No eating on buses. Biscuits to be sold in plain packaging. A calorie limit on takeaway meals. A few years ago such suggestions would have been considered laughable, not so much a nanny state but a fantastical Mary Poppins on steroids one.
But all these ideas are now both serious and respectable. They were among the recommendations of the final report from the retiring Chief Medical Officer, Sally Davies. She is not the only one to have called for radical measures to combat obesity and ill health in 2019. The public policy think tank IPPR has called for “Plain packaging on sweets and other confectionary, sugary drinks and crisps” and banning advertising for unhealthy food products until after the 9pm watershed. The RSA Food, Farming and Countryside Commission has advocated restrictions on advertising for “high sugar, salt, trans fats and ultra-processed foods” including a requirement to use “plain and factual packaging.”The expression “Desperate times call for desperate measures” could have been invented for this deluge of unlikely and often impractical suggestions. The reality and scale of the problems they seek to tackle is undeniable. Davies’s report stresses that “Being overweight or obese in childhood has profound impacts on the health and life chances of children,” “Children living in the most deprived areas are disproportionately affected” and “Our environment has slowly changed, and it makes it hard for our children to be healthy.”
Little wonder that people are trying to find ways to radically disrupt a market that has been very good at delivering profits and ill-health. The problem is that food, nutrition, human behaviour and the economic system are all individually complex and collectively Byzantine. Most of the proposed solutions get caught in this Gordian knot.
A telling example of this is plain paper packaging. I was recently a juror for a Food Ethics Council “Food Policy on trial” event in which I heard expert evidence for and against the idea. I was unpersuaded of its merits, for reasons which apply to many other areas of public health, especially around food.
First, whenever there is a public health problem there is a desire to use tobacco as the model for how to deal with it. But tobacco is a special case. Smoking is not necessary, it is inherently harmful and tobacco is easy to single out. Food and eating aren’t like that. Most obviously, the difference between “good” and “bad” foods is not black and white. You could even say, as many do, that there’s no such thing as a bad food, only a bad diet. The chocolate mousse and dessert wine at the posh bistro might be no healthier than a Twix and a Diet Coke, but you don’t eat the former every day.
You might accept this but believe that at the extremes, it is pretty clear what bad food looks like: highly processed, high fat, high sugar, high salt. Can’t we at least take action against this? The problem here is that legislation needs unambiguous clarity, which with food has tended to mean focusing on precise contents of specific nutrients. This is too crude. It means fat- and salt-rich artisan cheese and bacon get lumped together with turkey twirlers and pot noodles.
Adding the “highly processed” criterion would not be easy and would probably result in even more perverse unintended outcomes. We know that the food industry has been very good at gaming legislation. Many claim the sugar tax has been a great success but the clearest result of reduced sugary drink consumption so far has been the increased use of artificial sweeteners, with unknown long-term consequences. So far, childhood obesity in England has continued to rise, reaching its highest level this year.
The heart of the problem is that we seek legislation to micromanage the food economy and people’s diets when both operate in more complex, holistic ways. That does not mean we can’t do anything at all. But it does mean we have to avoid the temptation of quick, easy wins and work to overhaul the wider causes and context of bad eating.
The packaging debate has at least had the benefit of making it clear that this must involve clamping down on unscrupulous marketing and packaging. It’s too easy to make spurious health claims, such as “lower sugar” or “low fat” when the product is still high in sugar, or “high in nutrient X” as though a little fortification turns otherwise nutritionally-empty edible substances into real food.
The way to do this, however, is not to set narrow rules that are invitations to abuse. For instance, at the Food Ethics on Trial event, Helen Crawley, Director of First Steps Nutrition, gave the example of an infant food that legally described itself as “Broccoli, pears and peas” with no added sugar. But it was in fact 79 per cent pureed pear and therefore extremely high in unhealthy free sugars.
A better approach is to demand honesty and clarity against a “competent judges” test. Any claim that a reasonable person would find misleading should be banned, and punished with high fines. It should also be compulsory to reveal means of production. Free-range meat commands a premium but more would be prepared to pay it if it was clear where the cheaper alternative came from. This may not seem like a nutrition issue but there is increasing evidence that means of production does effect the healthiness of food, a fact that the nutrition-profiling approach misses.
Regulation of the food industry is always attacked for being nannying. But what is becoming clear is that banning or taxing specific foods is a small part at best of a wider strategy to improve diet. Telling manufacturers to tick yet more boxes, which they are very good at doing, is not a solution. Nor is simply telling people how to eat well when every time they step into a shop or see an advert they are confronted with even more powerful messages pulling them in the wrong direction. What we need is to stop food manufacturers deceiving people, dressing up their low-grade feed as quality food, effectively telling lies. Demanding honesty in food retailing is the most joined-up and effective way of enabling citizens to choose how to eat well for themselves.
