Memorandum by the British Retail Consortium
(WP 40)
The British Retail Consortium (BRC) represents
the whole range of retailers including large multiples, department
stores and independent shops, selling a wide selection of products
through centre of town, out of town, rural and virtual stores.
In March 2004, the retail sector employed some 2.8 million people
(11% of the workforce) and retail sales were £235.8 billion
in 2003. The retail sector consists of 291,000 enterprises, contributing
an estimated 6% to national Gross Value Added (GVA). Grocery retailing
is significant in macro economic terms and was valued at end 2003
at £113 billion.
As this is a short enquiry, the following response
is in summary form. The BRC would be happy to respond to any questions
the Committee may wish to put if and when oral sessions are held.
Q.1 Will the proposals enable the Government
to achieve its public health goal?
1.1 The overall aim of the White Paper is,
in John Reid's words: ". . . for everyone to achieve greater
health and mental well being by making healthier choices."
This focuses attention on:
— the extent to which consumers generally
are aware of why they should make healthier choices for themselves
and their motivation to do so.
— in the case of diet, the extent to
which those choices are made easier by the actions of food retailers
(and the food industry in general) through their product development,
merchandising, promotions, pricing and communication strategies
and tactics.
— the balance between prescriptive
regulation and self-help incentives in the overall development
of policy in this area.
1.2 Consumer awareness and motivation are
major issues. According to recent research by IGD:
— the majority of consumers have a
reasonable understanding of what constitutes a healthy diet but
61% believe their own diet is currently healthy and only 11% believe
that it is consistently unhealthy.
— in deciding whether or not they are
overweight, most adopt a limited frame of reference, eg comparing
themselves with the average size of the population or their own
circle of friends.
— most see healthy eating as a means
of losing weight, not preventing weight gain.
— a large minority (45%) do not look
for any nutritional information on pack when choosing food.
1.3 Will the White Paper's proposals on
"signposting" help tackle these issues? If we believe
that the main reason why nearly half of all consumers never look
for nutritional information relates to its complexity and their
own lack of time and understanding, then a simple visual "signposting"
system should help them. But while this may well apply to some
consumers, it is very doubtful whether signposting is a panacea
for the lack of motivation noted above. Consumers seek dietary
guidance only if they believe they personally need it.
1.4 A serious objection to a simple, composite
signposting system, ie a colour coding applied on pack combining
the varying levels of fat, sugar and salt contained in the product,
is that it could mislead consumers and discourage them from following
a balanced diet. Many common foods (eg cheese) contain both positive
and negative components which are fine if consumed as part of
a balanced diet. The danger is that someone (presumably the FSA
and/or the manufacturers) will be obliged to make a one-size-fits-all
judgement about the colour coding a particular product should
carry. To the extent that consumers are influenced by the colour
code on the pack, this could (as in Sweden) seriously skew their
diet away from the idea of everything in balance.
1.5 The food industry generally prefers
to continue developing and if possible simplifying the system
of Guideline Daily Amounts, which UK retailers pioneered in the
1990s. The results of the FSA's current programme of testing alternative
signposting models with consumers are therefore awaited with interest.
1.6 In the meantime—and for the foreseeable
future—food retailers will continue to extend their range
of healthy options, particularly in convenience foods, and communicate
the "five a day" message to their customers. The industry
will also pursue its current strategy of gradual changes in the
composition of its standard products. Early last year, the BRC
committed its members to achieving the FSA's target of 6gm of
salt per person per day by gradually reducing the salt content
of thousands of products in nine categories. This programme, which
in some cases began two or three years ago, is based on gradual
reductions over the next few years, as distinct from a shorter
timescale. Gradualism is essential in order that consumers should
not notice a change in the flavour of their usual foods and be
tempted to add salt back when consuming them.
1.7 The next task is to look at how we can
reduce the fat and sugar content of standard and premium products
(ie those not already branded as a healthy option). These two
ingredients are even more fundamental than salt to the recognised
taste and character of many foods and the FSA recognises that
reducing their presence will be a more complex and longer-term
process. Preliminary discussions with the FSA will begin over
the next few weeks.
Q.2 Whether the proposals are appropriate,
will be effective and whether they represent value for money
2.1 The appropriateness of the proposals
depends on how you define the problem they are meant to resolve.
The emphasis in the White Paper on continuing consultation with
the food industry is welcomed and contrasts with some earlier
ministerial statements which implied a more adversarial approach.
At the risk of stating the obvious, food retailers want their
customers to eat sensibly, take exercise and live long and healthy
lives—if only so they can go on shopping. Contrary to the
views of certain conspiracy theorists, healthier options are not
inherently less profitable than other products. The food industry
as a whole has a critically important part to play in any strategy
designed to halt and reverse the current imbalance between energy
input and energy output. But, as the White Paper recognises, many
other actors have to be involved as well.
2.2 One disappointing aspect of the White
Paper is its failure to grasp the need for a major and sustained
national media campaign aimed at the 61% of the population who
apparently believe their diet is healthy enough as it is. Last
year the major parties in the food supply chain (NFU, FDF, BRC,
BHA) made a proposal to the DoH and separately to the Prime Minister
for such a campaign in which the food industry would play its
part. Drawing on our experience with "five a day" and
other campaigns, we believe that the frequent repetition of one
or two simple messages, communicated with dramatic visual aids,
is the only way to get through to a resistant or indifferent audience.
Recent anti-smoking media campaigns provide useful examples. Instead,
however, the White Paper seems to envisage a plethora of smaller
scale, more fragmented campaigns which the DoH believes the food
industry should help fund. This is unlikely to evoke a positive
response.
2.3 The White Paper also lacks clarity on
measures of success and timescales. In his introduction, John
Reid says that success will be measured "first, in the increased
number of healthy choices that individuals make, and then in the
lives saved, lengthened and improved in quality". The difficulty
here is that many of the social and lifestyle changes which are
driving the growth of obesity and related health problems have
been gradually gaining momentum over the past 30 years or more
and are not going to be halted, let alone reversed, in a hurry.
While there is clearly a strong temptation, especially in an election
year, for ministers to focus on quick wins and headline-grabbing
"initiatives", these will have little or no effect on
the problem.
Governments have been campaigning against smoking
for over 40 years, aided by heavy excise duties, a large and growing
number of smoke-free places to eat, drink, travel and be entertained,
and dramatic "smoking kills" warnings on labels. Yet
smoking remains fashionable among many teenagers and is still
common in lower income groups.
2.4 Experience with decades of anti-smoking
campaigns underlines yet again that most consumers are more responsive
to communication which encourages them to do something positive
than they are to messages which try to prevent them doing something
they would otherwise like to do. IGD research suggests that:
— Many consumers equate healthy eating
with dieting (ie weight loss), which they in turn associate with
self deprivation.
— The diet industry now offers so many
alternatives, some contradictory, that consumers are understandably
confused about which one is suitable for their own needs.
— Many consumers start weight-loss
regimes only to drop them after two or three weeks because they
fail to deliver rapid reductions in weight and they are often
bland, rather boring substitutes for "real" food.
2.5 The conclusion is that food is for most
people a source of pleasure. This is why we believe the basis
of future strategy must lie squarely in the concept of a balanced
diet, backed by sensible exercise designed to get energy input
and output back into balance.
Q.3 Will the necessary public health infrastructure
and mechanisms exist to ensure that proposals will be implemented
and goals achieved?
3.1 The food industry now has a well-established
but vigorous relationship with the Food Standards Agency. We also
have parallel discussions with DG Sanco. It would be helpful if
a clearer demarcation line could be drawn between the roles of
the FSA and the DoH respectively in this area of nutrition and
health. On several occasions over the past year, it has seemed
to the industry that these two agencies were in conflict over
the same nutritional territory.
3.2 Beyond the existing arrangements, it
might be useful if a national forum on health and nutrition could
be put in place to review progress towards achieving whatever
targets emerge from the Action Plan and discuss best practice.
The DTI has already introduced several bodies of this kind, eg
for retailing, the motor industry and chemicals, and Defra is
considering a similar initiative. The advantage is that they bring
all the major interested parties round the table to discuss upcoming
regulatory issues and help to develop shared understandings and
commitments. This model is worth further consideration.
January 2005
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