Criterion 3: What are their recommendations to curb the power of corporates who make and promote products that damage human and planetary health?

None of the recommendations made will curb the power of these corporates, the third of our five criteria in assessing the National Food Strategy.

We don’t underestimate the challenge of taking them on. Or in the difficulties in identifying, let alone facing down corporate lobbying power.

This blogpost has three parts:

  1. Some of the assumptions the team made that prevented them from recognising what needs to be done
  2. Why their recommendations affecting corporate activities will be limited or even counterproductive
  3. A three-stage process that could be used to meet the challenge


Part 1: Some of the assumptions the team made which prevented them from recognising what needs to be done
As a means to identify some of the assumptions the National Food Strategy team has made, we examine seven statements from the third and fourth paragraphs of the Executive Summary.

These seven statements, highlighted in this screen-grab  of the relevant page, are examined below:

Statement 1:
“unhealthy food is more popular”

  • Product sales will go up if permitted to be aggressively marketed and promoted; we know, for example, that Coca Cola alone has spent an average of $4bn per year on advertising and promotion over the last six years.
  • If some people are unable to access sufficient, safe, nutritious food, they will have diet-related morbidities. Nutrient-dense perishable food inevitably costs more than low-nutrient, long shelf-life foods. Climate change, population pressures and agri-food resource depletion means competition for these foods, already intense, will increase, with knock-on impact on prices.
    • As there are a growing number of people in the UK (millions of us already) who do not have economic access to nutrient-dense fresh produce. People have to eat, so cheap-to-produce unhealthy foods will have growing sales.
  • Hence a National Food Strategy has to address issues of access or, if their Terms of Reference do not allow this, they should clearly state this is so, as we pointed out here.
  • Plus, there are some products currently classified as ‘food’, that are addictive, the so-called ‘drug-foods’. If society controls these products and the companies that make and promote them, consumption and sales will reduce — as has happened with tobacco and alcohol. (1)

Statement 2:
The human appetite evolved in a world where calories were hard to come by” 

  • Anthropological records suggest this is highly unlikely: see, for example, James C Scott’s readable Against the Grain: A deep history of the earliest states. The challenge of accessing calories per se occurred after humans developed agriculture. Agriculture enables powerful elites to control access to storable calories (i.e. grain) for urban populations. Urbanisation began only a few thousand years ago, a blip in our evolutionary history.
  • There is, however, evidence that all living creatures, ourselves included, search for their daily need for protein (which we can’t store, and excrete any surplus), and will continue eating until this need is met; see the research work of Professors David Raubenheimer & Stephen Simpson, and/or their layperson’s guide to their work, Eat Like the Animals: What nature teaches us about healthy eating.

Statement 3:
We are predisposed to pounce on any food that is high in fat and sugar.”

  • Predisposed? Pounce?
  • Sugar is addictive. We don’t know of any evidence that fats are.

Statement 4:
And once we start eating this kind of food, we are programmed to keep going; our hormones take longer to send out satiety signals (the feeling of fullness) than they do on lower-calorie foods.”

  • Programmed?
  • Satiety signals: Satiety is not the same as a feeling of fullness.
    • Hormonal responses to food intake is complex. As said above, appetite appears dependent on protein intake.
    • Moreover, a high intake of fibre in a meal, which doesn’t have any calories, literally fills you up providing a physical sensation of fullness let alone any hormonal responses. As well a sensation of fullness, fibre has other significant benefits, notably to a healthy gut-biome and keeping you regular.

Statement 5:
Because there is a bigger market for unhealthy food, companies invest more into developing and marketing it

  • Markets don’t exist as a separate entity from the organisations that are permitted to operate within them. If permitted to do so, corporations will develop a market to make profits from their products.
  • Markets for unsafe (or, in this instance, unhealthy) products will expand unless and until corporations are prevented from so doing. Direct prohibitions, financial incentives, regulation and its enforcement change what products are allowed to be sold in the market.
    • Hence we have controls on inter alia who can practice/sell certain services and products ranging from prescription drugs to medical services, from cars and their post-sale condition to electrical goods, equipment & fitting, and from food and beverage products to their delivery to the customer via retail and hospitality outlets.

Statement 6:
Highly processed foods — high in salt, refined carbohydrates, sugar and fats, and low in fibre – are on average three times cheaper per calorie than healthier foods

  • The term ‘highly processed foods’ is often used pejoratively, as here. Yet all foods and beverages are processed to some degree, even the carrot dug out of your garden. Indeed, fresh produce goes through many processes before reaching the retail checkout in order to keep it safe and nutritious. (2)
  • A clearer definition of what is meant by ‘highly processed’ and ‘healthier’, would be helpful as both are vague terms and mean different things to different people. We would then know what was being compared to what.

Statement 7:
This is one reason why bad diet is a particularly acute problem among the least affluent.”

  • Given the above, this ‘one reason’ is based on weak or non-existent evidence.
  • As we argued in the blogpost about our first criterion here, the reason why a bad diet is a particularly acute problem among the less affluent is because, well, they are less affluent to the point that they don’t have the income to buy what is they need for a healthy and active life.


A brief note about calories, saturated fat and salt in the Statements 1-6:
In his book Spoon-Fed: Why almost everything we’ve been told about food is wrong (Penguin, 2020), Tim Spector challenges some of the assumptions made by the National Food Strategy team.

It is surprising the National Food Strategy document didn’t consider any of the content in this book, given that Spector is listed on page 263 as one of the ‘many experts‘ who have been ‘generous with their time and wisdom‘, and the book is listed on page 273 in their ‘additional reading list’ as one of the key texts we have drawn on in writing this report but are not specifically mentioned elsewhere.

Of particular interest are the following four chapters, and their supporting literature:
— Chapter 3: Calorie counting doesn’t add up. Myth: Calories accurately measure how fattening food is
— Chapter 4: The big fat debate. Myth: Saturated fat is a major cause of heart disease
— Chapter 5: The bittersweet hidden agendaMyth: Sugar free foods and drinks are a safe way to lose weight
— Chapter 12: More than a pinch of salt: Myth: We all need to reduce our salt intake


Part 2: Why their recommendations affecting corporate activities won’t be effective
Five of their recommendations affect corporate activities, and our comments on each one of them are as follows:

Their recommendation 1
Introduce a Sugar and Salt reformulation Tax. Use some of the revenue to help get fresh fruit and vegetables to low-income families

  1. Asking corporates to reformulate will achieve little, if anything. It does nothing to curb their power and, moreover, some reformulations may damage human health in different ways, as with non-sugar sweeteners, or affect different groups of people, as with some salt alternatives.
  2. Reformulation is highly unlikely to make difference to the damage to planetary health these kinds of products make; e.g. low salt crisps and diet drinks still use up the increasing scarce agri-food resources of water, land and soils — plus the energy it takes to make, market and distribute them.
  3. Their estimate is this tax could raise £2.9bn-£3.4bn per year for the Treasury. If all of the revenue is used to meet the costs of diet-related morbidities, it would reduce these costs, at the most, by about 3%. (3) (4)
  4. Low-income families need money, not “help” to get fruit and vegetables to them via an unspecified means; see our response to our first criterion here.

Their recommendation 2
Introduce mandatory reporting for large food companies

  1. ‘Large’ food companies? How large?
  2. What counts as a ‘food company’? Does it include beverage companies?
    See the BMJ Response cited below for a precise means to identify those corporates the authors argue should be treated differently from other companies in the sector.
  3. And to what purpose is this mandatory reporting? Is the rationale contained in this sentence on page 147: voluntary measures work best if they are monitored and subject to public scrutiny’. If so, how would mandatory reporting be effective in this context? (5)

Their recommendation 11
Invest £1 billion in innovation to create a better food system

  1. Unless and until those corporates as identified in the BMJ Rapid Response are excluded from participation on research programmes, we will not have a ‘better food system’ at the scale we need.
  2. We also have concerns about the use of such funds to create ‘synthetic’ foods (6)
  3. As said above, reformulation is not the answer to this challenge.

Their recommendation 12
Create a National Food System Data programme

  1. It’s difficult to assess where the value of such a programme would be from the terms in which it is expressed here.
  2. We also have concerns about how independent it would from the Government influence.

Their recommendation 14
Set clear targets and bring in legislation for long-term change

  1. They recommend that the Food Standards Agency (FSA) has a new role with specific duties. Will, however, the £5m earmarked for implementing all of recommendation 14 be enough, given how stretched the FSA already is?
  2. Also, it can be argued the FSA does not have the necessary independence from the Government to perform this role. (7)


Part 3: A three-stage process to meet the challenge
What could be done can be succinctly summarised thus:

  • First, identify the products which, when produced in quantity, then distributed and consumed, damage human and planetary health.
    • The identification process should be based on sound evidence.
    • And include metrics about what ‘in quantity’ precisely means.
  • Then identify the corporates that make and promote them.
  • Finally, decide what measures to take to curb the activities of these corporates, and monitor the effects of the measures taken. (8)


(1) See this BMJ Rapid Response It is time to act against drug-foods, for the health of the population and the planet. 14 September 202o for a definition of what the drug-foods are, the means to identify the corporations that make and promote them, and recommendations as to how their activities can be curbed.

(2) Many people do use the the terms ‘highly processed’ or ‘ultra-high processed’ loosely. Nonetheless, we should expect the National Food Strategy to define the term, as they are using so much. (See also this post on 19th April: How [not] to talk about [ultra-high] processed food in response to a tweet from Bee Wilson.)

(3) There are a range of estimates about the costs of diet-related morbidities, the lowest of which (based on 2014 figures) is £96bn. See our post: What does this food sector ‘balance sheet’ tell us? (July 2019).

(4) Fiscal measures are already used to curb corporate behaviours and reduce demand for alcohol and tobacco products, and for fossil fuels. The participants on our 2020 scenarios exercise proposed an Excise Duty on food and beverage products that carry standard-rate VAT, and a Food Resilience Levy, similar in remit and purpose of the Climate Change Levy; see page 3 in One Scenario: Buffer contingency stocks (November 2020).

(5) See our report: What works: Regulation or voluntary schemes in the food sector? (2015) which gives results of research by the RSPB.

(6) Our concerns are explained in this post: The perils of synthetic ‘food’ products and cheap carbs.

(7) Hence our recommendation for a independent UK Food Security Institute here (2018), and a Committee on Food Security here (2020)

(8) See again the BMJ Rapid Response It is time to act against drug-foods, for the health of the population and the planet cited in footnote (1).

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