Healthy Food Environment (Wales) – consultation response

In September 2022 we responded to the Welsh Government consultation on Healthy Food Environment.

We welcomed this consultation which looked at ways to improve making healthier food choices.

Our response (in brief)

  • The RCPCH is a member of the Obesity Health Alliance (OHA) and Obesity Alliance Cymru (OAC). The OHA recently published its Turning the Tide strategy, which clearly sets out the impact that temporary price reductions, multi-buy offers and volume offers have on consumer behaviour.
  • It sets out evidence that such offers tend to increase impulse purchases of less healthy food, including high sugar and high calorie snacks; and that consumers don’t save money because of the tendency to purchase more than they had planned, which does not lead to reduced purchases in subsequent shopping trips.
  • There is also clear evidence that where retailers place products in their stores has an impact on how likely consumers are to buy them increasing the visibility of unhealthy foods in busy, eye-catching locations, such as shop entrances or at the end of aisles, leads to an increase in the sale of the product.
  • Childhood obesity is one of the biggest public health issues facing the UK. Obesity increases the risk of developing a range of health conditions in childhood and later life, including heart disease; stroke; high blood pressure; diabetes and some cancers. Obese children are much more likely to be obese adults, which may lead to significant health risks.
  • Pre-pandemic, the data already suggested a huge problem requiring urgent action. In 2018/19, 26.9% of children in Wales were overweight or obese, a higher proportion than England, Scotland or any English region
  • Prevalence of obesity was significantly higher than the Welsh average in the areas of greatest deprivation and significantly lower in the least deprived areas. The gap between obesity prevalence in the most and the least deprived areas has risen from 5.9% in 2017/18 to 6.9% in 2018/19

Our recommendations

  • It would be inconsistent to apply rules differently across different types of retail setting. Turning the Tide notes that: “promotions are available across retail environments of all sizes, including supermarkets, convenience stores, garage forecourts and non-food retailers as well as online, and can increase the total amount of household food and drink purchased by around 20% – in other words, these are purchases that people would not make if the price promotions did not exist.”
  • Our view is that there is a strong rationale for exemptions for products close to their use by date from a food waste and environmental point of view and, especially in the context of the current cost of living crisis, poverty, inequality and food prices.
  • In terms of mandating calorie labelling in all out of home settings regardless of the size of business we note concerns raised by our members and eating disorder specialists and recommend that the Welsh Government continues to consult with eating disorder specialists to understand the impact of this policy and ensure mitigations are in place to protect those with or at risk of developing eating disorders. 
  • The Welsh Government should also continue to monitor and review this legislation with a detailed impact assessment as the policy is implemented.
  • We suggest that labelling is as simple and clear as possible. The most widely used and understood measure of energy in food and drink in the UK is calorie (Kcal) content so we would suggest sticking with that to communicate as clearly as possible with children and families.
  • Given the prevalence of overweight and obesity in children in Wales, parents and carers of children should be provided with calorie information to support them to make informed decisions on food and drink they buy for their children when eating out of home.
  • Considering the evidence highlighted by the OHA that calorie labelling may encourage businesses to offer healthier choices, this should extend to healthy choices for children and young people – encouraging healthier options for children and young people would be a helpful outcome.
  • As with adults, we should be cautious of potential impacts of calorie labelling on children and young people with eating disorders and menus without calorie labelling should therefore be available upon request.
  • The energy (calorie) needs of children and young people will vary significantly with age. Therefore, we do not recommend mandating that menus aimed specifically at children and their parents or carers must provide a recommended daily calorie intake in the way that they might for adults.
  • In terms of mandating businesses to make menus without calorie labelling available at request we would support this as a mitigation to support people with an eating disorder. 
  • Regarding the requirement to display calorie labelling extend to online sales we would consider this to be the consistent approach. Furthermore, the boundaries between online and paper menus are no longer always absolute – it is now common to order via apps or websites in restaurants, cafes and other settings. A consistent approach covering online and paper menus would ensure consumers are given appropriate information to make decisions for themselves and their children.
  • Banning refills of sugary soft drinks would be consistent with wide moves to reduce sugar consumption by children and young people; and to reduce unnecessary excess calorie consumption generally. It would also be consistent with our support for banning the sale of energy drinks to under-16s.
  • Restrictions on larger portion sizes of sugary soft drinks to children and young people in the out of home sector would be consistent with parts of our position on banning the sale of energy drinks to under 16s; and on banning free refills of sugary soft drinks
  • Food provided in schools, colleges, early years and childcare settings; and to children and young people in hospital settings should be nutritious, balanced and contain age-appropriate calorific content. 
  • This should be robustly monitored to ensure that standards are being met and that children, young people and their parents or carers can have confidence in food and drink provided in schools, colleges and other settings.
  • Particularly in schools, children and their parents or carers should be given information on menus and nutritional content, which would be consistent with proposals for the out of home sector to support parents with this information.
  • The Welsh Government should take this opportunity to consider as part of its policy and legislative response to the healthy food environment whether schools and other settings on this list are in compliance with existing guidelines and whether we have robust enough monitoring and reporting to ensure this is consistently the case.
  • In terms of small and medium out of home businesses being covered by both the calorie labelling and soft drink restriction requirements we recommended that all businesses should be covered by these rules to ensure consistency, avoid loopholes and ensure a level playing field.
  • The RCPCH recommends mandatory calorie labelling be introduced for all food and drink, including special and temporary menu items; along with items provided by the business and added by the consumer. This ensures consistency, minimises confusion, reduces the risk of ‘hidden calories’ and supports children and their parents or carers with information to make appropriate food choices.
  • We supported a review of planning and licensing opportunities to create healthier environments in spaces where children and young people come together, including limiting hot food takeaways near schools (within 400 metres). There should be consideration of expanding this to other locations with a high child footfall (e.g. leisure centres, parks, hospitals).
  • We have also called for a ban on advertising, sponsorship and promotion of products high in fat, sugar and salt (HFSS) products in public spaces including sporting events, family attractions and leisure centres with subsequent evaluation. 
  • If a review is taking place with the aim of delivering heathier environments, we would encourage consideration as to whether advertising, sponsorship and promotion could or should form part of that review, given that once the process is concluded it may be difficult to re-open conversations that may require updated policy, guidance or legislation.
  • In considering the scope of policy and legislation on healthy food environments, we recommend that the Welsh Government consider food and nutrition for babies and infants and review commitments made in its Breastfeeding Five Year Plan with a view to ensuring alignment and responding to issues relevant to both Healthy Weight Healthy Wales and the Breastfeeding Five Year Plan.