National Food Strategy Published: What this means for business 

Part One of Henry Dimbleby’s two-part National Food Strategy (“Strategy”) was published on 29 July 2020, which contains urgent recommendations to support the UK through the turbulence caused by the COVID-19 pandemic, and to prepare it for the end of the EU exit transition period on 31 December 2020.

Part Two of the Strategy, to be published in 2021, will present a comprehensive plan for transforming the food system in England[1]. The Government has committed to producing a White Paper six months after Part Two is published.

Recommendations

The recommendations in Part One cover two themes: (i) ensuring that all children get the nutrition they need in the context of post-lockdown recession; and (ii) protecting high standards in food, environmental and animal welfare when negotiating new trade deals, whilst subjecting prospective deals to independent scrutiny.

Of particular relevance to the food and drink industry are the recommendations that the Government should:

• Only agree to cut tariffs in new trade deals in respect of products which meet the UK’s core standards[2]. To this end, verification programmes should be established which allow (and require) third country producers wishing to sell food products in the UK to prove that they meet these minimum standards. These schemes should cover animal welfare concerns and environmental and climate concerns where the impact of particular goods are severe (for example, beef reared on land recently cleared of rainforest).
• Adopt a statutory responsibility to commission and publish an independent report on any proposed trade agreements including scrutiny on: economic productivity; food safety and public health; the environment and climate chance; society and labour; and human rights and animal welfare. The report should be presented alongside the Government’s response to any final trade treaty that is laid before Parliament.
• Adopt a statutory duty to provide Parliament the time and opportunity to properly scrutinise any new trade deal.

In response to the COVID-19 pandemic, the Strategy also recommends that the Government should:

• Expand eligibility for the Free School Meal scheme to include every child (up to the age of 16) from a household where the parent or guardian is in receipt of Universal Credit or equivalent benefits.
• Extend the Holiday Activity and Food Programme to all areas in England, so that summer holiday support is available to all children in receipt of Free School Meals.
• Increase the value of Healthy Start vouchers to £4.25 per week, and expand the scheme to every pregnant woman and to all households with children under four, where a parent or guardian is in receipt of Universal Credit or equivalent benefit.
• Extend the work of the Food and Other Essential Supplies to the Vulnerable Ministerial Task Force for a further the 12 months up until July 2021.

Obesity Strategy

The Strategy also supports the commitments the Government has made in the new Obesity Strategy, namely: legislating to end the promotion of high fat, sugar and salt foods (“HFSS”) by restricting volume promotions such as buy one get one free, and the placement of these foods in prominent locations to encourage purchasing, both online and in physical stores in England; and secondly, banning the advertising of HFSS products on television and online before 9pm. The Strategy recommends holding a short consultation as soon as possible on how the Government can introduce a total HFSS advertising restriction online.

Chapter 3 of the Strategy contains in-depth analysis of the issues surrounding the obesity crisis and the arguments supporting the aligned recommendations of the Strategy and the Obesity Strategy. Particular focus is given to the responsibilities of advertisers in relation to the promotion of HFSS in the context of the health crisis; and the need for Government intervention. Part Two of the Strategy will consider what a systemic intervention in the food

system might look like and how the Government should intervene to improve the UK’s eating habits. This could potentially involve further analysis of some of the other proposals in the Obesity Strategy such as the proposed consultations on the current ‘traffic light’ labelling system and the introduction of calorie labelling for alcoholic products; as well as the introduction legislation to require large restaurants, cafes and takeaways (with more than 250 employees) to add calorie labels to the food they sell.

Comment

Industry has generally been supportive of the views expressed in the Strategy in terms of exercising sovereignty through trade deals that protect high standards of food safety, animal welfare and the environment. Whilst the Food and Drink Federation (“FDF”) has welcomed the recommended measures to increase access and affordability of food for children and families on lower incomes, it is disappointed that the Strategy has endorsed the policies set out in the Obesity Strategy on advertising and promotion of HFSS products. FDF CEO Tim Rycroft stated that “the Government’s own evidence shows these measures combined will only reduce a child’s calorie consumption by 17 calories per day. Such measures will also massively disincentivise manufacturers to bring forward reformulated, healthier options since, in many cases, they will not be able to be advertised or promoted to consumers”.[3]

Part Two of the Strategy, which will introduce a framework to address the integrated food system, is greatly anticipated and is expected to flesh out the headline recommendations made in Part 1. The food and drink sector requires a strategic framework fit for the future that balances competing impact factors including: food safety, legal compliance, sustainability and ethical welfare, positive nutrition, affordability and consumer preference, to ensure the protection of the public and the supply chain. It is perhaps unfortunate that industry will have to wait until next year at the earliest to receive this, adding further pressure to investment decisions in this sector.

[1] The Strategy will predominantly apply to England, as the devolved administrations of Scotland, Wales and Northern Ireland each have their own food strategies. However, trade policy is not a devolved matter, so the trade recommendations would, if adopted, apply to the whole of the UK.

[2] The core standards should be defined by the newly formed Trade and Agriculture Commission.

[3] https://www.foodmanufacture.co.uk/Article/2020/07/29/National-Food-Strategy-Food-industry-reacts