New rules on food advertising to help tackle childhood obesity

Following a public consultation, strengthened rules controlling the advertisement of high fat, salt or sugar (HFSS) products to children came into force this summer. They’d been expected for a while and for many couldn’t come soon enough.

We think these rules can lead to a major reduction in the number of adverts for HFSS food and drinks seen by children. This will help in the fight against childhood obesity.

The new rules and their anticipated impact

The Committee of Advertising Practice (CAP) rules complement the existing Broadcast Committee of Advertising Practice (BCAP) rules. So what are the key points to note and what impact should they have on advertising HFSS products? Here’s a short rundown:

1. Age of a ‘child’ increased
A ‘child’ is now classified as anyone under 16, rather than under 12 as it was previously. Many of the rules apply to this wider age group.

A far greater number of young people will be protected from seeing the ads.

2. New restrictions based on audience
Adverts that promote an HFSS product, whether directly or indirectly (such as brand advertising using company logos or characters), cannot appear in children’s media or when children make up over 25 per cent of the audience.

The window of opportunity for advertising is more limited. It’s lovely to think that popular TV shows such as the X-Factor, which have a significant under-16 audience, will no longer be able to show adverts promoting products that are HFSS.

3. Celebrity endorsement prohibited for under-12 audience
Adverts for HFSS products that are likely to be seen as directly targeting under-12s cannot include promotions, licensed characters and celebrities popular with children.

Companies will no longer be able to use popular influencers such as footballers, Disney characters, etc. to help sell their products to children.

4. Reach extended, covering broadcast, print and online platforms
The rules now apply not just to broadcast media but also non-broadcast, such as print, cinema, digital and social media platforms.

Children are now protected across all platforms. The industry now has to factor in social media when it’s planning who and where to target its products.

5. Burden of proof shifted to advertisers
In order to determine whether a product is considered HFSS, advertisers must enter its nutritional content data into the Department of Health’s Nutrient Profiling Model. This model has been used to control TV advertising of food and drink products since January 2007.

Previously, all advertisers were required to submit a completed HFSS certificate to Clearcast before an advert could be aired on or around children’s programming. With the new rules, certificates do not need to be completed before an advert runs on non-broadcast media. However, as part of due diligence, businesses have an obligation to ensure they comply with the CAP code and hold the necessary documentation in-house.

If a complaint is made about an advert to the Advertising Standards Authority (ASA), measures will be taken to review it (which may involve a formal investigation) and non-compliant adverts will need amending or removing.

Impact: There’s a possible danger that as adverts are no longer pre-approved, more of them with inappropriate content will slip through the net – especially as the ASA admits it’s going to have a tough time enforcing the wider scope of application of its rules. However, the ASA will investigate any complaints seriously – even if it’s only one complaint against an advert. The complaint can come from anyone – likely to be competitors, pressure groups and parents. With the burden of responsibility for an appropriate ad more heavily weighing on the advertisers, we hope they will be careful to conduct their due diligence responsibly, to avoid costly amends or even the creation of a new campaign if they are forced to pull one.

Our overall assessment

The new CAP rules are very welcome. The wider remit, covering all platforms, presents both opportunities and challenges: the ASA will have its work cut out enforcing it. The more awareness there is amongst those interested in preventing HFSS products being advertised to children, the more likely it is that advertisers will be challenged if they flout the rules.

Change on the horizon for nutrient profiling

A decade has passed since the inception of the Department of Health’s HFSS nutrient profile. Nutrition science and dietary recommendations have moved on during that time – particularly in the area of sugar. The Government has announced its commitment to updating the nutrient profile as part of their Childhood Obesity Plan. So we expect that change is coming, which will mean companies will have to reevaluate their products and associated adverts.

Currently, products are scored on a points basis. You score negative points for elements that are damaging to health (sugar, saturated fat, salt, etc) and positive for those that are healthy (fibre, vitamins, etc). The benchmarks are going to change, in relation to total sugars and fibre levels. The amount of total sugars allowed will very likely be reduced (scoring proportionately more negative points) and you’ll probably have to have more fibre to score the positive points. Essentially, it will make it easier for products to be classified as HFSS.

Need help understanding or applying the rules?

The rules are complex, especially alongside European regulations that UK companies need to be aware of too. If you’re a food business affected by these new CAP rules, we can help support you in meeting your obligations. We’re also able to advise you on reformulation opportunities to improve nutrient profiling scores coming out of the HFSS categorisation, and to make sure your products are following the most up-to-date guidelines. We’d love to discuss your needs: email us today – email

For more information visit the CAP website or download the Advertising Guidance: Identifying brand advertising that has effect of promoting HFSS product

Is coconut oil really good for you? A Nutrilicious health check

Is coconut oil really good for you? A Nutrilicious health check

Over the last few years, coconut products – in particular coconut oil – have become very trendy. Celebrities such as Gwyneth Paltrow and Angelina Jolie are enthusiastic consumers of the oil and one in 10 UK 16–24 year-olds currently buys it. Sales rose from around £1 million to £16.4 million in the three years up to 2016, according to the consumer research group Kantar Worldpanel.

The main driver? The popular belief that coconut oil or fat* is more nutritious than other types of fats.

But do the alleged health benefits stand up to scrutiny?

A summary of our assessment

Around 87% of coconut oil is saturated fat – more than in lard or butter. Despite what advocates of a ‘low carb, high fat’ diet suggest, scientific reviews and respected health organisations including the NHS and the British Nutrition Foundation concur that consuming too much saturated fat overall is bad for us.

As a result, the growing consumption of coconut products – especially coconut oil – is of great concern to those who work with scientific evidence-based nutrition. Coconut’s popularity is likely to add to the burden of obesity and heart disease, not reduce it.

So coconut products should be sold as an indulgent product, not a health food. Manufacturers, retailers and the media need to stop exploiting any health associations.

The scientific evidence on coconut oil

Coconut is bursting with cholesterol-raising saturated fats. Some companies marketing coconut products over-simplify what is a very complex topic. They assert that medium-chain length saturated fatty acids (MCTs) in coconut oil can actively protect heart health.

However, while some studies suggest some MCTs in isolation might have benefits, coconut oil contains a mix of fatty acids. Focusing on any benefits of a few MCTs while ignoring the detriments of the other fatty acids is at the least misleading and at worst very damaging for consumer health.

Saturated fats – a complex story

There are over 30 different types of saturated fatty acids. While there’s good evidence that some will have little, if any, effect on cholesterol, three in particular have been proven beyond a doubt to elevate cholesterol levels and are all contained in coconut oil in high amounts.

  • Lauric acid, an MCT, makes up 14% of coconut oil (and is also found in palm kernel oil and cow’s and goat’s milk).
  • Myristic acid, a long chain fatty acid (LCT), makes up 20% of coconut oil, and is in palm kernel oil and butter.
  • Palmitic acid, an LCT, is found mainly in palm kernel oil, meat and full cream dairy milk and products, but also makes up 8% of coconut oil.

Clinical studies have consistently demonstrated that coconut oil increases total and LDL cholesterol – directly linked to higher cardiovascular disease risk. Despite some (not all) studies also demonstrating an increase in HDL (‘good’) cholesterol through the consumption of coconut oil, this is common with other saturated fats and does not negate the effect on LDL cholesterol.

Coconut products – putting statistics into context**
  • Highest of all are the coconut oils and coconut butter, which are higher in saturated fat than any other commonly eaten food. Most coconut oils contain just short of nearly 90% saturated fat, compared with butter at 52%. Just 1½ tablespoons will provide the entire recommended daily intake of saturated fat.
  • Four 100% natural coconut yogurt alternatives are currently on the market as ‘healthy alternatives’. Three of these provide between 17% and 20.5% saturated fat; the other a more modest 4.2% – which is still higher than full cream dairy yogurt. So an average 125g serving of three out of the four coconut yogurts will provide 21.3g to 25.6g saturated fat. That’s up to 128% of the maximum saturated fat daily recommendation. Other yogurt alternatives with coconut added to ingredients such as soya may not be high in saturated fat. It’s important to check the label.
  • Creamed coconut (the block sort added to dishes like curries) is on average 58% saturated fat (some almost 70% saturated fats), which is more than butter (52%) and lard (44%)
  • Canned coconut milk (made with coconut extract and water) averages 14.6% saturated fat, with reduced fat coconut milk weighing in at a somewhat lower 6.3% (three times greater than full cream dairy milk).
  • Desiccated coconut is over 50% saturated fat and crops up increasingly in energy balls and similar products.
  • Coconut drinks are not of concern in terms of saturated fat. On average a 200ml glass of coconut drink contains only 1.5g saturated fat (7.5% of the Reference Intake). Coconut water contains no saturates at all, or only a tiny trace.***

What needs to be done differently?

We think more responsibility is needed

Chefs, celebrities, manufacturers, retailers and the media all share a responsibility in how coconut products are positioned and portrayed. In some cases, there is a genuine ignorance and misunderstanding of the science, which could perhaps be addressed through more public health messaging.

HEART UK, the British Heart Foundation and Department of Health already advise that coconut oil should be consumed only in small quantities and the Change4Life website lists coconut oil within a category of foods labelled ‘leave these on the shelf!’

But these messages need more reinforcement. Manufacturers see that the market for coconut products is a lucrative one, so they are harder to influence. However, given that the majority of coconut products are excessively high in saturated fat (with the exception of waters and drinks), we believe that responsible manufacturers should position the products of concern as an indulgence rather than something that provides any health benefits.

The products should have clear nutrition labels, ideally using the traffic light system. Consumers should look out to see which are classified as high, medium or low, to help them cut down on their intake. The classifications are:
High: More than 5g saturates per 100g. May be colour-coded red.
Medium: Between 1.5g and 5g saturates per 100g. May be colour-coded amber.
Low: 1.5g saturates or less per 100g. May be colour-coded green.

*’Coconut oil’ and ‘coconut fat’ are synonymous. A fat is usually called an oil when it’s liquid at room temperature.
sing data from Forestfield Software Ltd. Dietplan7 (2017)
***On-pack labelling of current leading brands on the market (October 2017)

Draft Soft Drinks Levy – Objectives, Thresholds, Exemptions & Impact?

Draft Soft Drinks Levy – Objectives, Thresholds, Exemptions & Impact?

How much is the UK public willing to pay for sweetened soft drinks?
The draft Finance Bill 2017 was published on Monday, 5th December. Not normally associated with health and nutrition news, this year, the introduction of the soft drinks levy has definitely hit the newspaper headlines. Still awaiting the finer details, the draft does provide further insight and confirms the details announced during the 2016 budget announcement. Out for comment, it will be interesting to see how industry reacts with many of the big players already making huge reformulation changes to ensure the few of their products are taxable.

So what is in the draft Finance bill?
All soft drinks which contain 5g or more of added sugars per 100ml will be in scope of the tax. This will also include alcoholic drinks of ABV up to 1.2%.

The exemptions:
• Smallest manufacturers and importers of the smallest producers abroad.
• Soft drinks containing less than 5g added sugars per 100ml or no added sugars drinks.
• Drinks classified as ‘Foods for Special Groups’ which includes baby foods and formulae.
• Sugar containing milk-based drinks with a minimum of 75ml of milk per 100ml.
• The new trend of plant-based milk alternatives is also exempt as long as they are a source of calcium.
• Alcohol substitute drinks.

Transition period until April 2018 – providing reformulation time for all industry.

The two sugar thresholds still remain:
Products with 5-8g added sugars will be taxed at a lower level than those providing 8g or more of added sugar per 100ml.

The exact tax level has yet to be defined, but according to the Guardian Monday 5 December headlines, the levy would increase the cost of a 1L bottle of soft drink containing 5g sugar per 100ml by 18p and those containing 8g and more of sugar per 100ml by 24p.

Policy objective is to reduce childhood obesity through the reduction of total calories by removing additionally calories consumed via added sugars within soft drinks. It hopes to raise in excess of £500 million in the first year which they have promised to invest in physical activity for children.

The government wants to encourage industry to reduce sugar levels by:
• Reformulation
• Reduction in portion size
• Import of lower sugars / reformulated drinks

Economic impact (Estimated by the Office for Budget Responsibility). Based on estimates made in 2016:
The levy will add a quarter of a percentage point to CPI growth in 2018 and 2019.

Health impact.
It is believed that the health of the nation will be significantly improved especially with a reduction of obesity related diseases e.g. diabetes type 2.
The main reason for the sugar focus is that it is seen as additional excess calories.

Impact on industry.
The government believes that 300 UK producers will need to register for the levy and the impact on their business should be negligible. However, the Coca Cola representative’s view at the All Party Parliamentary Group on Adult & Childhood Obesity Meeting on the 5th December, had a different opinion stating that the average cost per reformulation was in the range of £½million and that smaller manufacturers would not be able to absorb this cost.

Operational impact (HMRC costs): there will be a one-off capital costs to develop the system for tax collection and on-going resources costs for HMRC to implement this change and monitor compliance.

An additional comment made by at the All Party Parliamentary Group on Adult & Childhood Obesity Meeting on the 5th December, was that the government had yet to demonstrate clearly if this sugar tax will have a significant impact on obesity.

The Brits are immune to dietary change!

The Brits are immune to dietary change!

The latest NDNS survey is out today!  The new survey (Years 5 and 6 – 2012/13-2013/14) will be met with disappointment and possibly frustration by many public health campaigners.

The Brits have done little to improve their intakes of essential nutrients despite significant government and NGO campaigns. We’re still eating too much sugar and saturated fat and seem to be unable to increase our fruit and vegetable, fibre and essential vitamin and mineral intakes. On a positive, and there was only one positive, we are reducing our intakes of red and processed meats. And at least our diets have not got worse. But the question remains, with little dietary improvements over the last 10 years, what really needs to be done to help the nation change their eating behaviour and nudge them into a healthier and happier life?

  • Brits still struggling to meet their 5-a-day with no improvements in consumption compared to previous years:
    • Just 8% of children and less than a third (27%) adults achieving their 5-a-day.
    • Children’s average intake is less than 3 portions per day, whilst adults are so close to the recommendations at 4 portions a day.
  • Heart healthy omega-3 and much needed vitamin D intakes cannot be expected to improve with oil-rich fish consumption continuing to fall short of the recommended 140g per day.
    • Brits are only managing 62% of the recommendations at a max of 87g per day.
  • The message is getting through about red and processed meat with reductions in intakes from previous years.  However, men need to make further improvements as their intakes are significantly higher than women’s and the maximum recommendations of no more than 70g per day of red meat and avoidance of processed meat.
  • Could the sugar reduction public health campaigns be making some small inroads to reducing added sugar intakes in children?
    • Let’s not get too excited, but 4-10 year olds have reduced their intakes by 1% compared to previous years (13.4% of total energy intake vs. 14.4%).
    • Unfortunately, teens and adults continue on their sweet ways with intakes remaining unchanged at 15.2% and 12.3% contribution to total energy intakes.
    • Intakes are a long way from meeting the SACN recommendations of no more than 5%!  Is sugar tax really going to be the solution?
  • The attack on sweetened soft drinks seems to have made an impact on 4-10 year old’s intakes with a 23% reduction in amount consumed daily compared to previous years (100g vs 130g respectively).
    • Unfortunately, adults and teens refuse to be told what to do and continue to struggle with the sweet nectar!
  • Could the misleading media headlines ‘butter is good for you’ be responsible for the population continuing to exceed saturated fat intake recommendations (11% of total energy intake) and in fact have higher intakes than previous years.
    • The latest data shows saturated fat to contribute to 12.7% of total energy intake, whilst in previous years it has been at 12.3-12.5%.  A major contributor to elevated ‘bad’ cholesterol which afflicts over half the adult population.
  • Fibre – another new government dietary recommendation doomed for failure! Although less publicity has been given to fibre, the SACN carbohydrate report did not only make new recommendations on sugar intakes but also recommended a significant increase in fibre intakes to 30g AOAC (23g non-starch polysaccharides NSP).
    • The nation continues to struggle to meet the previous recommendations of 18g NSP per day with adults making no improvements to previous years at 13-14g NSP intakes daily.
    • It would be great to see a public campaign for us to eat MORE of something rather than to deprive ourselves!
  • Is it time for mandatory vitamin D fortification?  The survey found around a fifth of adults with low vitamin D status and with an average level of 42-48nnmol/L.
    • Few have the optimal status as recommended by many vitamin D experts of 50-70nnmol/L.
  • Fatigue and tiredness in teenage girls and young women could be explained by continued poor iron intakes, with almost half of teenage girls and over a quarter (27%) of young women having iron intake below the lower reference nutrient intake.




Having a sneaky bacon buttie behind the bike shed?

Having a sneaky bacon buttie behind the bike shed?

The media loves a good headline, and the World Health Organisation (WHO) and the International Agency for Research on Cancer (IARC) provided the perfect story on October 26th – processed meat causes cancer. So is bacon the new tobacco?

The review of over 800 studies found conclusive evidence that processed meats cause colorectal cancer, placing them into the AICR’s top category for carcinogenic substances alongside tobacco. Strong associations were also found for stomach cancer. Red meat was classified as ‘probably causing’ colorectal cancer with the working group unable to exclude all other confounding factors from the data available.

So, are sausages and bacon as bad for us as smoking? Comparing the lowest with the highest consumers, the evidence concluded that for every 50g of processed meat consumed a day, the relative risk of colorectal cancer increased by 18% and for every 100g of red meat consumed daily, the risk increased by 17%.

However, when the findings are put into perspective, it is clear that the level of damage caused by smoking is far greater. The IARC, highlights that their findings and risk categories reflect how strong the scientific evidence is for a substance to cause cancer rather than how many incidences of cancer it will actually cause.

Cancer Research UK’s (CRUK) blog on this topic puts things into perspective:

  • 61 out of 1,000 people are expected to develop bowel cancer.
  • For the lowest meat consumers, this risk will be lower, at around 56 per 1,000.
  • For processed meat consumers with a 17% increased relative risk, the incidence would therefore be 66 per 1,000, i.e. 10 more cases per 1,000 for processed vs. non-processed meat consumers.

CRUK went on to put the risk in more real terms.Red Meat

It’s not about the quality of the meat – it’s all in the cooking or processing technique! The mechanism by which red meat and processed meat cause cancer is still being investigated. However, the current evidence points towards the method of processing and cooking as key drivers for production of carcinogens and there seems little impact with regard to the quality or cut of meat. Processed meats include ancient traditions of smoking, curing and salting as well as any other process to enhance the flavour or shelf life of meat. Included in this category are ham, sausages, bacon, tinned meat and sausages. It is thought that the processing results in the formation of carcinogens within the meat such as N-nitroso-compounds (NOC) and polycyclic aromatic hydrocarbons (PAH).

Get the slow cooker out to help reduce cancer risk! For red meat, which includes pork, beef, lamb and goat, it is the cooking of the meat that seems to generate carcinogenic compounds such as heterocyclic aromatic amines (HAA) and PAH. And these carcinogens like higher temperatures such as those produced during pan frying, grilling and barbecuing.

So how much is too much? On this, there is less clarity as the evidence did not indicate to a ‘safe’ level. CRUK recommends following the current guidelines of no more than 70g red meat per day, avoid processed meat and to use more plant-based protein foods to part or fully replace meat dishes.

How much processed and red meat is the UK currently eating? According to the NDNS data, men eat an average of 86g per day and women 56g. However, there is a significant range from zero for non-meat eaters up to 219g daily for some men. Focusing on the higher processed meat consumers and identifying effective behaviour change strategies seems to be key.

What should our advice be to consumers? Although the Atkin’s supporters may be a little displeased, the average consumer and the press cannot blame scientists and health professionals for always changing their minds. The advice is the same as always…a varied balanced diet, cutting down on red meat and trying to avoid processed meat.



  1. Chan DSM, Lau R, Aune D et al. Red and processed meat and colorectal cancer incidence: meta-analysis of prospective studies. PLoS ONE 6(6): e20456. doi:10.1371/journal.pone.0020456. accessed 5th Nov.
  2. Bouvard V, Loomis D, Guyton KZ et al. (International Agency for Research on Cancer Monograph Working Group). Carcinogenicity of consumption of red and processed meat. Lancet Oncol. 2015 Oct 23. pii: S1470-2045(15)00444-1. doi: 10.1016/S1470-2045(15)00444-1. [Epub ahead of print] Accessed 5th November.
  3. Dunlop C. Cancer Research UK Science Blog. Processed meat and cancer – what you need to know. 26 October 2015. Accessed 5th November.
Can the UK Lose its Sweet Tooth?

Can the UK Lose its Sweet Tooth?

Initial thoughts on the recent PHE Report: Sugar Reduction: The evidence for action

Many realists thought it unthinkable, but it happened, the Scientific Advisory Committee on Nutrition (SACN) recommended that sugar recommendations should be halved.  Although many have tried to refute it, the evidence is strong for sugar and dental caries and however anyone tries to pull apart the publications associating sugar intake and weight gain, common sense and practical experience tells us, drinking litres of liquid sugar without any other nutritional benefit is not going to help with our struggle against obesity.

Nevertheless, halving sugar recommendations to no more than 5% of energy intake although aspirational may be a tall ask for many. Some have suggested it unachievable unless applied in a controlled environment where all sugar containing foods are banned. So let’s look at the facts and the plans now in place for achieving this.

Current sugar intakes exceed the old DRV recommendations of no more than 10% energy. Adults were not far off at 11.5%, the issue was with young children and teens with intakes of 14.7% and 15.4% of energy intake respectively.  With the new guidelines, we are expecting adults to be able to reduce their sugar intakes by over half and children and teens by three-quarters…that does seem like a tall ask.

Which are the main culprits?

Food contribution to Non-Milk Extrinsic Sugar (NMES) intakes
Food contribution to Non-Milk Extrinsic Sugar (NMES) intakes

Source: National Diet and Nutrition Survey Results from Years 1, 2, 3 and 4 (combined) of the Rolling Programme (2008/2009 – 2011/2012)

Not surprisingly soft drinks are the major contributors to sugar. Other unsurprising contributors are biscuits, cakes, pastries, buns plus obvious sugar and confectionary sources. Surprisingly however, fruit juice is also a key contributor, particularly for the very young. Some health professionals in the past have criticised attacks on fruit juice as it can help contribute to the nation’s 5-a-day.  Fruit juice does have a halo effect for contributing to the UK’s vitamin intakes.  According to the latest NDNS data, fruit juice contributes towards 14-19% of vitamin C intakes for 4-18 year olds and 12% for adults.  However, soft drinks such as energy drinks, cordials and fruit drinks, contribute similar amounts of vitamin C – 18-20%.  Whole fruit and vegetables remain top vitamin C contributors.  Apart from the vitamin C contribution, fruit juice is not a significant contributor of any other vitamins or minerals, nor is it a source of fibre – a common myth (smoothies would on the other hand contribute to fibre intake). In addition, it’s interesting to note that vitamin C in bought fruit juice is due to fortification and not naturally derived from the fruit source.  Based on these facts, soft drinks and fruit juice are not dissimilar, in that they are both a liquid form of concentrated sugar and contribute up to a fifth of vitamin C intakes.

PHE report on a rapid review of the evidence to assess the relationship between fruit juice consumption and health including cardiovascular disease. It reports that the very limited evidence shows no benefit or no harm. However, shouldn’t a review now consider the nutritional composition of fruit juice and its contribution to nutrient intake? This doesn’t appear to have been included. PHE report on how advice has been strengthened to limit consumption of fruit juice to no more than one portion a day i.e. 150ml. However, if 150ml of fruit juice is adhered to, which is highly unlikely given that only 1% of the population currently meet healthy eating guidelines, this in itself will provide approx. three teaspoons of sugar, making up 60% of the recommended maximum free sugars for 4-6 years and 50% in those 7-10 years.  A more detailed review of advice in relation to fruit juice seems warranted, particularly in relation to children’s diets.

How can the nation so drastically lower their sugar intakes?

How the government aims to achieve this is through 8 key strategies, published by the PHE on the 22nd October 2015:

  1. Reduce price promotions on high sugar drinks and foods (in all retail and out of home sections including supermarkets, convenience stores, restaurants, cafes and takeaways).
  2. Significantly reduce opportunities to market and advertise high sugar food and drink products to children and adults across all media including digital platforms and through sponsorship.
  3. Set a clear definition for high sugar foods to aid with actions 1 and 2 above. They aim to review and update the 2011 Ofcom nutrient profiling model5.
  4. Gradual sugar reduction in everyday food and drink products, combined with reductions in portion size.
  5. The sugar tax.  A price increase of a minimum of 10-20% on high sugar products through the use of a tax or levy such as on full sugar soft drinks.
  6. Government buying standards for food and catering services (GBSF) across the public sector, including national and local government and the NHS to ensure provision and sale of healthier food and drinks in hospitals, leisure centres etc.
  7. Accredited training in diet and health for all who have opportunity to influence food choices in the catering, fitness and leisure sectors and others within local authorities.
  8. Continue to raise awareness of sugar to the public as well as health professionals, employers, the food industry etc., encourage action to reduce intakes and provide practical steps to help people lower their own and their families’ sugar intake.

Much of the above makes sense and we look forward to seeing how all of this will be actioned. It comes as no surprise that no single action will be effective in reducing sugar intakes and it’s positive to see much direction for change in terms of the environmental drivers of poor diets. In the meantime we have a number of initial thoughts.

PHE in their report highlight the lack of evidence for a sugar tax where many experts do not support this as an effective strategy.  Food tax has failed in some countries where there is limited data for success in others. Placing a 10-20% tax on a cheap commodity such as soft drinks, would surely have little impact on sales where many individuals will simply seek out cheaper own brand alternatives.

While we don’t believe a sugar tax in itself will change sugar intake, any revenue generated from the tax could be put into other actions on reducing sugar intake. However, the halo effect from the extensive media headlines on sugar tax may have in itself already started to impact on inspiring lower sugar food choices. We all know the impact of “celebrity”. However the end impact is rarely positive when it comes to celebrity and public health nutrition. It’s not surprising that Jamie Oliver is once more being regarded as a public health nutrition “angel”.

Banning advertising of sweetened foods and drinks should have come in a long time ago. We know how powerful this tool is, especially for confusing the public with ‘skewed’ health and nutrition claims that seem to by-pass current legislation.

What’s missing?

What could be lacking from the government’s 8-point strategy, is the inclusion of more ‘enforced nudging strategies’ in all retail and out-of-home outlets selling sugary drinks and foods at point of purchase and in areas where there is the highest consumption.  Removing high sugar foods and drinks from end of aisles and till points are mentioned. However, very little weight is given to this in the summary, despite that fact that this strategy has been proven to work in many scenarios both in the UK and abroad.  Many corner shops and out-of-home food establishments have a limited range of ‘sugar free’ drink variants, bottled water is often highly priced, and point of purchase is often adorned with high sugar / fat /salt snacks and in some well-known establishments, 500g chocolate bars are aggressively promoted.

Another dichotomy is the drive for industry sugar reductions within major sugar contributors such as confectionary, cakes, biscuits and sweetened drinks. While this is needed as an immediate and realistic solution (changing peoples’ behaviour and eating habits will take a number of generations!), on its own, it cannot help towards improving the overall dietary and lifestyle habits of individuals.  Swapping like with like will not educate or help change behaviour to enjoy and consume sugar / high fat foods in moderation nor can it empower the most in need to increase fruit and vegetable, water, wholegrains, oil-rich fish and plant-based protein intakes and be more physically active. This is an important factor that needs to be incorporated into any responsible reformulation programme and subsequent communication plans.

There are of course a number of challenges associated with removing sugar from a food or drink product and there little mention of this in the report.   Positively industry have already been reformulating and achieving significant reductions in the sugar content of foods and drinks already, particularly in relation to retail own brands.  A range of solutions have been employed which include the use of high intensity sweeteners, some bulking agents alongside some fibres. Adding fibre successfully provides a big opportunity for businesses and public health where the population are not eating enough fibre and where SACN has recently recommended increases in daily intakes. These of course all come with various challenges which need to be considered in full before embarking on re-formulation. The use of sweeteners for example are tightly regulated at EU level. There are restrictions for use on some sweeteners in some food groups. Claims in relation to sugar reduction are also tightly regulated. Importantly the other challenge is to reformulate in ways that still deliver on the consumer expectation for taste. A challenge for all industry members and particularly medium and start-up companies of course will be cost of re-formulation.

Competent training in diet and health for the wider workforce has been hugely welcomed at Nutrilicious. This is a key passion and area of work for us. The power of many occupations and individuals to influence the diet and health of those they have contact with is enormous. Yet many lack training. Guidance on how to achieve this is mentioned but one of the key stumbling blocks for most which is funding is not addressed in this report.

Something we feel PHE failed to tackle, possibly due to the enormity of the task, is food labelling.  Regulations and guidance for front and back of pack labelling stipulates that ‘Total’ sugar must be shown. There are justifiable technical reasons for this.  With the increase of front of pack traffic light labelling and encouragement of its use by the government, this is bound to thwart any attempts by individuals to fully grasp which sugars they should be avoiding and more importantly, the importance of nutrient dense foods.  Focusing on just sugar content on food labels, the consumer could not be blamed for choosing digestive biscuits over an individual portion of nuts and raisins. The former would be traffic light coded amber for sugar and display 17.5g sugar per 100g (or 4.6g per 2 biscuits) whilst a 25g nuts and raisins pack would be traffic light coded red for sugar and display 34g sugar per 100g (8.5g per serve).  How are we helping the consumer understand that the latter will not contribute to ‘free sugars’ and more importantly, it would help towards meeting the new increased fibre recommendations, provide heart healthy fats and some minerals.  How confusing can it be for a consumer to see plain dairy yogurt with amber traffic light for sugar at 7.5g per 100g. Is there now a real need for the UK to adopt front of pack traffic light labelling for sugar to only include added sugar?

Focusing more on positive messages about foods rather than individual nutrients must be a major part of the way forward.  And to drive positive food choices, it would be paramount to make naturally healthier foods more attractive and readily available whilst reducing the shelf space in stores of highly processed high sugar and fat foods with little other nutritive value.

Driving healthy food choices involves nudging people in the right direction as well as helping them to learn how to achieve a healthy balanced relationship with all foods and drinks (not nutrients). All stakeholders across multiple sectors and channels can play their own unique role in this and its exciting times for those developing and creating new food and health strategies and engagement plans for better health and business.

While lots of thoughts questions and ideas abound, we welcome PHEs report on sugar reduction. We look forward to working with relevant partners in contributing to the action and seeing how all of this will be implemented and monitored so that the 5% target can be achieved in 10 years.

At this date PHE have kindly agreed for us to interview them in January 2016 about this report and we look forward to exploring our thoughts and questions further on this hot public health strategy.


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