Response to House of Lords report

Elaine Hindal, Chief Executive of the Foundation said:

“We welcome this report and its call for a comprehensive, integrated Government strategy to deliver a healthier food system. Unhealthy diets characterised by high intakes of foods high in fat, salt and sugar (HFSS) are driving an epidemic of diet-related disease and we need urgent action to help people choose heathier foods and live healthier lives.

Key to the report are actions to reduce intakes of HFSS foods. We welcome action to restrict the promotion of HFSS and to make healthier foods more accessible. We also welcome the focus on early interventions and prioritising children’s health. The report rightly points out the huge challenges we face in changing our food system, but it is imperative that we work together to promote health and wellbeing for all.”

Actions to reduce intakes of HFSS foods

There is substantial scientific evidence that energy-dense, nutrient-poor dietary patterns, characterised by high intakes of foods classified as HFSS are detrimental to health. Conversely, diets rich in fibre, vitamins and minerals from whole grains, fruits, vegetables, fish, pulses, nuts, seeds, and dairy products are associated with better health outcomes, forming the foundation of national and international dietary guidelines around the world.

We welcome the focus on reducing the consumption of HFSS foods in the House of Lords’ report. The report also references discussions on ultra-processed foods (UPF). We agree that further research should be commissioned to investigate the mechanisms, beyond energy and nutrient content, linking UPF and ill health. But with many UPF also classified as HFSS, we agree that the immediate focus for change should be on reducing HFSS consumption and that the need for further research into ultra-processed foods must not be an excuse for inaction.  

Intakes of HFSS foods are too high across the population and it is widely agreed that discouraging high intakes of HFSS foods is crucial for public health.  The UK’s healthy eating model, the Eatwell Guide, which we agree needs further work to translate the guidance for diverse audiences and to improve consumer understanding, highlights that HFSS foods, if consumed at all, should be eaten less often and in small amounts. The British Nutrition Foundation supports actions to curtail the consumption of HFSS foods and has welcomed recent regulations to restrict their promotion, in-store placement and advertising. 

Work to reduce the salt, sugar, saturated fat and calorie content of foods and drinks has had some success with efforts to reduce the salt content of foods reflected in reduced population intakes. The Soft Drinks Industry Levy (SDIL), introduced in 2018, increased efforts to reduce the sugar content of drinks and we have seen reduced population intakes of sugar-sweetened drinks and free sugars as a result. This evidence underscores the importance of making changes in the food environment rather than focusing on individual responsibility.

Reformulation can be a valuable strategy, alongside others, to improve nutrient intakes especially for widely consumed foods such as bread or soft drinks and can achieve change without requiring large-scale behaviour change. Action on reformulation as well as innovation to develop healthier products and responsible promotions must be part of the solution to reducing consumption of HFSS foods.  Provided the complexities of labelling across markets can be resolved, this should be supported by mandatory front of pack labelling, that is prominent and readable, to help consumers make more informed food choices.

In addition, we believe reporting by food companies on the healthiness of their products is an important lever for change, allowing companies, investors and other stakeholders to assess progress in reformulation and product development. We support the report’s recommendation that reporting should be mandatory. This is an important step to create a ‘level playing field’ that facilitates comparisons between companies and across sectors. To ensure that this happens, we support the recommendation that the Food Standards Agency should have independent oversight of the food system and responsibility for reporting to Parliament on progress against targets to reduce sales of less healthy food and associated health outcomes.