Restricting promotions on food and drink high in fat, sugar or salt

Yogurt and Fromage Frais
We strongly oppose options 3 and 4 which include yogurt and fromage frais within the products subject to restrictions. The list of food categories subject to restrictions, regardless of whether or not they pass the nutrient profiling model, sends out a powerful message to consumers of products to avoid. Yet yogurt and fromage frais are key contributors of nutrients, particularly to the young and old, and are relatively lower calorie, and frequently also low fat, and as such offer a quick, easy and ‘healthy’ snack or dessert option, particularly when compared to some of the alternatives.

While we acknowledge that yogurt and fromage frais are included in the UK Government’s list of products subject to restrictions, and there is value in a consistent approach, we disagree that yogurt and fromage frais should be included on that list. It is not helpful to consumers who are looking for lower calorie options to demonise the whole yogurt and fromage frais category just because products contain some sugar, particularly as the vast majority pass the 2004/5 nutrient profiling model and are therefore not classified as ‘less healthy’.

As with other dairy products, yogurt and fromage frais contribute a range of micronutrients to the diet and are key contributors of high value protein and calcium in particular. Calcium is important for growth and development of bone as well as several other functions such as blood clotting and neurotransmission. It is of particular importance to children and especially children between nine and 18 years because that is a period of rapid growth and development, and the key period of development where maximum bone mass is built to support calcium needs during the rest of the life. Poor storage of calcium at this crucial period can have critical health effects later on in life, in particular resulting in osteoporosis.

Please find attached a paper on ‘Yogurt and Public Health’ which outlines the health benefits of yogurt.

Processed Meat Products
The consultation document includes ‘processed meat products’ within ‘Option 4: All categories included in the UK-wide reformulation programmes’. However, ‘processed meat products’ are not specifically included within the UK Government reformulation programmes (other than for some named products with salt targets). PTF’s understanding was that ‘processed meat products’ (specifically sausages (raw and cooked) and sausage meat products, frankfurters, hotdogs and burgers) had been included on the UK Government’s draft list of products in scope of the calorie reduction programme before the 2019 consultation but were removed post-consultation.

We would welcome clarification of whether this is merely an oversight or if the proposal is to encompass the processed meat products category within the restrictions. If the latter, what products would fall within this category? PTF’s view is that products such as sausages and burgers are essential household staples for many families and, given the cost of living crisis, should not be included within the scope of any restrictions.

We agree that the 2004/05 NPM should be used alongside the targeted food categories to identify those products subject to restrictions. There will be many products (particularly yogurts and fromage frais) which, while falling within the targeted food categories, are not high in fat, salt or sugar. The use of the NPM ensures that only those that are HFSS are restricted. It also acts as a motivational tool allowing the potential for reformulated products within the targeted categories to move from HFSS to non-HFSS.

However, we would not support the use of the proposed revised NPM (consultation June 2018) without further consultation, as the drastically reduced sugars thresholds in the proposed revised model, would impact heavily on the scores of yogurts and fromage frais, many of which would move from non-HFSS to HFSS/less healthy, despite the clear health benefits outlined above and in the attached paper on ‘Yogurt and Public Health’.

This response has been provided on behalf of the Provision Trade Federation (PTF).

PTF is a long-established UK-wide trade association representing companies of all sizes involved in supplying dairy products (including milk powders, cheese, butter, yogurt and other dairy desserts), bacon, pig meat and fish. Collectively these categories account for about £24 billion a year, or roughly 20% of total UK household expenditure on food.

Our members include importers and exporters, as well as processors and manufacturers. Some of our members make branded products, where they themselves are responsible for advertising and marketing decisions. Others supply major retailers, who market and promote products under their own labels.

We strongly support measures to improve the nation’s health and to reduce the harms that can arise from excessive or inappropriate consumption of certain types of food, including through work to reformulate products and provide clear and consistent information to consumers about the importance of balanced and varied diets.

But we do not believe that categorising individual foods as inherently unhealthy reflects the scope and complexity of the issues involved. The products we represent are essentially protein based and contain a range of vital nutrients without necessarily being major contributors to energy intakes, even though some may be relatively high in fat, salt or sugar compared to other food groups.

We have particular concerns in relation to the rationale for classing particular food groups as ‘unhealthy’. Our comments below therefore relate exclusively to the foods that would be subject to the restrictions.