26 November 2021

Mini-series: introduction

Summer 2021 saw the publication of Henry Dimbleby’s long-awaited Part 2 of the 'National Food Strategy' ('NFS'). Part 1, released at the height of the Covid-19 pandemic in 2020, whilst well-received, was adjusted to focus on the urgent threats to hunger and health presented by the pandemic. Part 2 of the NFS has seen Dimbleby return to the original brief; 'a broad analysis of the strengths and flaws of the entire food system from farm to fork'. The independent review identifies four strategic objectives that are recommended for adoption by the UK Government as part of its new food and farming strategy:

Objective 1: Escape the Junk Food Cycle to protect the NHS.

Objective 2: Reduce diet-related inequality.

Objective 3: Make the best use of our land.

Objective 4: Create a long-term shift in our food culture.

In this mini-series we will be reviewing each of these objectives and Dimbleby’s recommendations on how they might be met. We will also consider the response from key stakeholders within the sector, and what the Government’s approach might be in their subsequent White Paper (due to be published by the end of January 2022).

Objective 1: Escape the junk food cycle to protect the NHS

What is the Junk Food Cycle? The ‘Junk Food Cycle’ seeks to explain why obesity rates have risen steadily since the 1980s. It moves the blame from the common view that 'we are getting fat and ill because we are too lazy to take exercise, and too ignorant to eat well' and provides a holistic explanation incorporating the connection between history, biology and business.

Dimbleby classifies the Junk Food Cycle as a 'reinforcing feedback loop - a vicious circle', which operates as follows:

  • humans have a biological predilection for calorie dense food...
  • which leads to food companies investing time and money creating high-calorie foods and marketing them to consumers...
  • this enhances: i) sales of high calorie foods and ii) consumer reliance on calorific foods...
  • which results in enhanced company profits and consumer demand, leading to further investment...

...and so the cycle goes on.

Dimbleby highlights that it is not only the consumer that is trapped in the Junk Food Cycle – food companies are too. In essence, if a food company stops creating unhealthy foods, another food company will pick up the mantle. The former will lose its competitive edge, profits will suffer and shareholders will become alienated. As such, the food company is trapped in the cycle as firmly as the consumer.

How do we escape it?

It is clear that the Junk Food Cycle is a complicated issue to address, as the NFS explains: 'Today’s dietary patterns have formed over a period of at least 70 years. We will need long-term political commitments to reverse them.'

According to the NFS, food companies agree with the need to legislate the issue. The NFS notes that companies: 'want to do the right thing, but they need a level playing field.' It quotes Tim Rycroft, a spokesman for the Food and Drink Federation, who says: 'The industry has to be guided by the Government. If the Government says there is a reason why these [foods] are no longer acceptable, of course we will change.'

In an attempt to manufacture this level playing field, the NFS makes three key recommendations:

Recommendation 1:  A sugar and salt tax to encourage businesses to reformulate products. Where products high in sugar and salt cannot be reformulated, the tax on these may be passed on to the consumer to ultimately make unhealthy products more expensive and therefore less appealing. A £3/kg tax on sugar is suggested, which is approximately the same rate as the current Soft Drinks Industry Levy (SDIL).

Recommendation 2: Mandatory reporting by large food companies (250+ employees) of certain data including:

  • sales of food and drink high in fat, sugar or salt (HFSS)
  • sales of protein by type
  • sales of fruit and vegetables
  • sales of products containing major nutrients: fibre, saturated fat, sugar and salt; and
  • food waste.

This requirement would apply to retailers, restaurants and fast food outlets, contract caterers, wholesalers, manufacturers and online ordering platforms.

Recommendation 3: A new ‘Eat and Learn’ initiative for all schoolchildren aged 3 to 18 years, which will be overseen jointly by the Department of Education and new Office for Health Promotion. Funding will be available for schools to implement this change.

What has the response been?

Predictably, industry response to the first recommendation has been mixed. In its formal response to the NFS Part 2, the Food and Drink Federation stated unequivocally that sugar and salt tax 'will not drive reformulation'. Rather, it will 'ultimately impact those families who are already struggling to make ends meet, by making food and drink more expensive'. It was also sceptical of the suggestion in the NFS that the tax might be used to assist low-income families to access healthy foods, saying : 'the same promise was made ahead of the introduction of the soft drinks industry levy, but was quietly dropped shortly afterwards.' This somewhat scathing response from the FDF may come as a surprise to Dimbleby who quoted the FDF in support of the need to legislate.

The British Frozen Food Federation also share concerns regarding the salt tax and the increased pressure on food companies who are already struggling to regroup following the effects of the Covid-19 pandemic.

Interestingly, the industry response may in the long-term sit at odds with the views of the public. A YouGov poll conducted at the time of the NFS reported that over half of Britons support the idea of high sugar and salt foods being taxed at a higher rate.

The second recommendation on mandatory reporting has seen a largely positive response from across the industry. Grocery retailers across the board seem to support the mandatory reporting recommendations with many noting they have already taken steps to report some of their data.

The third recommendation has had visibly less coverage in the media and seems to be the least controversial of the three. Key organisations such as School Food Matters and the Times Education Supplement (TES) have joined educators in supporting the proposals.

Next steps

The Government must provide its formal response to the NFS via a White Paper by the end of January 2022. This will set out which proposals will be progressed, as well as its position on the NFS generally. With regard to the recommended sugar and salt tax, prime minister Boris Johnson has already said that he was reluctant to impose 'extra taxes on hardworking people'.


Whilst there has been a mixed (mainly negative) reaction to the prospect of a sugar and salt tax, the Government and food industry seem to be in support of some form of mandatory reporting by large companies. The nature and extent of such reporting remains to be seen but food companies from every level of the supply chain would be wise to consider their existing internal reporting mechanisms and ensure they are able to adapt should this requirement be put in place. In the meantime, whilst the desire for healthy school meals is not a new initiative, we anticipate that the introduction of a formal ‘Eat and Learn’ initiative will impact on the nature of food services provided to schools and other educational institutions.

Key contact

Cheryl Parkhouse

Cheryl Parkhouse Senior Associate

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