BANT analysis of the Government’s newly announced ‘Healthy Food Standards’: reading between the lines
BANT welcomes Secretary of State for Health and Social Care of the United Kingdom, Wes Streeting’s intention to tackle the obesity epidemic in the UK. BANT has been consistent in its call for an effective obesity strategy, and as robust in its criticism of the 14 government-led strategies and 680 policies that have failed since 1992.
The proposed ‘Healthy Food Standards’ appears to build upon many of the recommendations from Henry Dimbleby’s 2021 National Food Strategy, commissioned but disappointingly not implemented by Boris Johnson’s cabinet. The white paper from which fell short of all BANT expectations with regards to addressing the continued rise in obesity and non-communicable metabolic disorders.
BANT is keen to ascertain who the Government has, or will consult with on the development of the standard, and explicitly requests that NICE recommended bodies and not just industry are involved. This is essential to ensuring the standard is realistic, achievable, and up to date with current thinking and science on obesity.
As the Government promises a ‘healthy food revolution’, BANT offers this critical review of the proposed standards to delve into the details.
Statement 1: Food retailers and manufacturers will “make the healthy choice the easy choice” in a world-first partnership between government and industry to tackle the obesity epidemic and ease pressure on the NHS
- Yes we must make the healthy choice the easy (and affordable) first choice. This is a bold statement that implies the food chain starts with manufacturers and retailers, completely ignoring the importance of whole foods from farming, fishing and agriculture. BANT questions: where is the partnership for these producers and growers of whole foods? The implication being that the ‘easy choice’ is a manufactured product. Is the Government right to cut deals with the food industry giants that profit greatly from the tsunami of ultra-processed foods and drinks (UPFDS) they supply and who make healthy eating so challenging, whilst ignoring the critical end of the food chain that provides what could be classified ‘the healthiest foods’ in their original whole format. BANT Manifesto – Policy to support a Healthy Population
Statement 2: Reducing daily intake by just 50 calories could lift 340,000 children and 2 million adults out of obesity
- We need to move away from this outdated calories-in and calories-out model and pivot our focus towards the quality and nutrient-density of food. It is possible to consume both a high calorie nutrient-deficient diet and a low-calorie nutrient-deficient diet. Maintaining this focus on calories allows food manufacturers to continue producing products that are poor in nutrition, all the while profiting from labelling loopholes; low calorie (but high in non-nutritive sweeteners, low fat (but high in modified starches), no added sugar (but high in fructose). Data shows that caloric intake and energy expenditure are not linear. Reducing calories, without optimising the nutrient-profile of the calories consumed, is a flawed strategy. BANT Manifesto, Legislation on Food Labels
Statement 3: If everyone who is overweight reduced their calorie intake by around 200 calories a day – the equivalent of a bottle of fizzy drink – obesity would be halved.
- This sounds like an advertising slogan. “ A cola less a day and the weight melts away”. As per above, the calorie model is not clinically robust and ignores the multifactorial causes of overweight and obesity. Highlighting one category of food; fizzy drinks, is a weak example. It glosses over the deeper and more concerning issues regarding the impact of ultra processed foods (UPFs) and their contribution to the obesity epidemic. We have a population who consume over 50% of their daily diet from UPFs; nutritionally empty calories, rising to over 85% in lower socioeconomic communities. One less fizzy drink per day barely scratches the surface.
Statement 4: The new standard reforms part of the shift from sickness to prevention in the forthcoming 10 Year Health Plan
- The shift from sickness to prevention starts with diet and lifestyle. Unhealthy habits are formed over a lifetime, and built upon by family beliefs, community and cultural ideals, and societal norms. We need to challenge our nation’s approach to diet and lifestyle and re-educate people on how to eat, move, sleep for health. Providing the food industry with new parameters from which to market new ‘healthy’ UPFDs will do little to promote meaningful behaviour change. It would likely fail to shift the nation’s purchasing habits from ultra processed to ‘real’ whole foods. There is however value in product reformulation to improve the nutritional profile of existing UPFDs for the benefit of consumers. A novel case study of this in action is the Kuwaiti Danish Dairy Company (KDD) – BANT Manifesto, Prevention-focussed Healthcare
Statement 5: A healthy nation means less strain on the NHS, helping drive down pressure on waiting lists as part of the Plan for Change.
- This is true. A healthy nation would considerably ease the pressure on waiting lists; however, the point of intervention needs to occur upstream in primary care. We need nutrition and lifestyle practitioners supporting GP’s and Primary Care Networks (PCNs) and preventing patients from needing to go on waiting lists in the first place. The evidence supporting nutrition interventions in chronic conditions; digestive syndromes, T2DM, overweight & obesity, fatty liver, cardiovascular health, mental health and more all points to the need for an extension to the PCN workforce and inclusion of nutritional therapy practitioners. A healthy nation should not be determined by ‘waiting lists’ but instead by the number of people who are returned to a state of health. – BANT Manifesto, Nutritional Therapy in Primary Care
Statement 6: Large retailers including supermarkets will be set a new standard to make the average shopping basket of goods sold slightly healthier.
- This is a weak statement. Define an average basket and ‘slightly healthier’. Will the new standard set clear targets or simply provide non-enforceable guidelines? What model or system will be used to determine whether a product is healthy? The risk is that this framework falls short of legislation, allowing loopholes for manufacturers and retailers to continue selling the same profit-generating UPFDs under the banner of a ‘slightly healthier’ reformulation. BANT would advocate for measurable targets to encourage the sales of more healthy whole food ingredients, thus switching consumers from UPFDs? It is unclear if there are any consequences for manufacturers and retailers who fail to meet the standard.
Statement 7: Businesses will be given the freedom to meet the standard however works best for them, whether that’s reformulating products and tweaking recipes, changing shop layouts, offering discounts on healthy foods, or changing loyalty schemes to promote healthier options.
- Freedom of choice versus creating an equal playing field and asking all manufacturers and retailers to adhere to the same policies and guidelines. This sounds impossible to monitor. Businesses will of course require flexibility to implement new standards and maintain their financial agility. However, a ‘what works best for them’ approach is weak and impossible to govern. The obvious risks being that businesses ignore the less palatable suggestions and only implement easy or quick fixes; such as changing shop layouts, and ignoring offering discounts on healthy foods which may be less profitable and therefore fall to the bottom of the priority list.
Statement 8: The policy will see all big food businesses report on healthy food sales. This will set full transparency and accountability around the food that businesses are selling and encourage healthier products. The government will then set targets to increase the healthiness of sales.
- Will policy be written into legislation and be mandatory for all food manufacturers and retailers to adhere to, or be voluntary under the new healthy food standard? Voluntary reporting is very different to mandating targets. Businesses are asking for a mandate to ensure fair competition. As Henry Dimbleby, Author of the National Food Strategy and Independent Review for Government said: “What gets measured gets done”. Against what parameters will ‘healthy targets’ be set? They must include fresh whole foods to be effective.
Statement 9: Major investment firms have already signalled that they would be keen to invest more in healthier products, if they were given due prominence and promotion by food retailers.
- This is a red flag. Is the healthy food standard motivated by economic drivers or health? Does it simply provide a new profit-grab sector for reformulated UPFDs rather than address the underlying problems in our food systems? What model or system will be used to evaluate whether a product is healthy? How does this benefit those at the non-profitable end of the food chain; farming, fishing, agriculture, providing arguably the healthy whole foods? We need to build a food system that is profitable for all and not only for those at the retail end. And encourage investment firms to extend their dollars to regenerative farming and innovations that moves us away from mass industrialised food production towards sustainable and environmentally beneficial practices.
Statement 10: This move to make it easier for people to shop for healthy and nutritious food options is so important.
- Access and affordability to healthy whole foods is essential if we are to rebuild a healthy nation and turn the tide on the obesity and chronic disease epidemic gripping the country. It is critical that whole foods and not manufactured foods, are the focus of this new food standard. People also need to know what to do with this food; how to source, prepare and cook healthy meals. We need an obesity strategy that goes beyond shopping. The UK population is in desperate need of updated national dietary guidelines and practical resources (The Eatwell Guide was last updated in 2016 and is no longer fit for purpose). Alongside this we need to improve education in schools and communities, provide access to nutrition practitioners in primary care and support systems to help people adopt and adhere to new diet and lifestyle habits. BANT Manifesto - Update National Dietary Guidelines.
BANT awaits further details of the Healthy Food Standard and NHS Ten Year Plan to determine the merits of each and whether they go far enough to truly impact the health of the nation.
BANT welcomes the opportunity to meet with the Government to discuss our comments and introduce our 3000-strong workforce of PSA-accredited Registered Nutritional Therapy Practitioners and BANT Registered Nutritionists who are primed and qualified to partner with the NHS and support making healthy lifestyles a reality.
