Hungry for change: fixing the failures in food Contents

Chapter 4: The food environment

152.The food environment encompasses every factor which could affect an individual’s food choices. It includes, but is not limited to, the physical presence of different types of food outlets and the physical layout of outlets, the marketing and advertising of foods, and the information provided to consumers.

153.Witnesses emphasised the power of the food environment in influencing consumer choices. Alex Holt, Programme Lead at Food Active, described the need to ensure that: “We have healthier places to live”.222 Mark Laurie, Director of the Nationwide Caterers Association, summed up the power of the food environment on food choices and posed a challenge to change it:

“People eat what is in front of them that day. You need to put an option in front of them. People do not choose unhealthy food out of spite; they choose it because that is what they know, that is what they can afford and that is what is in front of them.”223

154.We heard repeatedly that the current food environment is set up in such a way as to encourage people to make less healthy choices, and that this is largely due to the fact that less healthy choices are simply more profitable for the food industry. We also heard that additional factors contribute to an unhealthy food environment, including that:

The value and implementation of two Government food programmes designed to address food related inequalities—Healthy Start vouchers and the free school meals programme (FSM)—are inadequate;

Aggressive and highly effective marketing techniques employed by the food industries including advertising, product placement and price promotions have a profound effect on consumer choice;

There is a proliferation of fast food outlets, particularly around schools and in deprived areas; and

Ineffective and confusing labelling means that consumers are not armed with the information they need to choose healthier options.

155.Our witnesses were very clear that changing the food environment would require concerted effort from Government, but that action had not yet materialised.

An in-built system failure

156.We were told that there is system failure at every level. At the level of the food environment, as at others, there is a systematic and commercial incentive for manufacturers and the retail and catering industries to produce and sell food which has a detrimental impact on public health.

157.Clearly, companies aim primarily to make profit. There is a competitive incentive to add value at every stage of the production and retail process. Processing food, attractive packaging, marketing and promotions are all part of the ‘marketing mix’ which is key to adding value to raw ingredients. Tom Andrews from Sustainable Food Cities highlighted the increased profit margins that can be made on processed foods as compared to primary produce: “The whole basis of the food industry is predicated against low-processed food. There is no money in selling a head of broccoli. There is money only in high-level processing, which is about value added, and in very significant packaging, because it is about selling.”224

158.That profit is the key driver of the food industry is economically obvious—but this is generally achieved through selling less healthy food. The Food Foundation has suggested that: “46% of food and drink advertising goes on confectionary, sweet and savoury snacks and soft drinks; while only 2.5% goes on fruit and vegetables.”225 Similarly, there is a highly uneven spread of product price promotions and prominent product placement on less healthy products.

159.The food environment actively and effectively encourages unhealthier choices because there is a powerful commercial incentive for the food industry to ensure that people purchase highly processed products.

160.There are some examples of excellent industry behaviours, but these are largely based on competitive advantage and appear to form the minority. Tom Andrews talked about the Food for Life catering mark which encourages caterers to provide better quality because: “it gives them a point of difference”.226 Clearly, this possible advantage is not currently working at scale, but it is encouraging.

161.Professor Jebb told us that there was a market failure: “a failure in food delivering for health, food delivering for social justice and food delivering for the environment. What that does is to make the case for some substantive intervention by government in the system.”227

Experiences of the food environment

162.We were told, throughout our inquiry, that interactions with the food environment produce different effects for different groups, and that some groups are particularly adversely affected by factors within the food environment. That is to say, the negative effects of the food environment are socially distributed and can contribute to poorer health outcomes and health inequalities.

163.We received evidence, for example, that advertising, product promotions and food outlets selling fast food have a disproportionate effect on lower income groups. George Butterworth, Senior Policy Manager at Cancer Research UK, referenced research that found:

“teams from the most deprived families were 40% more likely to remember junk food adverts every day, compared with teams from better-off families. Food advertising in the UK disproportionately featuring less healthy food items could, therefore, play a role in increasing health inequalities.”228

164.We were also told that outlets which largely sell less healthy food are likely to be concentrated in lower income areas. Dr Vogel told us that in one lower income area in Hampshire: “For more than 2,000 food outlets we mapped, we found that 43% were fast-food outlets and independent takeaways. Big and small supermarkets made up only 11.5% of the area, and healthy specialty stores such as greengrocers made up only 6.5%.”229 Tom Andrews linked this to the incidences of health inequalities and food insecurity: “health inequalities and the incidence of food poverty map perfectly on to income inequalities, if you look at a map of the UK. They also map on to the distribution of fast-food outlets and takeaways.”230 It is self-evident that if these outlets are more concentrated in more deprived areas, consumption of these foods will be higher in these places.

165.The food environment has a substantially more negative impact on lower-income groups than their wealthier counterparts, and therefore directly contributes to rising health inequalities.

Measures to address the food environment

166.The Government’s policy on the food environment is largely contained in Chapters one, two and three of ‘Childhood Obesity: a plan for action’. This plan sets out the different measures intended to halve childhood obesity and reduce the gap in obesity between children from the most and least deprived areas by 2030. The plans contained a number of measures aimed specifically at changing the food environment to support healthier choices. Chapter One was published in 2016,231 Chapter Two in 2018,232 and chapter three in 2019.233

167.Measures outlined in the Childhood Obesity Plans have included: out of home energy labelling, restrictions on location and price promotions, advertising restrictions on products high in fat, salt or sugar (HFSS) and an extension of the Healthy Start voucher scheme.

168.The final report of the former Chief Medical Officer, Professor Dame Sally Davies, ‘Time to Solve Childhood Obesity’, sets out a range of evidence-based interventions to address childhood obesity. She called on policy makers to take action to ensure that children:

have access to healthy and affordable food,

are protected from marketing of unhealthy foods, and

have the opportunity to run, bike and play safely.”234

This report welcomed the Government’s proposals for change, calling for full implementation, but argued that more action was required to meet the 2030 ambition to halve childhood obesity. Throughout our report, we have taken the same view.

A critical consensus

169.Our evidence was overwhelmingly of the view that while the steps proposed by the Government in their action plans could have value, they were, as proposed, insufficient. There was also scepticism of the Government’s commitment to implementing them, with witnesses citing inaction and a plethora of long-closed consultations.

170.There was a clear consensus that Government action in this sphere had been limited. Kate Halliwell, Head of UK Diet and Health Policy at the Food and Drink Federation, said that: “there have been a lot of announcements and not necessarily the follow-through from those announcements”235, and Dr Hilda Mulrooney, Associate Professor in Nutrition at Kingston University said on behalf of the Obesity Group of the British Dietetic Association that: “We are stuck in a limbo land”.236 We agree entirely.

171.Proposals in the obesity plan were generally welcomed, so far as they go. There was agreement across our evidence that the Government is working along the right lines, but that its proposals neither go far enough, nor are being progressed quickly enough. Professor Jebb reflected the position of the large majority of our evidence:

“the Government are talking really tough on obesity and there is lots of discussion, and that is good, but it is not enough. Action is still far too slow. Most of the childhood obesity plans have said, “We will consult on”, “We will discuss”, “We will consider”, or, “We will think about”. Many of those consultations have been out and closed months and months ago. There is simply no apparent sense of urgency… All the things they have done are good, but they are not nearly enough, and they are not being done at a pace and with a sense of urgency that is anywhere near the scale of the challenge.”237

172.Several witnesses expressed frustration at the number of closed consultations where the Government had not yet published a summary of responses. Written evidence from the Ministers said that “we will be setting out our responses as soon as we can”.238 Jenny Oldroyd, Deputy Director of Obesity, Food and Nutrition at the Department of Health and Social Care, explained that some of the delay is due to processing times for consultation responses:

“We have had over 6,000 responses to the consultations on national policies. To be clear, that is not campaigns, so those are not responses where we can tick off a few hundred as one part of the campaign; they are responses that engage with the detail of the impact assessments that we have put out.”239

173.As illustrated by the table below, a number of proposals contained in Chapter 2 of Childhood Obesity Plan, announced in July 2018, have not (at the time of publication) progressed further than consultation stage.

Table 1: Progress of proposals in Chapter 2, Childhood Obesity: a plan for action (July 2018)

Policy measure

Progress (June 2020)

Calorie reduction programme

No further reports published since the programme’s initial scoping document was published in March 2018.240

Ban of the sale of energy drinks high in caffeine to children

The consultation closed 21 November 2018.241

Out of home energy labelling

The consultation closed 7 December 2018.242

Location promotions and price promotions

The consultation closed 6 April 2019.243

Advertising (reducing children’s exposure to advertising of HFSS products on TV and online, including 9pm watershed)

The consultation closed 10 June 2019.244

Updating the School Food Standards to reduce sugar consumption

The consultation closed 13 August 2019.245

174.We share our witness’s scepticism of the Government’s commitment to the measures that have already been published as proposals. Chapter three of the Childhood Obesity Plan, rather than being published as a separate document, was embedded within a separate consultation document: ‘Advancing our health: prevention in the 2020s’.246

175.Jo Churchill MP, the DHSC Minister for Prevention, Public Health and Primary Care, provided further proof of the lack of commitment to advancing the measures outlined in chapters one, two and three of the Childhood Obesity Plans. She suggested that work on progressing consultations had been delayed by the impact of COVID-19. When asked, however, what she would have done in the absence of the outbreak, she pointed to yet another consultation (on the marketing and labelling of infant food), an evaluation (of the Trailblazers programme), and work on the out of home labelling consultation, which closed in December 2018. She said that: “there is so much to do in this space… much of it is just sitting there, ready for us to get going with it”.247 We recognise the substantial personnel redeployment that has been required as a result of COVID-19, but this work has been ready for some time: at the time of this report the scoping document for the calorie reduction programme was 27 months old.(See Table 1) Action, including on the recommendations outlined by the former Chief Medical Officer, Professor Dame Sally Davies,248 should have already been taken.

176.The failure to enact proposals to tackle childhood obesity has meant that levels of obesity and diet-related ill health have continued to rise. The glacial pace at which the Government has acted upon its own proposals to tackle childhood obesity is unacceptable.

Suggested interventions to improve the food environment

177.A series of interventions were suggested throughout the inquiry that would address elements of the food environment. Some of these would extend proposals made by the Government, others are separate proposals. These included:

Extension, increased funding and more effective implementation of the Healthy Start scheme, the free school meals (FSM) programme and the Holiday Activities and Food programme;

Encouraging the uptake of healthy and sustainable food through public procurement;

Restricting and reducing the advertisement of HFSS foods;

Limiting the impact of product promotions and product placement of less healthy foods in supermarkets;

Strengthening local authority powers to limit the proliferation of fast food outlets;

Making changes to nutrition labelling; and

Increasing and improving the education and public health messaging on healthy diets.

Further detail on each of these proposals is set out below.

Government food programmes

178.It was apparent that three key national food programmes were not fulfilling their potential. Free school meals, the Healthy Start programme, and the holiday activities and food programme aim to increase access to food for people on lower incomes, the first by providing meals for pupils from lower-income families, the second by issuing vouchers to enable parents on lower incomes to purchase healthy food for young children, and the third by preventing holiday hunger.

179.Anna Taylor pointed to the “critical role” the Government have through its food programmes to tackle dietary inequalities. She argued that they are, on paper, good programmes but that: “there are huge areas of policy that are being implemented badly and where there are gaps”.249 On examination, we found several particular areas of concern which, if addressed, could go a long way to improving children’s health. The need to ensure that Government food programmes enable families to access healthy food was reinforced by the evidence provided to us by the Minister for Public Health, Jo Churchill MP, who stated that “One in 10 children enters primary school obese, and that rises to one in five by the time they leave”250 The adage that prevention is better than cure is emphasised in the report of the former Chief Medical Officer Professor Dame Sally Davies who wrote:

“Today’s children are tomorrow’s workforce and the parents of future generations. Their health will be a deciding factor in whether the UK is healthy and prosperous in the future … If we act now to preserve their health, this ‘country of children’ could provide a future ‘demographic dividend’. So, there is a strong economic case for more action to tackle childhood obesity.”251

The Healthy Start Scheme

180.Healthy Start’s website says that the scheme: “helps you give your family the very best start in life”252. The Healthy Start programme is a means-tested scheme which provides vitamins and vouchers to some parents of young children to help buy some basic healthy foods. The vouchers can be exchanged for milk, fruit or vegetables, and (depending on the age of the child) are worth either £6.20 or £3.10 per week. The principle of the scheme was widely welcomed in our evidence and there was mention of its potential to reduce health related inequalities. It was well described by one of our contributors as: “a basic, nutritional safety net for pregnant women, infants, and children in low-income families”.253 The model is sound, and forms the basis of the charitable Alexandra Rose scheme, which distributes vouchers of similar value to be spent on fruit and vegetables at local markets to families eligible for Healthy Start.254

181.We were made aware of some significant failures undermining the scheme’s potential. These factors were listed by one academic review of the scheme which identified: “erosion of voucher value relative to the rising cost of food, lack of access to registered retailers and barriers to registering for the programme”.255


182.The value of the vouchers is perhaps the scheme’s most concerning deficiency. They are currently worth (depending on the age of the child) either £6.20 or £3.10 per week. We were told that the value of the vouchers, which are not linked to inflation and have not risen since 2009, is far too low. It was described by Shirley Cramer, Chief Executive of the Royal Society for Public Health as: “a tiny amount”.256 It was suggested that this does not even cover the basics: we were told that it does not cover the current costs of infant formula.257

183.The Government has told us that the value of the voucher is kept under continuous review.258 While sensible additions have been made to the list of products one can buy, and to how the scheme works, the fact remains that the value of the voucher has not changed since 2009, and so its value in real terms has decreased. If linked to inflation, at an average of 3.1% per year between 2009 and 2019, the vouchers would now be worth either £8.37 or £4.18 per week; a sizeable difference from the current amount of £6.20 or £3.10.259 Healthy Start’s website says that the scheme: “helps you give your family the very best start in life”. £3.10 per week does not seem sufficient to meet this objective.

184.The value of the Healthy Start vouchers is insufficient. The vouchers must immediately be uprated. This uprating should be substantial, but as an absolute minimum it should enable recipients to purchase the same amount of food that could be purchased in 2009, when the scheme began. The amount must be linked to the Consumer Price Index thereafter.

Eligibility and take-up

185.Healthy Start vouchers are means tested and to qualify, families must be in receipt of social benefits and/or have a family income of £16,190 or less.(all pregnant women under the age of 18 qualify regardless of income or benefit status).260 We were told that eligibility has: “Declined by 30% since 2011 with less than half of children in poverty meeting the criteria”.261 This is extremely worrying and warrants a thorough review.

186.In January 2018, take-up was 66%, a decline of 14% since 2011.262 In 2019, it was 64%, with at least 135,671 eligible families not applying for Healthy Start vouchers.263 Reasons outlined by a series of reports for this low take up rate point to difficulty registering due to complicated application and acceptance processes, a lack of clarity about the scheme, and difficulty engaging with it.264

187.Nicky Dennison, Public Health Specialist at Blackpool City Council, explained that uptake is poor: “because of the bureaucracy that clients and our population have to go through. They have to complete forms and show proof, which they do not always have with them when they come.”265 Dr Katie Cuming, Public Health Consultant at Brighton and Hove City Council, said that: “It is nearly always the logistics of getting the health professional to sign the form and the fact that the vouchers arrive by post”.266

188.Our witnesses echoed the reports of the First Steps Nutrition Trust267 and Feeding Britain268 on this subject; the best way to increase take-up of this scheme is to remove the levels of bureaucracy. Public health professionals working in local authorities expressed a strong desire for a system that was: “easier to administer… the need to get the health professional’s signature and the fact that paper vouchers arrive, particularly in buildings or houses that are communal, is a very difficult way for families to do it… Any of those barriers being removed would be great.”269

189.In addition to the sensible additions the Government has made to what one can buy, we welcome the Government’s commitment to digitising the vouchers. We await reports on how effectively this will: “offer greater convenience and flexibility”270 in using the vouchers, but caution that reform of the application process is equally essential.

190.There was a strong argument for raising awareness of the scheme at both local and national level as a lack of awareness was repeatedly cited as a key challenge in implementing it effectively.271 The University of York IKnowFood Programme called for increased promotion of the scheme for recipients,272 and the Association of Convenience Stores also raised the issue of awareness among independent retailers, only a third of which engage with it.273


191.It appeared to us that everyone well acquainted with the scheme recognised its limitations. A joint submission from Church Action on Poverty, the Food Foundation, Nourish Scotland, Oxfam and Sustain said that: “Improving the scheme requires expanding eligibility criteria, starting with those on Universal Credit, increasing the voucher value, and introducing a programme to ensure all those who are eligible benefit.”274 This is a long list of changes and we are inclined to agree with evidence from First Steps Nutrition Trust which argued that: “numerous difficulties with the scheme mean it needs root and branch reform”.275

192.It appears that the Government has recognised these concerns. In Chapter 2 of the Government’s Childhood Obesity Plan, the Government committed to consult on plans to use Healthy Start vouchers to provide additional support to children from families on lower incomes.276 This consultation has, as of June 2020, yet to appear. In response to a parliamentary question, Jo Churchill MP, Parliamentary Under-Secretary at the Department of Health and Social Care, stated that the Government has postponed the consultation until after the UK’s exit from the European Union, but is “considering a range of options” for consultation.277 We have been told that work is underway to: “make it easier to apply for the vouchers and easier to spend the vouchers in store”.278 This work includes digitising the vouchers and extending the range of products which can be purchased with them: it has preceded the delayed consultation, and will not address the value of the vouchers.

193.As it stands, the Government is two years behind on its commitment: it seems that it is consulting on how to consult on its plans to reform the scheme.

194.Comprehensive reform of the Healthy Start Scheme is long overdue. The Government must release a wide-ranging consultation addressing “root and branch” reform before the end of 2020 and appoint a Healthy Start champion to raise awareness of the scheme among individuals and retailers.

Free school meals

195.In England, the Government provides free school meals (FSM) to primary and secondary school pupils who qualify through receipt of some benefits.279 All infant students (from reception to year two) are entitled to free school means under Universal Infant Free School Meals (UIFSM). Serious concerns were raised with us about these schemes and their implementation, including concerns about eligibility criteria, adherence to standards, and the low value of the meals grant to schools. Two witnesses also raised serious concerns about unclaimed money “going missing”.280 Anna Taylor described the operation of FSM as: “bad implementation of what on paper is a good programme”.281

Box 7: Experiences of food insecurity

In a series of phone calls, facilitated by Sustain and Church Action on Poverty, the secretariat spoke with individuals who have experienced food insecurity. Penny from Newcastle said:

“They roll out the free school meals for the kids but then I’ve had families come to me and ask me if I can print those vouchers out because that’s the only way that they will get their vouchers to go to the shop to actually access the free school meals. If you don’t have a printer at home, that’s another barrier.”

Source: See Appendix 5.

196.Following the COVID-19 outbreak, the Government issued guidance which states that schools are expected to continue to provide support. It outlines different approaches that could be taken through food parcels from existing providers. Where current provision cannot be extended in this way, the Department for Education has developed a centrally funded voucher scheme to be used at supermarkets.282 At the time of writing, the Department was unable to confirm how many vouchers had been delivered in a useable form, or how many eligible children had been registered.283


197.Since 2011, school meals (except UIFSM) have been funded through central funding for schools (the Dedicated Schools Grant).284 It is for the schools to make their own decisions about the use of this funding. UIFSM, which encompasses 1.5 million infants in England285 is funded by a separate grant under the Education Act 2002.286

198.To cover an anticipated increase in the number of pupils eligible for FSM “before the lagged funding system catches up”287 the Government issued a school-level meal cost grant for the 2018–19 and 2019–20 academic years. This is, annually, £440 per additional pupil, or £2.30 per day.288 It was made extremely clear to us that this amount of money is insufficient, both for the schools, and for the children.

199.Schools often allocate this money to pupils themselves via a card payment system, allowing students to choose what they spend the money on. Research by the Child Poverty Action Group has found that, often, the value does not cover the cost of a full meal:

“When you talk to children in schools, they tell you that it is not enough to buy a full meal with: it will buy you a main course and a drink or a pudding and a drink, but you cannot get all three. So, while other children around you are having the lot, children on free school meals are not; they are having a very reduced calorie intake by comparison”289

The Government’s written evidence stated that it was supportive of schools which made the same meal offer available to all students. It agreed that this was important, both for reasons of nutrition and social wellbeing.290 Our evidence suggests that schools are not always achieving this: it is important that the Government remain committed to ensuring that all pupils, regardless of household income, can access nutritious food at school.

200.The National Voucher Scheme was set up to provide money for food during school closures to parents whose children would ordinarily receive free school meals. The value is £15 per child per week, as opposed to the £11.50 which would ordinarily be paid to the school. This appears to be the Government’s assessment of the cost of providing five lunches. Funding must remain at this rate. In anticipation of the response that schools can benefit from economies of scale where parents cannot, it is likely that this is more than outweighed by the costs to the school (and not to the parent) of staffing, equipment, facilities and transport. The funding provided by the Government to cover free school meals does not appear to fulfil the costs to the school of providing them. This is supported both by a report from the IFS and a leaked 2016 report commissioned by the Government, both of which found that there is pressure on school’s budgets.291

201.The decision to increase the funding for lunches during school closures is welcome. The value cannot be allowed to regress once children return to school. The allowance allocated to schools for free school meals must be uprated to at least the level provided during the school closures and linked to inflation thereafter.


202.In primary schools, 15.8% of pupils are known to be eligible for, and claiming, free school meals. In secondary schools, it is 14.1%.292

203.Prior to April 2018, all claimants for Universal Credit were eligible for FSM. This was changed in 2018 to target those households with a net annual income of below £7,400 or who are on some of the legacy benefits. It has been found that under these proposals, slightly more children from low-income households will be eligible under the UC system—an increase of 50,000 children.293

204.There will be, however, a significant number of children excluded who would previously have been eligible. Though there are protections in place for existing claimants until Universal Credit is fully rolled out, the IFS study found that “About 160,000 (13%, or 1 in 8) of the 1.3 million children who would have qualified under the legacy system will find themselves ineligible under UC.”294

205.There was some concern that the eligibility criteria for FSM are too tight, excluding many who need this support. Alysa Remtulla, Head of Policy and Campaigns at Magic Breakfast, stated that: “the current eligibility criteria are becoming an increasingly unreliable determinant of need”.295 This is supported by a review by the Institute for Fiscal Studies (IFS) which found that under the Government’s plans: “only about half of children in the poorest fifth will be entitled to FSMs.”296

206.We recommend that the Government outlines how it intends to mitigate the impact that their eligibility proposals will have on those families who will lose eligibility for free school meals.

207.There have been some calls for free school lunches to be extended to every child.297 Dr Mary Bousted, Joint General-Secretary of the National Education Union, stated that a policy of universal free school meals would “end what our members report as the stigma for children who get free school meals.”298

Box 8: Experiences of food insecurity

In a series of phone calls, facilitated by Sustain and Church Action on Poverty, the secretariat spoke with individuals who have experienced food insecurity. Tia from Blackburn with Darwen said:

“Because it was such a small school, everyone was friends with each other but I never wanted to use my free school meals because sometimes you had to go in with a massive pink slip to get them and I just felt too embarrassed so I sometimes got my mum to put money on my card so I could use that instead.”

Source: See Appendix 5.

208.Witnesses cited evidence on the impact of UIFSM, which has generally been positive, to argue for extending school meal eligibility criteria. Professor Defeyter stated that: “The take-up in that scheme has been phenomenal, and all the research reports suggest that it has reduced the stigma. More importantly, it is teaching our children good skills around what they consume”.299 An evaluation of UIFSM published in January 2020 also pointed to positive health outcomes. The study found that: “those exposed to UIFSM have significantly better bodyweight outcomes then they otherwise would, in terms of being more likely to be [a] healthy weight (1.2 percentage point by the end of the school year), less likely to be obese (0.7 percentage points) and have a lower BMI”.300

209.The use of evidence currently available as a basis for extending FSM is problematic. The witnesses advocating for extended entitlement of FSM acknowledged that the research on the impact of UIFSM had been somewhat limited. Professor Defeyter acknowledged that the research around UIFSM is “patchy” and that there had not been “proper modelling”.301 This was reinforced by an IFS report costing Labour and Liberal Democrat election pledges to extend school meal entitlement. It outlined some weaknesses in the evidence base, concluding that while there had been some research to indicate a link to attainment: “It’s not yet clear whether these policies would have big further benefits for children’s attainment or health.”302

210.There has been some study on the cost implications of different proposals to extend eligibility for FSM. In the 2019 general election, the Labour party initially proposed extending free school meals to all primary school children. The IFS estimated that, in 2024, this proposal would cost £850 million in today’s prices.303 A proposal by the Liberal Democrats (and later the Labour party) to extend FSM to all secondary school pupils whose family receive universal credit was estimated at costing between £280 million and £310 million. Coupled with the cost of universal primary free school meals also proposed by the Liberal Democrats, this could cost between £1.1 and £1.2 billion.304

211.We fully agree with Professor Defeyter’s view that the high costs of extending FSM have to be offset with the longer term gain305 but there has not been sufficient modelling of the impacts of FSM to establish what the longer term gain would be.306 We cannot yet recommend it on the basis of long term health benefits.

212.We recommend that the Government must undertake rigorous research on the impact of Universal Infant Free School Meals on health and attainment outcomes and use the results of this evidence base to inform future policy on school meals, including breakfasts.

Missing money

213.One financial concern was raised by Anna Taylor and Professor Defeyter, who drew our attention to money for FSM that was: “going missing”.307 When pupils miss a day of school, or for some other reason do not use the money on their cashless lunch card, this money is not returned to the child.

214.Anna Taylor referred to this money being taken from the child and: “absorbed into the coffers.”308 Referring to a study she had conducted with Feeding Britain, Professor Defeyter told us that: “there is approximately £88.3 million per annum in the system going missing. Nobody, including the DfE, seems to quite know where that money is.”309 No information is collected by Government on this matter.310

215.Sarah Lewis, Director, System Leadership and Strategy (Early years and schools) at the Department for Education, said that recuperating and redistributing this money was a decision for school administrations:

“Schools have the ability to give that money back to the children if they wish. We do not say they have to because free school meals are not a cash benefit for that individual child. It is money overall that is given to schools so they can ensure that children can access free school meals while they are in school. It is just set up in a different way.”311

216.It is not possible to exclude the possibility that some of the funding may therefore be lost to schools. Many schools have financial arrangements with the local authority, or with private caterers to provide school meals. The estimates we heard vary from £70 million312 to £88 million,313 but whatever the true figure, it is something which the Government should investigate further.

Adherence to food standards

217.Following an independent review of school food, revised school food standards came into force in January 2015. These standards apply to all food served in maintained schools,314 including food made in and out-of-house.315 We have been told that, without enforcement, the school food standards are in practice, voluntary, and that this undermines the intentions of the regulations.

218.The school food standards and accompanying guidance documents are intended to help children develop healthy eating habits and ensure that they get the energy and nutrition they need for the school day.316 The food-based standards specify “which types of food should be served at school, and how often.”317

219.The standards mandate provision of some healthy foods and stipulate a list of less healthy foods to avoid.318 There is no mention of the Government’s Eatwell Guide, but the standards recommend that schools purchase food according to the Government Buying Standards for Food and Catering Services (GBSF).319

220.Ms Lewis from the DfE told us that the Department was revising and updating the school food standards.320 It is unclear on what basis the Department is doing so; a consultation that had been announced in 2016, in Chapter 1 of the Childhood Obesity Plan321, and subsequently re-announced in Chapter 2322 (2018), has not yet been published.

221.The responsibility to ensure these standards are being met falls to school governing bodies for whom the Department for Education (DfE) has published guidance. These standards are mandatory for all maintained schools, pupil referral units and non-maintained special schools in England. Adherence is an explicit requirement in funding agreements for academies and free schools founded before 2010 and after June 2014.323

222.A critical weakness identified by several of our witnesses is that there is no mechanism or enforcement body to ensure that school food meets the required standards. Sarah Lewis confirmed that the Department does not monitor or enforce the standards: “No, we do not proactively go round and check whether schools meet the school food standards.”324

223.The Department appears to rely on parents to complain if they feel their child’s school is not meeting the requirements. Ms Lewis explained that they: “Rely on our regulatory system and we want parents to complain to us if they feel that schools are not meeting their statutory responsibilities.”325 The Government says that the standards were designed to be easily understood and that complaints should come through the school in the first instance.326 We feel this lacks an understanding of the real world practical scenario where parents may not feel able to challenge the school, nor have the available time and ‘emotional bandwidth’ to embark on a complaints process.

224.As a means of enforcing standards, reliance on parents is highly problematic for several reasons. Firstly: there are instances of what Anna Taylor termed: “information asymmetries”.327 Parents are not in a position to address nutritional standards which they may or may not be aware of, or be able to access information about–and this is a highly specialised task. Secondly, and more importantly, this places an inappropriate burden on parents to seek information from the school and report to the Department as to whether the Government’s own standards are being followed. As a means of enforcement, this is patently unfit for purpose, further evidenced by the Government’s admission that, to date, no action has been taken following a complaint made in this way.328

225.The guidance for governing bodies has no statutory footing and is thus inappropriate as a means of enforcement. Without a mechanism to monitor food provided in schools, there is no way to ensure schools are meeting the required standards. Alysa Remtulla, Head of Policy and Campaigns at Magic Breakfast explained: “The biggest challenge that we see is the lack of monitoring of the standards. Because of that, they are not necessarily enforceable. There is no watchdog or body that monitors how the standards are implemented.”329

226.It is a demonstrably ineffective approach. Witnesses highlighted a wide variation in school food standards across schools, which effectively amounts to a postcode lottery for nutritional standards. Nicky Dennison, Public Health Specialist for Blackpool City Council, expressed frustration with a lack of enforcement and provided figures for Blackpool: “ … across our 33 primaries; 11 schools meet the school food standard and the others do not.”330 Such a stark fluctuation of standards across England leads to children receiving widely variable standards of nutrition. Worryingly, since there is no enforcement mechanism or reviewer: we cannot estimate the scale of the problem.

227.We were made aware of some potential mechanisms to monitor food standards. The Local Authority Caterers Association (LACA) suggested that Ofsted, the education standards body, could play a role. They advocated for the inclusion of: “Enforcement and monitoring of the School Food Standards across all schools including academies and free schools, inclusion of the school food offer and food education programmes into Ofsted inspections’331Dr Mary Bousted, Joint General-Secretary of the National Education Union, however, felt strongly that monitoring should be specialised. In support of the need for an inspection process she stated: “If we look at food standards in schools, this should be done by people who know something about food standards. We cannot require Ofsted inspectors to be nutritionists and food standards experts as well.”332

228.The absence of any effective enforcement mechanism for school food standards means that the nutritional value of the food a child receives at school is one of chance rather than policy. It is difficult to understand what, in truth, the school food standards achieve.

229.Monitoring and evaluation of the school food standards must be centrally coordinated to ensure consistent compliance. The Departments for Education and Health and Social Care should establish a joint task force responsible for monitoring and enforcing adherence to the school food standards. The taskforce should have the power to publish the names of non-adhering schools and where necessary require the development of an agreed action plan to meet standards.

School breakfasts

230.Some evidence advocated for increased support for breakfast clubs in deprived areas. Breakfast clubs, which are run in schools and sometimes with private sector involvement, can provide a nutritious breakfast for children who may not otherwise eat breakfast. There is some research to demonstrate that an extension of the Government’s National School Breakfast Programme (NSBP) could provide health and attainment benefits to children from lower-income households.

231.In November 2018, the Government announced a new aim to “improve breakfast for pupils in more than 1,700 schools by 2020.”333 The National Schools Breakfast programme (NSBP), which is implementing this pledge, is a Government-third sector partnership to provide free breakfast clubs for children in the most disadvantaged areas and is funded by up to £26 million. As of January 2020, 1800 schools were participating in the scheme.334 In that month, the funding was extended to last until March 2021, and there was additional funding announced to recruit up to 650 new schools.335

232.Magic Breakfast, one of the third sector delivery groups for the programme, explained that the purpose of the scheme was to ensure that no child is too hungry to learn:

“A hungry child cannot concentrate on their lessons and misses out on hours of valuable learning. That means they fall behind their wealthier peers and that contributes to the educational attainment gap … Very strong evidence demonstrates that school breakfasts can play an important role in addressing this.”336

233.There is some evidence to suggest an attainment gain in schools which provide universal free school breakfast clubs. A study conducted by the IFS has indicated that pupil absences fell, and that some children made the equivalent of two months’ additional progress in reading and writing over the course of a year.337 Alysa Remtulla from Magic Breakfast referred to research which showed a link between breakfast consumption and achievement in GCSEs of two grades higher attainment,338 and a Department for Education assessment on the impact of attaining GCSEs, which indicated a lifetime productivity increase of between £55,000 and £283,000.339

234.Evidence from Professor Louise Dye outlined studies conducted by a University of Leeds research group on the effect of breakfast consumption. Their research had found that:

Breakfast consumption had a positive effect on cognitive function and that: “Tasks requiring attention, executive function, and memory were facilitated more reliably by breakfast consumption relative to fasting”;

There was a positive effect of breakfast on some classroom behaviours;

“Increased frequency of habitual breakfast was consistently positively associated with academic performance.”340

235.There are some limitations in the academic evidence on impact; the IFS study included a caveat that most of the gains are likely to be from the content or context of the clubs: eating healthier food or building stronger relationships with other pupils and staff while eating at school; rather than an overall increase in the numbers of children consuming breakfast at all. Furthermore, while relatively disadvantaged students were more likely to attend the clubs, the intervention was less effective at raising attainment of pupils from these backgrounds; there was limited impact on reducing socio-economic gaps in attainment.341

236.We received evidence of local councils establishing their own schemes to provide breakfasts for children at school.342 This evidence was extremely positive. One evaluation of a scheme in Blackpool found that:

“Children eating free breakfasts consume significantly more healthy items for breakfast than non-attendees; that the scheme contributes to reducing nutritional inequalities; the universality of the scheme reduced stigma by ensuring no child is singled out for a free breakfast and children are happier [sic.] more alert after attending the free school breakfast.”343

237.Aside from the evidence on attainment, there is compelling evidence of need. One of the most shocking conclusions we reached in Chapter 3 was that there are many children in this country living with constant or intermittent hunger. We heard of several cases where parents cannot afford to feed children breakfast.344 Magic Breakfast also referred us to a survey of Head Teachers of whom 81% had seen a rise in the number of pupils arriving at school hungry in the last five years.345 Regardless of the impact of breakfasts upon attainment, it seems to us that where there are instances of deprivation so acute that children cannot otherwise eat breakfasts, they must be provided. School breakfast clubs provide a sensible and effective way for this to happen.

238.The Government has already extended the funding for the NSBP, and we note that the 2017 Conservative manifesto originally included a pledge to provide free breakfasts for all primary school children in England346: evidence that there is, somewhere, a political will for this programme. More, however, needs to be done. First, the programme is not reaching enough of those who need it. Second, the funding is time limited.

239.The programme does not currently reach all or even most of those who need it. Professor Defetyer referred to the Households Below Average Income statistics, estimating that by 2022: “Almost 30% of all children—or nine children in every classroom of 30—will live in poverty.”347 The National Schools Breakfast Programme was specifically targeted at the most disadvantaged areas. The measurement the Government uses to assess eligibility, the Income Deprivation Affecting Children Index (IDACI) has been found to be: “quite an accurate measure of need.”348 The eligibility criteria that the Government has created based on this measurement is, perhaps, restrictive.349 The IDACI uses the postcodes of registered addresses to determine the likelihood that a pupil lives in an out-of-work or low-income family. A school will only become eligible for the NSBP if 50% of pupils fall into categories A-F, the highest levels of deprivation. Given that the programme is: “reaching about 20% of the children who we think are at risk of hunger”,350 it is clear to us that this threshold should be lowered.

240.Another key issue is that the funding is time limited. Although the Government has already announced a one-year funding extension to run the programme until March 2021. The idea is that this funding will “kick-start self-sustaining clubs”351 which will continue independently of Government funding. While warmly welcoming the programme, Ms Remtulla cautioned that it was not: “‘job done, problem solved’… The funding is only short term. After the year or two of support, schools are left to find their own financial support for their breakfast club.”352 Schools and groups of parents in the most deprived areas are beset with competing demands on their time, emotional bandwidth and money. While seed-funding is all very well, there is a very real risk that, when the money runs out, making further progress will be unsustainable.

241.We recommend that the eligibility threshold for the National Schools Breakfast Programme is lowered and funding increased to ensure that the programme reaches all of those who need it.

242.The National Schools Breakfast Programme must support and train facilitators to enable schools to access future external funding.

243.Notwithstanding Government support to access funds, central funding for the National School Breakfast Programme must not be withdrawn all at once, producing a ‘cliff edge’ effect. The funding must be removed gradually and only when schools are able to access reliable sources of funding to sustain the clubs.

Holiday Hunger

244.As outlined in Chapter 3, it is believed that around 3 million children in the UK are affected by holiday hunger.353 We welcome the Government’s decision, following a campaign by the footballer Marcus Rashford, to extend the National Voucher Scheme for the 2020 summer holiday: it will ensure that the most vulnerable children are supported.

245.Holiday clubs provide a buffer against hunger, but the work they do to educate and provide stimulating experiences for children is extremely valuable. These opportunities should be available for every child who needs them. We were told by Blackpool Council that:

“the summer holidays present an additional challenge by causing ‘learning loss’ for children, disproportionately affecting those children from more deprived backgrounds–thought to be caused by social isolation and boredom as well as inequity in opportunities and experiences to enhance learning, compared to their more affluent peers.”354

246.Concern has been expressed that the closure of schools during the COVID-19 outbreak could increase educational inequalities between the richest and poorest groups.355 This evidence of a “learning gap” indicates that extra-curricular activities offered by holiday groups (which in one area included “sport sessions, family craft, cook and eat sessions, team around the school, trips to the beach and a high ropes experience”356) remain of paramount importance in reducing educational inequalities that could otherwise be perpetuated over school holidays.

247.In 2019, the Department for Education awarded £9 million through its Holiday Activities and Food programme to local organisations to establish local coordinators of free holiday clubs. The funding reached around 50,000 children in 11 local authority areas. Co-ordinators were based in local organisations to: “work with providers and services in their local area … they were responsible for funding provision in their local area”357.

248.The funding for local coordinators is welcome, but we heard that it is insufficient. Clubs are run largely by the charitable sector, and issuing funding through a bidding process does not allow for long term planning. Nicky Dennison of Blackpool Council told us that: “It is quite challenging for the third sector when funding suddenly becomes available; everybody wants a piece of the pie or feel that they want to deliver everything.”358

249.The Government’s programme aims to reach 50,000 children, but this will fall short of supporting the 3 million children who are affected by holiday hunger. Alysa Remtulla told us:

“The response to holiday hunger is largely driven by the third sector and is piecemeal. It is like a postcode lottery which depends on where in the country you live and whether you have access to the work that the charity is doing … We would like to see a co-ordinated national response from the Government. At the moment, the Government’s funding for holiday hunger is around £9 million, which reaches 50,000 children—a small fraction of the children that we think might need those services.”359

250.We agree that provision of funding should be co-ordinated more effectively, and targeted to ensure it reaches the children that need that support. One proposal that was suggested to us was to make local authorities responsible for wrap-around holiday provision, and be provided ring-fenced funding to enable this.360 Local authorities are better placed than central Government to determine the needs of their populations during school holidays, but they cannot rectify the problem without sufficient resource.

251.Providing resources for local coordinators means that need can be effectively met in conjunction with local partner organisations, but for the purposes of accountability and consistency, this funding should be directed to the local authority. Holiday club coordinators should sit within the local authority, with ring-fenced finding from central Government.

252.Funding should be extended, without the need for bidding. Given the demand on Government funding following the COVID-19 outbreak, a targeted approach should be taken to fund coordinators in those areas which need provision. Area selection should be on the basis of eligibility criteria designed to capture as many areas in need as possible.

253.We recommend that the Government should significantly extend the funding provided through the Holiday Activities and Food programme to ensure that more children can access holiday clubs. It should use generous thresholds based on the Income Deprivation Affecting Children Index to determine which areas should receive this funding.

Public procurement

254.A number of respondents and witnesses suggested that harnessing the power of public procurement would be an effective way to create a healthier and more sustainable food environment. Witnesses mentioned the potential of public sector provision to shift demand by setting good examples and shifting the norm, as well as reducing the amount of less healthy or unsustainable food consumed from public sector providers. There were some differences in what our witnesses advocated for public procurement to achieve—from organic food, to British food, to food that supported better public health—which served to emphasise the great potential that, all agreed, procurement offers.

255.We were told that one benefit of providing healthier meals as the Government’s own offering would do a great deal to normalising healthy and sustainable diets. It is clear that the necessary, sizeable shift in consumption will require people to become accustomed to eating healthy food. Rob Percival, Head of Policy (food and health) at the Soil Association, argued that procurement was a way of creating a larger market361 and Dr Adrian Morley, Research Fellow at Manchester Metropolitan University, argued that the Government should reform its own provision—catering services in schools and hospitals—to expose the general public to healthy and sustainable diets.362

256.Perhaps the simplest advantage of changing procurement standards is that doing so would mean that people who consume publicly produced food could be eating healthier and more sustainable products, with all the associated benefits.

257.It was also suggested that public procurement could support horticulturist producers at the same time as increasing the nutritional value of food ingested. Kath Dalmeny, Chief Executive of Sustain, said: “There are smart and dynamic procurement systems that enable horticultural producers in particular to go into public sector procurement… Using clever technical systems, the mechanics of making the system sympathetic to the supply of fruit and veg means it then gets incorporated into dishes and people’s diets.”363

258.One of the key benefits of public procurement is that it is powerful. It forms a key component of the criteria for the Sustainable Food Cities awards because “it is such a key driver.”364 Ms Dalmeny from Sustain explained that the systematic nature of procurement made it a powerful lever to support sustainable production: it can be done at scale. Sustain had some success with a procurement project to work with catering bodies on serving sustainable fish. We were told that working with the methods of production and working to transition fishing fields sustainably: “Can be done in a principled, systematic way … it can happen at scale”.365 The power of this tool was recognised by two local authorities who were working to reform procurement standards as part of their food strategies and whole systems approaches.366

Government policy on public procurement of food

259.The Government’s public procurement policy is contained within the School Food Standards and the Government Buying Standards for Food and Catering Services. As we have already examined the School Food Standards, we focus here on the Buying Standards.

260.Government Buying Standards for Food and Catering Services (GBSF) apply to Government departments and agencies as well as prisons, the armed forces and the NHS. The guidance states that it provides a tool for: “setting technical specifications and evaluating bids”.367 It is not, to say the very least, forceful. While central government procurers are required to follow the standards, others are only encouraged to follow it. The guidance outlines a set of minimum standards to be applied in specification for tenders and contract performance conditions, rather than in daily delivery.

261.These standards were introduced as: “a means of meeting the Greening Government Commitments when buying and providing food and catering service”.368 It contains some guidance on environmental standards: namely that at least 10% of the total monetary value of raw ingredients must be certified to Publicly Available Integrated Production or Integrated Farm Management Standards of natural habitats, pollution control and prevention, energy, water and waste, and management of soils, landscape and watercourses. There are also some sustainability requirements for fish and palm oil.369

262.Nutrition standards are included; there are mandatory aims to reduce salt, increase fruit and vegetable consumption, reduce saturated fat, and ensure healthy fat, fibre and fish levels.

263.These standards are set low; those on production standards and animal welfare require only that UK legislative standards are met. It is accompanied by a scorecard which was, we were told: “not used very well or very often”.370 Even more concerningly, some of the basic minimum conditions can be departed from if there is a significant increase in cost which cannot be recuperated elsewhere.371

264.We also feel that the evidence from the Government indicated a reluctance to expand the use of public procurement to encourage people to eat in a certain way. The landscape was described as complex and allowing “varying levels of direct influence”.372 The Government pointed to different nutritional requirements for different groups such as hospital patients, army personnel and primary school children. They also made the point that if menus do not match customer demand consumers will take custom elsewhere, affecting the commercial viability of catering operations. We were unconvinced by these arguments:

As to the levels of influence, the Government has the ability to assert more control over these public procurers through legislation. This is demonstrated by the actions of the Scottish Government, which has set standards for all NHS food outlets.373 One witness even stated that public procurement was a lever which was “potentially within the readiest control”.374

Regarding the argument presented about nutritional requirements for different groups, a neat solution is presented by the inclusion of the Eatwell Guide in the nutritional standards. The Guide is designed to be used by anybody and sets out: “How much of what we eat overall should come from each food group to achieve a healthy, balanced diet.” It states that it applies to most people and directs anyone with special dietary requirements to: “Adapt the Eatwell Guide to meet their individual needs”.375 Requiring procurers or public bodies to consider the Government’s Eatwell guidance is therefore in no way inconsistent with meeting the nutritional needs of different groups.

We were not convinced by the argument on commercial viability. While the Government has correctly identified a risk that consumers will move from public offerings, this is not applicable in many cases, such as in hospitals or prisons. Moreover, we feel that the norm-shifting power of public procurement in tackling healthy diets overshadows the possible commercial drawbacks. If the Government cannot ensure its own food offering encourages adherence to the Eatwell Guide, how seriously can the public be expected to take it?

265.The benefits of high and robust standards for public procurement and public food offerings are clear. The Government must strengthen and develop the Buying Standards for Food and Catering Services to ensure that they fulfil their potential to create a healthier and more sustainable food environment. In particular, the revised standards should:

Apply equally and consistently to all Government procurement, including the NHS, prisons and the armed forces;

Apply to all private suppliers contracted to provide food for the above;

Require a significantly higher proportion of food to be produced in line with the Publicly Available Integrated Production or Integrated Farm Management Standard than is currently required;

Embed nutritional standards based on the Eatwell Guide;

Disallow any escape clause, as currently exists, for measures on the basis of cost; and

Provide for an enforcement mechanism.

The marketing and promotion of food

266.Marketing is an incredibly powerful tool. It shapes the environments within which consumers make their food choices. There are extensive freedoms for the food industry to market products more or less as they wish.

267.Marketing of less healthy products encourages consumers to buy less healthy products, and disproportionately affects lower-income people. Regulation is necessary to control it, and the Government’s action so far appears to have been limited to publication of consultations.

268.Perhaps the most obvious element of the food environment is the retail environment. Elements such as advertising, store layout and price and placement promotions play a key part in influencing consumer choices. To be blunt, if these techniques were not effective, the industry would not use them. Dr Clare Pettinger emphasised this point:

“There is no doubt that the food environment, (which includes marketing, advertising and promotions), influences us in our food choice behaviours (Butland et al, 2007), and this influence can potentially be modified by stronger and more radical political leadership in the form of legislation around marketing and advertising.”376

269.The Government has committed to a number of proposals aimed at reshaping the food environment, including ending the sale of energy drinks to children, calorie labelling in the out-of-home sector, restricting promotions of fatty and sugary foods by location and price, and further advertising restrictions. The Government confirmed in its written evidence that it has held consultations on all of these proposals but that its responses to these consultations are still in progress. 377


270.Our evidence told us that advertising works largely in favour of highly processed food which tend to be less healthy products. The Government has been criticised for failing to implement proposals which would restrict the times at which some less healthy foods are advertised on television. The Government’s evidence summarised the problem:

“children remain exposed to significant levels of high fat, salt and sugar (HFSS) advertising across the media they enjoy the most. This is a concern as evidence suggests that exposure to HFSS advertising can affect what and when children eat, both in the short term and in the longer term by shaping children’s food preferences from a young age”.378

271.Anna Taylor emphasised that advertising not only encouraged food choices, but also created new demand in the market, She stated that advertisers: “Create a market, and then habits and norms are formed around them.”379 Kate Halliwell of the Food and Drink Federation described the different ways in which marketing (which includes advertising) works: “Of course, marketing makes a difference. Companies use marketing predominantly to be competitive and take an advantage over their competitors, to raise their own profile or to look at new products coming on to the shelf.”380

272.There is evidence to suggest that less healthy foods are marketed significantly more often and with more financial muscle than healthy foods. The Food Foundation told us that: “The advertising industry is oriented towards selling us fast-food brands combined with manufactured confectionery and things that tend to be less good for us.”381 A Food Foundation report, ‘The Broken Plate’, found that in 2017 over £300 million worth of advertising was spent on less healthy food products.382 They suggested that this might be due to small margins for producers leaving little room for promotion spend and that the small variety of fruit and vegetables means the advertisers would benefit the whole market rather than their own share. Professor Lang put the discrepancy into perspective:

“About two-thirds of £1 billion is spent on food advertising in Britain, and about £5 million goes on something one can call health promotion. David and Goliath are not even in it… The problem with advertising is that its job is to keep the machine churning ever-cheaper food through the system, and do it by scale. That is why Unilever spends that money. That is why Coca-Cola spends $4 billion a year on marketing, which dwarfs the entire World Health Organization’s budget by a factor of two, every year.”383

Government policy

273.Chapter 2 of the Childhood Obesity Plan committed to a consultation on introducing further advertising restrictions on TV and online for products high in fat, sugar and salt (HFSS). This consultation closed in June 2019 and included proposals to ban advertising of some products before 9pm.384 Restrictions on advertising were widely welcomed by witnesses and within the written evidence.385 George Butterworth stated that, if the proposal were implemented, it “would have a big impact on reducing exposure to young people.”386

274.We were referred to research by the Obesity Health Alliance which had found that there was broad public support for this move: “72% of people support the introduction of a 9pm watershed on junk food adverts during popular family TV shows.”387 Our witnesses emphasised that while restrictions were necessary, they were not a: “magic bullet”388. Professor Susan Jebb stated that:

“On the nine o’clock watershed, yes, fine; that is clearly one of the things, but we absolutely must not get so obsessed with that that we think we have done it. Of course, we have not. It has to be much broader. It has to include social media, billboards and all those other things… I support the nine o’clock watershed but it is not nearly enough. It has to go much further than that. What I do not want is for the nine o’clock watershed to become a huge fig leaf that stops anything else.”389

275.Another proposal consulted upon was the suggestion that advertising restrictions should apply online. Jenny Oldroyd from the DHSC, stated that: “We have asked in our consultation on advertising on television and online whether there are other media that we need to consider and do more on in this space.”390 The answer to that query is, as far as our evidence goes, is yes—other media must be included. Written evidence from the Faculty of Dental Surgery indicated that 70% of people support a watershed on online advertisements.391

276.Physical environments such as bus stops and billboards that hold advertisements for less healthy foods also have an impact on consumer choices and health. Some of our witnesses advocated for providing increased powers to local authorities to tackle the influence of food advertising in the physical environment. We acknowledge the concern from retailers, manufacturers and broadcasters about restrictions to advertising.392 Mhairi Brown, Policy and Public Affairs Coordinator at Consensus Action on Salt, Sugar and Health, however, raised the success of the ban on HFSS food spending on Transport for London to argue that bans of this nature can be commercially viable: “I refer to the example of Transport for London’s restrictions on advertising high fat, salt and sugar products. That ban has not led to a loss in advertising revenue. In fact, revenue has gone up by £1 million since it was introduced.”393

277.It is important once again to state that, notwithstanding the commercial concerns inherent in the proposals to restrict advertising, diet related ill health is costing the NHS over £6.1 billion per year and £27 billion to wider society.394 The decision to impose restrictions has already been made by the Government: action must follow.

278.The proposals in Chapter 2 of the Childhood Obesity Plan to impose restrictions on the advertising of HFSS foods were welcomed by a large majority of our evidence. The Government must, by the end of 2020, roll out these proposals both for television and online.

Product placement

279.Several witnesses referred to the placement within supermarkets of less healthy foods in locations which are designed to promote impulse buying. The effect of this tactic may not be consciously noticed, but we were told that it is an important influence on food choices.

280.It was suggested to us that product placement disproportionately markets unhealthier foods. We were told that in a study in Sheffield: “on average 89.5% of food products on display to children in convenience supermarkets were less healthy, and that in most cases foodstuffs on display were at the upper end of the spectrum of less healthy foodstuffs”.395

281.Dr Vogel referred to research which suggested that this problem was worse in food outlets which offer cheaper food, and are thus more likely to be used by lower income groups: “Discount supermarkets and small supermarkets had poorer environments, with fewer choices of healthy foods, cheaper pricing of unhealthy foods and more prominent product placement of unhealthy foods.”396

282.Consultations under the Childhood Obesity Plan included a proposal to ban by regulation the placement of some products in popular locations in supermarkets such as the end of aisles, store entrances and checkouts. The options consulted upon were: retaining the status quo; banning placement of all HFSS foods in these locations; and banning placement of HFSS foods (as defined under the sugar and calorie reduction programmes and the Soft Drinks Industry Levy). The Government indicated a preference for the latter which would represent a smaller group of products than if they had opted for all HFSS foods.

283.Interestingly, it appears that, as in the work in advertising healthy food, the power of product placement can be harnessed to encourage healthier choices. Dr Vogel’s pilot study on the food environments indicated that there were also opportunities in providing healthier foods, when fruit and vegetables were placed in these prominent places, “the results were very promising”.397

284.A report of the Regulatory Policy Committee summarised the financial benefits of the Government’s proposed regulation:

“The expected benefits of the regulations include the health benefits that would accrue because of lower calorie consumption amongst overweight and obese people. This would be equivalent to £2.5 billion over the assessment period of 25 years. Social care savings would amount to £0.3 billion and a reduction in premature mortality would deliver an expected additional £0.1 billion of economic output.”398

285.The proposal would exclude small and micro businesses. We find this hard to justify. A report from the Regulatory Policy Committee on the Government’s impact assessment also found that the Department had not fully explained the decision to exclude small businesses.399

286.As with so much of the Childhood Obesity Plan, no summary of responses has been published to the consultation which closed in April 2019.400

287.Proposals to end the product placement of HFSS foods in popular supermarket locations were welcomed. The Government must, by the end of 2020, enact them, ensuring that the ban covers the widest range of less healthy foods possible and includes small businesses.

Price promotion

288.Price promotion is similar to other aspects of marketing of less healthy products; it encourages consumers to buy more products that are less healthy and disproportionately affects lower-income groups. Regulation is necessary to control it. As seen in other areas, the Government’s action so far has been to produce a consultation.

289.As with many of the marketing techniques employed by food manufacturers and retailers, price promotions disproportionately focus largely on less healthy foods. The Government’s evidence acknowledged this and outlined some of the key issues:

“Promotions on food and drink in the UK reached record levels in 2015 and were the highest in Europe, with 40% of the food and drink people purchased being on promotion Data shows that in store promotions tend to be skewed towards HFSS products as these are more likely to be promoted. Evidence also shows that volume promotions (such as multibuy offers i.e. buy one get one free) cause a greater sales uplift compared to other types of price promotions such as simple price reductions. Volume promotions increase the amount of food and drink people buy by around 20%. Consumers typically do not stockpile these extra purchases to take advantage of the lower price; instead they increase their consumption.”401

290.The Government’s consultation on this measure outlined proposals that restricted the following HFSS promotions:

multibuy promotions of pre-packaged HFSS food and drink

extra free promotions of pre-packaged HFSS food and drink

free drink refills with the purchase of a meal in out of home settings402

291.Our witnesses were welcoming of these proposals. The Royal Faculty of Dental Surgery referred to Public Health England research which showed that: “Eliminating price promotions on high sugar products altogether would lead to a 6.1% reduction in sugar volumes purchased by consumers, equating to around 7.4 grams of sugar per individual per day.”403

292.The Government’s consultation on this closed in April 2019, and a summary of responses has not yet been published.404

293.The Government must, by the end of 2020, act on their proposals to restrict price promotions on HFSS products.

Fast food outlets

294.Our evidence was more than clear about the problem of fast food takeaway outlets. Our witnesses all acknowledged that fast food outlets contribute a great deal to less healthy diets, and an unhealthy food environment. It was also argued that these outlets are largely concentrated in deprived areas and thus contribute to inequality. Local authorities can use planning permission powers and licensing regulations to restrict the opening of new fast food restaurants on the grounds that they pose a hazard to public health but it was explained to us that this is not always easily done.

295.Fast food outlets offer a cheap way of providing less healthy food. We were told that prices were low and that a standard meal with a fizzy drink would normally cost around £2.99.405 Dr Vogel pointed to the commercial driver to offer low prices and large portion sizes:

“Often in areas where there is high competition between fast-food outlets, they are highly competitive with each other. You might get free portions of chips. They do a lot of tactical pricing to make sure that they are bringing in the business. In areas of the high street where there are tens of fast-food outlets and takeaway shops, there is lots of competition”.406

296.There are clear indications that these fast food restaurants are concentrated in lower income areas. Data from Public Health England indicates that there is a: “Strong association between deprivation and the density of fast food outlets, with more deprived areas having a higher proportion of fast food outlets per head of population than others.”407 Self-evidently, this means that lower-income people are much more likely to consume this type of food. The concentration of this type of food in poorer areas is therefore contributing to the increased levels of obesity and diet related ill health in lower income groups and plays a key role in exacerbating health inequalities.

297.Some of our evidence called for the use of planning restrictions to reduce the number of fast food outlets, particularly when concentrated near schools. Guidance for local planning authorities states that plans should: “take account of and support local strategies to improve health, social and cultural wellbeing for all”.408 It appears, however, that this is more difficult than it should be.

298.Premises are defined on a ‘Use Classes’ system. A3 permission is historically required for in-house consumption of hot food, and A5 permission applies where the business primarily provides take-away food. Nicky Dennison from Blackpool Council pointed out that the permission is allocated to the premises rather than an individual and that this means the local Council does not have the ability to prohibit a new take-away outlet opening:

“I would love A5 planning to be looked at, because once a property has A5 planning it stays with the property and does not go. If one fast-food outlet goes away, the next landlord or owner can come in and open as a fast-food takeaway. I would love us to look at how we can make changes to that. It should probably be a bit like alcohol licensing, in that it goes with the name of the person who owns the business rather than the property itself.”409

299.The allocation of Use Classes to premises rather than to individuals using these premises is a missed opportunity for a potentially powerful tool for local authorities. If new proprietors were required to reapply for the appropriate Use Class, this would enable local authorities to adapt to changing circumstances and more effectively fulfil their statutory duty to improve the health of their local population.410

300.The problem is not restricted to take-away outlets. There was some discussion of exclusion zones around schools, which some local authorities do attempt to enforce. Dr Cuming from Brighton and Hove Council argued that this problem is more complex than simply restricting only fast food outlets:

“We found that secondary school-aged kids with a small amount of money to pay for their lunch ended up going to two or three different food businesses… They might be garage shops, newsagents, a café or a hot-food takeaway, which certainly would not come under the A5 restriction… We also realised that it is not just about lunchtimes; it is the route to and from school. Restrictions probably need to be a bit more comprehensive than just talking about A5 outlets at lunchtime.”411

301.Brighton and Hove also found that as the traditional exclusion zone of 400 metres around schools did not cover the distance secondary school pupils would walk, a distance of around 800 metres was more realistic.412 The complexity of the issue seems to have led Brighton and Hove to allocate their resources towards other methods of promoting a healthy food environment. While this might be a sensible approach for a local authority to make in the context of a national framework “that is not particularly supportive”,413 there is no justification for central Government to avoid tackling the issue of fast food outlets. We are fully cognisant that fast food outlets are not the only problem, but they are undoubtedly contributing to an unhealthy food environment.

302.The Government’s written evidence outlined some actions it was taking to clarify planning regulations, but Jenny Oldroyd from the DHSC acknowledged that while local authorities do have some powers to enforce exclusion zones around schools, there are serious difficulties in the ability to apply them in practice:

“Those powers are there, but I do not pretend at all that they are always easy and straightforward to use. They face a potential legal challenge, particularly on using planning powers to restrict the opening of fast food restaurants.”414

303.We recognise that the unprecedented circumstances presented by the outbreak of COVID-19 have limited the ability for restaurants, pubs and cafes to provide food on the premises. The Government has made it easier to change the use of premises for this reason—allowing, for instance, restaurants to become takeaways.415 We recognise that, during a time of crisis, this flexibility is necessary. It must not become a precursor to a highly permissive licensing environment which enables less healthy food outlets to proliferate unchecked. It remains of vital importance that local authorities can protect the health of their residents.

304.The planning environment must support the efforts of local authorities to limit the proliferation of fast food outlets around schools.

305.The Government must conduct a review on the use of licensing and planning to ensure that:

(1)local authorities are able to enforce exclusion zones of at least 800m around schools; and

(2)when use of a building subject to use class A3 or A5 is transferred, new planning consent must be obtained.

306.Immediately following the withdrawal of the permitted development rights introduced in March 2020, the Government should consult upon and enact a scheme to enable local authorities to charge out of home food outlets an amount of council tax which is in proportion to the healthiness of their food offering.

307.Mark Laurie, Director of the Nationwide Caterers Association, reminded us that the absence of a fast food shop does not necessarily imply the presence of healthy food instead: “If you ban food businesses from opening, you are not replacing them. It is not that Leon is going in because Greggs came out; there is just an empty shop. You have to provide affordable alternatives for people, and they have to be appealing.”416

308.Any reduction in access to fast food outlets should consider enabling or providing alternatives. Mr Laurie suggested working with existing outlets to provide appealing and cheap, but healthier food. This is an option which does not seem to have been suggested by the Government at any stage. The idea of working with and supporting retailers to change their offerings to make them healthier or more sustainable was, however, raised by Food Active,417 Sustainable Food Cities,418 and some local authorities. Mr Andrews, Programme Manager of Sustainable Food Cities, indicated that to achieve healthier and sustainable diets: “We have to find ways that enable food organisations to make a profit, one of which is through competitive difference. It is possible… You need national policy to guide that process, but you also need schemes.”419 Blackpool Council’s Healthier Choices Award works to support local businesses to “make small changes to their menu offer to improve the healthier options on offer” has had some success, with 142 local businesses signed up to the scheme.420 The Centre for Diet and Activity Research provided a further example, Takeaway Masterclass, a course to encourage healthier cooking practices and menu options, was found to be both feasible and acceptable in a small group of takeaways, although the Centre stated that further research was required on maintaining participation and retention.421

309.A national scheme to encourage healthier choices in take-away outlets, coupled with a toolkit for local authorities to assist, would be a significant first step in changing people’s intake. If there were a scheme and support which would enable fast food outlets to provide appealing and healthy food to their consumers, we believe that many outlets would do so.

310.Another way to ensure increased access to healthier, more sustainable food is to empower different food providers to sell to the public. Mr Laurie argued that Government should:

“… let us have the opportunity to sell it to them. We cannot take on the shops, but we could go out and sell healthy food in communities, or we could get people from these communities to sell, essentially, home-cooked food or show them how to do it in a safe, hygienic and compliant manner. There is a real appetite for people to sell home-cooked food to other people.”422

311.Allotments could play a role in shaping the physical environment in a healthier way, while also providing an opportunity for individuals to grow and consume nutritious food. Nourish Scotland told us that allotments could produce “very high yields while maintaining a diverse environment and providing social co-benefits”423 and evidence from Advice NI suggested that councils could have a role in developing local food markets alongside training programmes in horticulture, food nutrition and cooking.424

Box 9: Experiences of food insecurity

In a series of phone calls, facilitated by Sustain and Church Action on Poverty, the secretariat spoke with individuals who have experienced food insecurity.

Heather from Newcastle said:

“Public growing would be good. I’ve always wanted to have an allotment, but I’ve never been able to afford to have an allotment because there is a price tag on it. But if there was more space to do it, and less vandals to wreck it, I think that could be a really good idea for seasonal veg to be provided by the community to you are in … . I think it would be brilliant for the community around, even if it’s just a small plot of land … .”

Source: See Appendix 5.

312.The Government, in partnership with local authorities, should develop a scheme to support food retailer businesses, including those providing fast food, to develop and sell healthy alternatives. It should also determine and provide support to empower other kinds of food providers such as street vendors to sell healthy food in communities.


313.We received some evidence to indicate that food labelling is inconsistent and confusing. Anna Taylor referred to “information asymmetries” in the food system. She stated that: “it is pretty hard for a customer in a shop to work out what they are eating, where it has come from and how it was made, and to know that they are buying what they really want to buy”.425

Government consultations

314.Calorie and nutrient labelling is voluntary. The Government recommends the use of ‘traffic light’ labelling. Jenny Oldroyd of the DHSC told us of three different consultations planned by Government on labelling. She said the Government was:

“looking to introduce calorie labelling in restaurants and cafés in out-of-home settings. We have committed to launching a consultation later this year on the very successful front-of-pack labelling scheme and how we can build on that. We have committed to a consultation early next year on the marketing and labelling of infant foods so that we get the presentation of foods right for the youngest children in this country.”426

315.Given that the Public Health Minister, Jo Churchill MP, confirmed to the Committee that: “one in ten children enters primary school obese, and that rises to one in five by the time they leave”427 we consider that measures to address the presentation of infant foods must be viewed as an urgent priority. The Government has recognised that:

“Too many commercially available foods and drinks marketed for infants and young children have labels that do not align with the latest government scientific advice. They can also make a product appear healthier than it really is, or do not contain enough information about how they should be consumed. All of this can be confusing to parents and carers.”428

The Government also told us that sugar levels in some commercial baby foods and drinks can be very high, and that three in four children aged 4 to 18 months have energy intakes that exceed their daily requirements.429

316.The Government must publish its consultation on how to address the marketing and labelling of infant food without delay. The responses to that consultation, and the related measures to ensure parents and carers have accurate information on infant food products must be published in 2020.

317.Jenny Oldroyd also explained that the Department had committed to publishing a response to the consultation on calorie labelling in the out of home sector: “before the end of the year” which would have been December 2019. As of June 2020, no response to this consultation, which closed in December 2018,430 was available.

318.Professor Jebb explained that food labelling works for two reasons. Firstly, it provides the information required for consumers to make informed healthy choices, and secondly, when labelling is required, businesses choose to lower the calorie count. She said that, “Effectively, you get a population-level impact over and above individuals making better choices”.431

319.We were told that different groups interact with nutrient labelling differently. Dr Mulrooney, on behalf of the Obesity Group of the British Dietetic Association, told us:

“Food labels are not necessarily used and understood in the same way by all groups. There is evidence that their use is greater among those with an already greater interest in food and health.”432

320.We see a strong argument for front-of-pack labelling to be as simple and quick to read as possible. Complicated labels are likely to be of least use to those who most need them. The traffic light system of labelling, which rates different nutrient components as red, amber or green depending on the level of the nutrient, has potential to be simplified further, including by a mandate to present the information in a consistent (and therefore familiar) format. The ability to see at a glance how healthy (or otherwise) a food is could bring important benefits to consumers.

321.Labels on food indicating ‘best before’ or ‘use by’ dates do not necessarily provide information that is useful to consumers as to whether food is safe to eat. Guidance from the waste reduction charity, WRAP states that “food past its Best Before date remains safe, and perfectly good to eat for days, weeks, months or even years after the date–depending on the type of food and if it has been stored correctly.”433. We heard that ‘use by’ and ‘best before’ labels lead to confusion among consumers and both food and drinks being thrown away unnecessarily. Analysis of reasons for food waste conducted between 2013 and 2014 found that 16% of avoidable food waste was linked to a date label.434 Similarly, a poll conducted by Arla Foods found that:

“Whilst three-quarters (77%) of respondents check food and drink packaging before they purchase, only 15% are confident they can decipher everything on the label. This includes ‘best before’ and ‘use by’ dates with over a third (34%) of Brits unsure of the difference, and 11% believing them to be the same thing. This confusion means a third (34%) end up binning food if past its ‘best before’ date, while another 38% do the same once the product has passed its ‘use by’ date.”435

322.Steve Butterworth, CEO of Neighbourly, a surplus food redistribution platform, believed that there was scope to make date labelling clearer. He said that: “Use-by dates have definitely been guilty of fuelling food being thrown away far too quickly, and best-before dates will come in sooner rather than later … A simplification process is required.”436

323.Date labelling, while useful in retail stock control, is confusing for consumers and leads to unnecessary food waste. The system requires simplification. This is, however, a complicated area to address: simply removing date labelling entirely would require a comprehensive education initiative to ensure that consumers can ascertain whether or not food is safe to eat. The Government must review how consumers can most reliably be informed about when food can be consumed and when it should be thrown away.

324.We recommend that the Government conduct a review of labelling on food and drink products. The findings of the review should form the basis of regulations which address both date labelling and the standardisation and simplification of front-of-pack traffic light labelling. The new regulations should be compulsory for all food manufacturers and retailers.

325.Labelling, however, is not going to rectify the issue of less healthy and unsustainable diets alone. Dr Tara Garnett, Food Climate Research Network Leader, University of Oxford, warned us that there was a danger that the use of labelling can place the responsibility on the consumer and act as a “get-out-of-jail-free card for industry and government”.437 We acknowledge this concern, but agreed with her wider point that it can be a useful tool.

Education and public health messaging

326.It was suggested to us that a lack of knowledge or skill was a limiting factor in access to healthy diets. Much of our evidence suggested that the improved provision of information, through public health messaging or through education initiatives would be a positive step towards removing this limitation. Our evidence identified several possible initiatives and a list of potential benefits to providing this information and training, as well as limitations of this kind of intervention.

327.Some evidence emphasised that a lack of knowledge or skills around healthy eating was a crucial limitation in the ability to access healthy diets. This included the response from LACA, which suggested that there were three reasons for difficulty in accessing healthy diets: time, lack of education and skills, and portion control.438 Dr Rebecca Sandover explained that food bank clients identified a “general lack of food skills [and] food education”439 and in a Food Poverty Needs Assessment, the Royal Borough of Greenwich Council identified: “a lack of education around what constitutes healthy eating and the ability to budget correctly to support a healthy diet” as a key barrier affecting people’s ability to eat healthy food.440

328.Many of our contributors argued strongly that education on healthy diets could be powerful. There was, however, relatively limited consensus around what specific knowledge and skills should be provided by education. Evidence suggested that it could work to teach practical cooking skills,441 encourage and empower healthy choices,442 or encourage a sizeable shift in consumption patterns.443

329.This evidence indicated that on the whole there were two missing elements: the knowledge of what constitutes a healthy diet and healthy weight, and the skills to prepare nutritious and tasty food. Some evidence suggested that perceptions of what constitutes a healthy diet are inaccurate. Cllr Evelyn Akoto of Southwark Council wrote that: “Across ethnicities, all children’s views of what constitutes a healthy balanced diet are at odds with guidelines”.444 Similarly, a 2012 systematic review found that: “Parents are likely to misperceive the weight status of their overweight child”, with 62.4% of overweight children incorrectly perceived as having normal weight by their parents.445 Limited skills to prepare nutritious food was also identified by much of our evidence. Writing on behalf of the Obesity Group of the British Dietetic Association, Dr Hilda Mulrooney pointed to a lack of education on cooking skills which she said: “resulted in a generational loss of knowledge with impacts far beyond the individual affected”446. Bags of Taste also suggested that a lack of confidence in cooking is crucial for those on low incomes: “the idea that they may be able to cook something at home that is both tasty and affordable seems to them highly unlikely.”447

330.The national curriculum includes cooking and nutrition as part of Design and Technology. This is compulsory in maintained schools from Key Stages 1 to 3 and from September 2020, health education will be compulsory in all state-funded schools. It was clear that there is potential for schools to build on these mandated elements to further increase knowledge and skills relating to healthy lifestyles and nutrition and food preparation. The Nuffield Council on bioethics argued that schools were well placed for this role:

“Schools provide an important means of influencing many of the sociocultural factors that have a lasting impact on both food choices and exercise habits. They have a prominent role in the community, are a source of support for parents and families, and can produce community change in environments, knowledge, and behaviour”.448

Several examples of positive education around skills and healthy eating were provided to us. Blackpool Council pointed to their Give Up Loving Pop campaign, which it estimated had led to 10,564 days free of sugary or fizzy drinks for children involved with a 21 day challenge449, and the Soil Association pointed to their ‘Food for Life’ awards scheme which promoted healthier food and food education within schools. There was some demonstrable success in this programme, and the Soil Association have estimated that: “If every primary school in the UK was a Food for Life school, a million more children would be eating their five-a-day each day”.450

331.Schools must be adequately resourced to further increase knowledge and skills on nutrition and food preparation. Chapter 1 of the Childhood Obesity Plan recognised that: “Schools are a vital part of our plan, and have opportunities to support healthier eating, physical activity and to shape healthy habits.”451 An important part of schools contribution in reducing childhood obesity is in providing the skills and knowledge required for healthy lifestyles and diets. There are, however, many (and—due to the COVID-19 outbreak—increasing) demands on schools’ budgets and capacities.

332.Existing models to support healthy lifestyles could reduce the financial burden on schools while still enabling them to play an increasingly active role in reducing childhood obesity. The Primary PE and Sport Premium, for example, offers an easily transferable model. The premium provides direct and ring-fenced funding to make additional and sustainable improvements to the quality of their physical education, physical activity and sports.452 This could be used as a basis to improve the quality of education on healthy diets. Another possible solution is to fund a small number of professionals in a local area to engage with schools and facilitate classroom and skills-based learning on healthy and sustainable diets. Ideally, access to these resources should be available to all schools, but there is scope to target areas with the highest levels of deprivation or childhood obesity. A Government scheme, along the same lines as we have suggested for the Holiday Activities and Food programme, could facilitate this and effect real improvement in children’s health, including a reduction in childhood obesity levels.

333.We note the potential and applaud the success of school-based schemes to encourage healthy lifestyles. We urge local authorities and school leaders, in discussion with classroom teachers, to build on the foundation already provided by the National Curriculum to integrate further education on healthy lifestyles into their offer.

334.The power of public health messaging on healthy choices was highlighted. Many of our contributors argued that, properly harnessed, this could shift consumption habits to be healthier. Clearly, if people are to eat a healthy diet, knowledge of what constitutes a healthy diet is essential. The Change4life information campaign which suggests “easy ways to eat well and move more”453 was raised as an example of a successful scheme.454 Professor Jebb said that: “It has created a lot of trust in the brand. It has relayed some consistent messaging. If we did not have it, we would probably be saying we should do it.”455

335.There was a consensus that public health messaging should be carefully tailored to the intended audience. Dr Christian Reynolds argued that “information and education campaigns need to be tailored to different dietary patterns (and income groups) to be effective”.456 Alex Holt of Food Active told us that: “Current public health messages are very middle class. We need to make sure that they are more tailored to those on low incomes and, perhaps, those from religious and racial minority ethnicities.”457 We were also told by Health Action Campaign that “between 43% and 61% of working age adults routinely don’t understand health information”.458 There is a body of work that remains to be done to ensure that public health messaging is clear and easy to understand.

336.There is potential for increased investment in targeted public health messaging to help to encourage a shift towards healthier consumption patterns.

337.One measure suggested by much of our evidence was the increased advertising of healthy foods. Many witnesses pointed to the success of the VegPower initiative to advocate for more public health advertising. Mr Percival stated: “We need to level the playing field by tackling the overspend on junk food advertising and increasing the spend on fresh food advertising.”459 Henry Dimbleby, National Food Strategy Review Lead, expressed his interest in public health advertising and referred to the advertising programme for vegetables, VegPower:

“VegPower is amazing … All the kids were excited by it. My son was talking about it last night at the table; he just brought it up. He said, “Do you remember that bit where—? Could you link money in some way to adverts so that you could advertise more of the good stuff? Could you force people to advertise good stuff? There are all sorts of ways in which you might change advertising. We need to get creative. It is a huge amount of money, so we need to think carefully about that.”460

How effective is food related education and public health messaging?

338.It was suggested that the impact of public health messaging and education is limited. There were several components to this argument, including:

Some witnesses argued that messaging and information campaigns are relatively ineffective because change based on them requires individual action. Dr Vogel told us that this kind of intervention has “a limited effect on population-level change”.461 Professor Dominic Harrison and Emma Savage, both of Blackburn with Darwen Council, stated that: “Education and information interventions always putting the onus on the individual does not work when people are short of both money, time and resilience”.462 That knowledge does not equal behavioural change is evidenced by the 5 a day campaign which while well-known, communicates standards that are far from being met.463

Information campaigns and education do not address or remove many difficulties in accessing healthy diets. Factors outlined in chapters three and four, such as cost, physical accessibility, aggressive marketing and the availability of cheap healthy food are not addressed by providing more knowledge. As Dr Clare Pettinger told us: “Evidence shows that people do know about healthy eating (e.g. knowledge of 5 a day and/or ‘healthier foods’), but they do not always have the (financial) means to follow healthy eating guidelines (due to low income, or family circumstances”.464 Teaching children about healthy eating at school, for example, does not address the other issues which prevent healthy diets: “children are often well informed and educated but with working parents, time and financial constraints healthy options are still not being given at home”.465

Some witnesses told us that interventions which require individual choices and changes could increase inequalities and that this is particularly the case when interventions make greater demands on individuals that require them to exert considerable effort (‘agency’) to achieve a successful outcome. The Centre for Diet and Activity Research summarised:

“High-agency’ interventions include education and information campaigns. High-agency population approaches may be most effective in more affluent groups, and so may exacerbate existing inequalities. In contrast, ‘lower-agency’ population approaches such as reformulation, price changes and advertising restrictions are likely to be the most effective and equitable solutions.”466

Others agreed, arguing that lower-risk population groups were more likely to engage with public health messaging,467 although this was not a universal view: Professor Jebb, for example, pointed to the successful Change4Life campaign to argue that targeted information campaigns can have substantial impacts on high-risk groups 468

339.Increasing public understanding of what constitutes a healthy and sustainable diet is an important element of efforts to improve the population’s diet. Interventions designed to communicate information about food and nutrition must be adapted according the audience they are trying to reach. Crucially, they will be most successful when accompanied by other measures to address the underlying problems highlighted in this report which make it difficult to access healthy diets.

222 Q 47 (Alex Holt)

223 Q 109 (Mark Laurie)

224 Q 50 (Tom Andrews)

225 The Food Foundation, The Broken Plate (February 2019): [accessed 30 June 2020]

226 Q 50 (Tom Andrews)

227 Q 63 (Professor Susan Jebb)

228 Q 12 (George Butterworth)

229 Q 12 (Dr Christina Vogel)

230 Q 46 (Tom Andrews)

231 Department of Health and Social Care, Childhood Obesity: A plan for Action (August 2016): [accessed 30 June 2020]

232 Department of Health and Social Care, Childhood Obesity: A Plan for Action, Chapter 2 (June 2018): [accessed 30 June 2020]

233 Cabinet Office and Department of Health and Social Care, Advancing our health: prevention in the 2020s—consultation document (July 2019): [accessed 30 June 2020]

234 Independent report by the Chief Medical Officer, Time to Solve Childhood Obesity, (October 2019): [accessed 30 June 2020]

235 Q 72 (Kate Halliwell)

236 Q 72 (Dr Hilda Mulrooney)

237 Q 65 (Professor Susan Jebb)

238 Supplementary written evidence from HM Government (ZFP0098)

239 Q 28 (Jenny Oldroyd)

240 Public Health England, Calorie reduction: the scope and ambition for action (March 2018): [accessed 30 June 2020]

241 Department of Health and Social Care, Consultations: Ending the sale of energy drinks to children, (Updated November 2018): [accessed 30 June 2020]

242 Department of Health and& Social Care, Consultations: Calorie labelling for food and drink served outside of the home, (Updated October 2018): [accessed 30 June 2020]

243 Department of Health and Social Care, Consultations: Restricting promotions of food and drink that is high in fat, sugar and salt, (Updated April 2019): [accessed 30 June 2020]

244 Department of Health and Social Care and Department for Digital, Culture Media & Sport, Consultations: Further advertising restrictions for products high in fat, salt and sugar, (updated 7 June 2019): [accessed 30 June 2020]

245 Department of Health and Social Care, Consultations: Updating the government buying standards for food and catering services (GBSF): (updated August 2019): [accessed 30 June 2020]

246 Cabinet Office and Department of Health and Social Care, Advancing our health: prevention in the 2020s, (Updated October 2019): [accessed 30 June 2020]

247 Q 125 (Jo Churchill MP)

248 Professor Dame Sally Davies, Time to Solve Childhood Obesity. An Independent Report by the Chief Medical Officer (2019): [accessed 30 June 2020]

249 Q 5 (Anna Taylor)

250 Q 119 (Jo Churchill MP)

251 Professor Dame Sally Davies, Time to Solve Childhood Obesity. An Independent Report by the Chief Medical Officer (2019): [accessed 30 June 2020]

252 Healthy Start, ‘What is Healthy Start?’: [accessed 30 June 2020]

253 Written evidence from Cllr Evelyn Akoto, Cabinet Member for Community Safety and Public Health, Southwark Council (ZFP0024)

254 Alexandra Rose, ‘How Rose Vouchers work’: [accessed 30 June 2020]

255 Alison McFadden, Josephine Green, et al, ‘Can food vouchers improve nutrition and reduce health inequalities in low-income mothers and young children: a multi-method evaluation of the experiences of beneficiaries and practitioners of the Healthy Start programme in England’, BMC Public Health (2014) (February 2014),–2458-14-148 [accessed 30 June 2020]

256 Q 62 (Shirley Cramer)

257 Written evidence from First Steps Nutrition Trust (ZFP0044)

258 Supplementary written evidence from HM Government (ZFP0098)

259 Calculated from Bank of England, ‘Inflation Calculator’: [accessed 30 June 2020]

260 Healthy Start, ‘Do I qualify for Healthy Start?’: [accessed 30 June 2020]

261 Written evidence from Church Action on Poverty, Food Foundation, Nourish Scotland, Oxfam and Sustain: the alliance for food and farming (ZFP0031)

263 Feeding Britain, Increasing Healthy Start Uptake, (February 2019) pp 1-2: [accessed 30 June 2020]

264 Ibid and First Steps Nutrition Trust, The UK Healthy Start scheme, (2018): [accessed 30 June 2020]

265 Q 59 (Nicky Dennison)

266 59 (Dr Katie Cuming)

268 Ibid. and Feeding Britain, Increasing Healthy Start Uptake: [accessed 30 June 2020]

269 Q 59 (Dr Katie Cuming)

270 Supplementary written evidence from HM Government (ZFP0098)

271 Written evidence from Cllr Evelyn Akoto, Cabinet Member for Community Safety and Public Health, Southwark Council (ZFP0024)

272 Written evidence from the University of York IKnowFood programme (ZFP0040)

273 Written evidence from the Association of Convenience Stores (ZFP0050)

274 Written evidence from Church Action on Poverty, Food Foundation, Nourish Scotland, Oxfam and Sustain: the alliance for food and farming (ZFP0031)

275 Written evidence from First Steps Nutrition Trust (ZFP0044)

276 HM Government, Childhood obesity: a plan for action, Chapter 2 (2016): p 11: [accessed 30 June 2020]

277 HC written question, 29 January 2020, 9618

278 Q17 (Jenny Oldroyd)

279 Eligibility is determined by receipt of some qualifying benefits.

280 47 (Professor Greta Defeyter). See also Q 5 (Anna Taylor)..

281 Q 5 (Anna Taylor)

282 Department for Education, Coronavirus (COVID-19): free school meals guidance for schools, (30 April 2020): [accessed 30 June 2020]. In June 2020 this scheme was extended to cover the 2020 summer holiday.

283 BBC, Coronavirus: Families still waiting for free school meal vouchers, (30 April 2020): [accessed 30 June 2020]

284 House of Commons Library, School meals and nutritional standards (England), Briefing Paper 04195, January 2020

285 HC Deb, 4 February 2019, col 10

286 Education and Skills Funding Agency, Universal infant free school meals (UIFSM): conditions of grant 2019 to 2020 (June 2019): [accessed 30 June 2020]

287 Department for Education, Free school meals supplementary grant (July 2018): [accessed 30 June 2020]

288 Q 40 (Professor Greta Defeyter)

289 34 (Alison Garnham)

290 Supplementary written evidence from HM Government (ZFP0098)

291 Institute for Fiscal Studies, Universal free school meals are back on the table, (5December 2019): [accessed 30 June 2020] and The Guardian, Free school meals ‘putting pressure on small schools’ budgets, (31 August 2016): [accessed 30 June 2020]

292 Department for Education, Schools, pupils and their characteristics, (27 June 2019): [accessed 30 June 2020] l

293 Institute for Fiscal Studies, Free school meals under universal credit (April 2018): [accessed 30 June 2020]

294 Ibid.

295 Q 39 (Alysa Remtulla)

296 Institute for Fiscal Studies, Free school meals under universal credit (April 2018): [accessed 30 June 2020]

297 Sustain, Free School Meals for All: [accessed 30 June 2020]

298 Q 39 (Dr Mary Bousted)

299 Q 39 (Professor Greta Defeyter)

300 Angus Holford and Birgitta Rabe, Going universal—The impact of free school lunches on child body weight outcomes (6 March 2020): [accessed 30 June 2020]

301 Q 39 (Professor Greta Defeyter)

302 Institute for Fiscal Studies, Universal free school meals are back on the table, (5 December 2019): [accessed 30 June 2020]

303 Ibid. This estimate assumes that spending per meal is protected in real terms. The Labour party subsequently announced plans to extend free school meals to all secondary school pupils whose families receive universal credit, the same offer as proposed by the Liberal Democrats.

304 Ibid.

305 Q 39 (Professor Greta Defeyter)

306 Institute for Fiscal Studies, Universal free school meals are back on the table (5 December 2019): [accessed 30 June 2020]

307 Q 40 (Professor Greta Defeyter). See also Q 5 (Anna Taylor).

308 Q 5 (Anna Taylor)

309 Q 40 (Professor Greta Defeyter)

310 Supplementary written evidence from HM Government (ZFP0098)

311 Q 24 (Sarah Lewis)

312 Q 5 (Anna Taylor)

313 Q 40(Professor Greta Defeyter)

314 The standards do not apply to academies which opened from 2020 and agreed funding prior to June 2014.

315 Department for Education, School food in England: Advice for governing boards (March 2019): [accessed 30 June 2020]

316 School Food Standards, A practical guide for schools their cooks and caterers (2014), p 2: [accessed 30 June 2020]

317 Ibid.

318 The Requirements for School Food Regulations 2014, Schedule 2 (SI 2014/1603)

319 HM Government Written evidence (ZFP0079)

320 Q 17 (Sarah Lewis)

321 HM Government, Childhood Obesity: A Plan for Action, (August 2016) p 9: [accessed 30 June 2020]

322 HM Government, Childhood Obesity: A Plan for Action Chapter 2, (2018): p 10: [accessed 30 June 2020]

323 The Requirements for School Food Regulations 2014 (SI 2014/1603)

324 Q 24 (Sarah Lewis)

325 Ibid.

326 Supplementary written evidence from HM Government (ZFP0098)

327 Q 3 (Anna Taylor)

328 Supplementary written evidence from HM Government (ZFP0098)

329 Q 43 (Alysa Remtulla)

330 Q 59 (Nicky Dennison)

331 Written evidence from LACA (ZFP0048)

332 Q 43 (Dr Mary Bousted)

333 Department for Education, Thousands more school children receiving a nutritious breakfast, (2 November 2018): [accessed 30 June 2020]

334 Q 41 (Alysa Remtulla)

335 Q 41 (Alysa Remtulla) & Department for Education, Free meals and summer holiday activities for children, (4 January 2020): [accessed 30 June 2020]

336 Q 41 (Alysa Remtulla)

337 Institute for Fiscal Studies, Breakfast clubs work their magic in disadvantaged English schools, (4 November 2016): [accessed 30 June 2020]

338 Katie Adolphus, Clare Lawton, and Louise Dye, ‘Associations Between Habitual School-Day Breakfast Consumption Frequency and Academic Performance in British Adolescents’, Frontiers in Public Health, vol 7, (November 2019) p 283: [accessed 30 June 2020]

339 Q 46 (Alysa Remtulla) and Department for Education, The economic value of key intermediate qualifications: estimating the returns and lifetime productivity gains to GCSEs, A levels and apprenticeships (December 2014) pp 8–9: [accessed 30 June 2020]

340 Written evidence from Professor Louise Dye, University of Leeds (ZFP0058)

341 Institute for Fiscal Studies, Breakfast clubs work their magic in disadvantaged English schools (4 November 2016): [accessed 30 June 2020]

342 Written evidence from the Labour Hunger Campaign (ZFP0052) and Blackpool Council (ZFP0036)

343 Written evidence from Blackpool Council (ZFP0036)

344 Written evidence from Exeter Foodbank (ZFP0059)

345 Written evidence from Magic Breakfast (ZFP0076) and NAHT, ‘#NAHTconf: “Embarrassed and ashamed” the impact of austerity on England’s schoolchildren’,: [accessed 30 June 2020]

346 Following the 2017 election, this pledge was dropped. ‘Conservatives abandon manifesto plan for free school breakfasts’, The Independent (26 July 2017): [accessed 30 June 2020]

347 Q 38 (Professor Greta Defeyter). See paragraph 59 for related statistics.

348 Q 39 (Alysa Remtulla)

349 Ibid.

350 Q 41 (Alysa Remtulla)

351 Department for Education, Free meals and summer holiday activities for children, (4 January 2020): [accessed 30 June 2020]

352 Q 41 (Alysa Remtulla)

353 See paragraph 93.

354 Written evidence from Blackpool Council (ZFP0036)

355 Institute for Fiscal Studies, Educational gaps are growing during lockdown (18 May 2020): [accessed 30 June 2020]

356 Written evidence from Blackpool Council (ZFP0036)

357 Supplementary written evidence from HM Government (ZFP0098)

358 Q 55 (Nicky Dennison)

359 Q 42 (Alysa Remtulla)

360 Written evidence from the Labour Hunger Campaign (ZFP0052)

361 Q 90 (Rob Percival)

362 Q 76 (Dr Adrian Morley)

363 Q 86 (Kath Dalmeny)

364 Q 51 (Tom Andrews)

365 Q 83 (Kath Dalmeny)

367 Department for Environment, Food and Rural Affairs, The Government Buying Standard for Food and Catering Services: [accessed 30 June 2020]

368 Written evidence from HM Government (ZFP0079)

369 Ibid.

370 Q 93 (Rob Percival)

371 Department for Environment, Food and Rural Affairs, The Government Buying Standard for Food and Catering Services, ( [accessed 30 June 2020]

372 Written evidence from HM Government (ZFP0079)

373 NHS Health Scotland, Evaluation of the implementation and impact of the Healthcare Retail Standard in Scottish hospitals and other NHS facilities in 2017 (January 2019) [accessed 30 June 2020]

374 Q 63 (Dr Louise Marshall)

375 NHS, The Eatwell Guide: [accessed 30 June 2020]

376 Written evidence from Dr Clare Pettinger assisted by members of the Food Plymouth partnership (ZFP0033)

377 Supplementary written evidence from HM Government (ZFP0098)

378 Written evidence from HM Government (ZFP0079)

379 Q 4 (Anna Taylor)

380 Q 69 (Kate Halliwell)

381 Q 4 (Anna Taylor)

382 The Food Foundation, The Broken Plate (February 2019) p 14: [accessed 30 June 2020]

383 Q 4 (Professor Tim Lang)

384 Department of Health and Social Care, Restricting promotions of food and drink that is high in fat, sugar and salt (updated April 2019): [accessed 30 June 2020]

385 See, for example, written evidence from the Nuffield Council on Bioethics (ZFP0045), Cllr Evelyn Akoto, Southwark Council (ZFP0024), Sustain (ZFP0071), the Faculty of Dental Surgery at the Royal College of Surgeons (ZFP0010), and the Food Ethics Council (ZFP0054)

386 Q 16 (George Butterworth)

387 Written evidence from the Faculty of Dental Surgery at the Royal College of Surgeons (ZFP0010). See also Obesity Health Alliance, Protect children from all junk food advertising, say health experts - and parents agree (28 February 2019): [accessed 30 June 2020]

388 Q 69 (Dr Hilda Mulrooney)

389 Q 63 (Professor Susan Jebb)

390 Q 24 (Jenny Oldroyd)

391 Written evidence from the Faculty of Dental Surgery at the Royal College of Surgeons (ZFP0010)

392 Q 103 (Henry Dimbleby) and written evidence from the Food and Drink Federation (ZFP0009)

393 Q 69 (Mhairi Brown)

394 Public Health England, Health Matters: obesity and the food environment (31 March 2017): [accessed 30 June 2020]

395 Written evidence from the Faculty of Dental Surgery at the Royal College of Surgeons (ZFP0010)

396 Q 12 (Dr Christina Vogel) and Christina Vogel, et al., Education and the Relationship Between Supermarket Environment and Diet (August 2016): [accessed 30 June 2020]

397 Q 15 (Dr Christina Vogel)

398 Regulatory Policy Committee, Restricting checkout, end-of-aisle, and store entrance sales of food and drinks high in fat, salt, and sugar (HFSS) (22 February 2019): [accessed 30 June 2020]

399 Ibid.

400 Department of Health and Social Care, ‘Restricting promotions of food and drink that is high in fat, sugar and salt’, (updated April 2019): [accessed 30 June 2020]

401 Written evidence from HM Government (ZFP0079)

402 Department of Health and Social Care, Consultation on restricting promotions of products high in fat, sugar and salt by location and by price (January 2019) [accessed 30 June 2020]

404 Department of Health and Social Care, Restricting promotions of food and drink that is high in fat, sugar and salt, (Updated April 2019): [accessed 30 June 2020]

405 Q 89 (Mark Laurie)

406 Q 13 (Dr Christina Vogel)

407 Public Health England, Healthy people, healthy places briefing, Obesity and the environment: regulating the growth of fast food outlets (March 2014) p 4: [accessed 30 June 2020]

408 Ministry of Housing, Communities & Local Government, The National Planning Policy Framework, CP 48 (February 2019): [accessed 30 June 2020]

409 Q 58 (Nicky Dennison)

410 House of Commons Library, Local authorities’ public health responsibilities (England), Standard Note, SN06844, March 2014

411 Q 58 (Dr Katie Cuming)

412 Q 58 (Dr Katie Cuming)

413 Q 2 (Anna Taylor)

414 Q 24 (Jenny Oldroyd)

415 Ministry of Housing, Communities & Local Government, Government to grant permission for pubs and restaurants to operate as takeaways as part of coronavirus response, (17 March 2020): [accessed 30 June 2020]. This time limited permitted development right was introduced in March 2020 through a negative Statutory Instrument.

416 Q 109 (Mark Laurie)

417 Q 50 (Alex Holt)

418 Q 51 (Tom Andrews)

419 Q 50 (Tom Andrews)

420 Written evidence from Blackpool Council (ZFP0036)

421 Written evidence from the Centre for Diet and Activity Research (ZFP0038)

422 Q 111 (Mark Laurie)

423 Written evidence from Nourish Scotland (ZFP0064)

424 Written evidence from Kevin Higgins, Advice NI (ZFP0020)

425 Q 3 (Anna Taylor)

426 Q 17 (Jenny Oldroyd)

427 Q 119 (Jo Churchill MP)

428 Department of Health and Social Care, Advancing our health: prevention in the 2020s: consultation document (22 July 2019): [accessed 30 June 2020]

429 Written evidence from HM Government (ZFP0079)

430 Department of Health and Social Care, Calorie labelling for food and drink served outside of the home (updated October 2018): [accessed 30 June 2020]

431 Q 62 (Professor Susan Jebb)

432 Written evidence from the Obesity Group of the British Dietetic Association (ZFP0035)

433 WRAP, Updating Guidance to Food Businesses on the Application of date Marks and Related Advice (April 2017): [accessed 30 June 2020]

434 WRAP, Household food and drink waste: A product focus (June 2014): [accessed 30 June 2020]

435 Arla, Nearly a third of consumers unnecessarily binning food due to label confusion, (5 September 2019): [accessed 30 June 2020]

436 Q 49 (Steve Butterworth). ‘Best before’ dates are more about quality than safety and indicate when food may have passed its prime quality condition: Mr Butterworth was suggesting that these dates err on the side of caution. See also written evidence from City Harvest (ZFP0055).

437 Q 76 (Dr Tara Garnett)

438 Written evidence from LACA (ZFP0048)

439 Written evidence from Dr Rebecca Sandover (ZFP0056)

440 Written evidence from the Royal Borough of Greenwich Council, Corporate Services (ZFP0015)

441 Written evidence from Dr Clare Pettinger assisted by members of the Food Plymouth Partnership (ZFP0033)

442 Written evidence from Dr Kayleigh Garthwaite (ZFP0022)

443 Written evidence from Leeds Food Aid Network (ZFP0018)

444 Written evidence from Cllr Evelyn Akoto, Cabinet Member for Community Safety and Public Health, Southwark Council (ZFP0024)

445 Marloes Rietmeijer-Mentik, et al, ‘Difference between parental perception and actual weight status of children: a systematic review’, Maternal & Child Nutrition vol 9, Issue 1, (October 2012):–8709.2012.00462.x [accessed 30 June 2020]

446 Written evidence from Dr Hilda Mulrooney, Obesity Group of the British Dietetic Association (ZFP0035)

447 Written evidence from Bags of Taste Limited (ZFP0029)

448 Written evidence from the Nuffield Council for Bioethics (ZFP0045)

449 Written evidence from Blackpool Council (ZFP0036)

450 Written evidence from the Soil Association (ZFP0016)

451 HM Government, Childhood Obesity: A Plan for Action (August 2016), p 8: [accessed 30 June 2020]

452 Department for Education, PE and sport premium for primary schools (November 2019): [accessed 30 June 2020]

453 NHS, Change4Life: [accessed 30 June 2020]

454 Written evidence from City Harvest (ZFP0055)

455 Q 62 (Professor Susan Jebb)

456 Written evidence from Dr Christian Reynolds (ZFP0077) and Association of Convenience Stores (ZFP0050)

457 Q 47 (Alex Holt)

458 Written evidence from Health Action Campaign (ZFP0046)

459 Q 89 (Rob Percival)

460 Q 103 (Henry Dimbleby)

461 Q 13 (Dr Christina Vogel)

462 Written evidence from Professor Dominic Harrison and Emma Savage (ZFP0027)

463 Q 13 (Dr Christina Vogel)

464 Written evidence from Dr Clare Pettinger assisted by members of the Food Plymouth Partnership (ZFP0033)

465 Written evidence from City Harvest (ZFP0055)

466 Written evidence from the Centre for Diet and Activity Research (ZFP0038)

467 Written evidence from The Institute of Developmental Sciences, Faculty of Medicine, University of Southampton, MRC Lifecourse Epidemiology Unit and the NIHR Biomedical Research Centre, University of Southampton and University Hospital Southampton NHS Foundation Trust (ZFP0080) and Health Action Campaign (ZFP0046)

468 Q 62 (Professor Susan Jebb)

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