

  1.                    The programme includes initiatives to support three key lifestyle factors: healthy food and drink, exercise, and sleep. The initiative has led to a 12% decrease in obesity rates for all children; and an 18% decrease amongst the most deprived children. It provides a great example of how a holistic intervention targeted at those in need can deliver positive impacts and reduce inequalities between the most and least deprived. A summary and review of the programme is available on their website.

 

  1.                    EPODE International Network
  2.                    The EPODE International Network (EIN) aims to prevent childhood obesity and non-communicable diseases through sharing best practice of effective and sustainable strategies across the world. The network comprises 40 community based programmes, including ‘Phunky Foods’ in the UK, which is supported by Nestlé. The ‘Phunky Foods’ programme provides healthy lifestyle curriculum activities, lesson plans and resources for early years and primary schools. For more information, please see the EIN and Phunky Foods websites.

 

  1.                    Eating Better for Less
  2.                    The Food Foundation Eating Better for Less report explores fruit and vegetable incentive programmes in the United States which create cost savings for healthier foods at the point of purchase for low income consumers. The review highlights opportunities for scaling up fruit and vegetable incentive programmes in the UK and contains a range of recommendations including:

 

  1.                    Dietary Guidelines for the Brazilian Population
  2.                    The Dietary Guidelines for the Brazilian Population provide information and recommendations around eating for Brazilians aged two years and over. They are aimed at all professionals working on health promotion and disease prevention. They were updated in 2014, based on social changes experienced by Brazilian Society. The creation of new guidelines is part of a wider piece of work to improve standards of diet and nutrition across Brazil and contribute to improving health.

 

  1.                    One of the five principles that shape the Guidelines is that “Healthy diets derive from socially and environmentally sustainable food systems”. The report suggests a number of factors that could affect environmental sustainability of a diet, examples include method of fertilisations, pest control and treatment of waste and residues.

 

 

15) Are there any additional changes at a national policy level that would help to ensure efforts to improve food insecurity and poor diet, and its impact on public health and the environment, are effectively coordinated, implemented and monitored?

 

  1.                    It is important for any new policies to be tracked and evaluated to ensure that they support positive health outcomes and do not widen inequalities.  In terms of sustainability, it would be helpful to have a ‘balanced scorecard’ approach so that the key drivers are understood and can be managed concurrently.

 


The UK Food and Drink Manufacturing Industry

 

The Food and Drink Federation (FDF) is the voice of the UK food and drink manufacturing industry, the largest manufacturing sector in the country. Our industry has a turnover of £104billion, which is 19 per cent of total UK manufacturing, with Gross Value Added (GVA) of £31.1billion. Food and drink manufacturers directly employ over 450,000 people in every corner of the country. Exports of food and drink make an increasingly important contribution to the economy, exceeding £23billion in 2018, an increase of 2.5% on the previous year. The UK’s 7,290 food and drink manufacturers sit at the heart of a food and drink supply chain which is worth £121 billion to the economy and employs over four million people.

 

The following Associations actively work with the Food and Drink Federation:

 

ABIM              Association of Bakery Ingredient Manufacturers

ACFM              Association of Cereal Food Manufacturers

BCA              British Coffee Association

BOBMA              British Oats and Barley Millers Association

BSIA              British Starch Industry Association

BSNA              British Specialist Nutrition Association

CIMA              Cereal Ingredient Manufacturers’ Association

EMMA              European Malt Product Manufacturers’ Association

FCPPA              Frozen and Chilled Potato Processors Association

FOB              Federation of Bakers

GFIA              Gluten Free Industry Association

PPA              Potato Processors Association

SA              Salt Association

SNACMA              Snack, Nut and Crisp Manufacturers’ Association

SSA              Seasoning and Spice Association

UKAMBY              UK Association of Manufacturers of Bakers’ Yeast

UKTIA              United Kingdom Tea & Infusions Association Ltd

 

FDF also delivers specialist sector groups for members:

 

Biscuit, Cake, Chocolate and Confectionery Group (BCCC)

Frozen Food Group

Ice Cream Committee

Meat Group

Organic Group

Seafood Industry Alliance

 

 

 

6 September 2019

 

 

 

 

 

 

 

 

 

[1] There is no universally accepted definition of food insecurity, but the most commonly used is: “limited or uncertain availability of nutritionally adequate and safe foods or limited or uncertain ability to acquire acceptable foods in socially acceptable ways (e.g. without resorting to emergency food supplies, scavenging, stealing or other coping strategies).” (The Food Foundation, Too Poor to Eat: Food insecurity in the UK, May 2016, https://foodfoundation.org.uk/wp-content/uploads/2016/07/FoodInsecurityBriefing-May-2016-FINAL.pdf. This definition was also used for the UK’s 2007 Low Income Diet and Nutrition Survey.) 

[2] Health effects of dietary risks in 195 countries, 1990–2017: a systematic analysis for the Global Burden of Disease Study

[3] National Diet and Nutrition Survey - Years 1 - 9 of the Rolling Programme (2008/9 - 2016/17): Time Trend and Income Analysis

[4] National-child-measurement-programme-ncmp-trends-in-child-bmi

[5] McKinsey Global Institute (2014) Overcoming Obesity: An initial economic analysis

[6] Kantar Worldpanel data for FDF members (2019)

[7] PHE Child Health Profiles 2019

[8] The Food Foundation: Children’s-Future-Food-Inquiry-report

[9] The Food Foundation (2018) Affordability of the UKs Eatwell Guide

[10] National Childhood Measurement Programme Data 

[11] McKinsey Global Institute (2014) Overcoming Obesity: An initial economic analysis

[12] Kantar Worldpanel data for FDF members (2019)

[13] NatCen Social Research. National Diet and Nutrition Survey Years 1 – 6, 2008/09-2013/14 [data collection]. MRC Elsie Widdowson Laboratory, University College London. Medical School; 2017, 8th Edition.

[14] Public Health England (2018) Sugar Reduction and the Wider Reformulation Programme: report on progress towards the first 5% reduction and next steps.

[15] Kantar Worldpanel data for FDF members (2019)

[16] Scarborough, P, et al. Eatwell Guide: modelling the dietary and cost implications of incorporating new sugar and fibre guidelines, 2016, https://bmjopen.bmj.com/content/6/12/e013182  

[17] Kantar Worldpanel

[18] PHE Child Health Profiles 2019

[19] Food and Farming Futures