Guidance

Appendix 2: high level summary of stakeholder feedback to initial draft calorie reduction and reformulation proposals

Published 10 May 2019

In October 2018 Public Health England (PHE) began its stakeholder engagement on the initial draft proposed guidelines for the calorie reduction programme.

This round of engagement involved holding stakeholder forums to share the initial draft guidelines for retailers, manufacturers and the eating out of home sector^{[footnote 1]}. Around 200 businesses, trade associations and other stakeholders attended, including some businesses that had not previously engaged with the reduction and reformulation programme. Health non-governmental organisations (NGOs) and, in an observer capacity, other government departments and the devolved administrations also attended.

PHE gave details of the initial draft guidelines and the supporting rationale, including the structure of the product categories and the draft baseline analysis.

These forums were supplemented by 1:1 meetings and all stakeholders were also offered the opportunity to provide PHE with written feedback. PHE requested that the feedback include information on technical and other relevant issues associated with calorie reduction within the proposed categories, including any reformulation activity completed to date.

A summary of the main themes and key concerns raised within the feedback received from stakeholders to date is set out below. Appendix 1 includes a list of stakeholders who engaged with PHE through this process and across the reduction and reformulation programmes.

Support for a calorie reduction and reformulation programme

Overall, stakeholders were supportive of the objective of achieving an overall reduction in calories consumed, to contribute to improving public health.

Industry expressed concern regarding the expectation that a 20% calorie reduction would be achieved in each category. This related to where significant business progress had already taken place and where there are commercial and/or technological challenges to reducing calories in products. Feedback also suggested that guidelines should be tailored to match the feasibility of reductions within individual categories, rather than applying a blanket 20% reduction, to help ensure continued industry engagement.

Businesses acknowledged the changing landscape with other government actions arising from chapter 2 of the Childhood Obesity Plan (for example, consultations on restrictions on advertising, marketing and promotions and out of home calorie labelling) and the impact these actions may have on their ability to achieve the calorie reduction ambition. Comments were made on any further advertising restrictions potentially limiting consumers from switching purchasing towards lower calorie options if businesses are unable to promote them.

Baseline and progress reporting

There was concern that previous calorie reduction achievements may not be reflected in PHE reporting if a 2017 baseline year was used to monitor progress. NGOs supported an interim calorie reduction ambition at a mid-point of the programme and for the government to consider other measures if not enough progress is seen. There was limited wider support for this.

Calorie categories

This high-level summary does not include specific comments on the proposed categories, product categorisation and specific calorie reduction guidelines. Stakeholders comments on these areas will be reviewed by PHE and inform future development of the guidelines. General feedback covered the following areas.

The contribution of calories. Feedback was raised that not all products identified within categories contributed the same level of calories into the diet.

Potential misalignment with healthy eating messages. Industry questioned including products which feature in government healthy eating messages such as carbohydrate, fish and vegetable products. Some businesses cited concern regarding a potential reduction in consumer choice and unintended consequences for dietary health if a business decided to remove some products from sale or limit availability of others in response to the programme. Industry stakeholders suggested targeting those products higher in calories (and potentially higher in volumes sold).

Difference in business models. Eating out of home sector feedback raised concerns regarding the inclusion of both component and meal-based guidelines given their business models are predominantly focused on serving meals. Businesses strong preference was therefore for guidelines to be set on a meal basis.

The amount of time it would take businesses to correctly place their products within PHE’s intended categories was also raised.

Data, methodology and monitoring

At the stakeholder engagement forums PHE presented the proposed methodology for setting calorie reduction guidelines and the types of guidelines it intended to set. Further detail is provided elsewhere in this document.

Use of sales weighted or simple averages

The draft proposal was for sales weighted average (SWA) calories per 100g to be used for retailers and manufacturers as the principle guideline and measurement for progress. A simple average would also be calculated for this sector to allow comparisons to out of home where simple averages would be the principle guideline.

Industry stakeholders felt the methodology could be simplified with fewer metrics used but no details on how this could change were provided. The following reasons for simplification were cited:

• ease of stakeholder understanding and implementation
• multiple metrics increase the potential for inaccuracies in reporting and place an additional burden on businesses when seeking to internally validate PHE data
• confusion over the principle guideline for different sectors

Generally, stakeholders pragmatically accepted PHE’s justification for using a simple average for the eating out of home sector, and some comments suggested also using a simple average as the principle guideline for the retail and manufacturing sector. NGOs supported an approach where PHE continues to work with the eating out of home sector to achieve an SWA approach within the duration of the calorie reduction programme.

Despite broadly accepting a simple average approach, concerns were raised about this metric not taking account of volumes sold and the impact on comparability of data capture and reporting between sectors.

Industry concerns were raised about the eating out of home sector being potentially disadvantaged by a simple average approach given they may have fewer products within categories than retailers and manufacturers.

Stakeholders sought reassurance from PHE that, with a simple average approach, there would be a continued emphasis on products that contribute the most calories into children’s diets; and monitoring to ensure this focus.

Calories guidelines per 100g or maximum calorie guidelines for products consumed in a single occasion (kcals per single serve)

The difference in business models between retailers, manufacturers and the eating out of home sector was highlighted in comments in relation to how the initial draft proposed guidelines were presented and would be realised in practice.

Eating out of home businesses had a strong preference for categories to be structured differently to better fit the way their food is served (for example, starter, main meal, accompaniments and including ‘food to go’) with maximum calorie guidelines per meal, rather than per product category. However, the limitations for comparability across the sectors by taking this approach was acknowledged.

From a retailer and manufacturer perspective, views were generally mixed on preferences for calorie guidelines per 100g versus maximum calorie guidelines per single serve.

There was support for a more tailored approach to setting guidelines for individual categories or products. This would also add clarity to which guideline businesses should be working towards.

Differences in the maximum calorie guidelines per single serve for retailers and manufacturers compared to the eating out of home sector were noted. Responses suggested aligning guidelines, particularly where products were of a similar nature or fall into both in and out of home sectors, for example, ‘food to go’ (sandwiches, meals, salads).

Portion size reduction

Industry feedback focused on an improved understanding of consumer acceptance and behaviour change. This included exploring the ‘tipping point’ for consumers having more than one product at a time due to a reduction in portion size.

The fact that portion size reduction was unlikely to be an issue for all products was noted, and furthered industry support for a more tailored guideline setting approach across different categories. However, it was also noted that for some product categories, such as pizza and sandwiches, portion size reduction would be particularly challenging.

A significant number of comments asked how reducing calories through reducing portion size would be captured in PHE monitoring, particularly as portion size reduction may be a business’s main mechanism for action for some products.

Further clarity on the evidence base and data used by PHE to set the maximum calorie guidelines for products likely to be consumed in a single occasion was requested.

Other metrics proposed

Feedback suggested that the proposed guideline metric, where 75% of products should fall or be equal to the figure set, placed an additional burden on industry without offering any perceived benefit.

Some general queries were also raised on the data used to set the initial draft proposals.

Consumer acceptance of calorie reduction and portion size reduction

Industry raised the need for parallel government activity to increase consumer understanding of the ambition to reduce calories across the food sector and support businesses taking action. This was particularly important for portion size reduction, given this can lead to a perceived loss of “value for money”, generally a high priority for consumers. Feedback suggested providing consumer facing information to support calorie consciousness at point of sale, such as the ‘400-600-600’ consumer facing tip.

1. The term ‘out of home’ covers businesses such as quick service restaurants, casual dining restaurants, contract caterers (foodservice), cafés and coffee shops, sandwich and bakery led shops, pubs, vending, retail food on the go, takeaway and delivery services. ↩