Consultation outcome

The government buying standards for food and catering services (GBSF) – updating the nutrition standards: response to consultation

Updated 9 August 2021

Executive summary

The public sector in England spends over £2 billion^{[footnote 1]} on food and catering services annually, with just under half of that being the cost of food and ingredients. In 2011 the government introduced the government buying standards for food and catering services (GBSF). These standards aim to ensure that public food procurement is underpinned by evidence-based dietary recommendations so that the public sector can lead by example ensuring a healthy food environment for those who live and work in it.

The GBSF include mandatory nutrition standards intended to reduce the intake of salt, sugar and saturated fat, and to increase consumption of fruit, vegetables, fish and fibre. They also include voluntary best practice nutrition standards that cover availability and portion size of soft drinks, confectionery, savoury snacks, calorie or allergen labelling and menu analysis.

All central government departments in England and their agencies are required to comply with the GBSF, as are prisons, the armed forces and the NHS. Schools must follow the school food standards legislation but may also choose to use the GBSF. The wider public sector is encouraged to apply these standards, including to food and drink offered in vending machines (for example, in leisure centres).

In childhood obesity: a plan for action, chapter 2 it was announced that the government would consult on updating the nutrition standards contained within the GBSF. The primary aim of the update is to ensure it continues to reflect the latest evidence-based dietary recommendations.

The consultation ran from 21 May to 13 August 2019 and sought views from individuals, businesses and organisations on proposals to update the nutritional standards in the GBSF.

The consultation received 138 responses.

Having considered the responses received to the consultation, government has decided to:

• update the reducing salt mandatory and voluntary nutrition standards to reflect government’s 2017 salt targets as referenced in the consultation document, and any subsequent revisions as set out in the recently published 2024 targets

• update the meal deals mandatory nutrition standard to ensure food and drinks used within meal deals meet the healthier options in the GBSF standards

• update the reducing saturated fat mandatory nutrition standard to include pre-packed sandwiches and other pre-packed meals

• update the increasing fibre voluntary best practice nutrition standard, to ensure main meals containing beans or pulses (or both) as a main source of protein are made available at least once a week

• retain the best practice nutrition standard requirement for menus (for food and beverages)

Following feedback from the consultation, we acknowledge that in order to ensure that catering establishments have the practical advice and tips they need to implement the GBSF standards, the updated proposals would benefit from supporting guidance. The government will therefore publish technical written guidance by autumn.

To assist manufacturers and businesses to achieve the revised standards, there will be an implementation period of 12 months from the date the written technical guidance is published, with the exception of the reducing salt mandatory and voluntary ‘best practice’ standard and the pre-packaged sandwiches component within the reducing saturated fat standard where the overall implementation period will be 3 years.

Background to the GBSF

The GBSF was introduced in 2011 aiming to make it easier for people to make healthier choices. Overall policy responsibility for the GBSF rests with the Department for Environment, Food and Rural Affairs (Defra). The Department of Health and Social Care (DHSC), taking into account advice provided by Public Health England (PHE), has responsibility for the nutrition standards within the GBSF.

In July 2014, Defra introduced a plan for public procurement which includes a balanced scorecard approach to the procurement of food and catering services. The balanced scorecard describes an evaluation approach where more straightforward criteria, such as cost are ‘balanced’ against more complex criteria such as health and well-being, resource efficiency and quality of service. The nutrition standards in the GBSF are just one of the standards which underpin the balanced scorecard.

In England, the GBSF apply to:

• all central government departments and their agencies

• prisons

• the armed forces

• NHS trusts and foundation trusts (trusts that contain retail units are also mandated by NHS England within the NHS Standard Contract)

The wider public sector is encouraged to apply the GBSF standards, for example in leisure centres, including to food and drink offered in vending machines. Schools must follow the school food standards legislation but may also choose to use the GBSF in addition.

A wider government programme of work to provide nutritious food in public settings is also underway, building on the GBSF and contributing to healthier food choices and reducing obesity. This includes:

• the hospital food review independent report, which makes recommendations on how trusts will monitor and ensure compliance with all the hospital food standards requirements, including GBSF

• the NHS Standard Contract which is mandated by NHS England for use by commissioners for all contracts for healthcare services other than primary care. NHS England’s Commissioning for Quality and Innovation (CQUIN) framework supports improvements in the quality of services and the creation of new, improved patterns of care. Standards within CQUIN1b will be considered as part of work on ‘new national standards for healthcare food: patient, staff and visitor’, which is due for publication this year

• the school food standards, which provide the legislative framework requiring school caterers to serve healthy and nutritious food and drinks. The standards restrict foods high in fat, salt and sugar, including drinks and confectionery. The government has committed to update these standards. However, due to the priority of responding to the COVID-19 outbreak and the pressures on schools this presents, the government will not be taking further action on updating the school food standards during the course of the pandemic

Government has committed to a substantial overhaul of the GBSF. A public consultation on the GBSF will launch this year and will examine ways to promote greater uptake of local, seasonal, sustainable produce, and make public sector contracts more accessible to small and medium-sized enterprises (SMEs). This is intended to help deliver the plan for growth and maximise delivery of sustainability, net-zero and health outcomes. It may therefore be necessary to review the nutrition standards further following that consultation.

Updating the GBSF nutrition standard with evidence-based dietary recommendations

Being overweight or obese is a leading risk factor for a number of health conditions. In 2019, 64% of adults were overweight or living with obesity.^{[footnote 2]} In the 2019 to 2020 school year over a fifth (23%) of children aged 4 to 5 years, and over a third (35.2%) of children aged 10 to 11 years, were overweight or living with obesity.^{[footnote 3]} Poor diets are a leading contributor to levels of excess weight in England.

As a population we consume too much saturated fat, salt and sugar, and not enough oily fish, fruit, vegetables or fibre. The latest estimate of mean salt intake in adults aged 19 to 64 years in England is 8.4g per day based on a urinary sodium survey in 2018 to 2019. This is higher than the recommended maximum of 6g per day.^{[footnote 4]} Furthermore, the latest National Diet and Nutrition Survey (NDNS) data collected in 2016 to 2017 and 2018 to 2019 found that:

• mean intake of free sugars for adults aged 19 to 64 years was 9.9% of total energy, almost double the recommended maximum of no more than 5% of total energy

• mean saturated fat intake in the same age group was 12.3% of total energy, and for adults aged 75 years and over 14.1% of total energy, exceeding the recommendation of no more than 10% total energy in both cases

• mean intakes of fibre in adults were 16g to 21g, below the recommendation of 30g. 67% of adults, 60% of adults aged 65 to 74 years, and 73% of adults aged 75 years and over did not meet the 5-a-day recommendation for fruit and vegetables consumption

• mean consumption of oily fish was well below the recommended one portion per week in all age groups

Since the introduction of the GBSF in 2011, there have been updated recommendations from the Scientific Advisory Committee on Nutrition (SACN) on sugar and fibre intakes which have been accepted by government and included in government dietary recommendations. These guidelines are being delivered in practice in part through the government’s sugar reduction and reformulation programme.

Furthermore, there is ongoing work to reduce the nation’s intakes of salt and calories through the voluntary reduction and reformulation programmes which are overseen by PHE on behalf of government and are a commitment in all parts of the government’s strategy and policy papers on tackling obesity (2016, 2018, 2019 and 2020). Each strand of the programme requires action by all sectors of the food industry including retailers and manufacturers and for products sold in those businesses that provide the food and meals that we buy and eat out of the home, take away or have delivered to the home. Where possible, the GBSF have been updated to reflect these evidence-based reduction and reformulation programmes.

Sugar reduction and reformulation programme

The sugar reduction programme challenges all sectors of the food industry to reduce sugar by 20% by 2020. This is in respect of the categories of food that contribute most to the sugar intakes of children up to aged 18 years including biscuits, breakfast cereals, cakes, chocolate and sweet confectionery and yogurts. Guidelines for industry were published by PHE in 2017.

The most recent detailed assessment of progress by the food industry was published in October 2020.

Calorie reduction and reformulation programme

This programme challenges the food industry to achieve up to a 20% reduction in calories by 2024, in product categories that contribute to children’s calorie intakes (up to the age of 18 years), and where there is scope for substantial reformulation or portion size reduction (or both). The products covered by the calorie reduction programme include ready meals, pizzas, crisps and savoury snacks, chips and potato products, sandwiches and other ‘on the go’ foods and relevant meals and dishes served out of the home.^{[footnote 5]}

Salt reduction and reformulation programme

Work on salt reduction began in the UK in 2004 following advice from SACN that to lower the risk of high blood pressure and cardiovascular disease,^{[footnote 6]} the recommended population average salt intake should not exceed 6g per day. The most recent set of revised targets was published in September 2020.

The GBSF consultation

Childhood obesity: a plan for action, chapter 2 announced that government would consult on updating the nutrition standards in the GBSF. The 12-week public consultation was launched on 21 May 2019 and closed on 13 August 2019. As well as seeking views on updating the nutrition standards in the GBSF so that they reflect the latest scientific nutritional evidence, the consultation also sought views on:

• whether 12 months was an appropriate amount of time for businesses to implement any updated GBSF nutrition standards

• whether any categories would be easier or more challenging to implement

• whether businesses would need any additional support to comply with the new standards

• what other approaches the government should consider to improve enforcement, monitoring and compliance

• whether there were other potential impacts, including costs, from updating the nutrition standards in the GBSF

The technical consultation received 138 responses from a range of individuals, businesses and organisations.

There were 126 responses submitted via the online survey, and 15 submitted via email. Three organisations that responded by email also responded via the online survey. Responses were analysed by DHSC analytical and policy officials. Most questions provided the opportunity for respondents to give a justification for their answer or to provide additional information in a free-text box. All free-text responses were read by DHSC officials and grouped into discrete themes.

Respondents broadly agreed with the updated proposals. In-depth analysis on each specific proposal can be found in the next section. The updated nutrition standards can be found in annex A.

Consultation responses to questions 1 to 14

Question 1: Do you agree or disagree with the outlined proposals for mandatory and / or voluntary standards for reducing salt intake?

What government consulted on

Reducing salt intake: proposed mandatory nutrition standard

Proposed wording:

Vegetables and boiled starchy foods such as rice, pasta and potatoes, shall be cooked without salt.

Salt shall not be available on tables.

At least 75% of meat products, breads, soups, cooking sauces, and ready meals procured by volume, and 75% of breakfast cereals and pre-packed sandwiches available meet current core salt targets. And all stock preparations shall be lower salt varieties (that is, below 0.6g per 100mls reconstituted).

Note: The 75% applies individually to each food category described in the above specification, and not only to the combined availability or volume. The requirement relates to meeting maximum targets or using an average target as a maximum where a maximum target is not set.

This would result in:

• a change to reflect the current salt targets as referenced in the consultation document, and any subsequent revisions
• increase from 50% to 75% of products outlined meeting the targets
• a change in wording from ‘procured by volume’ to ‘available’

Feedback

Table and chart 1: Reducing salt intake – proposed mandatory nutrition standard

Response	Individuals	Businesses	Organisations
Yes	73	2	22
No	17	1	1
Not relevant	0	2	5
Not sure	2	1	1

What government consulted on

Reducing salt intake: proposed voluntary (best practice) nutrition standard

At least 75% of all products (procured by volume or available) that are covered by the current salt targets meet this target.

Note: The 75% applies individually to each food category described in the above specification, and not only to the combined availability or volume. The requirement relates to meeting maximum targets or using an average target as a maximum where a maximum target is not set.

Feedback

Table and chart 2: Reducing salt intake – proposed voluntary (best practice) nutrition standard

Response	Individuals	Businesses	Organisations
Yes	72	2	19
No	12	1	18
Not relevant	0	2	5
Not sure	4	1	0

Respondents also had an opportunity to provide a free-text response to justify their answers to this question – 25% of respondents did so.

Respondents agreeing with the proposal:

• highlighted the negative health issues associated with increased salt intake such as high blood pressure and cardiovascular disease

• stated that the standards should be amended to reflect PHE set salt targets for levels of salt in all food and drink products

• suggested increasing the product categories which should meet the PHE salt targets

They also felt that:

• government should do more by introducing legislation for the mandatory standard

• proposals should go further to ensure overall nutrient content standards are met

In addition, clear guidance was requested, and the need for time to adapt to any changes to the standards stressed.

Respondents that disagreed to the proposals felt that:

• it should be for individuals to make their own informed decisions about salt consumption, and that salt should be available on tables

Some of these respondents were concerned that:

• there was mixed progress on PHE’s salt targets, which would weaken the proposals

• that the additional target for lower salt stocks is not in line with the salt reduction programme target

• that the proposed standards did not align with the school food standards

Discussion

For the proposed mandatory standard, some respondents raised the issue that salt should not be removed from tables for reasons such as:

• salt would not be added during the cooking of vegetables or boiled starchy foods
• it may impact negatively on the overall ‘look’ of the tables for clients at formal meals (such as banquets)

However, it should be noted that this consultation did not include any proposal to change the requirement for salt not to be available on tables. This component of the standard is already operating successfully. Therefore, government does not think a change is required at this time.

Mixed progress on PHE’s salt targets was highlighted and a need to increase from 75% to 100% the number of relevant products meeting the salt targets. Due to the varying performance of individual food categories, the proposed mandatory and voluntary salt reduction standard has been set pragmatically at 75% to provide flexibility, and to support compliance that may be affected by any product availability.

Some respondents also suggested a need to increase the mandatory product categories, and suggested that the proposals should go further and ensure overall nutrient content standards are met. The salt reduction targets for the foods within the mandatory standard are those provided under the following product categories:

• category 1: meat products

• category 2: bread

• category 3: breakfast cereals

• category 8: ready meals and meal centres

• category 9: soups

• category 13: bought sandwiches

• category 15: cook-in and pasta sauces, thick sauces and pastes

Government’s opinion is that the product categories captured in the proposed mandatory standard are pragmatic and cover the key contributors to salt intake. Meat products and bread are among the top contributors to overall salt intakes in the UK. Soups and cooking sauces, ready meals, breakfast cereals and pre-packed sandwiches are food categories which are widely available in the catering sector which can contribute significantly to large amounts of salt intake.

The existing voluntary standard, that at least 75% of all products (procured by volume or available) that are covered by the current salt targets meet this target, allows those businesses and organisations that wish to go further in reducing salt intake, to do so by allowing them to apply the voluntary standard to other products.

Respondents highlighted that the target (of 0.6g) for ‘lower salt stocks’ is below the 2017 average salt target for stocks of 0.75g per 100g. The 0.6g GBSF target is an existing standard that has been in place for some time and government is not proposing any change here. Stock is widely used in catering practice and can contribute considerably to salt intake. Lower salt varieties (that is, below 0.6g per 100mls reconstituted) are readily available. It therefore seems a reasonable and achievable approach to take to help reduce intakes of salt by using these lower salt products. This standard aims to promote reformulation over time so that use of lower salt stock becomes the norm rather than the exception.

While a perceived misalignment with the school food standards was highlighted, it should be noted that GBSF is for use on a voluntary basis alongside the school food standards to help reduce salt, saturated fat and sugar in children’s diets.

Responses from this consultation were shared with PHE to help inform the development of revised salt reduction targets for 2024.

Government response

Having considered the responses to this consultation, government has made the decision to update the reducing salt standards as outlined below:

Reducing salt intake: updated mandatory nutrition standard

Vegetables and boiled starchy foods such as rice, pasta and potatoes, shall be cooked without salt.

Salt shall not be available on tables.

At least 75% of meat products, breads, soups, cooking sauces and ready meals procured by volume, and 75% of breakfast cereals and pre-packed sandwiches provided meet current core salt targets. And any subsequent revisions to this target and all stock preparations shall be lower salt varieties (that is, below 0.6g per 100mls reconstituted).

Note: The 75% applies individually to each food category in the above specification, and not only to the combined provision or volume. The requirement relates to meeting maximum targets or using an average target as a maximum where a maximum target is not set.

Reducing salt intake: updated voluntary (best practice) nutrition standard

At least 75% of all products (procured by volume or provided) that are covered by the current salt targets meet this target and any subsequent revisions to this target.

Note: The 75% applies individually to each food category described in the above specification, and not only to the combined provision or volume. The requirement relates to meeting maximum targets or using an average target as a maximum where a maximum target is not set.

To allow time for manufacturers to reformulate their products to meet the 2024 salt reduction targets, government will extend the period of compliance by 2 years, allowing a total implementation period of 3 years for the salt standard following the publication of the written technical guidance.

Question 2: Do you agree or disagree with the outlined proposals for the mandatory standard for increasing fruit and vegetable consumption?

What government consulted on

Increasing fruit and vegetable consumption: proposed mandatory nutrition standard

Proposed wording:

A portion of fruit shall be sold at a lower price than a portion of hot or cold dessert.

Half of desserts available should contain at least 50% of their weight as fruit, which may be fresh canned in fruit juice, dried or frozen. This excludes whole fresh fruit as a dessert option. Whole fresh fruit can be a dessert option but should not be included as an option when calculating whether half of dessert options should contain at least 50% of their weight as fruit.

Main meals within the meal deal should include a starchy carbohydrate, which is not prepared with fats or oils, vegetables and one portion of fruit.

This would result in:

• excluding fresh fruit as a dessert for calculation purposes
• a change to the meal deal standard so that main meals within a meal deal should include a starchy carbohydrate, vegetables and one portion of fruit
• an additional requirement of carbohydrate in meals not being prepared with fats or oils

Feedback

Table and chart 3: Increasing fruit and vegetable consumption – proposed mandatory nutrition standard

Response	Individuals	Businesses	Organisations
Yes	80	3	27
No	10	1	2
Not relevant	0	2	3
Not sure	2	0	1

Respondents had an opportunity to provide a free-text response to this question – 22% of respondents did so.

Respondents that agreed with the proposal:

• cited there is evidence to suggest that the UK population, across all age ranges, are not meeting the recommendation of 5 portions of fruit and vegetables every day

• recommended that the standard should encourage providing 2 portions of fruit or vegetables

• said more positive language would be welcomed

• suggested a need for a clear definition for carbohydrate in meals not being prepared with fats and oils

Respondents that disagreed felt that:

• government interference was not necessary

• it is for individuals to make informed choices – for example, people should be able to choose to have less healthy options if they so wish, as part of a balanced diet

• it is not necessary to ban carbohydrates being prepared with fats and oils

• fruit is high in sugar and can affect the digestive system

• the proposal would exclude almost all potato recipes

• many starchy carbohydrates are available on the market and are low or medium in fat and low in saturated fat, and they may use a small amount of oil or fat as an essential part of the manufacturing process

• clear messaging is needed on whether this standard refers to oils or fats used in the manufacturing process as well as those added during preparation in the kitchen

• further clarification on what types of dishes should be classified as a ‘dessert’

• the proposal would incur increased cost to the customer to provide these products

• there is a need to continue to provide higher energy products to meet inpatient menu demands.

Discussion

Incorporating fruit into the desserts and puddings on offer in public service buildings is an attractive way to add fruit to menus, enabling consumers that purchase those desserts to consume more fruit. There is evidence to suggest that people who eat more than 400g of fruit and vegetables per day are less likely to develop chronic diseases such as coronary heart disease and some cancers.^{[footnote 7], [footnote 8]}

Some respondents cited evidence that the UK population is not consuming the recommended 5 portions of fruit and vegetables a day which are an important source of fibre, vitamins and minerals. The government acknowledges that the UK population needs to consume the recommended 5 portions of fruit and vegetables. The latest data from the National Diet and Nutrition Survey (NDNS) shows that 33% of adults aged 19 to 64 years and 12% of 11 to 18 year olds met the 5-a-day recommendation.

Some respondents highlighted that government should go further and should specify 2 portions of fruit and vegetables in the standard. The proposed standard should be interpreted as at least one portion of vegetables. Some felt there was no need to ban carbohydrates being prepared with fats and oils from meal deals. The rationale for basing meal deal main meals on starchy carbohydrates not prepared with fats or oils, and to include fruit and vegetables, is to support the availability of healthier food and drink options in line with the national food guide, the Eatwell Guide. The relevant aspects of the Eatwell Guide and supporting messages are:

• to base meals on starchy carbohydrates, choosing wholegrain versions where possible

• eat at least 5 portions of a variety of fruit and vegetables every day

• if consuming foods and drinks high in fat, salt or sugar, have these less often and in small amounts

Some respondents requested that government specify whether this standard refers to oils or fats used in the manufacturing process, as well as those added during preparation in the kitchen. The proposed standard for carbohydrates in main meals in a meal deal should be interpreted that carbohydrates should not be cooked in fat or oil. Clear supporting messaging will be provided in the written technical guidance.

There was some concern raised that starchy carbohydrates, such as potatoes are naturally low in fat, and that through this proposal government would be excluding the use of potatoes from many recipes. The government encourages the provision of healthier eating options, including the consumption of low-fat starchy carbohydrates such as potatoes. However, healthier food and drink options should be available across the public sector. Therefore, this standard encourages public sector food providers to offer oven baked options, rather than, for example, the provision of fried chips and other fried potato products such as wedges, waffles, croquettes and hash browns.

Government response

To help support catering establishments, government will provide supporting information in the technical guidance to provide necessary clarity on the preparation of carbohydrates in meal deals.

Having considered the responses to this consultation, government has made the decision to update the fruit and vegetable consumption standard as outlined below:

Increasing fruit and vegetable consumption: updated mandatory standard

A portion of fruit shall be sold at a lower price than a portion of hot or cold dessert.

Half of desserts available should contain at least 50% of their weight as fruit – which may, be fresh canned in fruit juice, dried or frozen. This excludes whole fresh fruit as a dessert option. Whole fresh fruit can be a dessert option but should not be included as an option when calculating whether half of dessert options should contain at least 50% of their weight as fruit.

Main meals within a meal deal should include a starchy carbohydrate, which is not prepared with fats or oils, and the meal deal options should include at least one portion of vegetables and one portion of fruit.

Question 3: Do you agree or disagree with the outlined proposals for the mandatory standard for meal deals?

What government consulted on

Meal deals: proposed mandatory nutrition standard

Any pre-packaged food and drink products in a meal deal to not include high in fat, sugar or salt (HFSS)* and to ensure food and drinks used within meal deals meet the healthier options in the GBSF standards.

* See ^{[footnote 9]}.

Feedback

Table and chart 4: Meal deals – proposed mandatory nutrition standard

Response	Individuals	Businesses	Organisations
Yes	78	3	22
No	9	2	10
Not relevant	1	1	3
Not sure	3	0	1

Respondents had the opportunity to provide a free-text response to this question – 26% of respondents did so.

Respondents that agreed with the proposal felt that:

• it would encourage consumption of healthier options

• discourage consumption of HFSS products

• and encourage food manufacturers to produce more non-HFSS products

However, they also suggested:

• clarification was required on whether the standard would replace CQUIN 1B, and suggested cross-referencing with the updated saturated fat nutrition standard

• government should use a consistent method of defining HFSS such as the Nutrient Profiling Model (NPM) and asked whether other promotions would be considered in the guidance

Respondents that disagreed with the proposal said:

• it is for individuals to make informed decisions on meal deals

• government intervention was not necessary

• high sugars are not necessarily bad if they are natural or no added sugar

• the best way of tackling many of the diet-related public health crises is to increase the level of provision of plant-based and vegan-friendly meals

• compliance with the proposal would be challenging in order to remain competitive in a fiercely competitive market

• colour-coded front-of-pack labelling to define HFSS foods would result in excluding products with a red category

• it would be challenging for catering establishments to manage, and to find products that meet all of the requirements

• further clarity was needed on whether the standard related to both hot and cold meal deals as well as pre-packed and non-prepacked meal deals

Discussion

Balancing the content of promotional meal deals so that they contain healthier products could help improve people’s diets and help move average population intakes towards dietary recommendations.

Respondents raised the issue of whether other promotions such as ‘2-for-1’ or ‘3-for-2’ offers would be considered in this GBSF proposal. The government published its new strategy to tackle obesity and help adults and children to live healthier lives. As part of that announcement, the government will legislate to end promotion of HFSS products by volume (for example, buy-one-get-one-free offer) and location both online and in store in England.^{[footnote 10]} The government’s response to the consultation was published on 28 December 2020 and this sets out the details of the policy and which businesses it will apply to.

Some respondents questioned whether the proposal applied to both hot and cold meal deals as well as pre-packaged and non pre-packaged meal deals. From 1 January 2021 the UK is no longer part of the European Union (EU). All direct EU nutrition-related legislation as it stands at the end of 31 December 2020 will form domestic law. Pre-packaged food is defined in retained EU Regulation No 1169/2011. This regulation applies where pre-packaged food consisting of a food and the packaging into which it is put before being offered for sale, relates to any single item for presentation to the final consumer and to mass caterers. It excludes sandwiches made on site and hot food in canteens. Guidance produced by the Food Standards Agency that refers to the EU regulation will amend reference to the regulations or will do so in due course. The meal deal standard proposed has been developed to cover any type of meal deal offered. Government will provide further clarification in the technical written guidance.

Some respondents thought that high sugars are not necessarily bad. Supporting healthier food and drink options in the proposal is in line with national food guidelines, the Eatwell Guide. The relevant aspect of the Eatwell Guide and supporting messages is:

If consuming foods and drinks high in fat, salt or sugar, have these less often and in small amounts.

Respondents cited the use of the colour-coded front-of-pack labelling to define HFSS foods as detrimental, resulting in the exclusion of products which are categorised as red-category criteria. This could lead to it placing a burden on catering establishments – for example, by familiarising and monitoring compliance of this standard.

It is important that government consider the impact on catering establishments using the guide to creating a front-of-pack (FoP) nutrition label for pre-packed products sold through retail outlets.

The colour-coded (red, amber and green) labels on the front of pack show at a glance if a food has high, medium or low amounts of fat, saturated fat, sugars and salt. This helps individuals to make informed decisions about the nutritional content of the food and drink they are buying. It is not the intention to prohibit anyone from consuming a food or drink product that is colour coded red, but individuals should try to bear in mind how often they are choosing these foods, and how much of them they eat. Choices containing lower amounts of fat, sugars and salts can help an individual achieve a healthier diet.

From reviewing the responses relating to HFSS proposals, government understands that caterers will already be aware of the food and drinks used within meal deals that meet the healthier options in the GBSF standards – for example, sugar sweetened beverages should not be included in meal deals, and that this would be a more practical way of achieving ‘healthier’ promotional meal deals.

The NPM is an evidence-based tool used to classify appropriate food and drinks as HFSS and some respondents felt it should be included in the standard. The NPM was considered when developing the meal deal proposal as well as what products could be included. However, upon testing the tool, it became clear that it did not fit the purposes for this GBSF standard.

Government response

Having considered the challenges provided in the consultation responses and reference to front-of-pack nutrition labelling guidance for the mandatory standard, government has decided not to revise the standard with the previously proposed wording ‘any pre-packaged food and drinks products in a meal deal should not be high fat, sugar or salt products in meal deals’.

Having considered the responses to this consultation, government has made the decision to update the meal deals standard as outlined below:

The revised wording for this standard fits with the PHE One You campaign that can help individuals keep track of how many calories they consume in a day. An adult should aim to consume around 400 calories for breakfast, 600 calories for lunch and 600 for dinner leaving room for a couple of healthier snacks and drinks. This is also in line with the national food guide, the Eatwell Guide. To help support catering establishments, government will provide supporting information in the technical guidance.

Meal deals: updated mandatory nutrition standard

Any foods and drinks within a meal deal must also meet the relevant GBSF standards for the healthier options – for example, healthier sandwiches.*

* See ^{[footnote 11]}.

Question 4: Do you agree or disagree with the outlined proposals for the mandatory standard for reducing saturated fat?

What government consulted on

Reducing saturated fat: proposed mandatory nutrition standard

Proposed wording:

• meat and meat products (procured by volume), biscuits, cakes and pastries (available) be lower in saturated fat, where available
• at least 50% of hard yellow cheese procured by volume shall have a maximum total fat content of 25g per 100g
• at least 75% of ready meals procured by volume shall contain less than 6g saturated fat per portion
• at least 75% of milk procured by volume is lower fat (semi-skimmed, 1% or skimmed milk)
• at least 75% of oils and 75% of spreads procured by volume are based on unsaturated fats
• at least 75% of pre-packed sandwiches (and other savoury pre-packed meals (wraps, salads, pasta salads) available contain 400 kcals (1,680 kJ) or less per serving and do not exceed 5.0g saturated fat per 100g

This would result in:

• additional requirements around pre-packed sandwiches and other savoury pre-packed meals to decrease saturated fat content
• slight rewording for clarity regarding milk

Feedback

Table and chart 5: Reducing saturated fat – proposed mandatory nutrition standard

Response	Individuals	Businesses	Organisations
Yes	81	2	26
No	10	2	3
Not relevant	0	2	3
Not sure	1	0	0

Respondents had an opportunity to provide a free-text response to this question – 20% of respondents did so.

Respondents that agreed with the proposal said that:

• it would encourage the consumption of products lower in saturated fat

• food manufacturers would be encouraged to reduce levels of saturated fat in their products

• all groups of the population are consuming too much saturated fat

• it fits with the One You Campaign of a total calorie lunch or dinner of 600 kcal

• for patients with malnutrition, a higher saturated fat diet – for example, using more cheese – may be recommended

However, they sought:

• consistency with the criteria within the 2018 to 2019 CQUIN scheme

• time to adapt to any further changes to these standards

• clear messaging around the term ‘lower’

• ensuring overall nutrient content standards are met

Respondents that disagreed with the proposal felt that:

• it is for individuals to make informed decisions on saturated fat intake

• government intervention was not necessary

• government should encourage the use of vegetable sources of protein, such as beans, pulses, nuts and seeds, as a strategy to reduce total saturated fat

• suppliers will need to invest time and money into product development

• clarity was needed on the wording ‘…be lower in saturated fat…’ and ‘where available’ and what it would mean in practical terms

• targets are higher than CQUIN, which will have an impact on businesses

• taste would be compromised

• questioned whether retail units within hospitals would need to comply with this standard

Discussion

Data shows that the average population is consuming too much saturated fat. High intakes of saturated fat can raise blood cholesterol levels and, in turn, increase the risk of coronary heart disease and stroke.^{[footnote 12]} It is important that the GBSF nutrition standards reflect the latest evidence-based dietary recommendations.

Some respondents to this consultation highlighted that the proposals to reduce saturated fat would mean taste would be compromised. The government has updated the standard due to the health impact it can deliver.

Some respondents suggested that they would need time to adapt to any further changes to these standards. To help businesses meet the updated saturated fat standard, government has decided to lower the percentage from 75% to 50% to be made available for both the saturated fat and calorie cap in the pre-packaged sandwiches component of this standard during the implementation period of 18 months. The standard will then increase to 75% thereafter with a further implementation period of 18 months, allowing for a total 3-year implementation period.

Respondents highlighted that government should encourage the use of plant-based sources of protein to help reduce total saturated fat. Government encourages the provision of healthier eating and the consumption of vegetable sources to reduce saturated fat intake. This is also in line with the national food guide, the Eatwell Guide. The relevant aspect of the Eatwell Guide and supporting message is:

Eat more beans and pulses, 2 portions of sustainably sourced fish per week, one of which is oily. Eat less red and processed meat.

Respondents suggested government provides clearer messaging on the parts of the standard that state ‘lower in saturated fat’ and ‘where available’. For catering establishments implementing the standard, government has used the words ‘lower in saturated fat’ and ‘where available’ to provide flexibility for such establishments to reduce the saturated fat content of the relevant foods they offer based on the options that are available to them (that is, levels of saturated fat in the products they procure or the recipes they use if these are made on site). Government will provide further clarification in the technical written guidance.

Whether retail units within hospitals should need to comply with this standard was also raised. It is the intention that all the elements of GBSF apply to premises controlled by NHS trusts and foundation trusts in England.

Government response

Having considered the responses received, government has made the decision to update the saturated fat standard in line with the proposal, as outlined below.

To help businesses meet the updated saturated fat standard, government has decided to lower the percentage from 75% to 50% to be made available for both the saturated fat and calorie cap in the pre-packaged sandwiches component of this standard during the implementation period of 18 months. The government will then do a review to ensure businesses are on track with compliance. The standard will then increase to 75% thereafter with a further implementation period of 18 months, allowing for a total 3-year implementation period.

Reducing saturated fat: updated mandatory nutrition standard

Meat and meat products (procured by volume), biscuits, cakes and pastries (provided) be lower in saturated fat, where available.

At least 50% of hard yellow cheese procured by volume shall have a maximum total fat content of 25g per 100g.

At least 75% of ready meals procured by volume shall contain less than 6g saturated fat per portion.

At least 75% of milk procured by volume is lower fat (semi-skimmed, 1% or skimmed milk).

At least 75% of oils and 75% of spreads procured by volume are based on unsaturated fats.

At least 50% of pre-packed sandwiches and other savoury pre-packed meals (wraps, salads, pasta salads) provided contain 400 kcals (1,680 kJ) or less per serving and do not exceed 5.0g saturated fat per 100g for an 18-month implementation period to increase the standard to 75% thereafter with a further implementation period of 18 months.

Question 5: Do you agree or disagree with the outlined proposals for the following updated mandatory and / or voluntary standards for increasing fibre?

What government consulted on

Increasing fibre: proposed mandatory nutrition standard

At least 50% of bread available contains at least 3g fibre per 100g (that is, is a source of fibre), excluding pre-packed sandwiches.

At least 75% of pre-packed sandwiches (and other savoury pre-packed meals (wraps, salads, pasta salads) available contains bread with at least 3g fibre per 100g.

Feedback

Table and chart 6: Increasing fibre – proposed mandatory nutrition standard

Response	Individuals	Businesses	Organisations
Yes	77	2	25
No	11	2	2
Not relevant	0	2	5
Not sure	3	0	1

What government consulted on

Increasing fibre: proposed voluntary (best practice) nutrition standard

To ensure at least 50% of all bread available contains at least 3g fibre per 100g (that is, is a source of fibre), as per the mandatory standard.

And, in addition to the mandatory standard at least 25% of all bread available contains at least 6g per 100g (that is, high in fibre), excluding pre-packed sandwiches.

Feedback

Table and chart 7: Increasing fibre – proposed voluntary (best practice) nutrition standard

Response	Individuals	Businesses	Organisations
Yes	63	2	17
No	12	2	1
Not relevant	0	2	5
Not sure	3	0	1

Respondents had an opportunity to provide a free-text response to this question – 22% of respondents did so.

Respondents that agreed with the proposal said that:

• a high-fibre diet can have several health benefits, and can help to reduce incidences of heart disease, type 2 diabetes, bowel cancer, cholesterol and obesity

• an increase in fibre can help promote satiety

However, they also sought more specific reference to inclusion of plant-based proteins.

Respondents that disagreed to the proposal felt that:

• the standard should be updated to align with the Nutrition and Health Claims Regulation definition

• a voluntary standard could be added which encourages caterers to include more wholegrain varieties on their menus

• more specific reference to inclusion of higher fibre plant-based proteins was needed

• there was no fibre target in pre-packed sandwiches in the CQUIN 1b indicator: healthy food for NHS staff, visitors and patients

• they would need to invest time and money into product development

• the mandatory and voluntary percentages should be increased to 75% in both cases

• the proposal would not be possible for patient menus

Discussion

Respondents suggested that the mandatory and voluntary percentages should be increased to 75%. The proposed mandatory standard is set at 50% source of fibre (with an additional 25% high fibre for best practice). The proposed mandatory and voluntary standards for bread have been set pragmatically to provide flexibility and to support compliance that may be affected by current product availability.

Respondents highlighted that the levels proposed did not directly reflect current nutrition claims legislation. A ‘high fibre’ claim can be made where the product contains at least 6g of fibre per 100g or at least 3g of fibre per 100 kcal. A ‘source of fibre’ claim can be made where the product contains at least 3g of fibre per 100g or at least 1.5g of fibre per 100 kcal. A ‘source of fibre’ claim has been used for the mandatory standard and the ‘high fibre’ claim for the voluntary (best practice) standard per 100g only as this approach has been used for products such as breakfast cereals and has been maintained for consistency.

Government response

Having considered the responses received, government has made the decision to update the mandatory standard in line with the proposals as set out below.

However, following consultation feedback that highlighted that an inclusion of healthy high-fibre plant proteins should be considered, government has also decided to include provision of beans and pulses in the voluntary (best practice) nutrition standard. This is in line with the national food guide, the Eatwell Guide. The relevant aspects of the Eatwell Guide and supporting messages is ‘eat more beans and pulses’.

Increasing fibre: updated mandatory nutrition standard

At least 50% of bread provided contains at least 3g fibre per 100g (that is, is a source of fibre), excluding pre-packed sandwiches.

At least 75% of pre-packed sandwiches provided contains bread with at least 3g fibre per 100g.

Increasing fibre – updated voluntary (best practice) nutrition standard

To ensure at least 50% of bread provided contains at least 3g fibre per 100g (that is, is a source of fibre), excluding pre-packed sandwiches as per the mandatory standard.

And, in addition to the mandatory standard at least 25% of all bread provided contains at least 6g per 100g (that is, high in fibre), excluding pre-packed sandwiches.

To ensure main meals containing beans or pulses (or both) as a main source of protein are made available at least once a week.

Question 6: Do you agree or disagree with the outlined proposals for the mandatory standard for reducing sugar intake?

What government consulted on

Reducing sugar intake: proposed mandatory nutrition standard

At least 75% of products available that are included in the following categories covered by the sugar reduction programme to not exceed the following:

• biscuits: 100 kcals
• cakes: 220 kcals
• morning goods: 220 kcals
• puddings: 220 kcals
• yogurts: 120 kcals
• ice cream: 220 kcals

Note: The 75% applies individually to each product category described in the above specification, and not only to the combined availability.

Feedback

Table and chart 8: Reducing sugar intake –- proposed mandatory nutrition standard

Response	Individuals	Businesses	Organisations
Yes	73	1	20
No	14	3	8
Not relevant	0	2	4
Not sure	4	0	1

Respondents had an opportunity to provide a free-text response to this question – 31% of respondents did so.

Those in agreement said that increased sugar intakes contribute towards a range of non-communicable diseases, from obesity, type 2 diabetes to tooth decay. In addition, they suggested:

• that government should go further in reducing sugar intake

• the proposal conflicts with the British Dietetic Association (BDA) digest where its nutrition target exceeds the proposal

• a call for industry to increase the availability of lower sugar options

Respondents that disagreed with the proposal felt that:

• the proposal would result in the increase of the use of artificial sweeteners to reduce sugar intake, for reasons such as intolerance, as well as concerns around sweeteners causing long-term health conditions due to them being chemical products

• it is for individuals to make informed decisions on reducing sugar intake

• government intervention was not necessary

• natural sugar is better than artificial sweeteners and added sugar

• educating the public so that individuals understand why they should eat better, rather than just remove options would be preferable

• limited products on the market currently meet the proposed maximum calorie guidelines

• the proposal placed a guideline on calories but not on sugar

• the proposal would not be possible for patient menus

• clarity was needed on whether the maximum calorie guideline applied per pack or per serving

• that the category should also include products such as cereal bars and flapjacks

• the sales weighted average (SWA) portion guideline from the PHE sugar reduction programme being used as a maximum guideline was concerning

Discussion

Respondents highlighted that they had concerns on the use of artificial sweeteners to reduce sugar intake.

To enable flexibility, when developing the reducing sugar intake, the proposal was set at 75% of these products procured or made available to reflect current product availability but also increase the healthier options on offer. DHSC, along with PHE, supports the European Food Safety Authority’s (EFSA) scientific opinion on low calorie or non-caloric sweeteners, as does the Food Standards Agency. Sweeteners that have been approved through EFSA’s processes are a safe and acceptable alternative to using sugar for the general population. There are some specific medical conditions where the use of individual sweeteners can cause an issue – for example, those with phenylketonuria are unable to metabolise aspartame.

It is up to businesses to decide if and how they wish to use sweeteners. It is known that some of the food and drink industry use them to lower the sugar content of their products while others do not, either due to legislative restrictions or issues relating to consumer acceptability. Replacing sugar with artificial sweeteners is only one way for business to achieve the standard. Alternative actions could include not adding sugar (or adding less sugar) to recipes, reducing portion size, or encouraging consumers to buy lower-sugar or sugar-free options.

Respondents highlighted that the proposals placed a maximum guideline on calories but not on sugar and wanted clarity on whether the maximum calorie guideline applied per pack or per serving. The maximum calorie guideline in the standard applies per single serve portion.

Respondents expressed the view that other products (flapjacks and cereal bars) should also be included in the proposal. It should be noted that flapjacks are already included in the cake category, and cereal bars are included in the biscuit category of PHE’s sugar reduction programme and are both therefore included in the standard.

Respondents highlighted that they had concerns that a sales weighted average portion guideline, from the PHE sugar reduction programme, is now being used as a maximum guideline. It is our view that catering establishments covered by the GBSF should be leading by example and setting the standard for others to follow in relation to the foods that are available. Compliance to the maximum guideline has been set for 75% of products available to allow some flexibility in the products which are offered.

Government response

Having considered the responses received, government has made the decision to update the mandatory standard in line with the proposals as set out below. This standard will help support healthier options as high intakes of sugar can cause weight gain and can also cause tooth decay.

To help support catering establishments, government will provide supporting information in the technical guidance as well as providing clarity that the maximum calorie guidelines applies per single-serve portion for the standard.

Reducing sugar intake: updated mandatory nutrition standard

At least 75% of products provided that are included in the following categories covered by the sugar reduction programme to not exceed the following:

• biscuits: 100 kcals
• cakes: 220 kcals
• morning goods: 220 kcals
• puddings: 220 kcals
• yogurts: 120 kcals
• ice cream: 220 kcals

Note: The 75% applies individually to each product category described in the above specification, and not only to the combined provision.

Question 7: Do you agree or disagree with the outlined proposals for the following updated mandatory and / or voluntary standards breakfast cereals?

What government consulted on

Breakfast cereals: proposed mandatory nutrition standard

Proposed changes:

At least 50% of breakfast cereals available are higher in fibre (that is, at least 6g per 100g) and shall not exceed 12.3g per 100g total sugars (10g additional allowance for dried fruit in cereal).

This would result in:

• update to maximum sugar content for at least 50% of breakfast cereals – to bring in line with sugar reduction guideline
• updated wording from procured by volume to available

Feedback

Table and chart 9: Breakfast cereals –- proposed mandatory nutrition standard

Response	Individuals	Businesses	Organisations
Yes	77	1	21
No	11	3	4
Not relevant	1	2	5
Not sure	2	0	0

Breakfast cereals: proposed voluntary (best practice) nutrition standard

To ensure at least 50% of all breakfast cereals available contain at least 6g per 100g of fibre (that is, high in fibre) and shall not exceed 12.3g per 100g (10g additional allowance for dried fruit in cereal), as per the mandatory standard.

And, in addition to the mandatory standard, at least 25% of all breakfast cereals available contain at least 6g per 100g (that is, high in fibre) and shall not exceed 5g per 100g (10g additional allowance for dried fruit in cereal).

Feedback

Table and chart 10: Breakfast cereals – proposed voluntary (best practice) nutrition standard

Response	Individuals	Businesses	Organisations
Yes	67	0	20
No	2	3	0
Not relevant	0	2	5
Not sure	0	0	0

Respondents took the opportunity to provide a free-text response to this question – 21% of respondents did so.

Respondents that agreed with the proposal said that:

• reducing the sugar content and increasing the fibre content can only have a positive impact on the diet of the thousands who consume this food on a daily basis

• cereals targeted at children should contain less sugar

• it was an incentive for industry to continue to reformulate breakfast cereals to make them healthier

They also felt that further reductions should be made in the future.

Respondents that disagreed with the proposal suggested:

• the mandatory standard could have gone further, including increasing to 80% or 100% and suggestion of recommending that 50% were to be low sugar (less than 5g per 100g)

• that breakfast cereals continue to be based upon restricting high-sugar cereals as defined by the criteria for front-of-pack nutrition labelling

• it was not clear how the 10g additional total sugars allowance for dried fruit in cereal would work in practice

• many people need low-fibre products

• less sugar and salt should be recommended

• there were concerns that sugar will be replaced by sweeteners

• the proposed standard would not be possible for patient menus

• the mandatory and voluntary criteria excluded breakfast cereals such as plain oats which contain skimmed milk powder but have no added sugar, and that this type of cereal should be an exception

• a lack of product variety availability

Discussion

Respondents suggested that the proposal continued to be based on the criteria for front-of-pack nutrition labelling for reducing high sugar in cereals. The standard to reduce sugar intake from breakfast cereals has been sourced from PHE’s first technical report for the sugar reduction programme, published in March 2017.

The voluntary standard builds on the mandatory standards for those that wish to go further: with an additional 25% of breakfast cereals available that are both ‘high in fibre’ (at least 6g fibre per 100g) but also meet a lower sugar standard (no more than 5g per 100g).

Clarity on how the 10g additional total sugars allowance for dried fruit in cereal would work in practice was requested. There is an allowance within the PHE sugar reduction programme for dried fruit in cereals where up to 10g of sugar in breakfast cereals is allowed if coming from plain dried fruit (sugar coated or treated fruit is excluded). In addition, businesses are not encouraged to reduce dried fruit in products to reduce the total sugar content, but are encouraged to move away from using fruit juice or concentrates and sweetened dried fruit.

Respondents highlighted that they had concerns on the use of artificial sweeteners to reduce sugar intake. DHSC, along with PHE, supports the EFSA’s scientific opinion on low calorie or non-caloric sweeteners, as does the Food Standards Agency. Sweeteners that have been approved through EFSA’s processes are a safe and acceptable alternative to using sugar for the general population. There are some specific medical conditions where the use of individual sweeteners can cause an issue – for example, those with phenylketonuria are unable to metabolise aspartame.

It is up to businesses to decide if and how they wish to use sweeteners. It is known that some of the food and drink industry use them to lower the sugar content of their products while others do not, either due to legislative restrictions or issues relating to consumer acceptability. Replacing sugar with artificial sweeteners is only one way for business to achieve the standard. Alternative actions could include not adding sugar (or adding less sugar) to recipes, reducing portion size, or encouraging consumers to buy lower-sugar or sugar-free options.

Respondents expressed the view that salt should be included in the standard. Reducing salt in breakfast cereals is considered in the mandatory standard.

Respondents highlighted that the mandatory and voluntary criteria excluded breakfast cereals such as plain oats which contain skimmed milk powder but have no added sugar. Government will consider this issue carefully, any potential exemptions such as this will be included in the technical guidance which is being developed to support implementation of the revised standards.

Respondents also suggested a lack of product variety available to meet the proposals. A mandatory standard of 50% of products available to be higher fibre (at least 6g per 100g) and lower sugar (maximum 12.3g per 100g with an additional 10g allowance for dried fruit) has been proposed with the intention of allowing flexibility and maintaining choice for consumers.

Government response

Having considered the responses received, government has made the decision to update the standards in line with the proposals as set out below.

Breakfast cereals: updated mandatory nutrition standard

At least 50% of breakfast cereals provided are higher in fibre (that is, at least 6g per 100g) and shall not exceed 12.3g per 100g total sugars (10g additional allowance for dried fruit in cereal)

Breakfast cereals: updated voluntary (best practice) nutrition standard

To ensure at least 50% of all breakfast cereals provided contain at least 6g per 100g of fibre (that is, high in fibre) and shall not exceed 12.3g per 100g total sugars (10g additional allowance for dried fruit in cereal), as per the mandatory standard.

And, in addition to the mandatory standard, at least 25% of all breakfast cereals provided contain at least 6g per 100g (that is, high in fibre) and shall not exceed 5g per 100g total sugars (10g additional allowance for dried fruit in cereal).

Question 8: Do you agree or disagree with the outlined proposals for the mandatory standard for fish?

What government consulted on

Fish: proposed mandatory nutrition standard

If caterers serve lunch and an evening meal, fish is provided twice per week (2 x 140g portions), one of which is oily. If caterers only serve lunch or an evening meal, oily fish (140g portion) is available at least once every 3 weeks.

Feedback

Table and chart 11: Fish – proposed mandatory nutrition standard

Response	Individuals	Businesses	Organisations
Yes	72	4	20
No	13	0	2
Not relevant	2	2	4
Not sure	5	0	1

Respondents had an opportunity to provide a free-text response to this question – 14% of respondents did so.

Respondents that agreed with the proposal said that it reflected healthy eating guidance.

But felt that it:

• was for individuals to make informed decisions

• would have an impact on manufacturers

• would have an impact on the cost of a dish

• fish should be sourced sustainably

Respondents that disagreed to the proposal felt that:

• that oily fish should be available more often, including once or twice a week

• it would reduce the intake of meat consumption

• portion size would be challenging from a cost perspective due to the lack of demand for some types of oily fish requested on menus

• there is a need to protect the sustainability of fish supply

Discussion

Respondents have suggested that fish should be available more often than currently proposed. When the standard was first developed the provision of oily fish could theoretically be assigned to breakfast (for example, kippers), lunch or dinner. Therefore, if only one meal episode was provided this equates to one portion of oily fish at least once every 3 weeks. As it was much more likely for oily fish to be served during a lunch or evening meal rather than at breakfast, this was considered when reviewing the proposal.

Respondents have highlighted that the costs of a meal are likely to increase due to factors such as a lack of demand and the pricing of fish. As this is an already existing standard that is operating successfully government believes this proposal does not provide a significant challenge for catering establishments to meet.

Government response

Having considered the responses received, government has made the decision to update the standards in line with the proposals as set out below.

Fish: updated mandatory nutrition standard

If caterers serve lunch and an evening meal, fish is provided twice per week (2 x 140g portions), one of which is oily. If caterers only serve lunch or an evening meal, oily fish (140g portion) is available at least once every 3 weeks.

Question 9: Do you agree or disagree with the outlined proposals for mandatory and/or voluntary standard for savoury snacks?

What government consulted on

Savoury snacks: proposed mandatory nutrition standard

Proposed change:

Savoury snacks are only available in packet sizes of 35g or less.

This would result in:

• moved from voluntary best practice to mandatory

Note: Savoury snacks include crisps and any product made from small pieces of potato, wheat, rice, corn or other base ingredient, which have been baked, extruded, cooked or processed in any way. Crisps are defined in this instance as products that comprise sliced whole, fried potato.

Feedback

Table and chart 12: Savoury snacks – proposed mandatory nutrition standard

Response	Individuals	Businesses	Organisations
Yes	65	3	21
No	17	2	4
Not relevant	1	1	6
Not sure	8	0	0

What government consulted on

Savoury snacks: proposed voluntary best practice nutrition standard

Savoury snacks are only available in packet sizes of 30g or less.

Feedback

Table and chart 13: Savoury snacks – proposed voluntary (best practice) nutrition standard

Response	Individuals	Businesses	Organisations
Yes	57	3	15
No	21	2	1
Not relevant	0	1	6
Not sure	9	0	1

Respondents had an opportunity to provide a free-text response to this question – 25% of respondents did so.

Respondents that agreed with the proposal said that:

• it would help to support local authority vending procurement

• it was an important step towards helping to reduce calorie intake and a further opportunity to increase fruit and vegetable consumption and many of these products can contain a large amount of total fat and saturated fat as well as salt

Respondents that disagreed with the proposal felt that:

• calorie content should be used instead of pack size

• it would create more packaging

• it would increase prices

• there would be an adverse effect to those on lower incomes

• it would inadvertently encourage people to buy multiple portions

• the proposals would not be possible for patient menus, as patients need high-energy, high-protein items

• ingredients and percentage of fat in ingredients was the issue rather than pack size

• the criteria should be revised to taking into consideration products that are currently available on the market and based upon energy contribution rather than on a weight figure

Discussion

Respondents highlighted that pack size has been used rather than calorie content and energy contribution when reviewing this proposal. The pack size was originally based on a Food Standards Agency consultation published as part of its programme to reduce saturated fat and energy intakes and has been set to support the reduction of current energy, fat and salt intakes.

Some felt that limiting portion sizes would inadvertently encourage people to buy multiple portions. Government recognises that pack sizes of some crisps can be bigger than suggested in the proposed standards. However, pack sizes of 35g and below are often included in meal deals on the high street and therefore government does not envisage that consumers would necessarily purchase more than one pack.

It was suggested that the proposals would affect prices and in particular negatively affect those on lower incomes. The proposed mandatory standard to limit portion size of savoury snacks to 35g has been set pragmatically to allow a range of products currently available, while avoiding availability of larger individual or sharing pack sizes, and therefore should not affect prices or those on lower incomes.

Government response

Having considered the responses received, government has made the decision to update the standards in line with the proposals as set out below.

Savoury snacks: updated mandatory nutrition standard

Savoury snacks are only provided in packet sizes of 35g or less.

Note: Savoury snacks include crisps and any product made from small pieces of potato, wheat, rice, corn or other base ingredient, which have been baked, extruded, cooked or processed in any way. Crisps are defined in this instance as products that comprise sliced whole, fried potato.

Savoury snacks: updated voluntary best practice nutrition standard

Savoury snacks are only provided in packet sizes of 30g or less.

Question 10: Do you agree or disagree with the outlined proposals for the mandatory or voluntary standards for confectionery?

What government consulted on

Confectionery: proposed mandatory nutrition standard

Proposed changes:

At least 75% of confectionery and packet sweet snacks are in the smallest standard single-serve portion size available within the market and do not exceed 200 kcals (maximum) for chocolate and 125 kcals (maximum) for sugar confectionery.

This would result in:

• moved from voluntary best practice to mandatory with new calorie caps, bringing in line with the sugar reduction programme

Feedback

Table and chart 14: Confectionery – proposed mandatory nutrition standard

Response	Individuals	Businesses	Organisations
Yes	71	3	19
No	15	1	6
Not relevant	1	1	6
Not sure	4	1	0

What government consulted on

Confectionery: proposed voluntary (best practice) nutrition standard

All confectionery and packet sweet snacks available are in the smallest standard single-serve portion size available within the market and do not exceed 200 kcals (maximum) for chocolate and 125 kcals (maximum) for sugar confectionery.

Feedback

Table and chart 15: Confectionary – proposed voluntary (best practice) nutrition standard

Response	Individuals	Businesses	Organisations
Yes	65	3	14
No	16	2	1
Not relevant	0	1	6
Not sure	6	0	1

Respondents had an opportunity to provide a free-text response to this question – 27% of respondents did so.

Respondents that agreed with the proposal, also suggested that:

• a further opportunity should be taken to increase fruit and vegetable consumption, by recommending fresh fruits and vegetables (or healthier snacks) to be provided wherever savoury snacks/confectionery snacks are being served

• products should be in environmentally friendly packaging

• low-sugar and sugar-free confectionery options should be given a quota

• the proposals be applied to 100% of relevant products

Respondents that disagreed with the proposal felt that:

• some individuals need a larger size portion

• the need to reduce the sugar and fat within the product rather than the portion size

• a maximum portion size should be set as part of the mandatory proposal

• there are limited products on the market that meet the proposed calorie caps and as a result this would limit the ability to price and be competitive with the high street and food retailers

• the proposals should go further

• there would be opposition for manufacturers to add artificial sweetener in products

• a clearer definition of confectionery was needed

• that the proposal used sales weighted averages as ‘maximum’ targets

Discussion

Many respondents wanted the proposals to go further. Government believes it is important consumers have the option to make ‘healthier’ food and drink choices, and for the healthier choice to be the default choice. However, a degree of flexibility needs to be provided, with the inclusion in the standard of at least 75% compliance to reflect current product availability but also increase the healthier options on offer.

Some respondents raised the issue of portion size and calorie cap restrictions in the mandatory standard. Categories within the updated standards align with the PHE sugar reduction programme, both in terms of names of categories and the products included within them, wherever possible and appropriate.

Respondents cited that the definition of confectionery needed to be clearer, and that cereal bars and flapjacks should be included. Flapjacks are included in the cake category and cereal bars are included in the biscuit category in PHE’s sugar reduction programme and are therefore captured under the reducing saturated fat GBSF standard. Government understands that the updated proposals would benefit from supporting guidance to ensure that catering establishments have the practical advice and tips to help to implement the GBSF standards.

Some respondents raised the issue of setting a maximum portion size as smallest standard serving size could be challenging to monitor, as portion size could change over time. The calorie cap applies per single serve portion. Government recognises that while the smallest standard serving size may change over time, the overarching calorie cap will remain the same. The smallest standard serving size can therefore help reduce calorie intake.

Some respondents highlighted that they did not agree with sales weighted averages being used as ‘maximum’ targets in the proposed standards and that it would be preferable for PHE sugar reduction programme maximum calorie portion guidelines to be used instead. Respondents raised that the maximum targets should be used as a standard across the food industry to keep a level playing field and allow fairness in a fiercely competitive market.

When the government considered how best to set the proposals through the GBSF it became clear that many catering establishments that are covered by the GBSF are unable to use sales weighted averages and therefore a maximum target has been set for 75% of products.

Respondents discussed that introducing the new proposals would result in new products being created with artificial sweeteners. DHSC, along with PHE, supports the EFSA scientific opinion on low calorie or non-caloric sweeteners, as does the Food Standards Agency. Sweeteners that have been approved through EFSA’s processes are a safe and acceptable alternative to using sugar for the general population. There are some specific medical conditions where the use of individual sweeteners can cause an issue – for example, those with phenylketonuria are unable to metabolise aspartame.

It is up to businesses to decide if and how they wish to use sweeteners. It is known that some of the food and drink industry use them to lower the sugar content of their products while others do not, either due to legislative restrictions or issues relating to consumer acceptability. Replacing sugar with artificial sweeteners is only one way for business to achieve the standard. Alternative actions could include not adding sugar (or adding less sugar) to recipes, reducing portion size, or encouraging consumers to buy lower-sugar or sugar-free options.

Fruit and vegetables being served alongside savoury and confectionery snacks was another issue raised during the consultation. Government encourages the provision of healthier snacks like fruit. Government advice is that dried fruit and fruit (and vegetable) juices or smoothies should be consumed at mealtimes rather than a between-meal snack, to reduce the impact of the sugars they contain on the teeth.

Government response

Having considered the responses received, government has made the decision to update the standards in line with the proposals as set out below.

To help support catering establishments government will provide supporting information in the technical guidance as well as clarity that the calorie cap applies per single serve portion for the standard.

Confectionery: updated mandatory nutrition standard

At least 75% of confectionery and packet sweet snacks provided are in the smallest standard single-serve portion size available within the market and do not exceed 200 kcals maximum) for chocolate and 125 kcals (maximum) for sugar confectionery.

Confectionery: updated voluntary best practice nutrition standard

All confectionery and packet sweet snacks provided are in the smallest standard single-serve portion size available within the market and do not exceed 200 kcals (maximum) for chocolate and 125 kcals (maximum) for sugar confectionery.

Question 11: Do you agree or disagree with the outlined proposals for the mandatory and/or voluntary standards for beverages?

What government consulted on

Beverages: proposed mandatory nutrition standard

Proposed wording:

No more than 10% beverages available can be sugar-sweetened beverages (SSB).

Note: SSBs are any drink, hot or cold, carbonated or non-carbonated, including milk based drinks and milk substitute drinks such as soya, almond, hemp, oat, hazelnut or rice, which contains more than 20 kcals per 100ml energy (that is, is not ‘low energy (calorie)) and also has had any sugar added to it as an ingredient (that is, is not ‘no added sugar’). Products sweetened with a combination of artificial or natural sweeteners and sugars would, if they contain more than 20 kcals per 100ml energy (that is, are not ‘low energy (calorie)’), fall within this definition.

At least 90% of beverages made available must be low-calorie or no-added-sugar beverages.

Note: Low-calorie (low-energy) beverages are products not containing more than 20 kcals (80kJ per 100ml) energy for liquids. No added sugar means beverages that have not had sugar added to them as an ingredient. This includes beverages such as coffee, tea and hot chocolate which should not contain sugar-sweetened flavoured syrups or be sugar-sweetened as sold or provided: fruit juice, vegetable juice, smoothies, ‘juicy waters’ and water.

All SSB to be no more than 330ml pack size. Any SSBs that are hot or cold milk-based drinks including milk substitute drinks such as soya, almond, hemp, oat, hazelnut or rice need to meet 300 kcals cap.

Any meal deals should not include any SSBs.

At least 75% fruit juice, vegetable juice and smoothies to be provided in single-serve packs. These single-serve packs should contain no more than 200ml for juice alone, and as close to 150ml per serving as possible.

Note: This could include larger single serve packs containing a 150ml serving of juice diluted with water.

This would result in:

• maximum 330ml pack size for sugar sweetened beverages (SSB) becoming mandatory
• increased to 90% from 80% (now 10% of beverages can be SSBs)
• change wording from 90% of beverages procured by volume to made available

New standards:

• new standard for fruit juices and smoothies
• new standard for milk-based drinks (including milk substitute drinks)
• no SSBs to be included within a meal deal

Feedback

Table and chart 16: Beverages – proposed mandatory nutrition standard

Response	Individuals	Businesses	Organisations
Yes	66	2	21
No	17	4	10
Not relevant	1	0	5
Not sure	8	0	1

What government consulted on

Beverages: proposed voluntary (best practice) nutrition standards

All beverages made available (100%) must be low calorie/no added sugar beverages, that is, no SSBs are offered for sale.

Feedback

Table and chart 17: Beverages – proposed voluntary (best practice) nutrition standard

Response	Individuals	Businesses	Organisations
Yes	56	3	17
No	20	3	2
Not relevant	0	0	5
Not sure	8	0	0

Respondents provided a free-text response to this question – 40% of respondents did so.

Respondents that agreed with the proposal said:

• many juices sold in the public sector are sold in larger sizes

• government should actively discourage procurement of both sugary and artificially sweetened drinks

• the drinks sector should facilitate the introduction of single serve packs that meet the mandatory standard

• beverages contributed a significant proportion of children and young people’s sugar intake and provide little other nutritional value other than sugar

In addition, they felt:

• the wording ‘voluntary’ should be removed and refer as new best practice standard for reducing sugar intake

• government should go further and introduce water in meal deals

• the importance that provision to patients or care home residents is excepted, as there may be times higher-calorie or high-sugar beverages are needed as part of specific treatment plans.

Respondents that disagreed to the proposal made the following comments:

• it is for individuals to make informed decisions on beverage consumption

• the proposal is not aligned with the CQUIN 1b indicator: healthy food for NHS staff, visitors and patients

• using artificial sweetener would limit choice for those with intolerances, it not being a natural product

• the proposals would encourage manufacturers to include artificial sweeteners in their products

• cold and hot drinks should be combined into one category as this would be difficult to manage and measure

• concerns on the use of the PHE sugar reduction programme sales weighted average calorie guidelines as a maximum target within the proposal

• no more than 20% of beverages available should be SSB and suggested the new mandatory standard could be reviewed in the future as customer choice adapts

• an implementation period of 2 years to coincide with the PHE sugar reformulation programme is needed

• proposals align with the Soft Drinks Industry Levy (SDIL) rather than energy level

Some of these respondents also had concerns:

• that drinking artificiality sweetened products could cause cancer or have other effects on the body from the chemicals they contain, and that sugar taken in moderation is not bad

• about the use of the PHE sugar reduction programme sales weighted average calorie guidelines as a maximum target within the proposal

• whether components of the proposal were effective such as:

  • 200ml limit for juice considered too small

  • SSBs should not be available

  • current proposal of 20 kcals per 100ml for a beverage excludes all milk even skimmed milk

Discussion

Concerns were raised around using artificial sweeteners in products. DHSC, along with PHE, supports the EFSA’s scientific opinion on low calorie or non-caloric sweeteners, as does the Food Standards Agency. Sweeteners that have been approved through EFSA’s processes are a safe and acceptable alternative to using sugar for the general population. There are some specific medical conditions where the use of individual sweeteners can cause an issue – for example, those with phenylketonuria are unable to metabolise aspartame.

It is up to businesses to decide if and how they wish to use sweeteners. It is known that some of the food and drink industry use them to lower the sugar content of their products while others do not, either due to legislative restrictions or issues relating to consumer acceptability. Replacing sugar with artificial sweeteners is only one way for business to achieve the standard. Alternative actions could include not adding sugar (or adding less sugar) to recipes, reducing portion size, or encouraging consumers to buy lower-sugar or sugar-free options.

The proposals are intended to ensure greater access to healthier options by increasing the healthier alternatives available, but it does not preclude the sale of sugared beverages as it is understood that some medical conditions such as phenylketonuria require consumption of these products.

Respondents highlighted concerns on components in the proposals, such as milk products. SSBs, by definition, have sugar added to them. Plain milk is therefore not considered an SSB.

Government has aligned the updated standards with the PHE sugar reduction programme, both in terms of names of categories and the products included within them, wherever possible and appropriate.

Some respondents suggested that the SDIL sugar thresholds should be used instead of the energy definition in the proposal. The definition of low-calorie or no-added-sugar beverages used in the proposals is that ‘beverages should not contain more than 20 kcals (80kJ per 100ml) energy for liquids’. This is the equivalent to the SDIL sugar thresholds of ‘lower than 5g sugar per 100ml’ It should be noted that currently the SDIL sugar thresholds do not include milk drinks or fruit juices.

A 200ml limit for juice was considered too small and too limiting a choice by some. When developing these proposals government decided that 75% of these products should have a 200ml cap to allow flexibility and to reflect current product availability. The government recommends that individuals should limit fruit juice or smoothies to a total of 150ml a day, understanding that there is a lower limit range of products at 150ml, which is why we have stated ‘as close to 150ml as possible’ to encourage movement towards the government dietary recommendation as depicted in the Eatwell Guide.

Some respondents have suggested government remove the word ‘voluntary’. The term voluntary advises that the standard is for those who wish to go further than the mandatory standard. These are existing terms and there is no justification to change the title of the standard.

Respondents highlighted that water should be included in the meal deal standard. In nutrition terms, government groups water with other healthier drink options as depicted in the Eatwell Guide messaging.

Government response

Having considered the responses received, government has made the decision to update the standards in line with the proposals as set out below.

Beverages: updated mandatory nutrition standard

No more than 10% of beverages provided can be sugar sweetened beverages (SSBs).

Note: SSBs are any drink, hot or cold, carbonated or non-carbonated, including milk-based drinks and milk substitute drinks such as soya, almond, hemp, oat, hazelnut or rice, which contains more than 20 kcals (80KJ per 100ml) energy (that is, is not ‘low energy (calorie)’) and also has had any sugar added to it as an ingredient (that is, is not ‘no added sugar’). Products sweetened with a combination of artificial or natural sweeteners and sugars would, if they contain more than 20 kcals (80 KJ per 100ml) energy (that is, are not ‘low energy (calorie)’), fall within this definition.

At least 90% of beverages provided must be low-calorie no-added-sugar beverages.

Note: Low-calorie (low-energy) beverages are products not containing more than 20 kcals (80kJ per 100ml) energy for liquids. No added sugar means beverages that have not had sugar added to them as an ingredient. This includes beverages such as coffee, tea and hot chocolate which should not contain sugar-sweetened flavoured syrups or be sugar sweetened as sold or provided: fruit juice, vegetable juice, smoothies, ‘juicy waters’ and water.

All SSBs to be no more than 330ml pack size. Any SSBs that are hot or cold milk-based drinks including milk substitute drinks such as soya, almond, hemp, oat, hazelnut or rice need to meet 300 kcals cap.

Any meal deals should not include any SSBs.

At least 75% fruit juice, vegetable juice and smoothies to be provided in single serve packs. These single-serve packs should contain no more than 200ml for juice alone, and as close to 150ml per serving as possible.

Note: This could include larger single-serve packs containing a 150ml serving of juice diluted with water.

Beverages: updated voluntary (best practice) nutrition standards

All beverages provided (100%) must be low-calorie or no-added-sugar beverages – that is, no SSBs are offered.

Question 12: Do you agree or disagree with the outlined proposals for voluntary standards for menu cycle analysis?

What government consulted on

Menu cycle: proposed voluntary (best practice) nutrition standard

Proposed wording:

Menu cycles are analysed to meet nutrient based standards relevant for the majority of customers using the catering provision.

Feedback

Table and chart 18: Menu cycle – proposed voluntary (best practice nutrition standard

Response	Individuals	Businesses	Organisations
Yes	74	1	19
No	3	1	1
Not relevant	2	3	6
Not sure	12	0	0

Respondents had an opportunity to provide a free-text response to this question – 9% of respondents did so.

Respondents that agreed with the proposal thought that:

• for vulnerable people, results of analysis should be interpreted by a registered dietitian to be assured that scope of menus are fit for purpose

• there is a need to encourage the consumption of pulses, lentils and beans

• the standard could go further by supporting a voluntary standard capping red meat consumption to align with guidelines

Respondents that disagreed with the proposal felt:

• consideration should be given to a minority of individuals who have the most health problems

• theoretical menu cycle analysis is time consuming and can be resource heavy to complete

• the voluntary standard should be made mandatory

• there should be funding or subsidy options for smaller businesses that may not be able to afford the services on their own budget

Discussion

Some respondents suggested a need to encourage the consumption of beans and pulses. The government acknowledges the request but notes that it is not possible to cover every option within the menu cycle best practice nutrition standard to provide choice and variety.

Respondents that disagreed with the proposal highlighted that consideration should be given to individuals who have the most health problems when analysing menu cycles. Analysis of menus can inform menu development, offer provision of healthier options and help move the population nutrient intakes towards government dietary recommendations.

Some suggested that this should be a mandatory standard. For some smaller organisations that do not have access to in-house expertise to achieve this standard, significant costs may be involved.

While some felt that funding or subsidy options for smaller businesses unable to afford the services on their own budget should be made available this standard remains a voluntary rather than a mandatory standard.

Government response

Having considered the responses received, government has made the decision to update the standards in line with the proposals as set out below.

Menu cycle analysis: updated voluntary (best practice) nutrition standards

Menu cycles are analysed to meet nutrient based standards relevant for the majority of customers using the catering provision.

Question 13: Do you agree or disagree with the outlined proposals for voluntary standards for calorie and allergen labelling?

What government consulted on

Calorie and allergen labelling: proposed voluntary (best practice) nutrition standards

Removed the best practice requirement for menus for (food and beverages) to include calorie and allergen labelling.

Feedback

Table and chart 19: Calorie and allergen labelling – proposed removed voluntary best practice requirement for menus for (food and beverages)

Response	Individuals	Businesses	Organisations
Yes	61	4	14
No	26	9	7
Not relevant	1	2	5
Not sure	11	0	2

Respondents had an opportunity to provide a free-text response to this question – 25% of respondents did so.

The most common response was disagreement with the proposal to remove the calorie and allergen labelling from the best practice requirement for menus for (food and beverages).

Respondents that agreed to the proposal on allergen labelling felt that:

• allergen labelling should be mandatory

• allergen information is crucial to some people

• menus should provide clear nutritional, ingredient labelling regardless of whether food is packaged or not

• voluntary standards are not effective

Respondents that disagreed said:

• displaying this information should be mandatory to bring the out-of-home sector more in line with food labelling in the retail sector

• providing calorie would help consumers make informed and healthier choices

• calorie labelling should still be included in the GBSF as the government has yet to respond to the calorie labelling consultation as part of chapter 2 of the childhood obesity plan

• it would be unfortunate to lose reference to calorie labelling on the assumption that there will be reference to the outcome of the calorie labelling consultation and a commitment to update the proposal once the policy action had been confirmed

• it was not clear whether proposed policies to introduce calorie labelling in the out-of-home sector will also cover catering settings where meals not paid at the point of consumption – for example, hospital and prison food

• there was evidence that links calorie labelling to reduction in the number of calories consumed

Discussion

The majority of respondents who provided free-text responses did not agree with the removal of the best practice requirement for menus for (food and beverages) to include calorie and allergen labelling. Legislation exists covering provision of allergen labelling for businesses and legislation planned for provision of calorie labelling.

From 1 January 2021 the UK is no longer part of the European Union (EU). All direct EU nutrition related legislation as it stands at the end of 31 December 2020 will form domestic law. The retained EU Regulation on the Provision of Food Information to Consumers describes the requirement for businesses to communicate the presence of allergens in food to consumers. This came into force in 2014. Food businesses are required to inform customers if their products contain any of 14 key allergens, either explicitly in writing or with a clear instruction about how to obtain the information (for example, asking staff). There is a difference in how this should be communicated to the consumer depending on the type of food product. The law requires pre-packaged food to label allergens on the product which should be emphasised within the ingredient list. For non pre-packaged foods, allergen information can be provided either in writing or orally, depending on which method best suits the businesses service model. New rules to cover allergen labelling for a third category of food called ‘prepacked for direct sale’ (PPDS) will come into force on 1 October 2021. Legislation for the allergen labelling of PPDS food has been introduced in England.

The government has recently committed to introduce mandatory calorie labelling for large businesses (businesses with 250+ employees) in response to its consultation on the proposal.

The government will evaluate the impact of introducing mandatory calorie labelling for large businesses and will consider extending the requirement to include smaller businesses in the future. In the meantime, smaller businesses are encouraged to voluntarily comply and therefore it makes sense to retain the ‘calorie labelling’ as part of the best practice guide for businesses bound by the GBSF.

Government has considered all responses and will keep an explicit best practice standard for nutrition standards, where not otherwise required by law.^{[footnote 13], [footnote 14]} This will clarify that the calorie and allergen labelling required by law is not considered ‘best practice’ or ‘voluntary’ by the GBSF, but any further calorie and allergen labelling in addition to this is.

Government response

Having carefully considered the comments provided by respondents, government has made the decision to update the GBSF voluntary (best practice) standard for menus for (food and beverages), as set out below.

Calorie and allergen labelling: updated voluntary (best practice) nutrition standard

Best practice requirement for menus (for food and beverages) to include calorie and allergen labelling where not stated in law.*

* See ^{[footnote 13], [footnote 14]}.

Question 14: Are there any categories, either mandatory or voluntary, that you think should be amended or added to be in line with government dietary recommendations?

What government consulted on

Additional information on what should be amended or added in line with government dietary recommendations.

Feedback

Respondents were invited to provide a free-text response to this question.

Of the 138 respondents, 34% took up the invitation.

Respondents requested that the following should be considered in line with government dietary recommendations:

• specific reference to the standards applying to vending machines should be made

• proposals should be introduced to limit the provision on red meat and processed meat as well as for protein

• vegetables should be considered as a snack within the proposals

• proposals should be integrated into the education of individuals working in the food and hospitality industry

• traffic light labelling on foods should be in agreed portion or weight sizes to enable customers to make accurate comparisons between products

• that the BDA is reflected in any mandatory or voluntary nutrition recommendations for NHS in-patient catering

• wording of the standards was inconsistent with the use of the words ‘shall’ and ‘should’

• that supporting information should be provided including a complete list of oily fish to reflect the guidance on NHS choices

• at least one vegan-friendly meal made mandatory on every public sector menu, every day

Discussion

Respondents suggested that there should be a specific reference to the standards applying to vending machines. The government did advise in the consultation document that the GBSF standards should apply to vending machines. Government will make it clearer in the written technical guidance that the GBSF standards also apply to vending machines.

Respondents highlighted that there should be specific standards for red meat, processed meat and protein. The NDNS data indicates that at a population level, the average red and processed meat intake of adults meets the recommendation of no more than 70g per day in all age or sex groups.

Government has included a voluntary best practice nutrition standard to encourage provision of beans and pulses in meals (such as lentils, beans) that could be offered in place of red or processed meat. As GBSF nutrition standards reflect government dietary recommendations for the general population, government would not consider procurement-based standards for protein to be necessary as NDNS data shows that protein intakes meet recommendations.

Respondents suggested that portion size would help consumers choose between products. Government believes that the calorie caps proposed for some categories, taken from the sugar reduction and wider reformulation programme, could act as suggestions for portion sizes, but government does not have general portion size guidance for foods other than fruit and vegetables, oily fish and red or processed meat, as there is no good evidence beyond these exceptions to support the setting of population portion sizes.

Respondents highlighted that vegetables should be considered as a snack. Government encourages the provision of healthier snacks like fruit and vegetables. Government advice is that dried fruit and fruit (and vegetable) juices or smoothies should be consumed at mealtimes rather than a between-meal snack, to reduce the impact of the sugars they contain on the teeth.

Respondents suggested that that proposals should be integrated into the education of individuals working in the food and hospitality industry and that supporting information should be provided.

Government understands that the updated proposals would benefit from supporting guidance to ensure that catering establishments have the practical advice and tips they need to implement the GBSF standards and will produce written technical guidance. PHE has worked with the Association for Nutrition to develop a competency framework for those working in hospitality or catering. If businesses require further information the Association for Nutrition website can offer further advice.

Respondents highlighted that at least one vegan-friendly meal should be made mandatory on every public sector menu, every day. The best practice menu cycle analysis standard is on meeting nutrient standards not the provision of menu choices.

Common themes from consultation responses

Common themes were identified when analysing across the updated proposals, including:

• addressing the nutritional needs for patients
• the CQUIN 1b indicator: healthy food for NHS staff, visitors and patients
• product availability

Theme	Discussion	Government response
Nutritional needs of patients	Respondents raised concerns that the updated proposals would not address the nutritional needs of patients throughout the consultation. Some people, in particular patients, may need rich food and drink higher in energy and/or lower in fibre for example. For those with specific requirements a personal nutritional care plan should be implemented and tailored dietetic advice sought.	Whilst the GBSF must be followed in the case of patients who are ‘nutritionally well’ and in the provision of staff food and hydration it is important to note that clinical need for those patients who are ‘nutritionally vulnerable’ must be the first priority. Risk assessments should be carried out to ascertain where exceptions to the GBSF guidelines are acceptable; and whether the use of the BDA guidelines are more appropriate. The specific nutritional needs of individual patients should always supersede the application of blanket principles. This exception may apply to a majority of in-patients in some clinical settings. When addressing the clinical, nutritional or other needs of patients, it is best to refer to the BDA. The individual nutritional requirements of patients are paramount and consequently should supersede the prescription to the nutritional standards of the GBSF as appropriate.
National Healthcare Standards for food and drink	Respondents raised concerns that the proposals for saturated fat, meal deals, beverages and confectionery did not align with the existing CQUIN 1b indicator: healthy food for NHS staff, visitors and patients.	The NHS Standard contract is mandated by NHS England for use by commissioners for all contracts for healthcare services other than primary care. The NHS Food Standards and Strategy Group are working on new national standards for healthcare food: patient, staff and visitor. Standards within CQUIN1b will be considered as part of this work and is due for publication this year.
Product availability	Respondents raised concerns that the updated proposals for saturated fat, reducing sugar intake, savoury snacks, beverages and confectionery would be difficult to achieve within a 12-month period, due to the lack of products available to meet the standards.	To enable flexibility, when developing the saturated fat, reducing sugar intake, beverages and confectionery proposals they were set at a percentage of these products procured or made available to reflect current product availability but also increase the healthier options on offer. Government has considered when developing the savoury snack proposal that a range of products are currently available to meet the standard while avoiding availability of larger individual or sharing pack sizes. To help businesses meet the updated saturated fat standard, government has decided to lower the percentage from 75% to 50% to be made available for both the saturated fat and calorie cap in the pre-packaged sandwiches component of this standard during the implementation period of 18 months. The standard will then increase to 75% thereafter with a further implementation period of 18 months, allowing for a total 3-year implementation period. For the updated reducing salt standards, government will extend the period of compliance by 2 years.

Consultation responses to implementation questions 15 to 18

Question 15: Would 12 months be an appropriate amount of time for businesses to implement the updated GBSF nutrition standards?

Feedback

Table and chart 20: Would 12 months be an appropriate amount of time for businesses to implement the updated GBSF nutrition standards?

Response	Respondents
Yes	71
No	24
Don’t know	30
Not answered	13

Of the 138 respondents:

• 71 (51%) agreed with the outlined proposal
• 24 (17%) disagreed with the outlined proposal
• 30 (22%) responded that they did not know
• 13 (9%) did not answer the question

The majority of individuals and half of businesses agreed that 12 months would be an appropriate amount of time for businesses to implement the updated GBSF nutrition standards.

Respondents had an opportunity to provide a free-text response to this question – 41% of respondents did so. The most common response was that respondents needed longer than 12 months for implementation.

Discussion

51% of respondents agreed that 12 months would be an appropriate amount of time for businesses to implement the updated GBSF standards.

Some respondents suggested that the implementation period would need to be longer than 12 months for implementation for a number of reasons. Respondents highlighted that as a food manufacturer they would need a 6-monthly range refreshment and development process to allow customers to change their menus in time. This is especially important in hospitals where menus are often printed 6 months in advance.

Respondents said that their ability to meet the standards for compliance are still very much dependent on enough suitable products being available on the market to buy-in or sell on. They cited that 12 months was too short a time to allow for manufacturers to reformulate their products or make changes to packaging sizes.

Conclusion

Government has considered the challenges for businesses provided in the consultation response.

Government recognises that catering establishments will need sufficient time to plan their menus to include products that meet the guidelines and that there are fewer products available to catering establishments now that meet these guidelines. Therefore, government intends to set an implementation period of 12 months to help with compliance.

Revised salt targets for 2024 were published in September 2020. To allow time for manufacturers to reformulate their products to meet the revised salt reduction targets government will extend the period of compliance by 2 years, allowing a total implementation period of 3 years for the salt standard.

To help businesses meet the updated saturated fat standard, government has decided to lower the percentage from 75% to 50% to be made available for both the saturated fat and calorie cap in the pre-packaged sandwiches component of this standard during the implementation period of 18 months. The standard will then increase to 75% thereafter with a further implementation period of 18 months, allowing for a total 3-year implementation period.

Question 16: Are there any categories that would be easier or more challenging to implement?

Feedback

Table and chart 21: Are there any categories that would be easier or more challenging to implement?

Response	Respondents
Yes	29
No	20
Don’t know	70
Not answered	19

Of the 138 respondents:

• 29 (21%) agreed there would be categories that would be easier or more challenging to implement
• 20 (14%) disagreed there would be categories that would be easier or more challenging to implement
• 70 (51%) responded that they did not know
• 19 (14%) did not answer the question

Respondents had an opportunity to provide a free-text response to this question –22% of respondents did so.

The most common free-text response was that respondents felt the most challenging proposal to implement was the sugar reduction mandatory standard.

Discussion

Some respondents suggested that sugar reduction is very difficult due to its addictive nature and that people would be resistant to this proposal. Respondents highlighted that manufacturers would need time to reformulate products to reduce sugar in products.

Government has updated the standard to align with the PHE sugar reduction programme, both in terms of names of categories and the products included within them, wherever possible and appropriate.

Conclusion

By providing a 12-month implementation period this would allow further product development and align with the sugar reformulation programme.

Question 17: Government will provide written technical guidance to help illustrate how the nutrition standards in GBSF will work in each food or drink category. Do you think businesses will need any additional support to comply with these?

Feedback

Table and chart 22: Government will provide written technical guidance to help illustrate how the nutrition standards in GBSF will work in each food or drink category. Do you think businesses will need any additional support to comply with these?

Response	Respondents
Yes	43
No	30
Don’t know	50
Not answered	15

Of the 138 respondents:

• 43 (31%) agreed that businesses will need additional support to comply with the nutrition standards
• 30 (22%) disagreed businesses will need additional support to comply with the nutrition standards
• 50(36%) responded that they did not know
• 15 (11%) did not answer the question

Respondents had an opportunity to provide a free-text response to this question and provide examples of additional support – 22% of respondents did so.

The following additional support to the tech guidance was suggested:

• a helpline
• online videos
• webinars
• case study examples

Discussion

From the feedback it is understood that the updated proposals would benefit from supporting guidance to ensure that catering establishments have the practical advice and tips they need to implement the GBSF standards.

The government will continue to work on producing guidance to help support delivery of the GBSF nutritional standards in line with this update. The written technical guidance will be published shortly after the publication of the government response to help businesses implement the updated standards. The implementation period will begin when the technical guidance is published.

Question 18: In addition to updating the standards if you have any suggestions for how enforcement, monitoring and compliance could be improved, please provide detail.

Feedback

This was a free-text response and 36% provided comment.

The most common response was the suggestion that a lack of compliance should result in penalties or meaningful sanctions.

Discussion

Overall policy responsibility for the GBSF rests with Defra. Defra works across Whitehall to ensure that the policy is embedded in Crown Commercial Service (CCS) procurement frameworks, and food standards led by other government departments. Defra does not liaise with or directly monitor public sector food contracts or procurement management processes, as this is a commercial and operational activity.

Currently, compliance with the GBSF is mandated via the CCS’s Public Procurement Notices and Facilities Management Frameworks, for central government and executive agencies. Clients are expected to use contract management processes to review contract specifications and manage expectations or contract breeches appropriately.

Defra is keen to encourage uptake of the GBSF and is working to understand how government departments and industry stakeholders could improve their own monitoring via, for example, updating standards, introducing targeted key performance indicators and metrics or conducting contract compliance checks to ensure suppliers are complying with specifications.

GBSF applies to NHS trusts and foundation trusts as well as these trusts that contain retail units as they are mandated by NHS England within the NHS Standard Contract.

The NHS Standard Contract is mandated by NHS England for use by commissioners for all contracts for healthcare services other than primary care. The contract stipulates that the provider must develop and maintain a food and drink strategy in accordance with the Hospital Food Standards Report and have regard to (and where mandatory comply with) food standards guidance, as applicable. This includes the GBSF.

NHS England consulted on the 2020 to 2021 NHS Standard Contract last year. NHS England proposed some amendments to the section dealing with food standards as follows:

The Provider must comply with NHS Food Standards and must develop and implement a food and drink strategy, setting out how it will ensure that, from retail outlets and vending machines, catering provision and facilities as appropriate, service users, staff and visitors are offered ready access 24 hours a day to healthy eating and drinking options and that products provided and/or offered for sale meet the requirements set out in NHS Food Standards, including in respect of labelling and portion size.

Following the consultation feedback these amendments have been included in the NHS Standard Contract for 2020 to 2021 at Service Condition 19.

Clinical commissioning groups (CCGs) can follow up with a provider to remedy any breach of contract but if such remedy is not forthcoming, the CCG is able, under the NHS Standard Contract, to apply sanctions. The GBSF is one of 5 compulsory food standards that are mandated in the NHS standard contract. These standards are currently under review and will be published this year.

Outcome and next steps

Following this consultation, the government has decided to update the nutrition standards in the GBSF.

It is acknowledged that catering establishments will need sufficient time to plan their menus to include products that meet the updated standards. Similarly, manufacturers will need an appropriate period of time to create new or reformulate existing products, or make changes to packaging sizes. This is why government will set an implementation period of 12 months from date of publication of the technical written guidance, giving businesses more time to achieve the standards set with the exception of the reducing salt mandatory and voluntary ‘best practice’ standard and the pre-packaged sandwiches component within the reducing saturated fat standard.

Revised salt reduction targets for 2024 were published in September 2020. To help allow time for manufacturers to reformulate their products to meet the revised targets, government will extend the period of compliance by 2 years, allowing a total implementation period of 3 years for the salt standard.

To help businesses meet the updated saturated fat standard, government has decided to lower the percentage from 75% to 50% to be made available for both the saturated fat and calorie cap in the pre-packaged sandwiches component of this standard during the implementation period of 18 months. The standard will then increase to 75% thereafter with a further implementation period of 18 months, allowing for a total 3-year implementation period.

The updated nutrition standards can be found in annex A.

Annex A: updated nutrition standards

Mandatory nutrition standards

1. Reducing salt

Vegetables and boiled starchy foods such as rice, pasta and potatoes, shall be cooked without salt.

Salt shall not be available on tables.

At least 75% of meat products, breads, soups, cooking sauces and ready meals procured by volume, and 75% of breakfast cereals and pre-packed sandwiches provided meet current core salt targets and any subsequent revisions to this target and all stock preparations shall be lower salt varieties (that is, below 0.6g per 100mls reconstituted).

Note: The 75% applies individually to each food category in the above specification, and not only to the combined provision or volume. The requirement relates to meeting maximum targets or using an average target as a maximum where a maximum target is not set.

2. Increasing fruit and vegetable consumption

A portion of fruit shall be sold at a lower price than a portion of hot or cold dessert.

Half of desserts available should contain at least 50% of their weight as fruit – which may be fresh, canned in fruit juice, dried or frozen. This excludes whole fresh fruit as a dessert option. Whole fresh fruit can be a dessert option but should not be included as an option when calculating whether half of dessert options should contain at least 50% of their weight as fruit.

Main meals within a meal deal should include a starchy carbohydrate which is not prepared with fats or oils, and the meal deal options should include at least one portion of vegetables and one portion of fruit.

3. Meal deals

Any foods and drinks within a meal deal must also meet the relevant GBSF standards for the healthier options – for example, healthier sandwiches.^{[footnote 11]}

4. Reducing saturated fat

Meat and meat products (procured by volume), biscuits, cakes and pastries (provided) be lower in saturated fat, where available.

At least 50% of hard yellow cheese procured by volume shall have a maximum total fat content of 25g per 100g.

At least 75% of ready meals procured by volume shall contain less than 6g saturated fat per portion.

At least 75% of milk procured by volume is lower fat (semi-skimmed, 1% or skimmed milk).

At least 75% of oils and 75% of spreads procured by volume are based on unsaturated fats.

At least 50% of pre-packed sandwiches and other savoury pre-packed meals (wraps, salads, pasta salads) provided contain 400 kcals (1,680 kJ) or less per serving and do not exceed 5.0g saturated fat per 100g for an 18-month implementation period to increase the standard to 75% thereafter with a further implementation period of 18 months.

5. Increasing fibre

At least 50% of bread provided contains at least 3g fibre per 100g (that is, is a source of fibre), excluding pre-packed sandwiches.

At least 75% of pre-packed sandwiches provided contains bread with at least 3g fibre per 100g.

6. Reducing sugar intake

At least 75% of products provided that are included in the following categories covered by the sugar reduction programme to not exceed the following:

• biscuits: 100 kcals
• cakes: 220 kcals
• morning goods: 220 kcals
• puddings: 220 kcals
• yogurts: 120 kcals
• ice cream: 220 kcals

Note: The 75% applies individually to each product category described in the above specification, and not only to the combined provision.

7. Breakfast cereals

At least 50% of breakfast cereals provided are higher in fibre (that is, at least 6g per 100g) and shall not exceed 12.3g per 100g total sugars (10g additional allowance for dried fruit in cereal).

8. Fish

If caterers serve lunch and an evening meal, fish is provided twice per week (2 x 140g portions), one of which is oily. If caterers only serve lunch or an evening meal, oily fish (140g portion) is available at least once every 3 weeks.

9. Savoury snacks

Savoury snacks are only provided in packet sizes of 35g or less.

Note: Savoury snacks include crisps and any product made from small pieces of potato, wheat, rice, corn or other base ingredient, which have been baked, extruded, cooked or processed in any way. Crisps are defined in this instance as products that comprise sliced whole, fried potato.

10. Confectionery

At least 75% of confectionery and packet sweet snacks provided are in the smallest standard single-serve portion size available within the market and do not exceed 200 kcals (maximum) for chocolate and 125 kcals (maximum) for sugar confectionery.

11. Beverages

No more than 10% beverages provided can be sugar-sweetened beverages (SSB).

At least 90% of beverages provided must be low-calorie or no-added-sugar beverages.

All SSBs to be no more than 330ml pack size. Any SSBs that are hot or cold milk-based drinks including milk substitute drinks such as soya, almond, hemp, oat, hazelnut or rice need to meet 300 kcals cap.

Any meal deals should not include any SSBs.

At least 75% fruit juice, vegetable juice and smoothies to be provided in single-serve packs.

For further guidance on how SSBs, low-calorie and no-added-sugar beverages are defined is available in the supporting documents.

Voluntary (best practice) nutrition standards

12. Reducing salt intake

At least 75% of all products (procured by volume or provided) that are covered by the current salt targets meet this target and any subsequent revisions to this target.

The 75% applies individually to each food category described in the above specification, and not only to the combined provision or volume. The requirement relates to meeting maximum targets or using an average target as a maximum where a maximum target is not set.

13. Increasing fibre

To ensure at least 50% of bread provided contains at least 3g fibre per 100g (that is, is a source of fibre), excluding pre-packed sandwiches as per the mandatory standard.

And, in addition to the mandatory standard at least 25% of all bread provided contains at least 6g per 100g (that is, high in fibre), excluding pre-packed sandwiches.

To ensure main meals containing beans or pulses (or both) as a main source of protein are made available at least once a week.

14. Breakfast cereals

To ensure at least 50% of all breakfast cereals provided contain at least 6g per 100g of fibre (that is, high in fibre) and shall not exceed 12.3g per 100g total sugars (10g additional allowance for dried fruit in cereal), as per the mandatory standard.

And, in addition to the mandatory standard, at least 25% of all breakfast cereals provided contain at least 6g per 100g (that is, high in fibre) and shall not exceed 5g per 100g total sugars (10g additional allowance for dried fruit in cereal).

15. Savoury snacks

Savoury snacks are only provided in packet sizes of 30g or less.

16. Confectionery

All confectionery and packet sweet snacks provided are in the smallest standard single serve portion size available within the market and do not exceed 200 kcals (maximum) for chocolate and 125 kcals (maximum) for sugar confectionery.

17. Beverages

All beverages provided (100%) must be low-calorie or no-added-sugar beverages – that is, no SSBs are offered.

18. Menu cycle analysis

Menu cycles are analysed to meet nutrient based standards relevant for the majority of customers using the catering provision.

19. Calorie and allergen labelling

Best practice requirement for menus (for food and beverages) to include calorie and allergen labelling where not stated in law.^{[footnote 13], [footnote 14]}

Annex B: standard consultation questions feedback

Question 19: Do you think that this proposal would be likely to have an impact on people on the basis of any of the following characteristics?

Respondents could select as many characteristics as they believe applied.

Age:

• yes: 57 respondents
• no: 55 respondents

Sex:

• yes: 21 respondents
• no: 89 respondents

Race:

• yes: 33 respondents
• no: 78 respondents

Religion:

• yes: 27 respondents
• no: 82 respondents

Sexual orientation:

• yes: 5 respondents
• no: 105 respondents

Pregnancy and maternity:

• yes: 50 respondents
• no: 61 respondents

Disability:

• yes: 37 respondents
• no: 73 respondents

Gender reassignment:

• yes: 4 respondents
• no: 106 respondents

Marriage or civil partnership:

• yes: 5 respondents
• no: 104 respondents

Forty respondents provided a justification to explain their answer. Answers were analysed to establish whether the respondent believed the policy would have a positive or negative effect on the particular characteristic.

Respondents highlighted that the proposals would have a positive impact on children and young people and those that are pregnant.

Respondents believed there would be a negative effect on disabilities due to diet and food choices as well as some gastroenterological conditions.

Respondents highlighted that the policy would have a negative effect on elderly people as they may be vulnerable, have different taste and have more food intolerances or digestive issues.

Respondents believed it would have a negative effect for those in religious groups due to restrictive diet requirements.

Question 20: Do you think this proposal would help achieve any of the following aims?

• Eliminating discrimination, harassment, victimisation and any other conduct that is prohibited by or under the Equality Act 2010: 13 (9%) respondents

• Advancing equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it: 18 (13%) respondents

• Fostering good relations between persons who share a relevant protected characteristic and persons who do not share it: 17 (12%) respondents

• Not answered: 113 (82%) respondents

Question 21: Do you think that this proposal would be likely to have any impact on people from lower socio-economic backgrounds?

• Yes: 77 (56%) respondents

• No: 16 (12%) respondents

• Don’t know or not answered: 25 (18%) respondents

Question 22: Which questions on impact would you want to answer?

Of the 138 respondents:

• 99 (72%) wanted the impact questions to focus on the individual

• 19 (14%) wanted the impact questions to focus on businesses and organisations

• 20 (14%) did not answer this question

Question 23: If there are any further matters that you would like to raise or any further information that you would like to provide in relation to this consultation, please give details here.

Respondents had an opportunity to provide a free-text response to this question.

33% of respondents provided free-text comments.

The majority of respondents either reiterated points they made elsewhere in the consultation or made points that were common in the responses of others.

3% of respondents gave further evidence in response to this question.

Most responses were anecdotal, commenting on the policy itself or referring to professional experience. Topics covered included the additional cost of food and the reduced choice on menus.

1. Smarter food procurement in the public sector. NAO report HC 963-I Session 2005 to 2006, 30 March 2006. ↩

2. Health Survey for England 2019. ↩

3. NHS Digital 2020, National Child Measurement Programme, England 2019 to 2020 School Year. ↩

4. Public Health England (2020), National Diet and Nutrition Survey: Assessment of salt intake from urinary sodium in adults (aged 19 to 64 years) in England 2018 to 2019. ↩

5. PHE, 2020, calorie reduction: guidelines for the food industry. ↩

6. Scientific Advisory Committee on Nutrition (SACN) Salt and Health report. ↩

7. World Health Organisation, 1990, Diet, nutrition and the prevention of chronic diseases. ↩

8. World Health Organisation, 2003, Diet, nutrition and the prevention of chronic diseases. ↩

9. The definition for ‘high’ in fat, sugar or salt is as defined in the DHSC and FSA publications Guide to creating a front-of-pack (FoP) nutrition label for pre-packed products sold through retail outlets, November 2016. ↩

10. Tackling obesity: empowering adults and children to live healthier lives. ↩

11. This would be for all categories of ‘meal deals’ such as ‘breakfast meal deals’, ‘hot food meal deals’, ‘sandwich meal deals’, ‘hot drink and snacks – for example, confectionery, savoury snacks or items under the reducing sugar category’. Meal deals should not include sugar sweetened beverages. Healthier breakfast cereals should be included in the ‘breakfast meal deals’. ↩ ↩²

12. SACN saturated fats and health report. ↩

13. EU Food Information for Consumers Regulation 1169/2011. ↩ ↩² ↩³

14. UK’s Food Information Regulations 1855/2014. ↩ ↩² ↩³