Manufacturers could put forward proposals on promotions, advertising and sugar reduction

Manufacturers could put forward proposals on promotions, advertising and sugar reduction

With suspicion of so-called Big Food at an all-time high, the food industry needs to be proactive in its response to Public Health England's report on sugar. Ben Cooper highlights ways manufacturers could show positive engagement.

The aphorism that if you're not part of the solution, you're part of the problem is often heard in relation to how companies engage on issues of public interest. It may be something of a truism but it is not surprising that, as multi-stakeholder solutions are increasingly being sought to address complex problems, it has become a common way to reflect on industry action.

It is particularly apt and relevant in relation to the current debate over sugar consumption and its relationship to obesity and diet-related health problems. The report published by Public Health England at the behest of the Department of Health makes eight policy recommendations. They each would represent a substantial ramping up of government intervention.

However, while there is much speculation in political circles and in the media as to how the government will react, it is not only the official government response that is being scrutinised.

The Public Health England report is not only advocating a more radical, interventionist approach from government. It is also arguably a comment on the government's approach so far and as its focus to date has been on voluntary action by industry – as represented by the Public Health Responsibility Deal – it is therefore also a comment on the level and effectiveness of industry engagement.

Campaigners are saying so-called Big Food is a big part of the problem, and the Public Health England report has unquestionably added grist to their mill.
Among the prime campaigner demands echoed in the Public Health England report are the call for a sugar tax or levy on soft drinks, official sugar reduction targets and increased controls on advertising and promotion. 

Public Health England is not just another organisation of medical professionals. While it is an operationally autonomous agency, it is nevertheless part of the Department of Health. The department commissioned Public Health England, the role of which is to "protect and improve the nation's health and wellbeing and reduce health inequalities" through "world-class science, knowledge and intelligence, advocacy, partnerships and the delivery of specialist public health services", to conduct this review after the Government's Scientific Advisory Committee on Nutrition (SACN) published its draft report on Carbohydrates and Health in June 2014.

Of course, government-sponsored reports have been ignored or kicked into the long grass before. However, the furore which ignited when it was rumoured the report may not be published suggests the Government will risk significant reputational damage if its response to the report is seen as insufficient.

The intervention of celebrity TV chef Jamie Oliver in the debate ensures greater public and media attention than might have been envisaged when Health Secretary Jeremy Hunt initially commissioned the report. Divining which policy recommendations government might follow up is crystal-ball gazing. While a tax may be more likely than it has ever been in the UK, it would still be a surprising move. If it were to happen, however, it may well be restricted to sweetened soft drinks.

More likely would be increased controls on promotions. Voluntary curbs on promotions were mooted as a possible measure within the Public Health Responsibility Deal. So far, however, the Public Health Responsibility Deal Food Network has failed to come up with a voluntary agreement on promotions but the Government could challenge it rather more forcefully to come up with a solution, stating unequivocally that unless industry participants agree to voluntary controls, mandatory measures will be introduced. Were this to be successful, it would have the added advantage of restoring some credibility to the Public Health Responsibility Deal.

Public Health England's recommendation of a "broad, structured and transparently monitored programme of gradual sugar reduction in everyday food and drink products" could be met within the Public Health Responsibility Deal. Tighter controls on advertising could also be addressed within existing regulatory and co-regulatory agencies.

Given the current rhetoric, the industry's aspirations to be regarded as part of the solution appear something of a vain hope, which is all the more reason for industry advocates to take as positive a position on the Public Health England recommendations as possible. In contrast to a campaign agenda invigorated by celebrity endorsement and affirmed by official government-sponsored research, the food industry's response runs the risk of sounding like a familiar and rather tired mantra. Food companies may still like to insist there are no bad foods, only bad diets but there are signs such traditional industry fallbacks will simply not cut it in today’s environment.

To be fair, the Food and Drink Federation’s official response appeared in a small way to betray that thinking but it arguably did not go anywhere near far enough. 

"We welcome the publication today of PHE's report since all policy-making should be evidence based," the FDF statement read, adding the industry was "determined to play its part in tackling childhood obesity".

The statement then gave a nod to existing self-regulatory measures on advertising junk food to children and the voluntary calorie reduction in food products through reformulation, without addressing the clear inference in Public Health England's report that in both areas current action is insufficient.
While stating its outright opposition to a sugar tax, the statement did appear to make a tentative offer of industry engagement in improving the definition of ‘high sugar foods’ which is another of Public Health England's recommendations.

Overall, however, the statement was fairly predictable. True, the FDF was careful to be respectful to the authority and expertise Public Health England embodies and also to endorse the idea of evidence-based policymaking, and only completely dismissed one of the eight recommendations. It could be said it fulfilled an important requirement in not being overly negative. However, in the current climate – and with public trust in big business and big food arguably at an all-time low – simply sidestepping confrontation is probably not sufficient.

There remains scope for a braver and more ambitious response. Just as Jeremy Hunt will not have to adopt all eight of these proposals, the industry could probably gain considerable reputational capital by making a proactive move on just one or two of the areas highlighted in the report. 

As it happens, they should probably be looking at the same areas the Government may see as most expedient - namely promotions, advertising and sugar reduction. With a change in outlook and greater will, the industry could come up with a self-regulatory solution on promotions, either within or independently from the Public Health Responsibility Deal. Instigating a process to bring that about would be a relatively easy first step and might in itself help with the industry's public image. The industry has opposed the introduction of a sugar reduction pledge within the Public Health Responsibility Deal. Perhaps, in light of the Public Health England report, it might offer to reopen discussion on the issue. 

There are also a host of ways the industry could voluntarily and unilaterally upgrade existing self-regulatory measures on advertising and marketing to children. Industry representatives will no doubt be discussing Public Health England's findings privately with government officials and ministers in the wake of the PHE report. However, in the context of what is now a very public campaign on the sugar issue where food companies are branded as the villains of the piece, the industry needs to show positive engagement on the issue more publicly.