Thursday, 23 November 2017

Five reasons why mandatory food reformulation is a terrible idea

I've written a short briefing paper for Epicenter about why state-sanctioned food reformulation, as currently being practised by Public Health England, is a bad idea. You can download it here or read it below....

Health by stealth

The food industry is highly competitive and innovative. Its products are being constantly reviewed and reformulated to maintain or gain market share. As with other fast moving consumer goods, the vast majority of new food products are withdrawn from the market within a year while some leading brands have been popular for decades. Manufacturers are naturally reluctant to modify their most trusted brands, but are generally happy to create ‘spin-off’ products, such as low-sugar or organic alternatives.

Food and soft drinks appeal to consumers on the basis of four key factors: taste, price, convenience and health. Historically, consumers have wanted energy-dense food at the lowest price but as countries become more affluent the problems of scarcity and hunger are replaced by the problem of obesity. Many consumers want to consume fewer calories but - crucially - they do not want to sacrifice flavour. This poses a challenge to the food industry because human beings have evolved to find calorific ingredients such as fat and sugar tasty.

In recent decades, the food and soft drinks industries have spent vast sums of money producing and marketing products which can be branded as ‘healthy’ or ‘healthier’. Taking their cue from nutritional science, they have reformulated products with less fat, salt and sugar to appeal to more health conscious consumers. In most cases, they have created alternative brands to give consumers more choice but some flagship brands have also been subtly altered.

Many of the alternative varieties have flopped, but some have succeeded. Diet soft drinks were niche products 40 years ago but are now extremely popular. Various sweeteners, including Stevia, aspartame and saccharine, have been used to mimic the taste of sugar. Full fat milk used to be the norm but skimmed and semi-skimmed milk now make up 80 per cent of milk sales in the UK (semi-skimmed has less than half the fat content and two-thirds of the calories) (Munday and Bagley 2017). Processed food with less salt, sugar and/or fat has proliferated and many low calorie products are successfully marketed as ‘light’ or ‘diet’ variants.

The supermarket chain Tesco claims to have ‘removed over 8,000 tonnes of sugar, fat and salt from over 2,000 products’ since January 2016 (Ewart 2017). In a survey of 102 global food companies, the Consumer Goods Forum (2017: 8) found that 180,000 products on shop shelves in 2016 had been ‘formulated to support healthier diets and lifestyles’. Clearly, it is possible to reformulate food products without losing customers. So far, these innovations have been mostly driven by consumer preferences and without government intervention, but there is growing interest in mandatory targets being set to ensure that reformulation continues.

State-sanctioned reformulation is not without historical precedent. A few countries, such as Denmark, have placed a legal limit on trans fat levels in food (although most countries have seen a sharp decline in trans fat consumption without state intervention). Several countries, such as Australia, require minimum levels of folic acid in bread to prevent children being born with spina bifida. British law requires calcium carbonate, thiamin and nicotinic acid to be added to most flour. Ireland and a number of US states have laws requiring drinking water to be fluoridated to prevent tooth decay.

But using the law to restrict the use of core ingredients for the purpose of reducing the calorie content of food is a new development. As yet, no government has legislated in this area. In Britain, a salt reduction scheme began in 2006 as a voluntary initiative between government and industry. This is believed to have resulted in a 5.1 per cent reduction in salt consumption by 2011 (Griffith et al. 2016: 2). The EU’s Framework for National Salt Initiatives set a target of reducing salt content in food by 16 per cent between 2008 and 2012, and its Framework for National Initiatives on Selected Nutrients proposed a 10 per cent reduction in sugar and saturated fat content by 2020. Participation in both EU projects by member states was entirely optional.

Although the European Commission reported in 2012 that all member states had some form of salt reduction scheme at work, it said that ‘the only country that had reported systematically engaging with and tracking the actions of individual companies through commitments and action plans’ was the UK. The British government has since followed up its anti-salt activity with an ambitious sugar reduction plan that aims for a decline in sugar content in food by 20 per cent by 2020. This scheme, which involves similar targets for fat and calories in its next phase, is technically voluntary but the government has threatened legislation if its targets are not met and has promised to ‘name and shame’ companies which fail to meet them. A sugar levy is also being introduced (in April 2018) with the specific aim of making companies reduce sugar content in soft drinks. The programme is therefore somewhat coercive.

Co-ordinated by Public Health England, this ‘health by stealth’ approach has only been underway since 2016 but it has already highlighted some of the problems with mandatory reformulation:

1. It can penalise companies that have already made significant changes to their products

As mentioned above, food companies have been reformulating products to reduce sugar, fat and calories for years, without pressure from government. Some degree of reformulation is often possible without having a noticeable effect on taste, but beyond a certain point the product becomes unpalatable. By requiring all companies to meet the 20 per cent target, Public Health England is effectively punishing firms that have already reduced sugar content. Those which have not modified their products will find their task easier, leaving them with the commercial advantage of having a tastier product by 2020.

2. It can lead to smaller products

In 2014, a newly formed pressure group called Action on Sugar began whipping up concern about the amount of sugar in savoury products such as ready meals, bread and pasta sauce. The sugar reduction programme includes these products but has also been extended to include items such as chocolate, cakes, biscuits and confectionery for which sugar is absolutely integral. Consumers do not generally find artificial sweeteners to be satisfactory substitutes for sugar in such products and so the only way sugar content can be reduced is to make the product smaller, leading to ‘shrinkflation’. Since prices are usually not reduced when the products is shrunk, consumers naturally feel exploited. The assumption that companies are making excess profits is not necessarily fair - reducing portion sizes requires capital investment in new machinery and packaging - but consumers get a worse deal nonetheless.  

3. It restricts choice by effectively banning the original product

Under consumer-driven reformulation, companies typically add a new low-sugar, low-fat or low-salt product to the market in addition to the original brand. This allows consumers freedom of choice. State-driven reformulation, by contrast, requires modification of the entire product range and effectively removes the original recipe from the market. This is a restriction of choice and is unfair to consumers, many of whom neither want nor need to restrict their calorie intake.

4. It can be unpopular

Because of the restriction of choice and shrinkflation (see above), reformulation can be unpopular with the public. Advocates of reformulation point to various products which were modified to reduce salt content without the public noticing or objecting. But reducing salt from savoury products is a relatively simple process compared with the task of removing sugar from sweet products. People tend to notice when sugar is removed from their trusted brands. The soft drink Lucozade, for example, had its sugar content slashed in April 2017, leading to thousands of complaints and a drop in sales (Fletcher 2017).

5. The targets can unrealistic and arbitrary

The UK’s target of reducing sugar by 20 per cent by 2020 seems to be based on nothing more than numerology. It is twice as challenging as that proposed by the EU and is equally arbitrary. Rather than make a realistic assessment of what can be achieved, the UK government seems to have picked a figure that fits in with the date of the deadline. Public Health England has no expertise in food manufacturing and seems to have been overly optimistic about what can be achieved in such a short timeframe. The 20 per cent target is a classic top-down, command and control diktat.

Conclusion

Food can be reformulated to be made less calorific but the process is by no means simple it can be practically impossible for some products. Governments can force companies to change their products but they cannot force consumers to buy them. Gradual reductions in salt, fat and sugar can sometimes be made, but there is a limit to how far reformulation can go before consumers reject it.

Many consumers do not enjoy the taste of artificial sweeteners are are not interested in reducing their sugar intake. Mandatory reformulation is a way for governments to bypass consumer preferences by putting pressure on manufacturers. The pioneering British scheme will show how far this coercive approach can be pushed before it creates a public backlash. It remains at an early stage and many of the newly reformulated products have not yet reached the market, but it would not be surprising if consumers respond negatively to the changes. 







Consumer Goods Forum (2017) Health and Wellness Progress Report. Deloitte Global

Ewart, K. (2017) Tesco continues work to reduce sugar, salt and fat in own label products. Tesco. https://www.tescoplc.com/news/blogs/topics/health-reformulated-tesco-products/

Fletcher, I. (2017) Lucozade sales plummet after brand dramatically cuts amount of sugar in drinks following tax levy. Mirror 4 November

Griffiths, R., O’Connell, M. and Smith, K. (2016) The importance of product reformulation versus consumer choice in improving diet quality. Economica 84(333): 34-53

Munday, H. and Bagley, L. (2017) The history of food reformulation. Food Science and Technology: http://fstjournal.org/features/31-3/food-reformulation


Friday, 17 November 2017

Plain packaging for alcohol (again)

The week's Lancet has an editorial about alcohol. It doesn't even bother to acknowledge the temperance lobby's victory in the minimum pricing court case. They are already moving on to the 'next logical step'.

Here are the closing sentences...

There is no excuse to ignore regulatory interventions for access, advertisements, and unit cost that are shown to reduce alcohol consumption. Like tobacco, the longer the delay in effective control, the more severe future interventions for alcohol will need to be. It is not unimaginable that bottles of Château Mouton Rothschild, which once bore the artwork of Salvador Dali and Pablo Picasso, might one day be required to have plain packaging and images of oesophageal cancer or a cirrhotic liver.

It only seems like yesterday when those of us who predicted this slippery slope were portrayed as paranoid libertarians who had fallen for a deceptive tobacco industry argument.

Freedom is indivisible and killjoys never sleep.

Europuppets defunded

A few years ago I wrote a report called Europuppets about the EU's exceptional largesse towards 'civil society' organisations of which it approves. Quite a few of them are in the business of punishing consumers under the pretext of 'public health', including the European Public Health Alliance (EPHA).

Over the years, EPHA has lobbied for minimum pricing, taxes on food and the Tobacco Products Directive, so I was delighted to hear that the European Commission is going to stop funding it next year.

In late October 2017, EPHA was informed that it had not been selected to receive an operating grant from the European Commission’s Health Programme, as from January 2018.

Such an occurrence has always been a possibility and the EPHA Board has undertaken contingency planning for several years. While this has some immediate implications for the organisation, the board and secretariat team are implementing plans to ensure EPHA’s long-term sustainability.

EU funding accounts for two-thirds of their income so hopefully their long-term sustainability is out of the question, unless Pharma steps in.

And the good news doesn't end there. The European Network for Smoking and Tobacco Prevention (ENSP) has been unsuccessful in applying for EU cash and the neo-prohibitionists at Eurocare have been defunded. The former relied on EU taxpayers for more than half of its budget so hopefully it will wither and die before it can bring about its 'tobacco endgame strategy'.

Not a bad start. The full list of unsuccessful grant applications can be read here. I don't recognise them all by the abbreviations so if you spot any gems, let me know in the comments.

Have a great weekend!

Thursday, 16 November 2017

Looking forward to minimum pricing

Now that the SNP are free to introduce minimum pricing, it's worth looking at what we're supposed to expect.

Back in 2009, when minimum pricing became a live issue, the Sheffield modellers predicted that a minimum price (of 40p in those days) would result in a drop in alcohol consumption of 2.7 per cent and a decline in alcohol-related deaths of 40 in the first year, rising to 210 per annum after ten years.

Given the 'public health' lobby's absolute obsession with this policy in the years since, we must assume that they regarded these as game-changing numbers. Imagine if alcohol consumption fell by 2.7 per cent! What a victory for health that would be.

We don't need to imagine because consumption fell by much more than that after 2009 without any notable policy change. In 2007, Scots were drinking 11.8 litres of alcohol a year. By 2016, this had fallen to 10.5 litres. This is a drop of 11 per cent - four times as great as the decline Sheffield said would occur if minimum pricing was introduced.

You probably haven't much about this, but if minimum pricing had been introduced in 2009 you would have never heard the end of it. Not only did alcohol consumption fall by 11 per cent, but the alcohol-related mortality rate fell from 34.6 per 100,000 to 30.0 per 100,000 for men and from 16.7 per 100,000 to 9.0 per 100,000 for women. This is a drop of 13% and 46% respectively.

It is interesting to see the decline in both drinking and alcohol-related deaths in Scotland in recent years and yet I do not see much interest in it from the denizens of 'public health', presumably because they can't take credit for it. 

Here are the alcohol-related deaths for men and women. Scotland is the top (light blue) line.

It's worth noting that the UK as a whole has seen a decline alcohol consumption of around 18 per cent since 2004 and yet Scotland is the only part of it to have seen a significant fall in alcohol-related deaths. This implies that the fall in alcohol consumption in Scotland has been driven by heavy drinkers consuming less whereas the fall in England, Wales and Northern Ireland has been driven by moderate drinkers consuming less and more people becoming teetotal.

Looking at the actual number of deaths below, you can see that mortality increased sharply between 1993 and 2003 before falling by about 20 per cent. It has not followed drinking trends perfectly, however. Note that there was a relatively large number of deaths in 2016 despite per capita consumption being at a twenty year low.

The latest Sheffield predictions for Scotland predict that a 50p unit price will reduce consumption by 3.5% and will reduce the number of deaths by 58 in the first year and by 102 per annum after ten years. This is what the SNP and its allies have been fighting for all this time. This is the promised land.

But despite all the wild celebrations from the neo-temperance lobby yesterday, these projected outcomes are so trivial that they would get lost in the noise of the data. If there is a 3 or 4 per cent downturn in per capita consumption in the first year of minimum pricing, you could plausibly attribute it to minimum pricing, but (a) it could just as easily be part of the longer term decline, and (b) so what?

The aim of the policy is to reduce alcohol-related deaths, but if minimum pricing did 'save' 58 lives, it would be impossible to tell from looking at the numbers because they fluctuate by more than that on a regular basis. Between 2015 and 2016, for example, they rose by 115 for no obvious reason. Between 2011 and 2012 they fell by 167.

Regardless of whether the figures rise, fall or stay the same over the next few years, it is inevitable that a regression model will be published - probably by the monopoly providers at Sheffield University - claiming that there were fewer deaths than there would have been in the absence of the policy. Such a regression model will be politically driven rubbish, but even if someone made a serious attempt to create a regression model, it would be impossible because they would not be able to project future trends. Why? Because they don't know the reason for the recent trend.

The stark reality is that the projected impact of minimum pricing, exaggerated though it almost certainly is, amounts to a rounding error too small to be seen with the naked eye. Even if it does everything its advocates claim it will, the impact of this supposedly world-leading policy will be too small to measure. The policy of doing nothing and selling alcohol at 'pocket money prices' in the last decade seems to have been vastly more successful than the most optimistic projections of Sheffield's activist-academics. 

Wednesday, 15 November 2017

Minimum pricing can now happen before Brexit

The UK Supreme Court has said that minimum pricing is legal under the ridiculous carve out that says that free trade doesn't matter if a policy is designed to protect ‘health and life’, ’public morality’, ‘public policy’ and ‘public security’ (ie. anything). The last reason to stay in the EU has disappeared.

It doesn't really matter for the UK because we're leaving but it's a shame for other EU countries. Now all we can do is see what happens. The clowns at Sheffield University have got the commission to evaluate the policy (quelle surprise) and they will obviously say that it's been a terrific success, but some serious people should be also be able to get hold of the data.

In the meantime, I've written a quick article for Spectator Health. Do have read of it.

Monday, 13 November 2017

#AlcoholAwarenessWeek

Alcohol Awareness Week has returned for another year. It is a scheme dreamt up by the likes of Alcohol Concern to lobby for minimum pricing, tax rises and advertising bans while purporting to educate the public about drinking.

Thanks to the myriad lies of the neo-temperance movement, there is certainly room for education. Here are ten things that people deserve to know for starters...

1. The theory that underpins the neo-temperance lobby's 'whole population' approach is a demonstrably false and self-serving delusion.

2. The lowering of the drinking guidelines in the UK last year was orchestrated by a bunch of anti-alcohol zealots and relied on a model which was changed at the eleventh hour when the original model failed to support the change.

3. Moderate drinkers live longer than teetotallers, on average.

4. And that is not because of the 'sick quitter' effect.

5. Drinkers in Britain pay 40 per cent of all the alcohol duty collected in the EU.

6. Alcohol duty revenues in Britain far exceeds the costs drinking imposes on state services. Drinkers subsidise teetotallers to the tune of £8 billion a year.

7. Britain has never been a particularly heavy drinking country by the standards of other developed nations.



8. The claim that minimum pricing has worked in Canada is based entirely on one man's junk science.

9. Since 2004, per capita consumption of alcohol in the UK has fallen at its fastest rate since the 1930s and is now at the same level as in 1980.

10. Public Health England claimed last year that Britons are drinking twice as much as they were in 1980. This is because Public Health England doesn't know what it's talking about.

Sunday, 12 November 2017

Plain packaging - a gift to the black market


 From Retail Express...

The first counterfeit plain packs of tobacco in the UK have been uncovered by Retail Express and trading standards departments.

Following a tip-off, Retail Express was sold a plain pack counterfeit of a premium brand by a London newsagent for £10.50. The retailer took a legitimate pack out of the gantry and swapped it out with a fake pack, while processing the card transaction.

Doug Love, Hammersmith and Fulham Trading Standards officer warned: “The quality of the counterfeits is so good, unless you know what you are looking for it is incredibly difficult to spot.”

Evidence suggests the quality and prices of the plain pack counterfeits is creating a two-tier illicit trade, with cheap smuggled and counterfeit non-plain packs, and the new plain format illicit packs often passed through at RRP.

The article mentions that the first counterfeit plain packs were uncovered by Trading Standards in July, a mere two months after the new regulations came into full effect. They were found in the north-west and are now 'heading south'. 

If organised criminals want their products on the shop shelves, they've got to be in plain packs otherwise nobody's going to buy them at full price. The great thing about plain packaging - from their perspective - is that they only need to counterfeit one pack. After that, they just need to change the name on the front (all brand names have to be displayed in the same simple font by law) and they've got a full range of brands to sell. Happy days!

Another big 'public health' win. Well done to everybody involved.