FDF Response / 30 June 2004

Choosing Health: Choosing a Better Diet

Final FDF Response – 30 June 2004

Introduction

  1. The Food and Drink Federation (FDF) welcomes this consultation and the opportunity it presents for stakeholders to work together and utilise their expertise in order to help individuals choose appropriate diets.
  1. We also welcome the ‘Choosing Activity’ document; but believe that these two documents should have been integrated. This would demonstrate that both are essential and complementary elements of any course of action designed to improve health and to reduce the prevalence of obesity. Mention of balancing “energy in” with “energy out” being key to reducing obesity is made in the ‘Choosing a Better Diet’ document (paragraph 1.13, p5), but we believe this needs further emphasis.
  1. FDF appreciates that this document has taken on board some of the comments it has made in previous consultations, for example, the need to build on positive changes that have already taken place. We are also pleased to see some industry initiatives, such as our foodfitness scheme and other food chain initiatives mentioned as positive examples.
  1. However, we are still concerned about the scientific basis for some of the proposed strategic action. Basing such action on insubstantial science would be misjudged, and could actually be detrimental to the goal of improving the health of the nation.
  1. 1.7 states that ‘the food we eat, and the way it is produced and manufactured, has a significant impact on our health’. The inference of this is negative whereas in reality the production and manufacture of food in the UK is a resoundingly positive story. Our food is produced and manufactured safely, with a view to maximising it’s nutritional benefits.
  1. 1.8 states that unhealthy diets, along with physical inactivity, have also contributed to the growth of obesity. Clearly it is overeating - and lack of physical activity in some cases - that contributes to obesity (i.e. a positive energy balance). Having a poorly balanced diet, while being inactive, will not cause weight gain if the total calorie intake does not exceed output. Equally, eating too much of any diet it will result in weight gain.

Enabling consumers to choose a better diet

  1. FDF applauds the tenor of the ‘Choosing Health’ philosophy: people need to take responsibility for their own diet; in order to do this, they need to be empowered to know what is an appropriate diet for them. They also need to have the skills to choose and prepare that appropriate diet, so that it becomes easier for them to identify appropriate choices.
  1. Industry believes it is already playing its part by providing a range of foods from which consumers can choose and compose a balanced diet. Furthermore, 80% of food products provide objective nutritional information on-pack. FDF also increasingly provides consumer education schemes, which aim to help consumers understand what constitutes a balanced diet.
  1. FDF welcomes the emphasis placed on vulnerable groups and agrees that more consideration is needed so that public health policy can be tailored to meet the needs of such diverse and disadvantaged population groups. We welcome the work that is being undertaken by FSA on the NDNS data to see if particular characteristics of certain groups can be identified and to try and ascertain characteristics of consumers of high salt, fat and sugar. This will allow an appropriate targeted approach.
  1. FDF is particularly pleased that reference is made to consumer demand influencing the type of foods produced by industry (paragraph 2.1, p8). This is a key point we have made in previous consultations. Subject to technical constraints, industry can innovate and make products that seek to meet certain criteria, whether it is lower fat/sugar/salt, added vitamins, etc. However, it cannot continue to make those products if consumers do not wish to purchase them. The success of a new product is only possible if it can be marketed so that consumers get to know about it. If consumers then purchase the product on a sustained basis, a place for that product is secured in the market place.

Food compositional changes

  1. FDF agrees that compositional changes in salt content can only be done gradually and across the board, so that one brand does not remain higher in salt than another with a similar recipe. This is why the various schemes for reducing salt in, for example, bread, breakfast cereals, soups and sauces are proving so successful. However the salt contents of different brands can not all be the same. Some consumers prefer a higher salt content, others a lower salt content and can thus choose accordingly. Making all products within one sector according to one set recipe would remove the variety consumers currently enjoy. Also, products have different characteristics and requirements. A higher salt content may be needed depending in shelf life and storage requirements.
  1. We believe that the issue of fat and sugar in products must to be handled differently from salt. It is not feasible to reduce the sugar and fat content of many food products as taste and texture would be compromised and consumers would not buy them. Industry understands however, that a range of lower fat and sugar products needs to be available for people who believe that such products are a good choice for them. It is therefore seeking to ensure that an increasing range of new products is available which are low in fat and sugar, and also, where technically possible and acceptable to consumers, existing recipes are re-formulated with lower or unsaturated fat content and lower sugar content. Wide choices already exist in most categories.

3.  The evidence available on the impact of energy balance of changing the energy density of people’s diet is confined to short term experiments conducted under highly artificial circumstances. There is little evidence of the impact of the energy density of diets, still less of particular foods on people’s eating behaviour or bodyweight maintenance in naturalistic circumstances. What evidence there is suggests that people compensate for a higher energy density by adjusting their energy intake[1]. It is important for health to obtain the right proportion of carbohydrates and fats in the diet but driving all food products to be lower in fat and sugar may not lead to a lowering in the rate of obesity. Indeed evidence is accumulating that weight loss and weight maintenance is more sustainable with moderate fat (around 35% of energy) and not low fat diets[2].

4.  Thus it is important that children are brought up to accept a balanced approached to eating from a young age. However there is no need to single out infant foods with respect to added sugar. Commercially prepared baby foods are already produced to strict guidelines and current legislation controls the total amount of sugar that they may contain. Indeed total sugar content of all baby foods and drinks is kept to a minimum and the norm is not to add sugar at all (paragraph 3.5, p 13).

Role of labelling

  1. As the document states in paragraph 2.10 (p10), labelling is governed by an EU Directive. The Directive states that nutrient content does not need to be declared unless a nutrition claim is made. The Directive requires sodium, not salt to be labelled. Despite this, industry voluntarily goes a lot further: around 80% of products now provide nutritional labelling and some also provide some kind of ‘salt equivalent’ labelling.
  1. Some companies go further than purely compositional labelling and include sign-posting in the form of Guideline Daily Amounts (GDA). This allows consumers to check the composition of the product against a set of recommended intakes (the GDAs), notably for energy and fat, so as objectively to assess their own dietary intake against recommended norms. Not only does this not demonise foods, but it allows consumers to see how all foods can fit in a balanced diet, and how best to construct an appropriate diet. More companies are considering giving this sort of additional information.
  1. Industry is against nutrient profiling (alluded to in paragraph 2.10, p10) as we believe it will be impossible to produce a scheme which covers all the nutritional issues involved in building up a balanced diet. For example, a scheme which concentrates on the fat content of food will only be focusing on the energy density of those foods. In such a scheme, foods which are high in fat, such as margarine, cheese and oils, but which provide essential micronutrients, may be misleadingly perceived to be ‘unhealthy’. Such profiling schemes lead to emphasis being placed on individual foods, rather than on trying to construct the whole diet. The wood will therefore have been lost for the trees! (See Annex 1 for more on why foods should not be labelled as ‘good’ or ‘bad’).
  1. Industry welcomes the EU review of the current Directive as an opportunity to change labelling requirements in the light of current consumer interests and concerns. It will be far more beneficial for EU consumers to have consistent, clear labelling reflecting their wishes wherever they buy their food in the EU than the current confusing plethora of voluntary labelling schemes.
  1. However industry is concerned that the EU claims directive may hinder industry innovation. For example, a manufacturer may decide to gradually reduce the fat content of one of his products. However, while reducing gradually, he may find that it still falls foul of the fat criteria and so he will be unable to claim that he is reducing the fat in that particularly product. This will be a disincentive to go to the expense of modifying his product.

Role of advertising and marketing (paragraphs 2.12-2.16)

1.  In Sweden and Quebec, where there has been a ban on advertising to children under 12 for the last two decades, levels of obesity are no lower than those of their neighbours.

2.  Too many other factors influence why, when, what and how much children eat, and looking at advertising as the major influence is misguided. For example, the influence of parental behavior was found to be fifteen times greater than that of television advertising and appears to be the dominant influence on children’s eating habits[3].

3.  Nevertheless, industry supports responsible codes and regulations and the regular review of codes based on evidence. This process is already underway – Ofcom is currently reviewing the broadcast advertising codes which relate to food advertising to children and will shortly be issuing its views.

4.  The food industry has an exemplary record in upholding advertising codes, and through CIAA and GMA, has developed a further set of codes which relate to food and beverage advertising. The codes, developed in 2004, have specific rules in relation to the advertising and marketing to children and have already been shared with the Department of Health (as Annex 2 to the FDF Response to the main Choosing Health? consultation).

5.  Influencing obesity can most effectively be achieved by harnessing the expertise of the industry rather than disproportionately restricting its practices.

Joined-up thinking

We support the idea, mentioned frequently in the document, that in order to have a cohesive strategy, stakeholders all need to play their parts. The industry is pleased that the Public Health White Paper tries to pull together the strands, but would like to see a more clearly defined co-ordination role coming from government, which would respond to needs by freeing up appropriate resources.

Just as government is adopting a cross-departmental approach to the complex issue of obesity, so we believe that a partnership approach across the food chain, advertising industry and government could have a substantial impact in changing behaviour. The whole food chain has been united in working with government and agencies in the current round of consultations relating to food and health.

The proposed White Paper will be the vehicle for new ideas and approaches. We think a government led but joint multi-media consumer information programme, based on consistent food and health messages agreed between government and other partners, should be one of them, and have submitted an outline proposal from the food chain and advertising industries to the Prime Minister, copied simultaneously to other relevant Ministers and officials. The letter was also shared with the Department of Health (as Annex 3 to the FDF Response to the main Choosing Health? consultation).

Role for nutritionists

  1. The food and drink industry is concerned that there are insufficient nutrition experts in positions to contribute to government’s nutrition policy. What is needed are people who understand the science behind nutrition, but can view diet in a holistic and pragmatic way.
  1. There seems to be a shortage of health professionals who can positively influence people’s diets, whether it be dietitians based in hospitals and in the community, or nurses and doctors trained to give good quality advice on diet. Again, qualified nutritionists need to be behind schemes to educate other health professionals on food and health issues. We are pleased that this fact has been acknowledged in the last bullet point of the table on page 24.
  1. FDF is not convinced that most consumers are aware, in general terms, of what constitutes a balanced diet. Indeed, a significant proportion of the population seems very confused about this. For example, the popularity of the Atkins diet has led some people to view carbohydrates as undesirable and away from having a diet which derives 50% of its calories from carbohydrates. Books, newspaper reports and other media channels continually bombard consumers with the latest fad diets, usually developed by unqualified individuals. Qualified nutritionists need to be used by government to guide the development of key messages, which can be used to deflect some of this misinformation.

Nutrition in schools