Hungry For Change: Fixing The Failures in Food

HOUSE OF LORDS
Select Committee on Food, Poverty,

Health and the Environment
Report of Session 2019–20
Hungry for change:

fixing the failures in
food
Ordered to be printed 23 June 2020 and published 6 July 2020
Published by the Authority of the House of Lords
HL Paper 85
Select Committee on Food, Poverty, Health and the Environment
The Select Committee on Food, Poverty, Health and the Environment was appointed by the
House of Lords on 13 June 2019 to “consider the links between inequality, public health and
food sustainability”.
Membership
The Members of the Select Committee on Food, Poverty, Health and the Environment were:
Lord Krebs (Chair) Baroness Redfern (resigned 8 January 2020)
Baroness Boycott Baroness Ritchie of Downpatrick
The Earl of Caithness (appointed 30 January 2020)
Lord Empey Lord Rooker (resigned 9 January 2020)
Baroness Janke Baroness Sanderson of Welton
Baroness Jay of Paddington (appointed 22 January 2020)
(resigned 9 September 2019) Baroness Sater
Baroness Osamor Lord Whitty
Baroness Parminter
Declarations of interests
See Appendix 1.
A full list of Members’ interests can be found in the Register of Lords’ Interests:
https://www.parliament.uk/mps-lords-and-offices/standards-and-financial-interests/house-of-
lords-commissioner-for-standards-/register-of-lords-interests/
Publications
All publications of the Committee are available at: https://committees.parliament.uk/
committee/408/food-poverty-health-and-environment-committee/publications/
Parliament Live
Live coverage of debates and public sessions of the Committee’s meetings are available at:
http://www.parliamentlive.tv
Further information
Further information about the House of Lords and its Committees, including guidance to
witnesses, details of current inquiries and forthcoming meetings is available at:
https://www.parliament.uk/business/lords/
Committee staff
The staff who worked on this inquiry were Beth Hooper (Clerk), Samantha Kenny (Policy
Analyst) and Rebecca Pickavance (Committee Assistant)
Contact details
All correspondence should be addressed to the Select Committee on Food, Poverty, Health and the
Environment, Committee Office, House of Lords, London SW1A 0PW. Telephone 020 7219 4878.
Email hlfoodpoverty@parliament.uk
CONTENTS
Page
Summary 4
Chapter 1: Introduction 11
The inquiry and the Committee’s work 13
Box 1: A note on definitions 15
Chapter 2: The current situation 17
The food system at a glance 17
Figure 1: Breakdown of Gross Value Added (GVA) per food
sector and employment figures per sector 18
Figure 2: UK Trade in different food groups, 2018 19
Figure 3: UK grocery market shares, 2017/18 21
Diet and health 21
Health inequalities 23
Figure 4: Life expectancy and healthy life expectancy by age,
sex and deprivation decile in England, 2016-18 24
Diet and food production 26
Current Government intervention 26
Childhood Obesity Plans 26
Agriculture Bill 27
National Food Strategy 28
The ‘real’ cost of food 28
Conclusions 29
Chapter 3: Poverty and food insecurity 30
Box 2: Experiences of food insecurity 31
Measurements of poverty 31
Figure 5: Number and proportion of adults and children in
relative and absolute poverty, before and after housing costs,
UK, 2018/19 34
COVID-19 and poverty 34
Food insecurity 35
COVID-19 and food insecurity 37
Measuring food insecurity 38
‘Food poverty’: a misnomer 41
Hunger and food banks 43
Universal Credit and hunger 44
People with no recourse to public funds 47
Difficulty accessing a healthy diet 48
Affordability of healthy diets 49
Figure 6: The 13 main categories of average weekly household
expenditure, UK, 2018/19 50
Figure 7: Average weekly household expenditure on the 33 main
categories of foods, UK, 2018/19 51
What is the cost of a healthy diet? 51
Figure 8: The Eatwell Guide 52
Risks and priorities 56
Practical barriers to accessing a healthy diet 57
‘Emotional bandwidth’ 58
Box 6: Why don’t people just make soup? 60
Chapter 4: The food environment 61
An in-built system failure 61
Experiences of the food environment 62
Measures to address the food environment 63
A critical consensus 64
Table 1: Progress of proposals in Chapter 2, Childhood Obesity:
a plan for action (July 2018) 65
Suggested interventions to improve the food environment 66
Government food programmes 67
The Healthy Start Scheme 67
Free school meals 70
Public procurement 83
The marketing and promotion of food 86
Fast food outlets 91
Labelling 95
Education and public health messaging 98
Chapter 5: Reformulation and regulation 103
Existing reformulation measures 104
Voluntary reformulation programmes 106
Salt reduction 106
Sugar reduction 109
Voluntary reformulation programmes: conclusions 110
Mandatory reformulation 110
The Industry View 112
Barriers to reformulation 112
Creating a level playing field 114
Portion sizes 115
The case for reformulation: conclusions 116
Chapter 6: Food and the natural environment 119
Impact of food production on the environment 120
Figure 9: Percentages of UK pollution from ammonia and
greenhouse gases derived from agriculture in 2017 122
What is a sustainable food system? 122
The Agriculture Bill 123
The case for a dietary shift 126
Food production and public health 128
Financial support for horticulture 129
Resilience and continuity of supply 131
Trade 132
Production efficiencies 135
Research and Development 135
Food industry reporting 138
Food waste 139
Chapter 7: Governance, accountability and food policy 142
Setting an ambition for the food system 143
National Food Strategy: England 144
Scotland 145
Wales 146
Monitoring and accountability 148
The ‘right to food’ 150
Co-ordination of food policy 152
Summary of conclusions and recommendations 157
Appendix 1: List of Members and declarations of interest 165
Appendix 2: List of witnesses 167
Appendix 3: Call for evidence 175
Appendix 4: Acronyms and abbreviations 177
Appendix 5: Experiences of food insecurity 179
Appendix 6: Leeds Visit 191
Evidence is published online at https://committees.parliament.uk/

committee/408/food-poverty-health-and-environment-committee/ and
available for inspection at the Parliamentary Archives (020 7219 3074).
Q in footnotes refers to a question in oral evidence.

4 Hungry for change: fixing the failures in food
SUMMARY
The UK’s food system—the production, manufacture, retail and consumption
of food—is failing. Food should be a source of enjoyment, good health and
cultural expression, but there are stark contrasts in the way that people
experience the food system in this country. For many people, food is the source
of considerable anxiety. Significant numbers of people are unable to access the
food they need, let alone access a healthy diet. Billions of pounds are spent each
year by the National Health Service (NHS) treating significant, but avoidable,
levels of diet-related obesity and non-communicable disease. Although diet-
related ill health affects all sectors of the population, its effects are felt more
acutely in deprived areas, and considerable health inequalities persist. The food
industries, manufacturers, retailers and the food services sector, perpetuate the
demand for less healthy, highly processed products. This not only impacts on
public health, but also inhibits efforts to produce food in an environmentally
sustainable way. The health of the population, and the health of the planet, is at
risk. This report makes clear how this situation might be reversed.
The devastating impact of the COVID-19 crisis is likely to have lasting
consequences for the economy and for public health. The crisis has exposed
the fragility of many people’s economic situation and exacerbated many of the
problems relating to poverty, food insecurity and health inequalities that our
inquiry examined. The crisis should serve as an urgent wake up call to the
Government. People should be able to access not only enough food, but also the
food that they need to stay healthy; the food system, and action in related policy
areas such as health, welfare and food production, should guarantee this.
The Committee was set up to “consider the links between inequality, public
health and food sustainability.” We found barriers at all levels of the food system
that make it harder for people, particularly those living in poverty, to access a
healthy and sustainable diet. The lack of a unifying Government ambition or
strategy on food has prevented interrelated issues such as hunger, health and
sustainability from being considered in parallel, meaning that opportunities
have been missed to develop coherent policies that could effect widespread
change. Our recommendations are built around the central aim of ensuring
that everyone, regardless of income, has access to a healthy and sustainable diet.
Key recommendations
The Food and Agriculture Organization of the UN estimated that around 2.2
million people in the UK are severely food insecure (i.e. with limited access
to food, due to a lack of money or other resources).1 Until recently, however,
the Government has not collected data on this and so does not have an
accurate picture of the prevalence of food insecurity. Without a comprehensive
understanding of the scale of the problem, neither the root causes of food
insecurity, nor the detrimental impact it has on public health and wellbeing can
be fully evaluated or addressed. We have asked that the Government commits
to detailed and routine monitoring of the levels of food insecurity. That data
should be published transparently and be subject to scrutiny to ensure that
1 Food and Agriculture Organization of the United Nations, The State of Food Insecurity and Nutrition
in the World, Building Climate Resilience for Food Security and Nutrition (2018), p 138: http://www.
fao.org/3/I9553EN/i9553en.pdf [accessed 29 June 2020]. Definition of food insecurity from FAO,
IFAD, WFP and WHO, The State of Food Security and Nutrition in the World, (2017), p 96: http://
www.fao.org/3/a-i7695e.pdf [accessed 29 June 2020]
Hungry for change: fixing the failures in food 5
trends in food insecurity can be linked to wider socioeconomic reforms, and

can inform policy in other areas such as public health and welfare so that efforts
to tackle food insecurity can be targeted effectively.
The welfare system is failing to prevent situations where people find themselves
without the resources to access food. Food insecurity is a consequence of
poverty. An estimated 11 million people, including around 2.8 million children,
are living in poverty2 in the UK.3 Poverty is characterised by a lack of resources,
and for many people, their food budget is the only budget that can be reduced.
Although the Government has not, until recently, collected routine data on food
insecurity, the existence, and rising use of food banks provides a clear indication
of the severity of the problem. Food aid organisations told us that reliance on
food banks is increasing. In 2019, the Trussell Trust reported that it had seen
a 73% increase in the number of emergency food parcels it has delivered over
the past 5 years4. Following the outbreak of the COVID-19 pandemic, the
Trussell Trust reported an 81% increase for emergency food parcels from food
banks during the last two weeks of March 2020, compared to the same period
in 2019.5 The Trussell Trust, and others, have suggested that problems with
Universal Credit are one factor in the increased use of food banks.6 Specifically,
we were told that many people lack the financial resilience to cope with the five-
week wait between making a claim and receiving the first payment of Universal
Credit. As a result, some people struggle to afford food, with many going hungry.
We are not the first to urge the Government to rethink and replace the current
system of the five-week wait but we have added our support to calls to urgently
address the long-standing problems with Universal Credit, problems that place
people in the vulnerable situation of not being able to afford enough food. The
charitable sector is shouldering this burden and although it is providing vital
support, the Government should not be relying on food aid to fill the gaps in
the welfare system.
People with limited resources to access food often find it hard to access healthy
food. Less healthy diets and their adverse consequences are not limited to those
in the lowest income groups, but affect these groups disproportionately. Adults
and children in deprived areas are significantly more likely to become obese
or suffer with diet-related ill health7, a disadvantage that is contributing to
widening health inequalities in this country.8 The Government has introduced
guidance on what constitutes a healthy diet through Public Health England’s
Eatwell Guide but it has not fully evaluated whether the diet it recommends is
affordable to everyone. We were referred to a Food Foundation report which
estimated that: “the poorest decile of UK households would need to spend 74%
2 In relative low income before housing costs.

3 House of Commons Library, Poverty in the UK: statistics, Briefing Paper, Number 7096, 29 April
2020
4 The Trussell Trust, Record 1.6m food bank parcels given to people in past year as the Trussell Trust calls
for end to Universal Credit Five Week wait (25 April 2019): https://www.trusselltrust.org/2019/04/25/
record-1-6m-food-bank-parcels/ [accessed 29 June 2020]
5 The Trussell Trust, Food banks report record spike in need as coalition of anti-poverty charities call for strong
lifeline to be thrown to anyone who needs it, (1 May 2020): https://www.trusselltrust.org/2020/05/01/
coalition-call/ [accessed 29 June 2020]
6 Q 37 (Garry Lemon)
7 House of Commons Library, Obesity Statistics, Briefing Paper Number 3336, 20 March 2018
8 Institute of Health Equity, Health Equity in England: The Marmot Review 10 year on (February
2020) p 84: https://www.health.org.uk/sites/default/files/upload/publications/2020/Health%20
Equity%20in%20England_The%20Marmot%20Review%2010%20Years%20On_full%20report.
pdf [accessed 30 June 2020]
of their after-housing disposable income on food to meet the cost of the Eatwell
Guide compared to just 6% in the richest decile.”9 The Government should
know whether or not people can afford to adhere to its own dietary guidance. We
have therefore recommended that a fuller understanding of the cost of a healthy
diet should be reached, and factored into the calculation of benefit rates. This
cost should also act as a reference point to inform other policy interventions,
including those relating to welfare and public food provision.
Highly processed foods—those that contain high levels of energy, unhealthy
types of fat, salt or highly refined carbohydrates such as sugar10—are produced
in abundance in this country. These products are then aggressively marketed
and promoted to the consumer. Highly processed food products are also more
likely to be on promotion, making them appealing to those on a tight budget.11
Manufacturing, retail and the food service sector, has a central role in this. As
a consequence, a high proportion of both adults and children’s dietary energy
comes from processed food12 with the UK consuming more processed products
than any other European country.13 The less healthy choice has become the
easier, cheaper choice for the consumer but this is inflicting profound costs on
public health and the NHS.
The Government is fully aware of the need to reduce the prevalence and
consumption of less healthy food and has, to date, introduced a range of policies
and proposals aimed at improving the food environment, including numerous
measures outlined in the three chapters of the Childhood Obesity Plan. Despite
this, obesity rates continue to rise.14 There is no excuse for the Government not
to re-double its efforts in these areas. Many Government proposals to impose
restrictions on the marketing, advertising and price promotion of less healthy
foods have so far failed to progress beyond consultation stage. We have urged
the Government to publish the results of these consultations so that policies can
finally be developed and enacted to conclusively tackle the factors in the food
environment that make the less healthy choice so readily available.
We also have recommended that the Government step up its efforts to encourage
the food industry to reformulate its products to reduce harmful levels of salt, sugar
and unhealthy types of fats. Both the salt and sugar reduction programmes are
likely to fail to achieve their stated targets so the Government must increase and
maintain the pressure on industry to act. Industry progress against voluntary
reformulation targets should be subject to transparent and regular monitoring,
to highlight where successes and failures occur. Crucially, the Government
should make clear what regulatory action will follow if the industry does not
respond comprehensively and swiftly to voluntary targets. Mandatory (fiscal)
approaches can work, as evidenced by the Soft Drinks Industry Levy. As there
is a proven mechanism for delivering successful reductions in ingredients that
may be associated with poor health outcomes in a way which has not had a
9 Written evidence from the Food Foundation, London School of Hygiene and Tropical Medicine
and Sustainable and Healthy Food Systems (SHEFS) (ZFP0073)
10 And low levels of fruits, vegetables, whole grains, nuts or seeds
11 Written evidence from the Food Foundation, London School of Hygiene and Tropical Medicine
and Sustainable and Healthy Food Systems (SHEFS) (ZFP0073)
12 Ibid
13 Written evidence from the University of Southampton and the MRC Life Course Epidemiology
Unit Southampton General Hospital (ZFP0080)
14 NHS Digital, Statistics on Obesity, Physical Activity and Diet, England, 2020 (5 May 2020): https://
digital.nhs.uk /data-and-information/publications/statistical/statistics-on-obesity-physical-
activity-and-diet/england-2020/part-3-adult-obesity-copy [accessed 30 June 2020]
detrimental impact on the industry, the Government must not delay in exploring
the application of fiscal measures (such as further levies or changes to VAT) to
other product categories where reformulation is not in line with Government
targets. Food manufacturers and retailers have been reluctant and slow to act,
but Government regulation can and must compel them to do so now.
In all sectors of society, a shift in consumption is required. Clear public
health messaging is an important start, but the extension and reform of three
public food measures—Healthy Start vouchers, free school meals and holiday
hunger programmes—is absolutely necessary too. If properly funded, properly
implemented, and extended to all who need them, these programmes could
help to prevent the poorest children from going hungry and could enable a shift
in consumption that would make a healthy diet more accessible for children and
families. Combined with a renewed and more targeted effort to communicate
public health messages, these programmes could help make healthy food
an easier and more accessible choice. Schools and local authorities have an
important role in increasing knowledge and skills on nutrition, and supporting
people to make healthier choices, but the Government must ensure that they
are adequately resourced to do so.
Current patterns of consumption are not only impacting adversely on the
population’s health, but also on the environment. Our evidence indicated that
economic forces, including the demands of supermarkets, food manufacturers,
the food services sector, and the large food commodity companies, requiring
farmers to produce food as cheaply as possible can act as an inhibitor to producing
food in an environmentally sustainable way. This can increase the negative
impacts of agriculture on the natural environment, threatening biodiversity and
the quality of farmland. Future agricultural policy should aim to balance food
production with the protection of health and the environment. We welcome
the general direction of the Agriculture Bill, but we have highlighted where
we think there are limitations in its proposals that must be addressed. The Bill
proposes to reward farmers for producing environmental benefits, but we have
warned that without a consistent, reliable system for determining, measuring
and reporting these impacts, the Bill will not fulfil its potential. We have
therefore recommended that every public good outlined in the Agriculture
Bill is accompanied by a standardised framework to allow measurements and
targets to be clear, consistent and easy to use. Farmers should be supported to
achieve the public goods outlined in the Bill, and financial rewards should be
conditional upon action and progress.
The Agriculture Bill must also help to support wider improvements to public
health. There are convincing arguments for a fundamental shift in consumption
towards a more plant-based, balanced diet: current patterns not only have an
adverse impact on the population’s health, but also on the environment. The
Government must clarify the vision for a healthy, sustainable diet, and set out a
clear path towards achieving this. We have recommended that the Agriculture
Bill should recognise, support and reward farmers for measures that promote
improved public health.
In addition, if trade agreements allow for the import of cheap food, produced
according to lower environmental and animal welfare standards, this could put
UK producers, and even consumers’ health, at a disadvantage. In a joint letter to
MPs and Peers, dated June 5 2020, the Secretary of State for International Trade,
the Rt. Hon. Elizabeth Truss MP, and Secretary of State for the Department for
Environment, Food and Rural Affairs, the Rt. Hon. George Eustice MP, stated
that in all of its trade negotiations, the Government “will not compromise on
our high environmental protection, animal welfare and food standards.”15 We
have called on the Government to stand by this commitment and set out what
safeguards it will provide.
Substantive change is required throughout the whole food system—from
plough to plate—to ensure that everyone has access to a healthy, sustainable
diet. Rising levels of obesity, food insecurity and health inequalities, and the
damage caused to the environment by the current system of food production
demonstrates that further action is needed now. In light of these persistent
problems many of our witnesses advocated for ‘whole system change’. In this
report we have identified the points in the food system where changes can and
should be made. We have made recommendations that aim to address issues
relating to: people’s ability to access food and the impact on diet of living in
poverty; the efficacy of existing Government food programmes; the factors that
influence consumer behaviour; the availability of less healthy foods; and food
production and the natural environment. We are clear, however, that to ensure
long-term, sustainable progress can be realised, a clear, overarching vision for
what the food system should achieve is also required, underpinned by robust
governance and accountability. The Government’s National Food Strategy is a
positive and universally welcomed step in the right direction. The Government
has committed to publishing a White Paper in response to the forthcoming
recommendations of the National Food Strategy review, led by Henry Dimbleby.
These recommendations are likely to require cross-departmental co-ordination
and a dedicated system of oversight to bring about a tangible change to the way
we produce, purchase and consume food. We have, therefore, recommended
the establishment of an independent body, responsible for strategic oversight
of the implementation of the National Food Strategy. This independent body
should have the power to advise the Government and report to Parliament on
progress.
At a time of crisis, when Government spending has necessarily and dramatically
risen in response to the impact of the COVID-19 outbreak, we were conscious of
the difficulty of making recommendations which require further demands on the
public purse. With this in mind, we have been selective. The recommendations
we have made would, if implemented, reduce the many burdens that poor diets
place upon the environment, the NHS, and the wider economy.
Food policy has an impact on all sectors of our economy, environment, and
society, and the ability to access a healthy diet has a profound impact on people’s
health and wellbeing. Before the COVID-19 pandemic, the burden placed
on the environment, economy and the NHS by the nation’s diet was already
unsustainable. The unacceptable inequality in people’s ability to access healthy
food also predates the current crisis. The COVID-19 outbreak has pushed
more people into economic difficulty, and has had, and will continue to have,
a serious negative impact on the nation’s health and economy, an impact that
is being felt more acutely by those in deprived areas. It is now, therefore, more
important than ever to ensure that everyone can access a healthy, sustainable
diet. Jo Churchill MP, the Minister for Prevention, Public Health and Primary
15 Letter to MPs and Peers from the Rt. Hon. Elizabeth Truss MP, and Secretary of State for the
Department for Environment, Food and Rural Affairs, the Rt. Hon. George Eustice MP, 5 June
2020. Letter referred to by Lord Gardiner of Kimble, Parliamentary Under-Secretary of State,
Department for Environment, Food and Rural Affairs, HL Deb, 10 June 2020, cols 1753-1754 .
Care at the Department for Health and Social Care, appeared to share that
view, and told us:
“We have a teachable moment, and we should seize it.”16
The COVID-19 pandemic has reinforced the need, and provided the
opportunity, for the Government to act now with commitment and focus to
deliver the improvements to the food system, public health and environmental
sustainability that are so urgently required.
16 Q 123 (Jo Churchill MP)

Hungry for change: fixing the
failures in food
Chapter 1: INTRODUCTION
1. The future configuration, resilience and efficiency of the UK food system is

vital for the economy and the health of the nation. Yet, while the agri-food
sector as a whole contributes around £121 billion to the UK economy each
year17, ill health resulting from poor diets is costing the NHS around £6.1
billion per year and £27 billion to the wider economy.18 The UK farming
sector provides important public goods, yet UK agriculture also accounts
for over 10% of the UK’s greenhouse gas emissions19, and around 10 million
tonnes of food leaving farms is wasted each year.20 A food system that is
better for public health and the environment must be created but it will
require Government intervention.
2. The term food system is difficult to define. It can be understood as simply
describing the ‘food chain’, from farm to fork and comprising agriculture,
food production and manufacturing, retail (sale and purchasing of food) and
consumer behaviours. There are, however, other important elements that
shape food production and consumption, including marketing, regulation
and policy. Finally, there are the factors that affect access to that food: price,
personal income and circumstances, and even geographical location. We
were conscious that the term ‘food system’ is somewhat ambiguous so for
the purposes of this inquiry our report has focused on what we produce and
how it is produced, and what influences people’s choices and ability to access
food.
3. We were told two key things about the food system. First, it is a significant
and essential part of the economy and, as such, it could be a powerful lever
to improve public health. Second it is failing—failing to deliver for public
health, for social equalities and for the environment—it is, at present,
‘unsustainable’. This failure most clearly manifests itself in three key issues:
the two seemingly contradictory problems of growing obesity rates, and
rising food insecurity; and the damage that is sustained to the environment
by the current system of food production.
4. Our witnesses described a food system that is biased towards providing an
overabundance of cheap, less healthy food, with adverse consequences for
17 Department for Environment, Food and Rural Affairs, National Statistics: Food Statistics in your
pocket Summary’ (updated 30 March) : https://www.gov.uk/government/publications/food-statistics-
pocketbook /food-statistics-in-your-pocket-summary#gross-value-added-of-the-uk-agri-food-
sector-2018 [accessed 30 June 2020]
18 Public Health England, ‘Health Matters: obesity and the food environment’, (31 March 2017): https://
www.gov.uk/government/publications/health-matters-obesity-and-the-food-environment/health-
matters-obesity-and-the-food-environment--2 [accessed 30 June 2020]
19 Department for Business, Energy and Industrial Strategy, 2018 UK Greenhouse Gas Emissions, Final
Figures (4 February 2020) p 12: https://assets.publishing.service.gov.uk/government/uploads/system/
uploads/attachment_data/file/862887/2018_Final_greenhouse_gas_emissions_statistical_release.pdf
[accessed 30 June 2020]
20 Committee on Climate Change, Net Zero The UK’s contribution to stopping global warming (2 May 2019)
p 188: https://www.theccc.org.uk/wp-content/uploads/2019/05/Net-Zero-The-UKs-contribution-to-
stopping-global-warming.pdf [accessed 30 June 2020]
health and the environment. We were told that farmers are trapped in a cycle
where there is not enough emphasis or incentive on the need for healthy,
environmentally sustainable produce. A significant proportion of food is
highly processed by food manufacturers to a point where products contain
high levels of energy (calories), salt, sugar and unhealthy types of fat, which
contribute to disease risks; and low levels of fruit, vegetables, legumes, whole
grains, nuts and seeds, which help to protect against diet-related diseases.
Highly processed foods are then aggressively marketed and promoted to the
consumer, often at discounted prices. While some responsibility lies with
consumers themselves, it is clear that the food system is stacked against the
consumer accessing a healthy diet, particularly for those with less choice and
limited resources.
5. Our task was to focus on the links between the issues outlined above—food,
inequality, public health, and sustainability—to identify where interventions
(policy, regulatory or fiscal) might be applied, or reinforced, to tackle the
serious health, social and environmental damage that is being inflicted by
the current food system. We have brought these themes together under our
central line of inquiry: how to ensure a healthy and sustainable diet can be
accessed by everyone.
6. We examine these issues in more detail in the following chapters. However,
we emphasise at the outset the following conclusions:
(a) The externalities of the current food system—the cost to public health
and to the environment—are unsustainable. Without further action
and oversight by the Government, “others will always end up paying
the true cost of cheap food.”21
(b) The issue of food insecurity is a serious concern, but it should not be
viewed as a failure of the food system itself; it is a consequence of poverty
and the economic and social failures that sit behind it. Measures to
reduce poverty can and should be made elsewhere by the Government.
Evidence shows that poverty-driven food insecurity drives people to
adopt cheaper and less healthy diets, often with high levels of highly
processed foods, resulting in health inequalities that manifest in obesity
(particularly in children) and non-communicable diseases. People who
have a hard time accessing food have an even harder time accessing
healthy food.
(c) In addition, problems accessing healthy food are felt across the
population. The whole population is consuming diets that are too high
in energy, unhealthy types of fat, salt and added sugar and the health
system is shouldering the cost of this. By addressing the dependency
on less healthy food in the food system, we can make progress towards
more equitable access to healthy food for everyone.
7. Continuing with business as usual does not make economic sense. It will
lead to greater costs to the public purse through an excess burden on the
health system from preventable non-communicable diseases and through
increasing environmental degradation. We should aim to ensure the
food system provides safe, healthy and affordable food, that is built upon
a resilient and sustainable agricultural system, at the same time as being
economically viable. Our recommendations are aimed at driving changes to
21 Written evidence from the Food Ethics Council (ZFP0054)
the food system to enable more people to access the food which will keep the
population healthy and reduce the burden on the NHS, economy and the
environment.
8. Finally, we know that the outbreak of COVID-19 is having, and may continue
to have, a very significant impact on the economy and the health of the
nation. When the lockdown measures were first introduced, we had almost
concluded our evidence gathering, but were forced to cancel three evidence
sessions. While we did not have time to take formal evidence on the impact
on the food system of the crisis, we have, where possible, reflected the most
recent data, generated during the pandemic, on the areas covered by our
inquiry. We note that a significant amount of scrutiny work is underway
across Parliament on the impact of COVID-19 including an inquiry into
COVID-19 and food supply being conducted by the House of Commons
Environment, Food and Rural Affairs Committee.
9. While we acknowledge that the Government is at the moment, rightly,
focused on its response to COVID-19, our inquiry highlighted some serious,
systemic problems with the food system, problems that the COVID-19 crisis
only serves to underscore. Many people were already struggling to access a
healthy diet, and the current crisis will worsen that situation, as more people
face unemployment, uncertainty and the effects of ill health. It is, as the
Food Foundation has stated: “A crisis on a crisis.”22
The inquiry and the Committee’s work

10. The Committee was first appointed by the House of Lords on 13 June
2019 to: “Consider the links between inequality, public health and food
sustainability.” This followed a recommendation from the House of Lords
Liaison Committee that such a Committee be established. The Committee
was originally set up with a requirement that it should report by 31 March
2020.
11. The Committee met for the first time on 25 June 2019. On 24 July 2019 we
published our call for evidence, which is reprinted in Appendix 3.
12. The Committee’s original work programme included taking evidence during
around 20 evidence sessions spread over 14 meetings, concluding on 10
December 2019, and agreeing the report by the end of March 2020. Our
programme was disrupted by three subsequent events. The prorogation on
10 September 2019 meant the Committee was dissolved. As the ruling by the
Supreme Court meant that the prorogation was not lawful, the Committee
was able to continue without being reappointed. Prorogation on 6 October,
however, meant the Committee was dissolved again and was reappointed on
22 October 2019. After meeting only twice more, the Committee was yet
again dissolved for the general election, and was not reappointed until 22
January 2020. The order reappointing the Committee required us to report
by 23 June 2020.
13. Over the course of our inquiry, we received 105 submissions of written
evidence and heard from 44 witnesses in 17 oral evidence sessions. We are
very grateful to all those who took the time to provide us with evidence. A
22 The Food Foundation, Covid-19: latest impact on food, (March 2020): https://foodfoundation.org.uk/
covid-19-latest-impact-on-food/ [accessed 30 June 2020]
list of those who gave us written and oral evidence is included in Appendix 2,
and is available on our website.
14. It was of vital importance that we heard from people with lived experience
of food insecurity, and from those who are working ‘on the ground’ to
tackle the issues the inquiry was set up to consider. We had planned, with
the help of Sustain: the alliance for better food and farming, and Church
Action on Poverty, an engagement session with people who have experienced
food insecurity on 17 March 2020. Due to the growing concerns around
the coronavirus, this event was cancelled. We were able instead to arrange
phone calls between the individuals with whom we had planned to meet and
the secretariat of the Committee. A note containing a summary of these
conversations has been included in the report in Appendix 5. We thank
Sustain and Church Action on Poverty for their support with this process
and to the individuals who took the time to share their experiences with us.
15. The Committee also had a visit to Leeds planned for 18 March 2020,
which again had to be cancelled. This was to include a visit to the Compton
Centre, one of the Council’s Community Hub sites, Neruka’s Soup Kitchen,
which provides meal provision for people in need of food, and CATCH, a
community café and Healthy Holiday’s Programme Leader. We are grateful
to Emma Strachan and Nick Hart of Leeds Council who helped to plan
the visit. Information and insights that Leeds Council and its local partners
wanted to share with us were instead submitted as written evidence and are
listed in Appendix 6.
16. Policies relating to food are largely devolved in the United Kingdom.
Consequently, much of the evidence we received and the corresponding
conclusions and recommendations we have drawn focus on the situation in
England.
17. Inevitably, given the breadth and complexity of the issues involved, our
reporting deadline of 23 June, and the considerable disruption to our
timetable, it has not been possible to go into great depth in all the policy
areas that impact on how we access food. Similarly, it was not possible to
examine all aspects of the food system in granular detail. Instead, we have
focused on those policy areas which seemed to be of principal concern, the
areas that require the most urgent change and where we think intervention
could help to achieve the greatest impact.
18. On 27 June 2019, the then Secretary of State for Environment, Food and
Rural Affairs, the Rt. Hon. Michael Gove MP, commissioned Henry
Dimbleby to conduct an independent review to help the Government create
a National Food Strategy. The Government committed to responding with
a White Paper six months after the review is published. The National Food
Strategy review is ongoing, and we want to express our gratitude to Henry
Dimbleby for providing evidence to us. The National Food Strategy review
will doubtless contribute towards tackling many of the issues identified
over the course of our inquiry, and we hope our recommendations will
complement its work.
19. We are grateful to our two Specialist Advisers: Professor Elizabeth Robinson,
Head of Applied Economics and Marketing at the School of Agriculture,
Policy and Development at the University of Reading; and Professor Martin
White, Professor of Population Health Research in the Centre for Diet
and Activity Research and MRC Epidemiology Unit, at the University of

Cambridge. Their expertise has greatly assisted our deliberations during the
course of this inquiry.
Box 1: A note on definitions
For the purposes of this report, we use the following terms and definitions:
• Food system. This term comprises: agriculture and horticulture; food
manufacturing; food retail; the food environment, and the interaction of
all of these elements with each other and consumers.
• Food environment. In the report, this term is used to describe the factors
that impact on 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 nutritional
information.
• Food insecurity. The FAO defines food insecurity as “limited access to
food, at the level of individuals or households, due to lack of money or other
resources.”23 We also note the definition used by the Food Foundation
and the UK’s Low Income Diet and Nutrition Survey, 2007: “limited or
uncertain availability of nutritionally adequate and safe foods or limited
or uncertain ability to acquire acceptable foods in socially acceptable ways
(e.g. without resorting to emergency food supplies, scavenging, stealing or
other coping strategies).”24
• ‘Food security’ refers to a household or an individual’s ability to access
food. In the report, that is distinct from discussions on the resilience and
continuity of the food supply.
• ‘Healthy diet’. This term is generally understood to mean a diet that is
high in fruits, vegetables, legumes, nuts, seeds and whole grains and
low in unhealthy types of fat25, salt and unrefined carbohydrates (e.g.
added sugars). A healthy diet also contains sufficient, but not excessive
energy (calories) and is low in foods that are ‘energy dense’ (i.e. foods
that have a large number of calories per serving). In the UK, government
recommendations for a healthy and sustainable diet are set out in the
Eatwell Guide.26 An ‘unhealthy diet’ is generally understood to be one
that does not adhere to the properties set out above.
232425 26
23 FAO, IFAD, WFP and WHO, The State of Food Security and Nutrition in the World, (2017), p 96: http://
www.fao.org/3/a-i7695e.pdf [accessed 29 June 2020]
24 The Food Foundation, Too poor to eat: Food insecurity in the UK (May 2016) p 3: https://enuf.org.uk/
resources/too-poor-eat-food-insecurity-uk [accessed 30 June 2020]
25 All fats are energy dense, so should be eaten in moderation, but some fats are healthier than others,
being essential for bodily functions (e.g. absorption of some vitamins, production of some hormones,
development of cell membranes).
Healthier fats include polyunsaturated fats (e.g. pure vegetable oils, fish oils), monounsaturated fats
(e.g. from some fruits, nuts and seeds, such as olive oil, peanut oil) and saturated fats derived from
dairy products. Unhealthy fats include industrially processed fats (e.g. ‘transfats’—now banned in the
UK), and saturated fats from animal sources (e.g. red and processed meats): Jason Wu, Renata Micha,
& Dariush Mozaffarian, ‘Dietary fats and cardiometabolic disease: mechanisms and effects on risk
factors and outcomes’,. National Reviews of Cardiology, 16, 581–601 (2019) doi: 10.1038/s41569-019-
0206-1: https://pubmed.ncbi.nlm.nih.gov/31097791/ [accessed 30 June 2020]
26 NHS, The Eatwell Guide: https://www.nhs.uk/live-well/eat-well/the-eatwell-guide/ [accessed 30 June
2020]
• ‘Less healthy food’. This term is generally understood to mean foods that
are high in unhealthy types of fat, salt or added sugar, and is used to
describe foods that are low in fruits, vegetables, legumes, nuts, seeds and
whole grains. The terms also covers foods that are ‘energy dense’, foods
that have a large number of calories per serving.
• ‘Highly processed foods.’ The report also includes reference to ‘highly
processed’ foods. These are foods that are created by a series of industrial
techniques and processes. The Food and Agriculture Organisation (FAO)
of the United Nations states that foods which have been highly processed
(it uses the term ‘ultra-processed’) are: “energy-dense, high in unhealthy
types of fat, refined starches, free sugars and salt, and poor sources of
protein, dietary fibre and micronutrients and are made to be hyper-
palatable and attractive, with long shelf-life, and able to be consumed
anywhere, any time.”27
• HFSS foods. The Childhood Obesity Plan refers to ‘HFSS’ foods,
which it defines as products that are high in fat, sugar and salt.28 The
Department of Health and Social Care (DHSC), through its Standing
Advisory Committee on Nutrition (SACN) developed its Nutrient
Profiling Model (NPM) to define which foods are classified as HFSS.
The NPM classification system was used to classify foods in the Ofcom
regulation of the TV advertising of foods to children (2007) and has been
proposed as the basis for classifying foods subject to further regulations
in the Government’s Childhood Obesity Plan. The NPM was updated in
2018, and the new version published, but it is yet to be implemented for
new policies.29
27 28 29
27 Carlos Monteiro, Geoffrey Cannon, Jean-Claude Moubarac, Renata Levy, Maria Louzada and
Patricia Jaime,. ‘The UN Decade of Nutrition, the NOVA food classification and the trouble with
ultra-processing’,. Public Health Nutrition. 2018;21(1):5–17. doi:10.1017/S1368980017000234: https://
pubmed.ncbi.nlm.nih.gov/28322183/.[accessed 30 June 2020]
28 HM Government, Childhood obesity: a plan for action, Chapter 2 (June 2018): https://assets.publishing.
service.gov.uk/government/uploads/system/uploads/attachment_data/file/718903/childhood-obesity-
a-plan-for-action-chapter-2.pdf [accessed 30 June 2020]
29 Public Health England, Annex A The 2018 review of the UK Nutrient Profiling Model (March 2018)
p 9: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/
file/694145/Annex__A_the_2018_review_of_the_UK_nutrient_profiling_model.pdf [accessed 30
June 2020]
Chapter 2: THE CURRENT SITUATION
20. Before examining the links between the core themes of the inquiry and
drawing any conclusions about how to address the issues of food insecurity,
diet-related ill health and food sustainability, it was important to consider
the food system as a whole, to examine what it produces and what we
consume, and the scale of the challenges that are present. The following
sections set out a broad overview of the ‘food system’, focused in particular
on agriculture, food and drink manufacturing, food and drink retailing, and
consumer interaction with the food environment.
The food system at a glance

21. British food and farming are vitally important to UK industry. The agri-
food sector (which DEFRA defines as including: agriculture and fishing;
food and drink manufacturing; food and drink wholesaling; food and drink
retailing; and non-residential catering) makes a major contribution to the
UK’s economy:
• In 2018 the agri-food sector contributed £121 billion or 9.4 %

to national GVA (Gross Value Added).30 The food sector31
employs around 4.1 million people32 (see Figure 1).
• The UK food and drink manufacturing sector contributes more than

£28 billion to the economy and is the biggest manufacturing sector
in the UK.33 96% of the UK’s 7,400 food and drink manufacturing
businesses are small and medium-sized enterprises (SMEs).34
• Agriculture and fishing employs almost half a million people in the

UK, and in 2018, contributed £10.4 billion to GVA.35
• In 2018 the value of imports was greater than the value of exports in
each of the broad categories of food, feed and drink except ‘Beverages’
which had a trade surplus of £1.81 billion, largely due to exports of
Scotch Whisky (see Figure 2).36
30 Department for Environment, Food and Rural Affairs, National Statistics: Food Statistics in your pocket:
Food Chain (updated 30 March 2020): https://www.gov.uk/government/publications/food-statistics-
pocketbook/food-statistics-in-your-pocket-food-chain [accessed 30 June 2020]
31 DEFRA states that ‘food’ includes non-alcoholic drinks: Department for Environment, Food and
Rural Affairs, National Statistics: Food Statistics in your pocket: Summary (updated 30 March 2020):
https://www.gov.uk/government/publications/food-statistics-pocketbook/food-statistics-in-your-
pocket-summary#gross-value-added-of-the-uk-agri-food-sector-2018 [accessed 30 June 2020]
32 DEFRA states that the agri-food sector employs 4.1 million people if agriculture and fishing are
included along with self-employed farmers: Department for Environment, Food and Rural Affairs,
National Statistics: Food Statistics in your pocket: Summary (updated 30 March 2020): https://www.
gov.uk/government/publications/food-statistics-pocketbook/food-statistics-in-your-pocket-summary
33 The Food and Drink and Federation, Our Industry at a glance (June 2020): https://www.fdf.org.uk/
statsataglance.aspx [accessed 30 June 2020]
34 Ibid.
36 2018 figures are provisional. Department for Environment Food and Rural Affairs, National Statistics:
Food Statistics in your pocket: Global and UK supply (Updated 30 March 2020): https://www.gov.uk/
government/publications/food-statistics-pocketbook/food-statistics-in-your-pocket-global-and-uk-
supply [accessed 25 June 2020]
• The supermarket industry is dominated by four large companies. The

combined market share of food and non-alcoholic drinks of the largest
four food and drink retailers (Tesco, Sainsbury’s, Asda and Morrisons)
was 50% in 2017–18 (see Figure 3). The three largest discount
supermarkets (Aldi, Iceland and Lidl) had a combined market share of
16%, up from 6% in 2010.37
Figure 1: Breakdown of Gross Value Added (GVA) per food sector and
employment figures per sector
Agri-food Agriculture and Fishing £10.4bn
Food and Drink Manufacturing £28.6bn

sector contributed
Food and Drink Wholesaling £14.5bn
£121 billion Food and Drink Retailing £30.6bn
or
Non-Residential Catering £36.9bn
9.4%
Gross Value Added in 2018
Agriculture and Fishing 0.44m
Food and Drink Manufacturing 0.43m

sector employed
Food and Drink Wholesaling 0.26m
Food and Drink Retailing 1.17m

4.08 million Non-Residential Catering 1.78m
in the last quarter of 2018
Largest food manufacturing category in 2017:

Source: Department for Environment, Food and Rural Affairs, ‘National Statistics: Food Statistics in your pocket:
Food Chain’, (updated 30 March 2020): https://www.gov.uk/government/publications/food-statistics-pocketbook/
‘other food products’
food-statistics-in-your-pocket-food-chain#gross-value-added-of-the-uk-agri-food-sector-2018 accessed 25 June
2020]
Figure 2: UK Trade in different food groups, 2018
Fruit and veg

Meat
Beverages
Cereals
Dairy & eggs
Fish
Misc
Coffee, tea, cocoa etc.
Animal feed
Oils
Sugar
0 2 4 6 8 10 12
imports £billion exports £billion
Source: Department for Environment Food and Rural Affairs, National Statistics: Food Statistics in your pocket:
Global and UK Supply (Updated March 2020): https://www.gov.uk/government/publications/food-statistics-
pocketbook/food-statistics-in-your-pocket-global-and-uk-supply [accessed 25 June 2020]
22. The industrial revolution changed our food system dramatically and together
with free trade and cheap imports it has, over time, become disproportionately
focused on the output of cheaper, less healthy foods. This has resulted in a
situation where highly processed foods make up a significant proportion of
the diet of typical families.38
• In 2017, the largest manufacturing category (with a value of £6 billion,

contributing 19% to the total food and drink manufacturing GVA), was
‘other food products’ which included prepared meals, confectionary,
condiments and seasonings. Following this, bakery products made the
second largest contribution (£3.9 billion), followed by meat and meat
products (£3.7 billion).39
• UK households have been shown to purchase the highest proportion of

highly processed foods across 19 European countries. In the UK, more
than half (50.7%) all total dietary energy from purchases came from
highly processed foods, compared to only 10.2% in Portugal and 13.4%
in Italy. Furthermore, this research found that across all 19 countries,
for each 1% increase in national purchasing of highly processed foods,
obesity prevalence increased by 0.25%.40
• The proportion of advertising spend on less healthy foods is significantly

higher than on more healthy products. The Food Foundation estimated
that in 2017, over £300 million worth of advertising was spent on less
38 The Food Foundation, Food System Challenges: https://foodfoundation.org.uk/food-system-challenges/

39 Department for Environment, Food and Rural Affairs, National Statistics: Food Statistics in your
pocket: Food Chain, (updated 30 March): https://www.gov.uk/government/publications/food-statistics-
40 Written evidence from the University of Southampton and the MRC Life Course Epidemiology Unit
Southampton General Hospital (ZFP0080) cited: CarlosMonteiro , et al (2018) Household availability
of ultra-processed foods and obesity in nineteen European countries. Public Health Nutrition.
21(1):18-26, DOI: 10.1017/S1368980017001379
healthy food products, compared to £16 million spent on fruit and

vegetables in the UK. Overall, it estimated that 46% of food and drink
advertising is spent on confectionary, sweet and savoury snacks, with
only 2.5% on fruit and vegetables.41
• The UK population’s fruit and vegetable consumption is low. The

latest National Diet and Nutrition Survey found that only 31% of
adults, 32% of 65- to 74-year-olds and 8% of teenagers meet the 5 a
day recommendation for fruit and vegetables.42 The National Diet and
Nutrition Survey also found that over the period 2008/09-2016/17,
there was little change in fruit and vegetable consumption, with
all age and sex groups showing a mean intake of below the 5 a day
recommendation.43
• While consumption of fruit and vegetables is low, consumption of less

healthy food is high. Evidence from the Food Foundation, the London
School of Hygiene and Tropical Medicine (LSHTM) and Sustainable
and Healthy Food Systems (SHEFS) highlighted research that
suggested that 37% of adults’ dietary energy comes from HFSS foods.
It stated that children’s diets were found to be even worse with 47% of
primary school children’s dietary energy from HFSS products.44
• Those in the poorest deciles are even less likely to meet recommendations
on healthy eating guidance. Evidence from the Food Foundation,
LSHTM and SHEFS stated that: “The poorest households only
purchase 3.2 portions of fruit and vegetables per day”45 and that
only “17% of the poorest decile were consuming sufficient fruit and
vegetables compared with 26% in the general population.”46
41 The Food Foundation, The Broken Plate, (26 February 2019) p 14: https://foodfoundation.org.uk/wp-
content/uploads/2019/02/The-Broken-Plate.pdf [accessed 30 June 2020]
42 Public Health England, PHE’s publishes latest data on nation’s diet, (16 March 2018): https://www.gov.
uk/government/news/phe-publishes-latest-data-on-nations-diet [accessed 30 June 2020]
43 Public Health England and Food Standards Agency: National Diet and Nutrition Survey, Years 1 to
9 of the rolling programme (2008/2009–2016/2017): time trend and income analyses (January 2019) p
25: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/
file/772434/NDNS_UK_Y1-9_report.pdf [accessed 30 June 2020]
44 Written evidence from the Food Foundation, London School of Hygiene and Tropical Medicine and
Sustainable and Healthy Food Systems (SHEFS) (ZFP0073)
45 The Food Foundation, Food system challenges: https://foodfoundation.org.uk/food-system-challenges/
Figure 3: UK grocery market shares, 2017/18
Morrisons 9% Aldi 8%
Sainsbury’s 11%
Marks
Tesco 21%
and
Spencer Waitrose
Internet 7% 4% 4%
Iceland
Others 14% Asda 10% Lidl 5% Co-op 4% 3%
Source: Department for Environment Food and Rural Affairs, National Statistics: Food Statistics in your pocket:
Food Chain, (30 March 2020): https://www.gov.uk/government/publications/food-statistics-pocketbook/
food-statistics-in-your-pocket-food-chain [accessed 30 June 2020]. ‘Internet’ includes online orders from the
largest supermarkets.
Diet and health

23. For most of the population in this country, buying food is based on choice,
availability, price and personal preference. However, the dependency on less
healthy, processed foods is having dire consequences for population health,
and places a significant burden on the health system and the economy. The
levels of obesity in the UK are perhaps the most obvious indication of the
quality of the population’s diet. Obesity is a risk factor for a number of health
conditions, including coronary heart disease, type 2 diabetes, some types of
cancer, and strokes.47 The Government’s own assessment of the scale and
impact of obesity makes for concerning reading:
• It is estimated that the NHS spent £6.1 billion on overweight and

obesity-related ill health in 2014 - 2015. Annual spend on the treatment
of obesity and diabetes is greater than the amount spent on the police,
the fire service and the judicial system combined. Public Health
England has warned that obesity has a serious impact on economic
development, as it estimates that the overall cost of obesity to wider
society £27 billion. Furthermore, PHE predicts that the UK-wide
NHS costs attributable to obesity are projected to reach £9.7 billion by
2050, with wider costs to society estimated to reach £49.9 billion per
year.48
• Excess calorie consumption (in relation to energy expenditure) is the

root cause of the obesity crisis. Overweight or obese children consume
47 Public Health England, ‘Health Matters: obesity and the food environment’, (31 March 2017): https://
www.gov.uk/government/publications/health-matters-obesity-and-the-food-environment/health-
matters-obesity-and-the-food-environment--2 [accessed 30 June 2020]
48 Ibid.
up to 500 extra calories per day, depending on their age and sex, while
adults consume between 200 and 300 calories too many.49
• In 2018, the majority of adults in England were overweight or obese

(63%). Of these, 28% of adults were classified as obese. There has been
a clear long-term increase in obesity levels from 15% in 1993 to 28%
in 2018.50 Hospital admissions where obesity was a factor rose by 23%
between 2017/18 and 2018/19.51
• According to the Organisation for Economic Co-operation and

Development (OECD), across its member countries52, obesity rates
continue to rise, with 56% of adults overweight or obese and almost
one-third of children aged 5-9 are overweight (2019 publication).53
In 2017, OECD data showed that, among the countries reporting
measured data (rather than self-reported data), the UK had the tenth
highest rates of obesity among adults from the 23 countries listed.54
24. A recently published (June 2020) report by Public Health England on the
disparities in the risk and outcomes of COVID-19 suggested that “emerging
evidence has established a need to better understand the association between
obesity and COVID-19 particularly as 28% of adults in England in 2018
were obese (Body Mass Index (BMI) of 30kg/m2 or more) and 3% were
morbidly obese.”55 The PHE report cited three studies on the relationship
between obesity and COVID-19:
• A report from the Intensive Care National Audit and Research Centre
that used data up to 21 May 2020 and showed that 7.7% of patients
critically ill in intensive care units (ICU) with confirmed COVID-19
were morbidly obese compared with 2.9% of the general population
(after adjusting for age and sex). This disparity was also seen when
looking at white and non-white patients separately. The report also
showed a relationship between BMI and death from COVID-19 in
BMI over 30 kg/m2.56
49 Public Health England, Sugar Reduction Programme, Progress made by the industry in the first year, (May
22 2018): https://publichealthengland.exposure.co/sugar-reduction-programme [accessed 30 June
2020]
50 NHS Digital, Statistics on Obesity, Physical Activity and Diet, England, 2020, (published 5 May 2020):
https://digital.nhs.uk/data-and-information/publications/statistical/statistics-on-obesity-physical-
activity-and-diet/england-2020/part-3-adult-obesity-copy [accessed 30 June 2020]
51 NHS Digital, Statistics on Obesity, Physical Activity and Diet, England, 2020’, (5 May 2020):https://
digital.nhs.uk/data-and-information/publications/statistical/statistics-on-obesity-physical-activity-
and-diet/england-2020 [accessed 30 June 2020]
52 List of OECD countries: https://www.oecd.org/about/document/list-oecd-member-countries.htm
53 OECD, Health at a Glance 2019, OECD indicators, (2019) p 10: https://www.oecd-ilibrary.org/
docserver/4dd50c09-en.pdf [accessed 30 June 2020]
54 NHS Digital, Statistics on Obesity, Physical Activity and Diet, England, 2020, (5 May 2020): https://
digital.nhs.uk/data-and-information/publications/statistical/statistics-on-obesity-physical-activity-
and-diet/england-2020/part-3-adult-obesity-copy [accessed 30 June 2020]
55 Public Health England, Disparities in the risk and outcomes of COVID-19 (June 2020) p 60: https://
assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/891116/
disparities_review.pdf [accessed 30 June 2020]
56 PHE states that this analysis controlled for other demographics and health conditions but is restricted
to those patients admitted to ICU from 289 participating trusts. Public Health England, Disparities
in the risk and outcomes of COVID-19 (June 2020) p 60: https://assets.publishing.service.gov.uk/
government/uploads/system/uploads/attachment_data/file/891116/disparities_review.pdf [accessed 30
June 2020
• A study using data from over 400,000 patients aged 40 to 69 from UK

Biobank linked to COVID-19 test data from PHE found that higher
BMI was associated with a positive COVID-19 diagnosis.57
• A study by the OpenSAFELY collaborative used a dataset of 17 million

adult primary care electronic health records linked to deaths data from
the COVID-19 Patient Notification System up to 25 April 2020. This
found a relationship between death from COVID-19 and BMI when
controlling for demographics and other health conditions.58
Public Health England noted that, although measuring the different
outcomes of dying from COVID-19 once in ICU, contracting COVID-19
and dying from COVID-19, all three studies showed a relationship between
COVID-19 and increasing BMI. PHE stated that these findings were also
consistent with studies from other countries.59
Health inequalities
25. Given the focus of our inquiry, we were particularly concerned about the
extent to which diet-related ill health affects those in lower income groups.
There is considerable evidence to suggest that there is inequality when it
comes to being able to eat a healthy diet:
• In 2017, prevalence of excess weight was 11 percentage points higher

in the most deprived areas than the least deprived areas. In the most
deprived tenth of areas, 67% of people were overweight or obese,
compared to 56% in the least deprived.
• Children living in deprived areas are around twice as likely to be obese.

Among children aged 4-5, 12.4% of those in the most deprived areas
were obese compared to 6.4 % in the least deprived areas. By age 10-11,
this had risen to 26.7% in the most deprived areas compared to 13.3%
in the least.60
26. Figures from the Office for National Statistics have shown that life expectancy
for males in the most deprived areas can be up to 9.5 years less than those
in the least deprived areas, with the difference at 7.7 years for females.61 (See
Figure 4).
27. In February 2020, Health Equity in England: The Marmot Review 10 years
on was published, the follow up report to Professor Sir Michael Marmot’s
57 PHE states that compared with non-overweight people (BMI < 25 kg/m2), the odds ratios were 1.26
(confidence interval of 1.01-1.56) for those who were overweight, 1.37 (1.06-1.76) for those in obese
class I and 2.04 (1.50-2.77) for those in obese classes II and III combined. Public Health England,
Disparities in the risk and outcomes of COVID-19 (June 2020) p 60: https://assets.publishing.service.
gov.uk/government/uploads/system/uploads/attachment_data/file/891116/disparities_review.pdf
58 PHE states that the hazard ratio compared to those who were not obese increased as BMI increased
and was 1.27 (1.18-1.36) for those in obese class I, 1.56 (1.41-1.73) for those in obese class II and 2.27
(1.99 to 2.58) for those in obese class III (morbidly obese).
59 Public Health England, Disparities in the risk and outcomes of COVID-19 (June 2020) p 60: https://
60 House of Commons Library, Obesity Statistics, Briefing Paper Number 3336, 6 August 2019
61 Office for National Statistics, Health state life expectancies by national deprivation deciles, England: 2016 to
2018’, (27 March 2020): https://www.ons.gov.uk/peoplepopulationandcommunity/healthandsocialcare/
healthinequalities/bulletins/healthstatelifeexpectanciesbyindexofmultipledeprivationimd/2016to2018
landmark report on health inequalities. The report examined the progress

that has been made in addressing health inequalities in England over the last
decade. It stated that:
• Life expectancy follows the social gradient—the more deprived the

area the shorter the life expectancy. This gradient has become steeper;
inequalities in life expectancy have increased. Among women in the
most deprived 10 percent of areas, life expectancy fell between 2010–12
and 2016–18.
• The gradient in healthy life expectancy is steeper than that of life

expectancy. It means that people in more deprived areas spend more of
their shorter lives in ill health than those in less deprived areas.62
Figure 4: Life expectancy and healthy life expectancy by age, sex and
deprivation decile in England, 2016-18
Male Female
Most deprived
1
2
3
4
5
6
7
8
9
10
90 80 70 60 50 0 0 50 60 70 80 90
Least deprived
Good health Poorer health
Source: Office for National Statistics, ‘Health state life expectancies by national deprivation deciles, England:
2016 to 2018’, 27 March 2020: https://www.ons.gov.uk/peoplepopulationandcommunity/healthandsocialcare/
healthinequalities/bulletins/healthstatelifeexpectanciesbyindexofmultipledeprivationimd/2016to2018.Life
expectancy refers to period life expectancy, the average number of years a person would live, if they experienced that
particular area’s age-specific mortality rates for that time period throughout their life. Based on survey data. Survey
respondents who answered their general health as “very good” and “good” were classified as having good health.
Those who answered “fair”, “bad” and “very bad” were classified as having poorer health.
28. The report also referred to the issue of food insecurity and observed that:
“One of the clearest and most immediate impacts of being in poverty is
an inability to buy nutritious food. The 2010 Marmot Review discussed
the relationship between food and health but the common use of food
banks and the term arose after the report was published. There is also
widespread concern at food insecurity and poor nutritional intake and
62 Institute of Health Equity, Health Equity in England: The Marmot Review 10 year on (February 2020)
p 84: https://www.health.org.uk/sites/default/files/upload/publications/2020/Health%20Equity%20
in%20England_The%20Marmot%20Review%2010%20Years%20On_full%20report.pdf [accessed
30 June 2020]
impacts on health and wellbeing; likely contributing to inequalities in

cancer, diabetes and coronary heart disease.”63
29. Diet-related ill health is more likely to affect those in lower income groups and
it is reasonable to conclude that those who are struggling to eat are certainly
struggling to eat well. Evidence from the Food Foundation, LSHTM and
SHEFS told us that:
“Food insecurity not only damages physical health but also causes social
harm bringing profound anxiety and stress to families and can affect
children’s school attendance, achievement and attainment. It is associated
with poor social well-being, poor quality of life and unhealthy lifestyles
with food insecure children being more likely to report poorer health
status and more likely to be hospitalised than food secure children.”64
30. Professor Marmot also pointed to the relationship between food insecurity
and poor diet, stating that:
“There is evidence to reject the twin notions that people are poor
because they make poor choices, and that the poor health of the poor
results from poor choices. Rather, it is poverty that leads to less healthy
choices and the poor health of those lower down the social hierarchy
results from the restricted range of options available to those on low
incomes, as well as the direct health impacts associated with the stresses
and poor conditions which result from poverty.”65
31. The report by Public Health England on the disparities in the risk and
outcomes of COVID-19 confirmed that the impact of COVID-19 has
replicated existing health inequalities, and in some cases, has increased
them. It found that:
• Risk of dying among those diagnosed with COVID-19 was also higher
in males than females; higher in those living in the more deprived areas
than those living in the least deprived; and higher in those in Black,
Asian and Minority Ethnic (BAME) groups than in White ethnic
groups.
• People who live in deprived areas have higher diagnosis rates and death
rates than those living in less deprived areas. The mortality rates from
COVID-19 in the most deprived areas were more than double the least
deprived areas, for both males and females.66
30 June 2020]
30 June 2020]
66 Public Health England, Disparities in the risk and outcomes of COVID-19 (June 2020): https://assets.
publishing.service.gov.uk /government /uploads/system /uploads/attachment_data/f ile/891116/
Diet and food production

32. We also received evidence on the environmental impact of food production,
including that:
• Agriculture is responsible for 87% of UK ammonia emissions (mainly

from livestock farming and fertiliser use. Agriculture is also responsible
for 10% of the UK’s greenhouse gas emissions.67
• Evidence from the Food Foundation, the London School of Hygiene

and Tropical Medicine (LSHTM) and SHEFS highlighted LSHTM
research which had found that the least healthy diets on average produce
around 25% more greenhouse gas emissions than the healthiest, largely
because they contain more meat and less fruit and vegetables.68
• There are high levels of food waste in the UK: “an estimated 10.2
million tonnes of food and drink are wasted annually after the farm
gate, worth around £20 billion.”69
33. A number of witnesses suggested that the current food system is biased
towards producing less healthy foods. UK Research and Innovation provided
the following summary of the impact of this demand:
“Food production processes directly and indirectly impact consumers’
dietary choices, with the effects related to food production extending
across income groups, with some impacted more than others. The
global food system produces more grains, sugars and fats than we need
for health, but not enough fruits and vegetables. These grains, sugars
and fats are highly subsidised, and when refined and combined in
manufacturing, lead to cheap and unhealthy products that permeate our
food environments, resulting in over-consumption, poor nutrition and
health.”70
Current Government intervention

Childhood Obesity Plans
34. In August 2016, the Government published Childhood Obesity: A Plan for
Action, the first of three chapters which include measures to help tackle meet
the Government’s ambition both to halve childhood obesity and to reduce
significantly the gap in obesity between children from the most and least
deprived areas by 2030.71
35. Although this ambition has been welcomed, concerns have been raised that
significant challenges still exist, including: that childhood obesity rates are
showing little signs of reducing, and are actually increasing in some age
groups; that obesity continues to place a considerable burden on the NHS;
and that some of the measures outlined in the Plan are not sufficiently robust
67 Department for Environment, Food and Rural Affairs, The future farming and environment evidence
compendium (September 2019): https://assets.publishing.service.gov.uk/government/uploads/system/
uploads/attachment_data/file/834432/evidence-compendium-26sep19.pdf [accessed 30 June 2020]
69 Written evidence from HM Government (ZFP0079)
70 Written evidence from UK Research and Innovation (ZFP0039)
71 Department of Health and Social Care, Childhood Obesity: a plan for action, Chapter 2 (June 2018)
file/718903/childhood-obesity-a-plan-for-action-chapter-2.pdf [accessed 30 June 2020]
or sustainable to facilitate the change in levels of childhood obesity needed to

meet the Government’s 2030 target.
36. The efficacy of the individual policies set out in the chapters of the
Childhood Obesity Plan are considered in further detail in Chapter 4,
the Food Environment. There was, however, a clear consensus across the
evidence that efforts to tackle obesity have stalled. This was a view very
clearly expressed by Professor Susan Jebb, Professor of diet and population
health at the University of Oxford, who said:
“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.”72
37. In 2019, Professor Dame Sally Davies, the then Chief Medical Officer,
published an independent report on childhood obesity, which stated that:
“The Government ambition is to halve childhood obesity by 2030—in
England, we are nowhere near achieving this.”73 The report went on to
conclude that:
“The Government has laid important foundations for change with
two ‘chapters’ of a national childhood obesity plan, a prevention green
paper, Advancing our health: prevention in the 2020s, and the NHS
Long Term Plan. If implemented in full, these plans will significantly
reduce levels of childhood obesity and improve our children’s health.
This would be a major achievement, but the plans, alone, will not meet
the 2030 ambition. To meet the ambition and children’s needs, we must
go further and faster.”74
38. Jenny Oldroyd, Deputy Director Obesity, Food and Nutrition at the
Department of Health and Social Care (DHSC), highlighted that UNICEF
and World Obesity Federation reports had set out how the UK is paving
the way to ensure children grow up in a healthy food environment.75 When
questioned further by the Committee, however, as to whether there was
any evidence to suggest that childhood obesity is declining, Jenny Oldroyd
confirmed that: “No, that evidence is not there at the moment … It is slowly
moving up.”76
Agriculture Bill
39. The Agriculture Bill 2019–20 (preceded by the Agriculture Bill 2017–
19 which fell at Dissolution in October 2019), will provide the legislative
framework for agriculture support schemes to replace the EU’s Common
Agricultural Policy (CAP). Current payments to farmers for environmental
protection are incorporated within the Countryside Stewardship funding or
72 Q 65 (Professor Susan Jebb)

73 Professor Dame Sally Davies, Time to Solve Childhood Obesity. An Independent Report by the Chief Medical
Officer (2019), p 2: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/
attachment_data/file/837907/cmo-special-report-childhood-obesity-october-2019.pdf [accessed 30
June 2020]
74 Ibid.
75 Q 17 (Jenny Oldroyd)
76 Ibid.
the Basic Payment Scheme, and will be replaced by the Environmental Land
Management scheme (ELMS) contained in the Agriculture Bill.
40. The ELMS proposes to reward a number of environmental ‘public goods’
with public money. The Government will support and reward farmers for
providing improved environmental outcomes such as improved soil health
and carbon emissions. The Department told us that the scheme may lead
some farmers to move away from “traditional agricultural activity”.77 The
discussions of the scheme, including what, exactly, farmers will be rewarded
for and the frameworks by which progress will be measured, are at a very
early stage, and few details are available.
National Food Strategy

41. The Government told us that it recognises that there are a number of
interconnected challenges across the food system, including food security,
health and climate change. It told us that its response to these challenges has
been to commission the National Food Strategy review.78
42. On 27 June 2019, the Department for Environment, Food and Rural Affairs
(DEFRA) announced an independent review of the UK food system. The
review, supported by DEFRA officials and an advisory group, is being led
by Henry Dimbleby, co-founder of the restaurant chain Leon, and lead non-
executive board member of DEFRA. Its findings will be used to develop a
National Food Strategy for England.
43. The review aims to address environmental and health problems caused by
our food system, to ensure the security of our food supply, and to maximise
potential of the coming revolution in agricultural technology. The aims of the
National Food Strategy were universally welcomed throughout the evidence.
The ‘real’ cost of food

44. Throughout the evidence, a clear concern emerged; that, through the
damage to health and the environment it causes, the food system is generating
considerable ‘external’ costs (sometimes referred to as ‘externalities’) that it
is not accounting for. Professor Tim Lang, Professor of Food Policy, City
University of London stated that: “We have very cheap food, relatively, but
the costs are dumped elsewhere, on health and on the environment.”79
45. According to one estimate made by the Sustainable Food Trust:
“for each £1 spent on food in the shops in the UK, consumers incur
extra hidden costs of £1. In addition to the £120 billion spent annually
on food by consumers in the UK as a whole, the UK food system
generates further costs of £120 billion in external costs.”80
46. In reaching the figure of the “hidden £1”, the Sustainable Food Trust
stated that it had accounted for the cost of factors, including: natural capital
degradation; biodiversity loss; diet-related ill health; farm support payments;
77 Q 29 (Alison Ismail)

79 Q 2 (Professor Tim Lang)
80 Written evidence from the Sustainable Food Trust (ZFP0007)
and regulation81 though we recognise that this is just one view on the potential
external costs of the food system.
47. A number of witnesses suggested that extra costs incurred by the food
system to health and the environment are currently not paid by the food
manufacturers and retailers that cause the damage, nor are they included
within the retail price of food. The Sustainable Food Trust claims those
costs are passed on to the public through “taxation, lost income due to
ill health and the price of mitigating and adapting to climate change and
environmental degradation.”82
Conclusions
48. The food system is vast and complex. Any measures aimed at ‘wider system
change’ will need to take into account the diversity of the industries.
Decisions about the food system will also have implications for health and for
the economy. As Henry Dimbleby, the leader of the National Food Strategy
Review, said about the food system: “it is almost impossible to act on it in
any way without creating winners and losers.”83
49. Over the course of the inquiry, we have encountered several ‘quick fix’ policy
areas. These are either: policies which are being poorly implemented and not
therefore having the intended effect, or policies which are causing harm and
should be removed.
50. Many witnesses spoke of the need for overwhelming ‘system change’,
although this term was not satisfactorily explained. We have decided to
refine these requests and recommend an overhaul of Government policy to
address three specific problem areas identified in the evidence as crucial to
the functioning of the current ‘system’:
(a) Changing ‘the food environment’, for example by regulation, education,
or incentive;
(b) Changing agricultural practices by altering criteria for farming
subsidies and providing support and clarity to the sector; and
(c) Improving the governance of ‘food policy’ and integrating this into
social and economic policy.
81 The full breakdown of these extra costs was listed as: natural capital degradation; biodiversity
loss; production-related ill health; diet related disease; imported food; farm support payments; and
regulation and research. The Sustainable Food Trust, The Hidden Cost of UK Food (21 November
2017) p 8: https://sustainablefoodtrust.org/wp-content/uploads/2013/04/Website-Version-The-
Hidden-Cost-of-UK-Food.pdf [accessed 30 June 2020]
82 The Sustainable Food Trust, The Hidden Cost of UK Food (21 November 2017): https://
sustainablefoodtrust.org/articles/hidden-cost-uk-food/ [accessed 30 June 2020]
83 Q 100 (Henry Dimbleby)
Chapter 3: POVERTY AND FOOD INSECURITY
51. Poor diet can have a significant impact upon an individual’s health and life
chances and is associated with considerable, unacceptable costs to the NHS
and UK economy. Incidences of poor diets and resultant health problems,
though widespread in every demographic, are more densely concentrated
in lower income groups who must overcome far greater hurdles to access
a healthy diet than their more fortunate counterparts. These individuals
and groups are significantly more likely to suffer from the particularly acute
levels of food insecurity marked by visits to food banks and, in some cases,
persistent hunger. One academic described food insecurity as: “a public health
emergency”.84The outbreak of COVID-19 has had a significant impact on
income for many people, exacerbating existing problems of poverty and food
insecurity. We have, where possible, incorporated some of the preliminary
analysis of this impact into our report.
52. Food insecurity should have no place in 21st century Britain. No individual
should be skipping meals because there is insufficient food for themselves
or their family. And yet, this is still the case. We were compelled to ask:
how does the situation of food insecurity arise and what could be done to
prevent it? The first section of this chapter therefore addresses the causes of
food insecurity, concluding that it is a symptom of poverty. It is important to
understand the lived reality behind the statistics, so this chapter draws from
what people with lived experience of poverty and food insecurity told us. It
was beyond our remit to address the root causes of poverty, but it was perhaps
inevitable that we make some comment on areas that were drawn to our
attention: particularly the five-week wait for the first payment of Universal
Credit (UC) which has for many represented a crisis leading to hunger.
53. Beyond this issue of acute food insecurity is a wider issue: access to healthy
diets. A large proportion of the population, not just the poorest in society,
cannot easily access a healthy, balanced diet that provides them with the
right quantities of the nutrients they need. Like hunger, this is a type of
malnutrition—in this case, individuals can be both overnourished with
calories and at the same time undernourished in relation to key nutrients.85
No demographic group in the UK meets the Government’s guidance on
healthy diets, and levels of obesity and diet related ill health are too high
in every demographic group—but both obesity and diet-related ill health
disproportionally affect lower income groups.
54. The question of the affordability of healthy food arose early in our inquiry:
healthy food has been shown to be three times more expensive, calorie for
calorie, than less healthy alternatives. We were also directed to research
estimating the true cost of meeting the Government’s recommendations
for healthy eating, including unsettling statistics demonstrating the large
proportion of disposable income that the poorest families would have to
spend to meet them. We investigated the benefits system and asked why
consideration of the cost of a healthy diet does not form part of its design.
Other barriers to healthy diets, including physical resources and the
increased level of effort and ‘emotional bandwidth’ required for the poorest
84 Written evidence from Dr Sinéad Furey (ZFP0019)

85 Environmental Audit Committee, Sustainable Development Goals in the UK follow up: Hunger,
malnutrition and food insecurity in the UK (Thirteenth Report, Session 2017–19, HC 1491)
families to meet these recommendations also emerged as very real barriers to

consuming a healthy diet.
Box 2: 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:
“In Biker, people are on the pre-paid meters so they’ve got to go and
top up their electricity, however many times, so it will be the same
for them, having to look constantly how much electricity, how much
gas they’ve got, and then trying to work out exactly how much it is
going to cost to boil that kettle. Is it going to be cheaper to boil that
kettle to make a pot noodle or is it going to be cheaper to try and cook
something from their freezer, like a pizza? Is it going to be cheaper to
put that in the oven? Or is it going to be a case of you just don’t cook
that night. Constant awareness, constant choices but it’s not really a
choice because you have no choice but to think of things like that, and
it is mentally draining.”
Source: See Appendix 5.
Measurements of poverty
55. All measures of poverty rely, to some degree, on determining the amount
of money available to people. The Government’s definition of poverty is
based on the median household income without reference to expenditure
other than housing costs. Other measurements, including those based on
the recommendations of the Social Metrics Commission, (SMC)86 include
measurements of other aspects of life which affect spending power such as
savings and living costs. As defined by the Joseph Rowntree Foundation
(JRF), income must be related to necessary outgoings: “poverty is when your
resources fall well below your needs.”87
56. The SMC recommended a new measure of poverty which is based on the
extent to which someone’s resources meet their needs. There was broad
support for this measure. Helen Barnard, Deputy Director of Policy and
Partnerships at the Joseph Rowntree Foundation, told us that:
“The best measure that we have now is the Social Metrics Commission
measure. This is particularly because it takes into account the inescapable
costs—such as housing, childcare and the costs of being disabled—as
well as your resources, which are income but also things such as liquid
savings. Those two sides of the equation are very important: it is not just
about how much income you have but about what things cost.”88
57. Garry Lemon, Director of Policy, External affairs and Research at the
Trussell Trust, explained that by considering costs as well as expenses, “you
can see that groups that have had policy solutions put in place for them are
86 Social Metrics Commission, Social Metrics Commission 2018 Report (September 2018): https://
socialmetricscommission.org.uk/social-metrics-commission-2018-report/ [accessed 30 June 2020].
The Social Metrics Commission was established in 2016 to determine a new series of poverty metrics
to better reflect the reality of poverty in the UK.
87 Q 31 (Helen Barnard)
88 Ibid.
less likely to be in poverty than in the past. For example, particularly with
older people we have seen an impressive decrease in poverty.”89 Mr Lemon
suggested better understanding of poverty levels could help to improve policy
making, and suggested that, “the decrease in poverty for older people is an
example of where good evidence-based policy can make a real difference if
the numbers are understood properly.”90
58. The headline poverty measures used in the UK count the number of
individuals falling below a threshold of household income. One commonly
used measure is people in relative low income (sometimes referred to as
relative poverty). This counts people living in households with income
below 60% of the median household income. Another measure is absolute
low income (or absolute poverty), which counts people living in households
with income below 60% of the median in some base year (usually 2010/11),91
uprated for inflation.92 Income can be measured before housing costs (BHC)
or after housing costs (AHC).
59. The 2018/19 figures for the UK suggest that:
• 11 million people (17%) are in relative low income BHC and 14.5 million
AHC (22%). This includes 2.8 million children (20%) in relative low
income BHC and 4.2 million AHC (30%).93
• 9.7 million people (15%) are in absolute low income BHC and 12.9
million AHC (20%). This includes 2.4 million children (17%) in
absolute low income BHC and 3.7 million AHC (26%).94
These figures are also outlined in Figure 5.
60. Trend analysis of poverty statistics suggests that, over the longer-term,
there has been a reduction in poverty rates since the late 1990s for children,
pensioners and working-age parents. However, for working-age adults
without dependent children, the likelihood of being in relative low income
has increased. There are also suggestions that poverty rates as a whole have
started to increase. Projections from the Institute for Fiscal Studies and the
Resolution Foundation,95 indicate that:
“The official rate of relative AHC poverty is projected to rise by over 2
[percentage points] between 2015–16 and 2021–22. All of the projected
increase in relative poverty is driven by relative child poverty, which is
projected to rise by 7 [percentage points].”96

90 Ibid.
91 There appears to be no statistical basis to this ‘base year’, which is only occasionally reviewed.
2020
93 Ibid. For the purposes of the data, a ‘child’ is an individual aged under 16 or one aged 16 to 19 years old
who is not married, in a civil partnership nor living with a partner, living with parents/a responsible
adult and in full-time non-advanced education or in unwaged government training.
2020
95 Which estimate how the incomes of different households would evolve up to 2021–22. Estimates are
based on if current tax and benefit policy plans are kept to and if the macroeconomic forecasts from
the Office of Budget Responsibility—for things such as earnings and employment—were correct.
96 Institute for Fiscal Studies, Living Standards, poverty and inequality in the UK: 2017–18 to 2021–2022
(November 2017): https://www.ifs.org.uk/uploads/publications/comms/R136.pdf [accessed 30 June
2020]
Trends in the SMC measure are similar to relative poverty measured after
housing costs (AHC), though the SMC measurement gives a lower percentage
for pensioner poverty, and higher for poverty among children and people in
families where someone is disabled than the official statistics.97
61. Alison Garnham, Chief Executive of the Child Poverty Action Group
(CPAG), highlighted that child poverty has risen significantly and that the
figures for child poverty also highlight the levels of in work poverty. She
stated that child poverty, “has risen by 500,000 since 2010, up to 4.1 million
from 3.6 million. According to the Institute for Fiscal Studies, we expect
that level to go on rising to above 5 million. Seven out of 10 of those children
live with at least one parent who works.”98 Ms Garnham highlighted that the
proportion of in work poverty has a particular impact on children in those
families because fewer of them are entitled to support like free school meals
which are based on receipt of benefits.99
2020
98 Q 32 (Alison Garnham) Ms Garnham was giving evidence in October 2019, at which time the number
of children known to be in relative low income after housing costs was 4.1 million. Based on 2018/19
figures this has risen further, to 4.2 million.
99 Q 32 (Alison Garnham)
Figure 5: Number and proportion of adults and children in relative and

absolute poverty, before and after housing costs, UK, 2018/19
11 million people, including 14.5 million people, including

2.8 million children, are in relative 4.2 million children, are in relative
poverty before housing costs. poverty after housing costs.
9.7 million people, including 12.9 million people, including

2.4 million children, are in absolute 3.7 million children, are in absolute
poverty before housing costs. poverty after housing costs.
Source: Department for Work and Pensions, Households below average income (HBAI) statistics, (26 March
2020): https://www.gov.uk/government/collections/households-below-average-income-hbai--2 [accessed 30 June
2020]
COVID-19 and poverty

62. Following the outbreak of COVID-19, it became clear that the figures on
poverty we received at the beginning of the inquiry may no longer reflect
the current and future reality. The World Bank has estimated that up to 60
million people worldwide will be pushed into “extreme poverty” as a result

of the pandemic100 and the UK will not be exempt from this trend.
63. Official national statistics indicating the impact of the COVID-19 outbreak
on the UK labour market are not yet available but there are some clear
indicators that coronavirus will have a significant effect on poverty levels.
Some sectors have almost entirely shut down, 101 and a sharp recession
appears likely.102 The Chancellor, the Rt. Hon. Rishi Sunak MP, told the
House of Lords Economic Affairs Committee that:
“I certainly will not be able to protect every job and every business.
We are already seeing that in the data. No doubt there will be more
hardship to come. This lockdown is having a very significant impact on
our economy. We are likely to face a severe recession, the likes of which
we have not seen, and that will have an impact on employment.”103
64. Analysis of YouGov survey data by the Food Foundation has found that 2%
of respondents had lost all of their income, whilst 6% said they have had to
borrow money or take out personal loans as a result of COVID-19.104 New
Universal Credit claims increased dramatically at the start of the COVID-19
outbreak. Since 16 March to the end of April 2020, the Department for
Work and Pensions received over 1.8 million claims for Universal Credit,
over 250,000 claims for Jobseeker’s Allowance, and over 20,000 claims for
Employment and Support Allowance. Overall, this is six times the volume
that it would typically experience and in one week, there was a 10-fold
increase. The rate for Universal Credit claims appears to have stabilised at
about 20, 000 to 25,000 per day which is double that of a standard week pre-
COVID-19. The DWP has stated that they issued almost 700,000 advances
to claimants who felt they could not wait for their first routine payment and
that the vast majority of these claimants received money within 72 hours.105
65. It appears that, financially, lower earners have been hardest hit by the
outbreak, with one third of employees in the bottom 10% of earners working
in shut down sectors, compared to 5% in the top 10%. Moreover, less than
10% in the bottom half of earners say they can work from home.106
Food insecurity
66. The term ‘food poverty’ is often used interchangeably with the term ‘food
insecurity’. Food insecurity has been described as: “limited or uncertain
availability of nutritionally adequate and safe foods or limited or uncertain
ability to acquire acceptable foods in socially acceptable ways (e.g. without
resorting to emergency food supplies, scavenging, stealing or other coping
100 BBC, Coronavirus: World Bank warns 60m at risk of “extreme poverty”, (20 May 2020): https://www.bbc.
co.uk/news/business-52733706 [accessed 30 June 2020]
101 House of Commons Library, Coronavirus: Impact on the Labour market, Briefing Paper Number
8898, 30 April 2020
102 BBC, Bank of England warns of sharpest recession on record, (7 May 2020): https://www.bbc.co.uk/news/
business-52566030 [accessed 30 June 2020]
103 Oral evidence taken before the Economic Affairs Committee, Tuesday 19 May (Session 2019–2021)
Q 1 (The Rt. Hon. Rishi Sunak MP)
104 The Food Foundation, New Food Foundation Survey: three million Britons are going hungry just three
weeks into lockdown, (April 2020): https://foodfoundation.org.uk/new-food-foundation-survey-three-
million-britons-are-going-hungry-just-three-weeks-into-lockdown/ [accessed 30 June 2020]
105 HC Debate, 4 May 2020, cols 421-424
106 House of Commons Library, Coronavirus: Impact on the Labour market, Briefing Paper Number
8898, 30 April 2020
strategies).”107 Food insecurity prevalence is, therefore, a measure of

individual or household inability to attain sufficient nutritious food.
67. Until recently, data on the prevalence of food insecurity was not collected
routinely in the UK.108 There are, however, some other measures of food
insecurity that were highlighted in our evidence that can be used to estimate
its prevalence:
• A 2018 report by the Food and Agriculture Organization (FAO) of the

United Nations found that between 2015 and 2017, 2.2 million people
in the UK were severely food insecure.109 A report from the House
of Commons Environmental Audit Committee suggested that this
represented “the highest reporting level of any EU country, and means
that the UK is responsible for one in five of all severely food insecure
people in Europe.”110
• Results from the 2018 Food and You Survey, which found that: “80%
of respondents lived in households with high food security, 10% in
households classified as marginally food secure, and 10% reported
living in households with low or very low food security.”111
68. Our evidence highlighted the use of food banks as a key indicator of levels
of food insecurity. Figures from the Trussell Trust, which runs around
1,200 food bank centres across the UK, indicated both a concerning level
of use, and suggested that the reliance on foodbanks was increasing. Figures
published by the Trussell Trust figures showed that:
• Between 1 April 2018 and 31 March 2019, the Trussell Trust distributed
1.6 million three-day emergency food parcels. This represents a 19%
increase on the previous year;
• In the last five years, food bank use in the Trussell Trust network has
increased by 73%.112
69. Based on the available evidence and despite the lack of official data on food
insecurity, we think it is fair to conclude that there are unacceptable levels
of food insecurity in this country. No one should struggle to access the food
they need. Evidence from the Food Foundation, LSHTM and SHEFS
reached a similar conclusion, stating that:
107 Evidence and Network on UK Household Food Insecurity, Too poor to eat: Food insecurity in the UK
(May 2016): https://enuf.org.uk/sites/default/files/resources/foodinsecuritybriefing-may-2016-final.
108 As outlined in paragraph 73, the Government will include new questions on food insecurity in the
Family Resources Survey. Data will not be available until 2021.
109 Food and Agriculture Organization of the United Nations, The State of Food Insecurity and Nutrition in
the World, Building Climate Resilience for Food Security and Nutrition (2018), p 138: http://www.fao.org/3/
I9553EN/i9553en.pdf [accessed 29 June 2020]
111 Food Standards Agency, The Food and You Survey, Wave 5, (2019): https://www.food.gov.uk/sites/
default/files/media/document/food-and-you-wave5-combined-report-web-revised.pdf [accessed 30
June 2020]. Wave 5 data collected between June and November 2018. This survey is a repeated cross-
sectional study run by the Food Standards Agency based on 2,241 interviews from a representative
multi-stage stratified random sample of adults across England, Wales and Northern Ireland.
112 The Trussell Trust, End of Year Stats: https://www.trusselltrust.org/news-and-blog/latest-stats/end-
year-stats/ [accessed 30 June 2020]
“Due to the lack of standardisation and comprehensive measurement of

food insecurity it is difficult to definitively state the prevalence. However,
it is clear that food insecurity rates are too high, and despite being the
fifth richest economy in the world, the UK has some of the worst rates
of food insecurity in Europe.”113

Cath from Newcastle said:
“When you are trying to make meals, you want to make a meal that is
going to fill everybody and unfortunately that means you use repetitive
ingredients as well. So, for example, to buy frozen vegetable is a lot
cheaper because you are getting quantity. So, if I can get three meals
out of buying say a frozen bag of onions and peppers, what am I going
to use? I’m going to use those packets three times in different meals.”
“I don’t know anyone who doesn’t use what we call the yellow sticker
aisle. We all do that. If you’re on a budget, you got to do that.”
“You used to get your money fortnightly. That’s got to last two weeks.
You need to make your bills, so your bills come out first, then your
shopping. So you want that shopping to be as economical as possible,
to last 14 days. In last few days, you may just have to eat once.”
COVID-19 and food insecurity

70. In-depth analysis of the impact of COVID-19 on food insecurity is not yet
available but from the existing figures it appears clear that levels of food
insecurity have risen sharply in a short space of time.
71. In April 2020 the Food Foundation commissioned YouGov to conduct
an online survey to determine the impact of COVID-19 and lockdown on
experiences of food insecurity. Based on the survey, the Food Foundation
estimated that: “More than three million people (6%) in Great Britain have
gone hungry since lockdown began three weeks ago, reporting that someone
in their household has been unable to eat, despite being hungry, because
they did not have enough food.”114 Similarly, the Trussell Trust has reported
an 81% increase in emergency food bank use during the last two weeks of
March 2020 compared to the same period in 2019.115
Sustainable and Healthy food Systems (SHEFS) (ZFP0073)
114 The Food Foundation, New Food Foundation Survey: Three million Britons are going hungry just three
weeks into lockdown (April 2020): https://foodfoundation.org.uk/new-food-foundation-survey-three-
million-britons-are-going-hungry-just-three-weeks-into-lockdown/ [accessed 30 June 2020]. Food
Foundation figures based on online survey that it commissioned YouGov Plc to undertake. The Food
Foundation states that: Total sample size was 4,343 adults. Fieldwork was undertaken between 7–
9 April 2020. The survey was carried out online. The figures have been weighted and are representative
of all GB adults (aged 18+). The Food Foundation states that its calculations were made using mid-
year population estimates.
115 The Trussell Trust, Food banks report record spike in need as coalition of anti-poverty charities call for
strong lifeline to be thrown to anyone who needs it (1 May 2020): https://www.trusselltrust.org/2020/05/01/
coalition-call/ [accessed 30 June 2020]
72. An increase in food insecurity due to the COVID-19 crisis is not an

exclusively British problem. Food banks in Spain and France have reported
an increase in food distribution,116 and the Italian Government has allocated
€400 million for food vouchers.117
Measuring food insecurity

73. In 2019, the Department for Work and Pensions announced that it would
introduce household food insecurity questions to the Family Resources
Survey,118 which it told us would “provide information on household food
security, allowing us to investigate drivers and identify the groups most at
risk.”119 This followed the introduction of a Private Member’s Bill by Emma
Lewell-Buck MP calling for the measurement to be introduced.120 The
Government told us that the first data will not be available until 2021.121
74. There was criticism within our evidence of the Government’s previous
failure to routinely collect data on levels of food insecurity. Written evidence
from the Government stated that: “There are no existing sources which give
us complete, comprehensive information on an annual basis for the UK as a
whole” and that the Food Security Assessment was last published as a whole
document in 2010.122
75. Julia Gault, Deputy Director Labour Market, Families & Disadvantage at
the Department for Work and Pensions, referred to food insecurity and its
relationship to household income, stating that: “One of the things that is
very clear from the existing evidence base is that it is really difficult to get
a good handle on that in a robust, analytical way from the data sources
that are currently available to us.” The Committee’s Chair, Lord Krebs,
suggested to Ms Gault that:
“… if you wanted to be critical, it is quite shocking that the Government
do not know the basic facts about food insecurity, which is what you are
telling us.”123
76. In response, Ms Gault conceded that: “We need to know more, and action
has now been taken since April through the Family Resources Survey. We
have been collecting more data to improve our understanding.”124
116 ‘“Hunger Queues” and use of food banks on the rise as Spain struggles to recover from coronavirus’,
The Independent (28 May 2020): https://www.independent.co.uk/news/world/europe/food-banks-
spain-hunger-coronavirus-poverty-covid-19-a9536341.html [accessed 30 June 2020] and BBC News,
Coronavirus: Lockdown bites poor as France eases grip (7 May 2020): https://www.bbc.co.uk/news/world-
europe-52557722 [accessed 30 June 2020]
117 ‘Italy sets aside €400m for food vouchers as social unrest mounts’, The Guardian (31 March 2020):
https://www.theguardian.com/world/2020/mar/29/italy-sets-aside-400m-for-food-vouchers-as-
social-unrest-mounts [accessed 30 June 2020]
118 An annual report that provides facts and figures about the incomes and living circumstances of
households and families in the UK.
120 Food Insecurity Bill [Bill 136 (2017–19)]
122 Ibid. The Food Security Assessment is an analysis of six separate themes of food security, one of which
is household food insecurity. It draws from a range of national and international indicators.
123 Q 21 (Lord Krebs)
124 Q 21 (Julia Gault)
77. The decision to measure household food security through the DWP’s Family
Resources Survey (FRS)125 was welcomed by campaigners, but concerns
were expressed that this move does not go far enough to ensure data on
food insecurity is regularly monitored and properly scrutinised. Doubts were
also expressed over the level of commitment to making this measurement
permanent. We consider that it is crucial that levels of food insecurity are
properly monitored and understood, so that the policy to address it can be
targeted effectively.
78. A number of respondents suggested that there was a distinct lack of
Government action at a policy level that deals directly with food insecurity.
Dr Loopstra and Dr Reeves from King’s College London suggested that:
“It is not clear what efforts have been made at the policy level to improve
food insecurity in the UK. Based on evidence available, it appears that
food insecurity is increasing among low income and vulnerable groups,
particularly those reliant on benefits. Changes in administration (i.e.
through the implementation of Universal Credit), harsher sanctioning
penalties, and loss of entitlements have repeatedly been identified as
drivers of food bank use. This evidence has not been acted on by the
Government.”126
79. The notion that food insecurity does not receive the dedicated attention it
required was also echoed by the University of York IKnowFood programme,
which suggested that: “the Government continues to see food insecurity as
an overseas issue, with DFID the only Department to include them in its
Single Departmental Plan.”127 The programme also highlighted that “there
is no clear ministerial accountability for combatting food insecurity in the
UK.”128
80. There were repeated calls for the Government to strengthen the evidence
base on food insecurity to help inform its evaluations of related welfare and
health policies. A number of suggestions were made as to how this might be
achieved, including:
• Monitoring the impact of food insecurity on health in the UK

population by linking measures of food insecurity with indicators of
dietary health. Dr Loopstra and Dr Reeves suggested that: “measures of
food insecurity need to be integrated and maintained in existing health
surveys (e.g. National Diet and Nutrition Survey, or the Health Survey
for England).”129 Such analysis will be important because it remains
unclear why food insecurity leads to hunger for some and obesity
among others. When asked whether data from the Family Resources
Survey would be examined alongside that from the National Diet and
Nutrition Survey, Will Quince MP, the Minister for Welfare Delivery
at the Department for Work and Pensions said he would: “certainly be
looking to sit down with my counterparts in the Department of Health
and Social Care, because you are right in your suggestion that we would
want to compare the two and then look at the evidence.”130 While this
125 The Family Resources survey is an annual publication which collects information on income and
living conditions from a representative sample of private UK households
126 Written evidence from Dr Loopstra and Dr Reeves (ZFP0065)
127 Written evidence from the University of York IKnowFood programme (ZFP0040)
128 Ibid.
129 Written evidence from Dr Loopstra and Dr Reeves (ZFP0065)
130 Q 128 (Will Quince MP)
is welcome, a more robust mechanism for comparison is essential—

an informal Ministerial meeting cannot fully explore the relationships
between dietary quality and food insecurity.
• A firmer commitment from the Government to robust monitoring

of food insecurity over the long-term. Dr Manu Savani from Brunel
University London called for: “Robust policy analysis and evaluation
that relates food insecurity trends to wider socioeconomic context and
reforms.”131 Professor Dominic Harrison called for food insecurity to
be elevated to the level of a National Statistic.132 Similarly, Southwark
Council called for: “A nationally agreed definition and measure of food
security/insecurity that is repeated at regular intervals to pick up on the
impact of substantial policy changes.”133
• That a food insecurity measurement should be enshrined in legislation.

The Labour Hunger Campaign suggested that the Government
should: “Enshrine a definition of household food insecurity in law and
set government targets to eliminate it.” Amendments were also tabled
to the Agriculture Bill, seeking the inclusion of a measurement of food
insecurity into the Government’s measurement of food security which
would be mandated by that Bill.134
• That policy to address food insecurity should be informed by

engagement with people with lived experience. Dr Clare Pettinger
and Food Plymouth CIC told us that: “there also needs to be more
effective consultation and ‘bottom up’ involvement (co-production)
with communities with lived experience so that their voices can form
part of the policy changing and solutions.”135
• That there should be a dedicated section of the Government that deals

with food insecurity, with some calling for a minister with accountability
for combatting food insecurity in the UK. The University of York
IKnowFood programme recommended that the Government: “appoint
a minister with responsibility and accountability for combatting food
insecurity within the UK.”136
81. There is very limited confidence in the Government’s current approach
to monitoring food insecurity. Household food insecurity must be
comprehensively and regularly measured, and subject to parliamentary
scrutiny to ensure that trends in food insecurity can be linked to wider
socioeconomic contexts and reforms and can inform policy making in other
areas such as public health and welfare.
82. The relationships between dietary quality and food insecurity must
be fully understood. The Government must commit to continuing to
131 Written evidence from Dr Manu Savani (ZFP0070)
132 Written evidence from Professor Dominic Harrison (ZFP0027)
133 Written evidence from Southwark Council (ZFP0024)
134 Amendment, Mrs Emma Lewell-Buck https://publications.parliament.uk/pa/bills/cbill/58-01/0007/
amend/agriculture_rm_pbc_0227.pdf .The Agriculture Bill includes a requirement for the Government
to measure and report on UK food security. In this case food security refers to availability, supply
sources, supply chain resilience, household expenditure on food, food safety and consumer confidence
in food. The proposed amendment would have required the Government to measure food insecurity:
“a person’s state in which consistent access to adequate food is limited by a lack of money and other
resources at times during the year.”
135 Written evidence from Dr Clare Pettinger and Food Plymouth CIC (ZFP0033)
136 Written evidence from the University of York IKnowFood Programme (ZFP0040)
run the food insecurity measurement questions currently contained

within the Family Resources Survey. To better understand the impacts
of food insecurity on diet and related outcomes, the Government
must determine how best to collect data on food insecurity and
dietary intake in the same individuals.
‘Food poverty’: a misnomer

83. Key to addressing food insecurity was establishing whether it can be
addressed separately from issues of poverty or whether food insecurity arises
from poverty. We were told, unequivocally, that food insecurity is a direct
result—indeed a symptom—of poverty.
84. The evidence was extremely clear on this point. Alison Garnham of the
Child Poverty Action Group told us that: “Food poverty is just an example
of a kind of deprivation that results from a lack of income… in many ways,
food poverty is not distinct from other types of poverty.”137 Ms Barnard from
the JRF agreed: “food poverty is one symptom of poverty.”138 As we have
seen, poverty is characterised by a lack of resources. Generally, hunger is
due to this same lack, that of financial ability to purchase sufficient food.
Ms Garnham said: “There are a number of people in the UK who lack
the income to buy the food they need”.139 Evidence from Exeter Foodbank
supported this, citing income as the top driver of food bank use.140
85. A factor of food poverty (food insecurity) that makes it perhaps more visible
than other forms of poverty is that, often, the food budget is the only budget
which can be reduced—cuts can be made to a food budget that cannot be
made to rent or fuel payments. Helen Barnard told us: “It is quite often
one of the first things that people on low income start cutting back on or
making trades about. Parents start skipping meals.”141 Food insecurity arises
quite logically out of a lack of resources and does not exist in isolation from
other kinds of poverty. As Ms Barnard said; “Someone skipping meals is also
going to be going without all sorts of other things.”142
86. It was made very clear that poverty has a significant impact on those living
with it. In relation to food insecurity and health, the key areas to emphasise
are:
• That poverty prohibits access to resources required for a socially

acceptable standard of life;
• That poverty affects emotional state, causing feelings of hopelessness

and persistent anxiety. The toll of this can reduce the emotional energy
available for important aspects of daily life; and
• That poverty increases the risk of physical and mental health problems.
87. Some evidence we received was distressing and included details of people
living in appalling conditions. We were told of parents skipping meals,
lying to children and claiming that they had eaten, and children unable to
concentrate at school due to physical feelings of hunger. We heard that effects
140 Written evidence from Exeter Foodbank (ZFP0059)
142 Ibid.
ranged from debilitating physical feelings of hunger to social isolation, and a

decreased ability to concentrate or make decisions. Magic Breakfast indicated
some of the effects of hunger upon children: “School age children with severe
hunger were more likely to experience stressful life events, had higher parent-
reported anxiety scores and were more likely to have behavioural problems
than children with no experience of hunger.”143
88. The mental and emotional aspects of poverty were also described to us.
Helen Barnard described the effect of poverty as being: “Shut out from
normal life.” She said:
“There is [also] very often a sense of there being no way out. We quite
often talk about this feeling of hopelessness. One of the parents we work
with described it as like being stuck on a hamster wheel: you are running
and running but never getting anywhere. You cannot give the kids the
things that we know all kids should have to have a good start in life.”144
89. Ms Barnard told us that these pressures could lead to a ‘tunnel vision’ effect:
“If you are really anxious and worried about things, you will psychologically
focus in on a very small number of crucial things … those things you are
focusing on cannot fail.”145 She described this narrowing in focus as a
reduced ‘emotional bandwidth’.
90. Exeter foodbank provided us with some quotes from their foodbank users to
illustrate what living with food insecurity means for people:
“I am on my own with 2 children and came to the foodbank today
because it’s the end of the school holidays. I have a part-time job—my
children needed new school uniforms and shoes so we had no money left
for food. We never have money for extras.”
“I came to the foodbank today because we had no food, no money and
we are in debt. I had an operation and was off work from October until
January. I went back to work for a few hours a day and I now work 25
hours a week. While I was off work, I accumulated debt—rent, council
tax and water rates. I was down and felt embarrassed about my situation.”
“I’ve been ill for a couple of years and was made redundant due to my
long-term sickness. I have really struggled getting help and have become
very demoralized and let myself go and stopped caring. A friend forced
me to come for help and I feel better being given some food and a friendly
ear with a cup of tea.”146
143 Written evidence from Magic Breakfast (ZFP0076)


Monica from Oxford said:
“Hunger does impact on your mental health and on your tiredness.”
Tia from Blackburn with Darwen said:
“You know everyone’s struggling but you just don’t know how much
everyone is struggling because no one wants to talk about it. An older
person who is struggling doesn’t want to talk about it because they
feel embarrassed or they’re embarrassing their kids. Some people
don’t want to talk about it in Darwen because there is such a stigma.”
Hunger and food banks

91. Food banks work largely on a donation basis. People in need of emergency food
assistance are given vouchers by care professionals, which can be exchanged
for non-perishable food parcels from food banks. Many food banks provide
additional support, for example in helping people understand and access the
benefits they are entitled to. Our evidence acknowledged the vital role that
food banks play, but emphasised strongly that food banks exist to plug a
hole in the social security system. Evidence from Blackburn with Darwen
Council, for example, stated: “Food banks should have NO role in a 21st
century Britain.”147 Dr Dave Beck from the University of Salford suggested
that the existence of food banks relieves Government of the responsibility to
protect the most vulnerable in society. He said they acted as: “a failsafe for
the government so that they can now step-back from their responsibility and
hand this provision over to the Big Society of volunteers … a stick-plaster
approach”.148 Dr Sinéad Furey described food banks as “successful failures”:
successful since they continue to grow, and failures because: “such initiatives
distract from the underlying issues of food insecurity”.149
92. Food banks, and food aid organisations in general, agree that there should
be no need for them. It is, for instance, the policy of the Trussell Trust—
the UK’s largest group of food banks—to put themselves out of business
by working together to “challenge the structural economic issues that lock
people in poverty, and campaign to end the need for food banks in the UK.”150

Penny from Newcastle said:
“It’s also a pride thing. Just because, you know, just because you’ve
got no money doesn’t’ mean to say you’ve got no pride.”
147 Written evidence from Professor Dominic Harrison and Emma Savage (ZFP0027)
148 Written evidence from Dr Dave Beck (ZFP0001)
149 Written evidence from Dr Sinéad Furey (ZFP0019)
150 The Trussell Trust, What we do: https://www.trusselltrust.org/what-we-do/ [accessed 30 June 2020]
Holiday Hunger
93. Witnesses raised concerns about the levels of holiday hunger, when children
who would normally receive free school meals during term-time go hungry
during the school holidays. We were told that around 3 million children are
affected by holiday hunger.151 Garry Lemon of the Trussell Trust explained
the reasons behind this:
“When you are on such a low income, that pound or two a day that you
are now having to spend on food—which would have been free school
meals—can be utterly ruinous to people’s finances when they are already
surviving on so little.”152
94. The Government has provided some funding to address the issue of holiday
hunger, and in June 2020 it agreed to extend the National Voucher Scheme
for the 2020 summer holiday.153 We welcome these interventions and have
addressed holiday hunger in greater depth in Chapter Four: Government
Food Programmes. It is worth stating, however, that it is not acceptable that
for three million children, the only thing standing in the way of hunger is a
school meal.
95. Like the use of food banks, the prevalence of hunger during holidays is
an indication that some people in this country simply do not have enough
money to feed themselves. Food aid organisations, including holiday hunger
initiatives do excellent work (and many provide much more than food), but
they should not need to exist to ensure that people can eat. We agree with the
evidence of the Leeds Food Aid Network which said:
“It brings considerable shame on this country that we are talking about
initiatives to address holiday hunger whilst ignoring the fact we live in
a system that allows the children of the most vulnerable sectors of our
nation to face holiday hunger in the first place … Addressing poverty at
its root is the only way to ensure these initiatives, that are either costly or
rely on the goodwill of the community, are no longer required.”154
96. The need for charitable food aid is a clear sign that the welfare system
is failing to provide adequate support to people in the lowest income
groups. The Government should not be reliant on charitable food aid
to plug the holes in the welfare system.
Universal Credit and hunger

97. While this report cannot address all of the underlying causes of poverty, one
issue was highlighted to us as being very directly linked to people struggling
to afford food and recourse to food banks: Universal Credit. Several witnesses
referred to Trussell Trust data indicating that food bank use had risen by
48% in areas where Universal Credit had been rolled out for two years.155
151 Q 42 (Alysa Remtulla), written evidence from the Food Foundation, London School of Hygiene and
Tropical Medicine, and Sustainable and Healthy Food Systems (SHEFS) (ZFP0073) and written
evidence from Church Action on Poverty, The Food Foundation, The Independent Food Aid
Network, Nourish Scotland, Oxfam GB and Sustain (ZFP0031)
153 Department for Education, Guidance: COVID Summer Food Fund (30 June 2020): https://www.gov.uk/
guidance/covid-summer-food-fund [accessed 30 June 2020]
154 Written evidence from the Leeds Food Aid Network (ZFP0018)
155 The Trussell Trust, Universal Credit and Food Banks: https://www.trusselltrust.org/what-we-do/
research-advocacy/universal-credit-and-foodbank-use/ [accessed 30 June 2020]. See also written
evidence from the Leeds Food Aid Network (ZFP0018)..
We could not ignore these sobering statistics, or the story they told about, in
particular, the five-week wait.
98. Recipients of benefits are transferred from the old (legacy) benefits system
to Universal Credit (UC) when there is a change in life circumstance. A
minimum five-week wait applies before UC is paid to a recipient (UC is
paid in arrears, monthly). This wait comprises an assessment period of a full
calendar month, after which the pay date will be within seven calendar days.
We were told that: “It is not possible to award a universal credit payment
as soon as a claim is made, as the assessment period has to run its course
before the award of universal credit can be calculated”.156 This choice to pay
monthly benefits in arrears was described to us by the Minister for Welfare
Delivery, Will Quince MP as being “more akin to the world of work”.157 In
April 2017, around 85% of people employees received pay in monthly or four-
weekly periods,158 leaving a significant number of workers who would usually
receive weekly or fortnightly payments: the “world of work” envisaged by the
Department is not necessarily representative of the reality of many people’s
working lives.
99. In February 2019, Amber Rudd MP, the-then Secretary of State for the
Department for Work and Pensions, admitted that the five-week wait may
have led to an increased use of foodbanks.159 The Department has since
introduced an advance to cover the waiting period, which is deducted from
future payments in instalments. The Trussell Trust has described this as
presenting a choice between: “destitution now or destitution later. If you take
the advance, that money is immediately clawed back out of your already cut
and too small universal credit monthly allowance, or you forgo the advance
and fall into debt and further poverty until you can bridge that five-week
gap.”160 The wait, and the repayment of advances still creates significant
problems for the individuals receiving it.
100. Julia Gault told us that people usually begin using food banks after some
manner of life crisis.161 Our evidence showed that a five-week wait for UC
has often represented this crisis. The Exeter Foodbank stated that many new
recipients:
“Simply do not have the financial resilience to cope with the 5 week
wait between making a UC claim and receiving first payment. Sadly,
a high proportion of these new referrals go on to experience chronic
food insecurity and repeated foodbank referrals due to arrears, debts
and deductions incurred during the initial waiting period.”162
A volunteer in another food bank told us that: “every single client who has
been put on UC stated they are now in more debt than they were before…
Most are in debt to family or friends and know that even when they do get

157 Ibid.
158 Office for National Statistics, Annual Survey of Hours and Earnings (ASHE): Proportion of all
employee jobs with weekly, fortnightly, four weekly and monthly pay periods, UK, April 2017:
(November 2017): https://www.ons.gov.uk/employmentandlabourmarket/peopleinwork/earningsan
dworking hours/adhocs/007746annualsurveyofhoursandearningsasheproportionofallemployee jobswi
thweeklyfortnightlyfourweeklyandmonthlypayperiodsukapril2017 [accessed 30 June 2020]
159 HC Deb, 11 February 2019, col 594
paid, their payment won’t be enough to repay their debt.”163 It has also been
made clear that foodbanks have often recorded changes or delays to benefits
as significant drivers of usage.164
101. We welcome the proposed extension of the repayment period and a reduction
on the repayment cap—but these changes are proving insufficient. The
Government plans to extend the repayment term for advances from 12
months to 24 months, and that the standard deduction cap will be reduced
from 30% to 25%. This change will not take effect until October 2021.165
Minister for Welfare Delivery, Will Quince MP, told us that, in relation to
advances, “the repayment of that advance over a 12 month period is currently
in the region of £50 per calendar month”.166 He explained that the reduction
will further lower this to around £30 per calendar month. For many people,
however, £50 per calendar month is a significant amount of money. There is
not a “spare” £50, or indeed £30 built into the Universal Credit entitlement:
it is likely that people paying this to the Department will be going without
something. It is worth noting here that the mean average weekly household
spend on food and non-alcoholic drinks is £61.90.167
102. The House of Lords Economic Affairs Committee is conducting an inquiry
into whether UC’s design and objectives reflect the reality of life on low
incomes,168 and the House of Commons Work and Pensions Committee is
undertaking an inquiry into possible alternatives and alterations for the five-
week wait.
103. Possible alterations published in advance of the Work and Pensions
Committee’s inquiry include:
• Scrapping the five-week wait for all claimants: for example, by making
the Advance non-repayable;
• Offering non-repayable Advances to some claimants: for example,

those considered vulnerable;
• Allowing more flexibility for the start of a claim to be backdated;
• Extending run on payments to cover all legacy benefits;
• Substantially reducing the rate at which Advance Payments—the main

existing mitigation measure—are paid back, to help claimants better
manage their money; and
• Paying UC two-weekly, like many legacy benefits, rather than monthly.169
163 Written evidence from Church Action on Poverty, Food Foundation, the Independent Food Aid
Network, Nourish Scotland, Oxfam GB, and Sustain (ZFP0031)
164 Written evidence from Dr Bowe, Dr Wakefield, and Nottingham Civic Exchange (ZFP0078) and
Consensus Action on Salt, Sugar and Health (ZFP0053)
165 Supplementary written evidence from HM Government (ZFP0098)
167 Office for National Statistics, Family spending in the UK: April 2018 to March 2019: https://www.ons.
gov.uk /peoplepopulationandcommunity/personalandhouseholdfinances/expenditure/bulletins/
familyspendingintheuk/april2018tomarch2019 [accessed 30 June 2020]. Mean average weekly spend
equal to the total reported weekly expenditure of households divided by the number of households.
168 Economic Affairs Committee, ‘The economics of Universal Credit inquiry’: https://www.parliament.
uk/economics-universal-credit [accessed 30 June 2020]
169 Work and Pensions Committee, ‘Universal Credit: the wait for a first payment’, : https://committees.
parliament.uk/work/135/universal-credit-the-wait-for-a-first-payment/ [accessed 30 June 2020]
104. The five-week wait for Universal Credit presents acute difficulties
and requires urgent overhaul. While we cannot anticipate the
findings of two Parliamentary reports dedicated to this topic, the
Government must fully respond to the reports of both Committees.
A replacement scheme must have regard to:
• The recommendations of the House of Commons Work and

Pensions Committee and the House of Lords Economic Affairs
Committee;
• Analysis of the impact of repayments over a period of time on

the ability to afford a healthy diet;
• The imperative to avoid a situation where a person awaiting

benefits has no choice but to visit a food bank;
• Analysis of data pertaining to the increase in UC claims

following the outbreak of COVID-19;
• The possibility that different groups of claimants may require

different arrangements for advances and their repayment; and
• A continual and effective system of training to help claimants

manage their money.
People with no recourse to public funds

105. We were told that people with no recourse to public funds (NRPF) are
particularly vulnerable to hunger. Professor Greta Defeyter, Professor
of Psychology at the University of Northumbria, explained that some
particularly vulnerable groups were excluded from measurements of food
insecurity: “We have thousands of extremely vulnerable children who are
entirely excluded from these figures because they are undocumented or have
no recourse to public funds.”170 As demonstrated above, the Government
has an extremely limited understanding of the scale of food insecurity: the
understanding is particularly weak in the case of some of the most vulnerable
groups.
106. Written evidence from Exeter Foodbank stated: “EFB’s experience suggests
that asylum-seekers, refugees, and others affected by recent changes to
habitual residency legislation, are at high risk of prolonged food insecurity.”171
Southwark food bank recorded that in 2017–18, 16% of their referrals were
due to a lack of recourse to public funds.172
107. In the case of people with no access to public funds, food banks are sometimes
the only means of subsistence. Exeter Foodbank gave an example:
“Between 2013–2019, EFB provided continuous weekly food parcels to
a lady and her young son whilst her complex immigration status was
resolved. Throughout this period, she had no recourse to public funds
and was not allowed to work; her sole source of income was a small
subsistence grant of £10 per week from a local charity.
170 Q 38 (Professor Greta Defeyter)

171 Written Evidence from Exeter Foodbank (ZFP0059)
172 Written evidence from Cllr Evelyn Akoto, Cabinet Member for Community Safety and Public Health,
Southwark Council (ZFP0024)
Foodbank parcels, although nutritionally balanced, are not designed for

long-term use; they are comprised of pre-dominantly non-perishable
foods, and lack variety. Nevertheless, for six years, they remained the
primary means through which this family could manage to eat and
survive.”173
108. The weeks following the outbreak of COVID-19 saw a number of programmes
to distribute food where it was necessary, including the temporary extension
of Free School Meal provision to some groups who have no recourse to
public funds.174 These programmes demonstrate a public and political will to
ensure that everyone can access food.
109. We note that a group of the most vulnerable people, those with no
recourse to public funds, are conspicuously absent from policy
discussions on food insecurity.
110. We recommend that the Government produce an action plan to
ensure that the gathering of data on food insecurity includes and
records the situations of those with no recourse to public funds.
Urgent planning must begin now to establish a Government-funded
programme to ensure that all those with no recourse to public funds
are able to access sufficient, nutritious food.
Difficulty accessing a healthy diet

111. Problems of the most severe type of food insecurity: those leading to hunger,
were our starting point. Hunger, however, is one end of a spectrum of food
insecurity. It is crucial that we understand different aspects of food insecurity,
and address the wider issue of access to a healthy diet.
112. Statistics on diet-related ill health, outlined in Chapter 2, demonstrate that
there is a serious problem with health inequalities between rich and poor
in the UK. This situation is not inevitable; it is, in part, the product of an
increased difficulty in accessing a healthy diet for those in the poorest groups.
This section identifies the factors that cause this situation. It is distinct from
Chapter 4, the Food Environment, which identifies a series of factors which,
together, create a deeply unhealthy backdrop for everybody.
113. We were told of the barriers that exist for lower income groups to access a
healthy diet, which fall into three broad categories:
• The affordability of food. Some research has shown that healthy food
is three times as expensive as less healthy food, calorie for calorie. The
Government’s guidance on healthy diets—the Eatwell Guide—was
said to be unaffordable for many families (including those receiving
universal Credit). Healthy food can also carry a higher risk of waste,
resulting in a greater financial risk than unhealthier foods.
• Practical considerations. We were told that people with lower incomes

were sometimes without access to physical cooking equipment, and
that there were more likely to be additional inhibitive costs to preparing
healthy foods (such as energy costs). We also heard evidence to suggest

174 Department for Education, Coronavirus (COVID-19): free school meals guidance for schools (April 2020):
https://www.gov.uk/government/publications/covid-19-free-school-meals-guidance/covid-19-free-
school-meals-guidance-for-schools [accessed 30 June 2020]
that for some, accessing food shops was expensive or difficult, as they
might have to travel by car or expensive public transport, to avoid
this many are limited to small convenience shops where prices can be
higher.
• ‘Emotional bandwidth’. Poverty can place demands and stresses upon

individuals and families. The priority for many people is to ensure
that there is enough food, meaning that there may be limited available
mental energy to make choices and dedicate time and effort to cooking
and preparing food which is nutritionally balanced.
114. We were disappointed to note that, when asked about widening health
inequalities, although the Government recognised the relevance of the food
environment, their answer contained only one mention of disparities and one
targeted intervention (Healthy Start Vouchers).175 We feel this demonstrates
a lack of Government recognition of the increased difficulty for lower income
groups in accessing a healthy diet.
Affordability of healthy diets

115. One question that arose frequently throughout this inquiry was: is food too
expensive? There was a clear consensus that, on the contrary, the current
price of food does not reflect “the real cost”.176 Henry Dimbleby pointed to a
variety of NGO reports identifying the true cost of food as: “anything from
50% more to just a bit more to twice as much, depending on the agenda of
the person who has done the report.”177
116. Between April 2018 to March 2019, the mean average household178 spend
on food and non-alcoholic drink was £61.90 per week, (see Figures 6 and
7) representing 10.6% of expenditure,179 significantly less than the average
spend across all EU countries, which was 12.2%.180 The food consumed in
the UK is the cheapest in Western Europe. Indeed, according to the EU
statistical body Eurostat, it costs 8% less than the EU average.181

176 Q 76 (Professor Andrew Balmford)
178 Data from the Living Costs and Food Survey which is a sample survey of private household’s
expenditure. Figures provided are mean averages of expenditure (equal to the total weekly expenditure
of households divided by the number of households). As the number of individuals in households
differs, the data does not represent ‘an average household’. (The mean average number of individuals
in a household is 2.37). Office for National Statistics, Dataset: Families and Households, (15 November
2019): https://www.ons.gov.uk/peoplepopulationandcommunity/birthsdeathsandmarriages/families/
datasets/familiesandhouseholdsfamiliesandhouseholds [accessed 30 June 2020]
179 Office for National Statistics, Family spending in the UK: April 2018 to March 2019, (19 March
2020): https://www.ons.gov.uk/peoplepopulationandcommunity/personalandhouseholdfinances/
expenditure/bulletins/familyspendingintheuk/april2018tomarch2019 [accessed 30 June 2020]
180 European Commission, How much are households spending on food?, (December 2018): https://ec.europa.
eu/eurostat/web/products-eurostat-news/-/DDN-20181204-1 [accessed 30 June 2020]
181 Eurostat, File: Table 1 Price level indices for food, beverages and tobacco, 2017: https://ec.europa.eu/
eurostat/statistics-explained/index.php?title=File:Table1Price_level_indices_for_food,_beverages_
and_tobacco,_2017_(EU-28%3D100).png [accessed 30 June 2020]
Figure 6: The 13 main categories of average weekly household

expenditure, UK, 2018/19
Other expenditure: £77.20 Recreation and culture: £76.90
Transport: £80.20
Miscellaneous Household goods

Food and non-alcoholic goods and services: and services:
drinks: £61.90 £45.50 £40.80
Alcoholic drink,
tobacco and
narcotics:
£13.00
Clothing and
Housing, fuel and power: Restaurants and hotels: footwear: Health:
£79.40 £51.30 £24.40 1 £8.00 2
Note: 1.Communications, £21.30, 2. Education, £5.70

Source: Office for National Statistics, Family spending in the UK: April 2018 to March 2019 (19 March 2020):
https://www.ons.gov.uk/peoplepopulationandcommunity/personalandhouseholdfinances/expenditure/bulletins/
familyspendingintheuk/april2018tomarch2019 [accessed 30 June 2020]
Figure 7: Average weekly household expenditure on the 33 main

categories of foods, UK, 2018/19
Buns, cakes, Fish and ﬁsh

Fresh fruit: £4.10 biscuits, etc: £3.90 products: £3.00
Other meats and meat

preparations: £6.60
Chocolate: Cheese and

Milk: £2.20 £2.10 curd: £2.10
Other food
products: £2.70
Pastry Dried fruit
(savoury): and nuts:
Beef (fresh,
£1.00 £1.00 1
chilled or
frozen): £2.70
Bread, rice and cereals:
£5.50 Other milk Eggs:
Other tubers 2
products: £2.30 £0.70 3 4
and products of
tuber vegetables:
£2.70 Bacon
and ham: 6 7
£0.80 5
Poultry (fresh, Other preserved

9 10
chilled or or processed Potatoes: Butter:
Fresh vegetables: £4.40 frozen): £2.70 vegetables: £2.70 £0.80 £0.50 8 11 12
1. Edible ices [lollies] and ice cream: £0.80 7. Sugar and sugar products: £0.40
2. Confectionary products: £0.80 8. Pasta: £0.40
3. Margarine, other vegetable fats and peanut butter: £0.60 9. Cooking oils and fats: £0.30
4. Lamb (fresh, chilled or frozen): £0.60 10. Jams, marmalades: £0.30
5. Other fresh, chilled or frozen fruits: £0.50 11. Preserved fruit and fruit-based products: £0.20
6. Pork (fresh, chilled or frozen): £0.50 12. Dried vegetables: £0.10
Source: Office for National Statistics, Family spending in the UK: April 2018 to March 2019, (19 March 2020):
https://www.ons.gov.uk/peoplepopulationandcommunity/personalandhouseholdfinances/expenditure/bulletins/
familyspendingintheuk/april2018tomarch2019 [accessed 30 June 2020] Figure totals £56.60 and excludes £5.30
spent on non-alcoholic drinks.
What is the cost of a healthy diet?

117. Much of our evidence pointed to research suggesting that healthy foods cost
more than less healthy foods. Public Health professionals from Blackburn
with Darwen Council wrote that: “Calories from healthy foods consistently
cost more than those from less healthy foods.”182 Research by the Food
Foundation has found that, calorie for calorie, it is three times more expensive
to eat a healthy diet than an less healthy diet.183
182 Written evidence from Professor Dominic Harrison, Director of Public Health and Emma Savage,
Speciality Registrar in Public Health, Blackburn with Darwen Council (ZFP0027)
183 The Food Foundation, Affordability of the UK’s Eatwell Guide (September 2018): https://foodfoundation.
org.uk/wp-content/uploads/2018/10/Affordability-of-the-Eatwell-Guide_Final_Web-Version.pdf
118. NHS analysis of this report commented that because healthier foods tend to
have a much lower energy density than less healthy foods, cost comparison
on the basis of calories may not always give a realistic comparison of food
you want to buy—a packet of ginger biscuits will give you around the same
number of calories as 30 cucumbers.184
The cost of the Eatwell Guide

119. The Government’s guidance on healthy diets is the Eatwell Guide. Issued
by Public Health England, the Guide breaks down food into five groups and
advises on the proportion of different groups that should be consumed over
the course of a day or a week (see figure 8). The five categories are ‘fruit and
vegetables’; ‘potatoes, bread, rice, pasta and other starchy carbohydrates’; ‘beans,
pulses, fish, eggs, meat and other proteins’; ‘dairy and alternatives’ and ‘oils and
spreads’. Foods high in fat, salt and sugar are listed separately from the former
five categories and should be eaten “less often and in smaller amounts”.185
Figure 8: The Eatwell Guide

Potatoes, bread, rice,
Fruit and pasta and other
vegetables starchy carbohydrates
Raisins
Potatoes
C hopped
t o m at o e s
Whole
grain Cous
cereal Cous
Frozen Bagels
peas Whole
wheat
pasta
Porridge
Rice
Lentils
Beans
lower
salt
and
L o w f at
s o f t c h ee s e Spaghetti
s ugar
Tuna
n
Lea ince
Plain Chick m
nuts peas
Semi
skimmed Soya
milk drink
Crisps
Beans, pulses, ﬁsh, Dairy and
eggs, meat and alternatives
other proteins
Eat less often and Oils and

in small amounts spreads
Source: NHS, The Eatwell Guide: https://www.nhs.uk/live-well/eat-well/the-eatwell-guide/ [accessed 30 June

2020]
184 NHS, ‘Healthy foods expensive’ claim is unrealistic’, (October 2014): https://www.nhs.uk/news/food-
and-diet/healthy-foods-expensive-claim-is-unrealistic/ [accessed 30 June 2020]
2020]
120. In its evidence to the Committee, the Government highlighted a study,

commissioned by Public Health England that looked at the cost of achieving
the Eatwell Guide when it was launched in 2016. The report estimated that
the diet would cost £5.99 per adult per day, or £41.93 per week. 186 The
report concluded that to achieve the dietary recommendations as set out in
the Eatwell Guide “would require large changes in the average diet of UK
adults” but “would not lead to significant changes in the price of the diet.”187
121. These findings have been questioned: the report itself acknowledges that its
conclusion that there would be no price increase associated with the Eatwell
Guide scenario diet was “not generally supported by the literature.” The
report is based on a modelled scenario at population level, did not adjust for
the popularity of different brands, and did not allow for the cost of preparing
products from scratch: “the ‘Eatwell Guide’ scenario is a modelled diet rather
than a real healthy diet that is achieved by a subgroup of the population.”188
The Food Foundation’s own analysis of the cost of the Eatwell Guide also
referenced this report, and added another important point—the estimated
cost of £41.93 a week is: “calculated on a per portion basis (for example, the
cost of a single portion of bread) rather than how much a person would need
to spend to buy the food in question.”189
122. The Food Foundation’s assessment of the cost and affordability of the Eatwell
Guide involved an analysis of the Living Costs and Food Survey and the Family
Resources survey, and considered the estimated cost of an ‘Eatwell’ diet: “in
relation to UK household expenditure on food and non-alcoholic drinks,
and to disposable household income.”190 The Food Foundation estimate of
the weekly Eatwell cost per household was determined based on household
composition.191. The analysis calculated that only 53% of households spent
at least enough to follow the Government’s Eatwell guidance.192 The report
also stated that: “the poorest decile of UK households would need to spend
74% of their after-housing disposable income on food to meet the cost of
the Eatwell Guide compared to just 6% in the richest decile.”193 The Food
Foundation’s findings suggests that the Government should seek a fuller
understanding of whether its dietary guidance is affordable.
123. Evidence from advocacy groups and food banks argued that meeting the costs
of the Government’s Eatwell guidance was unrealistic for many. Nourish
Scotland, for example argued that following the Eatwell guide would bring
“significant opportunity costs.”194
186 Peter Scarborough, Asha Kaur, et al., ‘Eatwell Guide: modelling the dietary and cost implications
of incorporating new sugar and fibre guidelines’, British Medical Journal Open, doi:10.1136/
bmjopen-2016013182 (November 2016): https://bmjopen.bmj.com/content/bmjopen/6/12/e013182.
full.pdf
187 Ibid.
188 Ibid.
189 The Food Foundation, Affordability of the UK’s Eatwell Guide, (September 2018) p 5: https://
foodfoundation.org.uk/wp-content/uploads/2018/09/Affordability-of-the-Eatwell-Guide_Final_
Web-Version.pdf [accessed 30 June 2020]
191 The Food Foundation, Affordability of the UK’s Eatwell Guide, (September 2018): https://foodfoundation.
org.uk/wp-content/uploads/2018/09/Affordability-of-the-Eatwell-Guide_Final_Web-Version.pdf
192 Ibid.
194 Written evidence from Nourish Scotland (ZFP0064)
124. For many in low income groups, meeting the costs of the Eatwell Guide
is unrealistic. Given the sizeable proportion of disposable income
that many in lower income groups would have to spend to meet the
recommendations of the Eatwell Guide, it is wholly unsurprising that
so few people are doing so.
125. The Food Foundation argued that any approach to formulating an
overarching strategy for the food system must be underpinned by an accurate
understanding of what a healthy and sustainable diet is and what it costs.
Evidence from the Food Foundation, LSHTM and SHEFS argued that
the government’s dietary guidelines, and its assessment of what a healthy,
sustainable diet costs, should be given a legal status and should be updated
annually. It was suggested that this could have two key outcomes:
(a) That a fuller understanding of the cost of healthy, sustainable diets
could be used as a reference point for other government interventions.
It was suggested, for example, that the cost of diet could be factored
into calculations in other policy areas, such as calculating welfare
payments, the level of the minimum wage, school meal provision, or
hospital food, for example.195
(b) By having a clear vision of what a healthy and sustainable diet is, it
was suggested that the Government could set standardised health
and sustainability targets and require business to report against them,
using this data to drive improvements and cross-government action in
a multitude of areas.196
Anna Taylor, Executive Director at the Food Foundation, explained that:
“ … we must have a notion of what a healthy and sustainable diet is
and what it costs. That, in turn, should feed through to other areas of
government intervention.”
“You would then ensure that the budget that you are allocating to school
meals makes reference to the fact that you have that in place. You would
make sure that your public procurement of food across the piece made
reference to that. You would think about it in respect of minimum wage
levels and, therefore, the cost of diet in relation to the cost of living. In
other words, you create a reference point against which it feeds through
to other areas of policy. Similarly, of course, you would make sure that
benefit levels were sufficient to cover the cost of eating a healthy diet.
At the moment, we have gross discrepancies, particularly for the poorest
20% of the population, where it becomes extremely difficult to afford a
healthy diet. We need something in place to protect those households,
in particular.”197
126. We were convinced by the argument that the Government needs a reference
point to use to co-ordinate its approach to ensuring everyone has access to
a healthy and sustainable diet, and to ensure that this aim is embedded into
related policy decisions.
196 Ibid.
197 Q 2 (Anna Taylor)
127. The Government should be fully aware of the cost of eating the diet
it recommends, and the ability of different demographic groups
to access this diet. To underpin any national food strategy, the
Government must, in its 2021 review of benefits rates, commit to
giving its dietary guidance—the Eatwell Guide—a firm place in the
development of policy.
128. Written evidence from the Government stated that income-related benefit
rates: “Derive from a review in the 1980s”198 rather than being based on a
“single mathematical calculation or historic set of rules.”199 This means that
benefits are not based on an understanding of how much things cost or a
representative household budget. Julia Gault confirmed this and stated that:
“we do not say, ‘We are assuming you are going to spend this much money
on food and this much money on other things’”.200
129. Given the enormous economic cost to the NHS and wider society of failing
to encourage healthy diets, we find it puzzling that the Eatwell Guide is
not used by the Government in the calculation of benefit payment rates.
Ensuring that the large (and, recently, dramatically increasing) number of
people in receipt of universal credit are able to afford a healthy diet could
be a sensible economic step. If the benefits system does not take account of
the cost of a healthy diet; it is not clear how households receiving Universal
Credit can achieve it.
130. We accept the premise that the benefits system must not prescribe how people
budget their money. Household spend is a matter for individual households
to decide. It is also clear that cost is not the sole issue in access to a healthy
diet: many households who can afford to consume according to the Eatwell
Guide do not do so. There is no guarantee that a rise in benefit rates to
incorporate the cost of a healthy diet would result in households deciding
to spend it on healthy food. However, in order for households to meet the
Eatwell recommendations, they have to be able to afford it.
131. The Eatwell Guide is, as the name suggests, guidance. It is not included,
for example, in calculations on social policy. The Eatwell Guide is currently
nothing more than an aspiration; and as a nation, we are comprehensively
failing to reach it. Anna Taylor argued strongly for: “a set of metrics in law
against which we track national progress that embed the Eatwell Guide
within them.”201 She argued that embedding the Eatwell Guide in social
policy, including in the benefits system, would provide some protection to
the poorest families.
132. The Government should embed consideration of the cost of the
Eatwell Guide into calculations of benefit payment rates.
133. We recommend that the Government should undertake a fuller
assessment of the cost of a healthy and sustainable diet. The cost of
the Government’s dietary guidance should be built in as a reference
point to consideration of government interventions, including those
relating to welfare and public food provision.

199 Ibid.
Risks and priorities

134. One element of the cost of food for families that is sometimes forgotten is the
element of financial risk involved in purchasing healthier food. Put simply, it
is financially dangerous to buy something “healthier” that family members
may not eat; it may be wasted, and you may have to buy something to replace
it. Healthier food may also go out of date more quickly.
135. We heard repeatedly that unfamiliar food can hold an inhibitive financial risk.
It can be much safer to purchase less healthy foods which will be eaten, and
will leave the consumer feeling full. Dr Christina Vogel, Principal Research
Fellow in Public Health Nutrition at the University of Southampton, told us
that women she had surveyed on lower incomes: “Often have to go through
a whole lot of wastage before they even get to the point where their children
will eat it, so they much prefer to buy things that they know their children
will eat.”202 This approach is a sensible financial decision, ensuring that
money is not wasted on food that will not be eaten.
136. Aversion to food waste is necessary on a small budget. Tom Andrews,
Programme Manager at Sustainable Food Cities pointed out that many less
healthy products are more processed and have a longer shelf life. He described
people on a low budget as being: “often worried about wasting food, so they
want to buy things that they can use and keep for a long period”.203
137. For many, the priority is to ensure that they and their families feel full when
they have eaten. Helen Barnard described a hierarchy of needs pyramid for
food: “The first thing you need from food is the feeling of fullness. On top of
that you put health and energy and so on.”204
138. We received some evidence that suggested that less healthy foods were
considered to be more filling. Dr David Beck described a perception that
fruit and vegetables are seen as: “less filling and more expensive when
compared with a high sugar alternative which is nutritionally less dense and
carries empty calories.”205 Evidence from the Food Foundation, LSHTM
and SHEFS explained that this led to people purchasing: “food that will
be filling rather than nutritional. Families will be more likely to purchase
foods that they know their children will eat, that are convenient and where
there will be minimal food waste.”206 After all: “If you only have £5 to feed
your family, you cannot risk trying another product (like a vegetable) in
case children won’t eat it—what will you then feed them? When faced with
hunger, food becomes about being the most filling, not the most nutritious.”207
139. Leeds Food Aid Network raised a final, social element that we found
compelling: that buying tasty food can be one of few options to make children
happy. “Parents living on low income talk about giving their children
rewarding foods is often the only nice thing they can do for their children.”208
The low price of some delicious food such as pastries, deep fried chicken,
202 Q 13 (Dr Christina Vogel)

203 Q 46 (Tom Andrews)
205 Written evidence from Dr Dave Beck (ZFP0001)
207 Written evidence from Bags of Taste (ZFP0029)
208 Written evidence from Leeds Food Aid Network (ZFP0018)
cakes or sugary drinks is much more financially realistic than many other,
non-food items that children ask for.
140. For many, particularly those in the lowest income groups, food
choices are about whether they will produce a feeling of being satiated.
Choices made by people in lower income groups to prioritise food that
is reliably satiating and prevents waste over a nutritionally balanced
diet should be understood as a reasonable response to the economic
reality they face.
Practical barriers to accessing a healthy diet

141. Difficulties in producing healthy diets are not limited to the price of food.
For people in lower income groups, considerations such as equipment,
energy costs, limited space to store bulk purchases, and the cost of travelling
to cheaper shops are very real barriers to consuming healthy diets.
142. Some people on lower incomes do not have the physical cooking equipment
needed to produce nutritious food. Helen Barnard explained that some people
may not have access to practical things required to provide healthy meals
such as fridges or ovens.209 Bags of Taste explained that even when these are
present they may not work very well, and described the difficulty of lacking
other equipment such as pans and knives.210 Exeter Foodbank outlined the
example of a woman in emergency social housing who did not have access to a
fridge or freezer, microwave, saucepans or basic kitchen crockery: “Although
a keen, competent cook, she was unable to prepare fresh, cooked meals for
her young family; they had been surviving on predominantly cold packaged
food until signposted to a local charity for further help.”211
143. Some local authorities provide support in obtaining white goods or kitchen
equipment through grants or loans. When available, these schemes can be
limited: the woman in the above example from Exeter Foodbank was only
eligible for assistance to obtain one white goods item.212 Clearly, a lack of
access to these items, or concern about using shared facilities in shared
accommodation will significantly increase the appeal of pre-prepared food.
144. Fuel costs were repeatedly mentioned as a deterrent for cooking. Helen
Barnard pointed to the ‘poverty premium’, telling us that energy can cost
more if on a pre-payment meter.213 Exeter Foodbank also told us that many
of their clients have been cut off from their energy supply: “We frequently
see people, particularly those on energy meters, whose gas/electricity supply
has been cut off entirely.”214
145. Evidence from Bags of Taste explained that space can be an issue; a lack
of space to store bulk purchases which tend to be cheaper reduces the
opportunity to use economies of scale with food shopping.215 A lack of space
means you have to buy smaller and usually more expensive quantities of
food.

212 Ibid.
146. Bags of Taste also pointed out that: “If you don’t have a car, carrying
shopping for a week or for a family is hard and even if public transport is
available and affordable (which it often isn’t) it requires you to shop little
and often.”216 Travelling several times per week to shops therefore requires
a higher time investment for those on a lower income, and, again, results
in smaller quantities being purchased and therefore fewer savings. There is
also, of course, the cost of the transport.
147. By themselves, none of these difficulties are necessarily insurmountable, but
together they make the processes of purchasing and preparing food much
more difficult and less rewarding. Arguably, very few of these barriers apply
for those on higher incomes.
‘Emotional bandwidth’
148. The impact of food insecurity on emotional wellbeing and mental health was
emphasised by our evidence. Birmingham Food Council CIC told us that:
“Some costs are intangible, including those related to pain and suffering,
poor quality of life and emotional distress.”217 The emotional impact of
food insecurity was echoed by other contributors and is also supported by
academic research. A Cambridge University study found that there was a
“persisting association between high self-reported stress … specific to [food
insecurity], over and above socio-economic deprivation.”218
149. We were told that poverty can reduce ‘emotional bandwidth’ rendering it
incredibly difficult to focus past immediate needs. Helen Barnard explained
further:
“Living in constant anxiety about money affects the way that you think
about everything else. There is a tunnel vision that people get: if you
are really anxious and worried about things, you will psychologically
focus in on a very small number of crucial things, such as keeping a roof
over your head or wanting your kids to go to bed feeling full. There is
some psychological research where they tested out inducing anxiety and
seeing what it did to decision making—and what it does is narrow your
focus because those things that you are focusing on cannot fail. It also
reduces the bandwidth that you have to be able to look across lots of
different options and start trading them off.”219
Exeter Foodbank told us that:
“[many people accessing foodbanks] are in crises (including relationship
breakdown, redundancy, insecure accommodation, acute financial
need or chronic ill health) which place their emotional and mental
resources under strain. Under such stressful conditions, many lack
sufficient capacity to acquire new skills or consider making long-term
lifestyle changes; all available energies centre on addressing much more
urgent, survival issues at hand. Eating can become low priority—a mere
216 Ibid.
217 Written evidence from Birmingham Food Council CIC (ZFP0057)
218 Amy Yau, Martin White, et al; ‘Socio-demographic characteristics, diet and health among food
insecure UK adults: Cross-sectional analysis of the International Food Policy Study’,. Public Health
Nutrition, 1-13. doi:10.1017/S1368980020000087 (27 April 2020): https://www.cambridge.org/
core/journals/public-health-nutrition/article/sociodemographic-characteristics-diet-and-health-
among-food-insecure-uk-adults-crosssectional-analysis-of-the-international-food-policy-study/
B6B5A7E104B8565AFF6A3DB8C0FBEF60/core-reader
necessity for survival—to be completed with as minimal mental input

as possible. Again, these factors increase the appeal of familiar, ready-
prepared and nutritionally limited food items.220
150. There are a series of hurdles to overcome to access a healthy diet.
These hurdles are particular to lower income groups, and their
combined effect means that it is significantly harder for people with
a lower income to access a healthy diet. The current food system
requires much more of people with fewer resources.
151. We accept that it is possible to eat healthily on a tight budget. One can, for
example, buy a variety of vegetables and prepare soup for very little. However,
posing this as a solution misses the point: there are many difficulties involved
in preparing healthy, nutritious meals, particularly for those on the lowest
incomes. We have synthesised the evidence we received on these practical
difficulties into an imagined scenario, to demonstrate why this is not as easy
a solution as it may seem.

Box 6: Why don’t people just make soup?
The person following well-meant advice to prepare vegetable soup may, first,
have to persuade the family that the dish will be enjoyable.
A person following this advice may look up a recipe. They may not have access
to recipe books, so spend time looking at internet recipes, which can be fairly
inaccessible.
There are new ingredients in the recipe, such as stock and possibly flavourings
which the person would have to purchase. With a more complicated recipe,
some ingredients may not be available in the local shop. Having spent time
discovering this, the person may have to go to a different shop further away,
taking longer, and possibly incurring transport costs.
If the ingredients are available in the local shop, these ingredients are likely only
to be available in small quantities (thus decreasing the value for money). We
were told that the cost of the ingredients of a new meal without a “middle class
store cupboard” was estimated at £15.221
While looking for perhaps unfamiliar ingredients, the person shopping will have
to ignore other temptingly displayed options, or price promotions. These are
likely to be less healthy foods, but foods that the family may have tried before. If
shopping with children, the person may have to ignore “pester power”.
The kitchen equipment required for the recipe (weighing scales, knives, peelers,
ovens, stoves) may be unavailable or inadequate, making the process more
difficult or perhaps impossible.
Following a new recipe, particularly if not familiar with cooking generally, can
be stressful and time-consuming.
If the soup goes wrong, is unpopular with the rest of the household, or simply
doesn’t taste good, the household may want to eat something else. Thus, two
meals have been paid for and the time, money and energy spent on the original
meal has been wasted. The remaining ingredients may also go to waste. Hungry
children or growing teenagers may not feel full having eaten soup, so may want
to eat something else.
Separately, these difficulties are not insurmountable. Combined, however, they
represent a real barrier to accessing a healthy diet. When there are so many easy,
cheap and reliable alternatives available, this process is a distinctly unappealing
proposition.
221

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.
222 Q 47 (Alex Holt)

223 Q 109 (Mark Laurie)
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

225 The Food Foundation, The Broken Plate (February 2019): https://foodfoundation.org.uk/wp-content/
uploads/2019/02/The-Broken-Plate.pdf [accessed 30 June 2020]
228 Q 12 (George Butterworth)
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

231 Department of Health and Social Care, Childhood Obesity: A plan for Action (August 2016): https://
Childhood_obesity_2016__2__acc.pdf [accessed 30 June 2020]
232 Department of Health and Social Care, Childhood Obesity: A Plan for Action, Chapter 2 (June 2018):
https://assets.publishing.service.gov.uk /government/uploads/system/uploads/attachment_data/
file/718903/childhood-obesity-a-plan-for-action-chapter-2.pdf [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): https://www.gov.uk/government/consultations/advancing-
our-health-prevention-in-the-2020s/advancing-our-health-prevention-in-the-2020s-consultation-
document [accessed 30 June 2020]
234 Independent report by the Chief Medical Officer, Time to Solve Childhood Obesity, (October 2019):
https://www.gov.uk/government/publications/time-to-solve-childhood-obesity-cmo-special-report
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
235 Q 72 (Kate Halliwell)

236 Q 72 (Dr Hilda Mulrooney)
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 The consultation closed 21
caffeine to children November 2018.241
Out of home energy labelling The consultation closed 7 December

2018.242
Location promotions and price The consultation closed 6 April

promotions 2019.243
Advertising (reducing children’s The consultation closed 10 June
exposure to advertising of HFSS 2019.244
products on TV and online, including
9pm watershed)
Updating the School Food Standards The consultation closed 13 August
to reduce sugar consumption 2019.256
240 241 242 243 244 245
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,
240 Public Health England, Calorie reduction: the scope and ambition for action (March 2018): https://
Calories_Evidence_Document.pdf [accessed 30 June 2020]
241 Department of Health and Social Care, Consultations: Ending the sale of energy drinks to children,
(Updated November 2018): https://www.gov.uk/government/consultations/ending-the-sale-of-
energy-drinks-to-children [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): https://www.gov.uk/government/consultations/calorie-labelling-
for-food-and-drink-served-outside-of-the-home [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): https://www.gov.uk/government/consultations/restricting-
promotions-of-food-and-drink-that-is-high-in-fat-sugar-and-salt [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):
https://www.gov.uk/government/consultations/further-advertising-restrictions-for-products-high-in-
fat-salt-and-sugar [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): https://www.gov.uk/government/consultations/
updating-the-government-buying-standards-for-food-and-catering-services-gbsf [accessed 30 June
2020]
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
246 Cabinet Office and Department of Health and Social Care, Advancing our health: prevention in the
2020s, (Updated October 2019): www.gov.uk/government/consultations/advancing-our-health-
prevention-in-the-2020s [accessed 30 June 2020]
248 Professor Dame Sally Davies, Time to Solve Childhood Obesity. An Independent Report by the Chief
Medical Officer (2019): https://assets.publishing.service.gov.uk/government/uploads/system/uploads/
June 2020]
• 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

251 Professor Dame Sally Davies, Time to Solve Childhood Obesity. An Independent Report by the Chief
Medical Officer (2019): https://assets.publishing.service.gov.uk/government/uploads/system/uploads/
June 2020]
252 Healthy Start, ‘What is Healthy Start?’: https://www.healthystart.nhs.uk/ [accessed 30 June 2020]
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
Value
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
254 Alexandra Rose, ‘How Rose Vouchers work’: https://www.alexandrarose.org.uk/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), https://bmcpublichealth.biomedcentral.com/articles/10.1186/1471–2458-14-148
256 Q 62 (Shirley Cramer)
257 Written evidence from First Steps Nutrition Trust (ZFP0044)
259 Calculated from Bank of England, ‘Inflation Calculator’: https://www.bankofengland.co.uk/
monetary-policy/inflation/inflation-calculator [accessed 30 June 2020]
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
260 Healthy Start, ‘Do I qualify for Healthy Start?’: https://www.healthystart.nhs.uk/healthy-start-

vouchers/do-i-qualify/ [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)
262 First Steps Nutrition Trust, The UK Healthy Start scheme, (2018): https://static1.squarespace.com/
static/59f75004f09ca48694070f3b/t/5b8e2d0e575d1f6f1e5d2dcd/1536044307456/Healthy_Start_
Report_for_web.pdf [accessed 30 June 2020]
263 Feeding Britain, Increasing Healthy Start Uptake, (February 2019) pp 1-2: https://feedingbritain.
org/wp-content/uploads/2019/02/Healthy_Start_Uptake-_Feeding_Britain_Case_Study_2-1.pdf
264 Ibid and First Steps Nutrition Trust, The UK Healthy Start scheme, (2018): https://static1.squarespace.
com/static/59f75004f09ca48694070f3b/t/5b8e2d0e575d1f6f1e5d2dcd/1536044307456/Healthy_
Start_Report_for_web.pdf [accessed 30 June 2020]
265 Q 59 (Nicky Dennison)
266 Q 59 (Dr Katie Cuming)
267 First Steps Nutrition Trust, The UK Healthy Start Scheme, (2018): https://static1.squarespace.com/
static/59f75004f09ca48694070f3b/t/5b8e2d0e575d1f6f1e5d2dcd/1536044307456/Healthy_Start_
Report_for_web.pdf [accessed 30 June 2020]
268 Ibid. and Feeding Britain, Increasing Healthy Start Uptake: https://feedingbritain.org/wp-content/
uploads/2019/02/Healthy_Start_Uptake-_Feeding_Britain_Case_Study_2-1.pdf [accessed 30 June
2020]
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
Reform
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
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: https://assets.publishing.
277 HC written question, 29 January 2020, 9618
278 Q17 (Jenny Oldroyd)
279 Eligibility is determined by receipt of some qualifying benefits.
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

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.”
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
Funding
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
280 Q 47 (Professor Greta Defeyter). See also Q 5 (Anna Taylor)..
282 Department for Education, Coronavirus (COVID-19): free school meals guidance for schools, (30 April
2020): https://www.gov.uk/government/publications/covid-19-free-school-meals-guidance/covid-
19-free-school-meals-guidance-for-schools [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): https://www.bbc.
co.uk/news/education-52488208 [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): https://www.gov.uk/government/publications/universal-infant-free-school-
meals-uifsm-2019-to-2020/universal-infant-free-school-meals-uifsm-conditions-of-grant-2019-
to-2020 [accessed 30 June 2020]
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.
287 Department for Education, Free school meals supplementary grant (July 2018): https://assets.
publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/731589/FSM_
Supplementary_Grant_Guidance.pdf [accessed 30 June 2020]
291 Institute for Fiscal Studies, Universal free school meals are back on the table, (5December 2019): https://
www.ifs.org.uk/election/2019/article/universal-free-school-meals-are-back-on-the-table [accessed 30
June 2020] and The Guardian, Free school meals ‘putting pressure on small schools’ budgets, (31 August
2016): https://www.theguardian.com/education/2016/aug/31/free-school-meals-putting-pressure-
small-schools-budgets-uk [accessed 30 June 2020]
Eligibility
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
292 Department for Education, Schools, pupils and their characteristics, (27 June 2019): https://assets.
publishing.service.gov.uk /government /uploads/system/uploads/attachment_data/f ile/812539/
Schools_Pupils_and_their_Characteristics_2019_Main_Text.pdf [accessed 30 June 2020] l
293 Institute for Fiscal Studies, Free school meals under universal credit (April 2018): https://www.ifs.org.uk/
uploads/publications/bns/BN232.pdf [accessed 30 June 2020]
294 Ibid.
295 Q 39 (Alysa Remtulla)
296 Institute for Fiscal Studies, Free school meals under universal credit (April 2018): https://www.ifs.org.uk/
uploads/publications/bns/BN232.pdf [accessed 30 June 2020]
297 Sustain, Free School Meals for All: https://www.sustainweb.org/childrensfoodcampaign/free_school_
meals/ [accessed 30 June 2020]
298 Q 39 (Dr Mary Bousted)

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.”
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

300 Angus Holford and Birgitta Rabe, Going universal—The impact of free school lunches on child body weight
outcomes (6 March 2020): https://www.iser.essex.ac.uk/files/projects/FSM/UIFSM_Bodyweight_
Outcomes_20200306.pdf [accessed 30 June 2020]
302 Institute for Fiscal Studies, Universal free school meals are back on the table, (5 December 2019): https://
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.
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.
304 Ibid.
306 Institute for Fiscal Studies, Universal free school meals are back on the table (5 December 2019): https://
June 2020]
307 Q 40 (Professor Greta Defeyter). See also Q 5 (Anna Taylor).
311 Q 24 (Sarah Lewis)
313 Q 40(Professor Greta Defeyter)
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
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): https://
School-food-in-England-April2019-FINAL.pdf [accessed 30 June 2020]
316 School Food Standards, A practical guide for schools their cooks and caterers (2014), p 2: http://www.
schoolfoodplan.com/wp-content/uploads/2014/06/School-Food-Standards-Guidance-FINAL-
V1a-140616.pdf [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)
321 HM Government, Childhood Obesity: A Plan for Action, (August 2016) p 9: https://assets.publishing.
service.gov.uk /government/uploads/system/uploads/attachment_data/file/546588/Childhood_
obesity_2016__2__acc.pdf [accessed 30 June 2020]
322 HM Government, Childhood Obesity: A Plan for Action Chapter 2, (2018): p 10: https://assets.publishing.
323 The Requirements for School Food Regulations 2014 (SI 2014/1603)
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
325 Ibid.
331 Written evidence from LACA (ZFP0048)
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
332 Q 43 (Dr Mary Bousted)

333 Department for Education, Thousands more school children receiving a nutritious breakfast, (2 November
2018): https://www.gov.uk/government/news/thousands-more-school-children-receiving-a-nutritious
-breakfast [accessed 30 June 2020]
335 Q 41 (Alysa Remtulla) & Department for Education, Free meals and summer holiday activities for children,
(4 January 2020): https://www.gov.uk/government/news/free-meals-and-summer-holiday-activities-
for-children [accessed 30 June 2020]
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

337 Institute for Fiscal Studies, Breakfast clubs work their magic in disadvantaged English schools, (4 November
2016): https://www.ifs.org.uk/publications/8714 [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: https://www.frontiersin.org/articles/10.3389/fpubh.2019.00283/full
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: https://assets.publishing.service.gov.uk/government/uploads/system/
uploads/attachment_data/file/387160/RR398A _-_Economic_Value_of_Key_Qualifications.pdf
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): https://www.ifs.org.uk/publications/8714 [accessed 30 June 2020]
342 Written evidence from the Labour Hunger Campaign (ZFP0052) and Blackpool Council (ZFP0036)
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
343 Written evidence from Blackpool Council (ZFP0036)

345 Written evidence from Magic Breakfast (ZFP0076) and NAHT, ‘#NAHTconf: “Embarrassed and
ashamed” the impact of austerity on England’s schoolchildren’,: https://www.naht.org.uk/news-and-
opinion/press-room/nahtconf-embarrassed-and-ashamed-the-impact-of-austerity-on-englands-
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): https://www.independent.co.uk/news/uk/
politics/conservatives-manifesto-general-election-2017-free-school-breakfasts-lunch-a7861836.html
347 Q 38 (Professor Greta Defeyter). See paragraph 59 for related statistics.
349 Ibid.
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
351 Department for Education, Free meals and summer holiday activities for children, (4 January 2020): https://
www.gov.uk/government/news/free-meals-and-summer-holiday-activities-for-children [accessed 30
June 2020]
353 See paragraph 93.
355 Institute for Fiscal Studies, Educational gaps are growing during lockdown (18 May 2020): https://www.
ifs.org.uk/publications/14849 [accessed 30 June 2020]
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.
360 Written evidence from the Labour Hunger Campaign (ZFP0052)
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
361 Q 90 (Rob Percival)

362 Q 76 (Dr Adrian Morley)
363 Q 86 (Kath Dalmeny)
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
366 Q 56
367 Department for Environment, Food and Rural Affairs, The Government Buying Standard for Food
and Catering Services: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/
attachment_data/file/418072/gbs-food-catering-march2015.pdf [accessed 30 June 2020]
369 Ibid.
371 Department for Environment, Food and Rural Affairs, The Government Buying Standard for Food
and Catering Services, (https://assets.publishing.service.gov.uk/government/uploads/system/uploads/
attachment_data/file/418072/gbs-food-catering-march2015.pdf [accessed 30 June 2020]
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;
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) http://www.healthscotland.scot/
media/2326/evaluation-of-the-healthcare-retail-standard.pdf [accessed 30 June 2020]
374 Q 63 (Dr Louise Marshall)
2020]
• 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
Advertising
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:
376 Written evidence from Dr Clare Pettinger assisted by members of the Food Plymouth partnership
(ZFP0033)
“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

382 The Food Foundation, The Broken Plate (February 2019) p 14: https://foodfoundation.org.uk/wp-
content/uploads/2019/02/The-Broken-Plate.pdf [accessed 30 June 2020]
384 Department of Health and Social Care, Restricting promotions of food and drink that is high in fat, sugar
and salt (updated April 2019): https://www.gov.uk/government/consultations/restricting-promotions-
of-food-and-drink-that-is-high-in-fat-sugar-and-salt [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)
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
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): http://obesityhealthalliance.org.uk/2019/02/28/protect-children-junk-food-
advertising-say-health-experts-parents-agree/ [accessed 30 June 2020]
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): https://www.
gov.uk/government/publications/health-matters-obesity-and-the-food-environment/health-matters-
obesity-and-the-food-environment--2 [accessed 30 June 2020]
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
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): https://pubmed.ncbi.nlm.nih.gov/27067035/ [accessed 30 June
2020]
£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
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): https://assets.publishing.service.gov.
uk/government/uploads/system/uploads/attachment_data/file/781451/RPC-DHSC-4333_1_ _-_
Restreicting_checkout__end-of-aisle__and_store_entrance_sales_of_food_and_drinks_HFSS__1_.
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): https://www.gov.uk/government/consultations/restricting-
promotions-of-food-and-drink-that-is-high-in-fat-sugar-and-salt [accessed 30 June 2020]
• 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
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) https://assets.publishing.service.gov.uk/government/
uploads/system/uploads/attachment_data/file/770704/consultation-on-restricting-price-promotions-
of-HFSS-products.pdf [accessed 30 June 2020]
403 Written evidence from Faculty of Dental Surgery (ZFP0010). See also Public Health England, Sugar
Reduction: The evidence for action – Annex 4: An analysis of the role of price promotions on the household
purchases of food and drinks high in sugar, (2015) pp 5–6: https://assets.publishing.service.gov.uk/
government/uploads/system/uploads/attachment_data/file/470175/Annexe_4._Analysis_of_price_
promotions.pdf [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): https://www.gov.uk/government/consultations/restricting-promotions-
of-food-and-drink-that-is-high-in-fat-sugar-and-salt [accessed 30 June 2020]
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
407 Public Health England, Healthy people, healthy places briefing, Obesity and the environment: regulating
the growth of fast food outlets (March 2014) p 4: https://assets.publishing.service.gov.uk/government/
uploads/system/uploads/attachment_data/file/296248/Obesity_and_environment_March2014.pdf
408 Ministry of Housing, Communities & Local Government, The National Planning Policy Framework,
CP 48 (February 2019): https://www.gov.uk/government/publications/national-planning-policy-
framework--2 [accessed 30 June 2020]
410 House of Commons Library, Local authorities’ public health responsibilities (England), Standard
Note, SN06844, March 2014
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.

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): https://www.
gov.uk/government/news/government-to-grant-permission-for-pubs-and-restaurants-to-operate-as-
takeaways-as-part-of-coronavirus-response [accessed 30 June 2020]. This time limited permitted
development right was introduced in March 2020 through a negative Statutory Instrument.
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

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

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 … .”
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.
Labelling
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
424 Written evidence from Kevin Higgins, Advice NI (ZFP0020)
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

428 Department of Health and Social Care, Advancing our health: prevention in the 2020s: consultation
document (22 July 2019): https://www.gov.uk/government/consultations/advancing-our-health-
prevention-in-the-2020s/advancing-our-health-prevention-in-the-2020s-consultation-document
430 Department of Health and Social Care, Calorie labelling for food and drink served outside of the home
(updated October 2018): https://www.gov.uk/government/consultations/calorie-labelling-for-food-
and-drink-served-outside-of-the-home [accessed 30 June 2020]
432 Written evidence from the Obesity Group of the British Dietetic Association (ZFP0035)
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
433 WRAP, Updating Guidance to Food Businesses on the Application of date Marks and Related Advice (April
2017): https://www.wrap.org.uk/sites/files/wrap/Briefing_note_Updated_guidance_to%20industry_
on_date_and_related_labelling.pdf [accessed 30 June 2020]
434 WRAP, Household food and drink waste: A product focus (June 2014): https://www.wrap.org.uk/sites/files/
wrap/Product-focused%20report%20v5_3.pdf [accessed 30 June 2020]
435 Arla, Nearly a third of consumers unnecessarily binning food due to label confusion, (5 September 2019):
https://news.arlafoods.co.uk/news/nearly-a-third-of-consumers-unnecessarily-binning-food-due-to-
label-confusion [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).
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%
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)
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.
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): https://
onlinelibrary.wiley.com/doi/full/10.1111/j.1740–8709.2012.00462.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)
450 Written evidence from the Soil Association (ZFP0016)
451 HM Government, Childhood Obesity: A Plan for Action (August 2016), p 8: https://assets.publishing.
service.gov.uk /government/uploads/system/uploads/attachment_data/file/546588/Childhood_
obesity_2016__2__acc.pdf [accessed 30 June 2020]
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.
452 Department for Education, PE and sport premium for primary schools (November 2019): https://www.
gov.uk/guidance/pe-and-sport-premium-for-primary-schools [accessed 30 June 2020]
453 NHS, Change4Life: https://www.nhs.uk/change4life [accessed 30 June 2020]
454 Written evidence from City Harvest (ZFP0055)
456 Written evidence from Dr Christian Reynolds (ZFP0077) and Association of Convenience Stores
(ZFP0050)
458 Written evidence from Health Action Campaign (ZFP0046)
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

462 Written evidence from Professor Dominic Harrison and Emma Savage (ZFP0027)
464 Written evidence from Dr Clare Pettinger assisted by members of the Food Plymouth Partnership
(ZFP0033)
• 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.
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)
Chapter 5: REFORMULATION AND REGULATION
340. The previous chapter set out how factors within the ‘food environment’ can
drive dietary choices. We have argued that there is a clear and compelling
argument for controlling what many see as the ‘aggressive’ marketing and
promotion of less healthy food, and for reshaping the food environment to
support healthier choices.
341. The food environment can have a profound effect on consumer choice, but
clearly, so can the types of product that are made available. Our attention
was drawn repeatedly to the prevalence of products high in energy, unhealthy
types of fat, salt or sugar, commonly associated with highly processed foods.
It bears repeating that these types of foods are much more likely to be on
promotion, making them appealing to those on a tight budget469, and that
a high proportion of both adults and children’s dietary energy comes from
highly processed food.470 We also eat more processed products than other
European countries.471 We are, as Anna Taylor suggested, “heavily dependent
on those foods.”472
342. The general consensus was that interventions which make minimal demands
on individuals and are delivered to whole populations are considered to be
more effective in driving public health improvements, than approaches that
aim simply to encourage individuals to change their behaviours. As such, many
witnesses highlighted that government-led reformulation programmes have
the potential to be a powerful lever in enabling healthier diets and improving
health outcomes. As levels of food insecurity and health inequalities were a
central concern of this inquiry and given the potential that reformulation has
for delivering equitable effects across the whole population, it was important
for us to consider that merits of different approaches to encouraging industry
to reformulate their products to make them healthier.
343. The Government certainly appears to have put a good deal of faith in
the ability of reformulation programmes to drive improvements in public
health, with voluntary sugar and calorie reduction forming key components
of Chapter 2 of the Childhood Obesity Plan. Further commitments to
salt, sugar and calorie reduction were outlined in its 2019 Green Paper on
prevention, which stated that: “Central to our approach to improving diets is
working with food and drink companies to make their products healthier.”473
344. The evidence we received was broadly in agreement that government-led
reformulation programmes can be effective in tackling excess levels of fat,
sugars and salt in processed foods, and should play a key role in continuing
efforts to improve dietary health. There were, however, serious concerns
raised about the limitation of reformulation, both in how effectively
reformulation programmes have been implemented and adhered to, and to
what extent reformulation should be relied upon to deliver the public health
470 Ibid.
471 Written evidence from the University of Southampton and the MRC Life Course Epidemiology Unit
Southampton General Hospital (ZFP0080)
473 Department of Health and Social Care, Advancing our health: prevention in the 2020s:consultation
document, CP 110 (July 2019): https://www.gov.uk/government/consultations/advancing-our-health-
prevention-in-the-2020s/advancing-our-health-prevention-in-the-2020s-consultation-document
improvements that are so urgently required. Witnesses emphasised that

reformulation should not be relied on too heavily as part of effort to improve
dietary health. Shirley Cramer from the Royal Society for Public Health,
said on reformulation:
“We feel, with others, that it is part of the mix of the things we need to
do to tackle obesity and promote healthy eating. It is for the researchers
to look at how big a part it is, but we cannot see it as the main plank of
what the UK needs to do to solve the obesity crisis.”474
345. There was a further concern expressed by others that reformulation is
a sticking plaster when a more widescale shift in the food environment is
required. This view was articulated most clearly by Professor Jebb:
“If we are fundamentally to address the very big issues this Committee
is focused on, we have to make bigger changes in the way people eat. We
cannot do it just by fiddling around when changing the composition of
the things that people currently eat. We have to eat fewer biscuits and
cakes, less chocolate and confectionery, and more fruit and vegetables.
You are not going to achieve that through reformulation.”475
346. The representatives from food retail and manufacturing sectors that we heard
from were keen to emphasise their willingness to help reduce the availability
and appeal of less healthy food. While we acknowledge that there is some
encouraging work underway by individual companies and organisations
to reformulate their products, the Government’s assessments of industry
progress against its reformulation targets show that significant improvement
is required. The food industry is highly competitive and, although SMEs
make up a significant proportion of food businesses, the industry as a
whole is dominated by the major supermarkets and by large multi-national
food manufacturers. The fact that industry progress against voluntary
reformulation targets has been limited suggests that many manufacturers and
retailers are not yet fully engaged in efforts to reduce harmful levels of less
healthy ingredients. The industry needs to take more responsibility for the
products it produces, manufactures, and sells to the consumer. Industry has
the power and the capability to make positive changes to the dietary health
of the nation but where it fails to do so, the Government must intervene.
347. Professor Susan Jebb suggested that the Government was placing too much
faith in reformulation: “Unfortunately, the Government have decided that
reformulation is the answer”.476 Requiring industry to make their products
healthier is a key element of Public Health England’s strategy in relation to
obesity. As such, it was important to consider if there are opportunities to
strengthen existing reformulation programmes, and to learn from the (in
some cases) not insignificant success of others.
Existing reformulation measures

348. Food reformulation is defined as the re-designing of an existing processed
food product with the objective of making it healthier. A key benefit to this
approach is that the nutritional composition of food and drink can gradually
improve. This has the potential to impact on the whole population, including

476 Ibid.
children and regardless of population subgroup. Crucially, it was argued, this

type of intervention does not require any behaviour change in individuals.
349. The key reformulation measures introduced by the Government include:
• The Salt Reduction Programme. Salt targets were first introduced

by the government in 2006, challenging the industry to reduce salt
in everyday foods. In 2003, the Scientific Advisory Committee on
Nutrition (SACN) recommended that salt intake should be reduced to
no more than 6 grams per day for adults.477 Following this, the Food
Standards Agency (FSA) set salt reduction targets for food and drinks
to be met by 2010. In 2010, responsibility for nutrition transferred from
the FSA to the Department of Health. According to Public Health
England: “To date, four sets of targets have been published (2006,
2009, 2011 and 2014), covering up to 80 individual product types.”478
• The Soft Drinks Industry Levy (SDIL). Announced in March 2016,

the SDIL is a tax on soft drinks that contain more than 5 g sugar per
100 millilitres, with a higher rate on drinks with more than 8 grams
per 100 millilitres. Fruit juices and milk-based drinks were exempt
from the levy. The stated aim of the SDIL was to encourage the soft
drinks industry to improve the healthiness of the drinks they produce,
by reducing sugar content or reducing portion sizes. The SDIL was
implemented in April 2018.479
• The Sugar Reduction programme. In August 2016 the Government’s

Childhood Obesity: A plan for action included a commitment for Public
Health England (PHE) to oversee a sugar reduction programme. This
challenged all sectors of the food industry to reduce sugar in their
products by 20% by 2020. Industry was also challenged to achieve a
5% reduction in the first year of the programme.480
350. The Government is also developing measures for a wider calorie reformulation
programme. It has consulted on measures relating to product ranges aimed at
babies and young children, and has undertaken a programme of engagement
with the eating out of home sector.481
351. There was some discrepancy in the evidence about how targets on
reformulation should be applied. The main argument centred around
whether voluntary or mandatory interventions were more likely to deliver the
necessary improvements in public health. There was some acknowledgment
of the achievements voluntary reformulation programmes have been able
to make, in particular for salt, but concern was expressed that mandatory
477 Scientific Advisory Committee on Nutrition, Salt and Health (April 2003), p ii: https://assets.
publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/338782/SACN_
Salt_and_Health_report.pdf [accessed 30 June 2020]
478 Public Health England, Salt Reduction Programme PHE’s first assessment of the food industry’s
progress towards meeting the government’s salt reduction targets (December 19 2018): https://
publichealthengland.exposure.co/salt-reduction-programme [accessed 30 June 2020)
479 HM Revenue and Customs, Soft Drinks Industry Levy (December 2016): https://www.gov.uk/
government/publications/soft-drinks-industry-levy/soft-drinks-industry-levy [accessed 30 June 2020]
480 Public Health England, Sugar reduction and wider reformulation, (20 September 2019): https://www.gov.
uk/government/collections/sugar-reduction [accessed 30 June 2020]
481 Public Health England, Reduction and reformulation programme: Spring 2019 update (10 May 2019):
https://www.gov.uk/government/publications/reduction-and-reformulation-programme-spring-2019-
update/reduction-and-reformulation-programme-spring-2019-update#out-of-home-engagement
reformulation measures may be required if significant progress is not made.

There was considerable support expressed for the Soft Drinks Industry Levy,
and the potential for fiscal measures to encourage industry more forcibly to
reformulate their products, with some calling for this approach to be extended
to cover other nutrients, food groups and products. The evidence did not,
however, dismiss voluntary measures entirely, with some witnesses making
suggestions on how voluntary measures might be improved to ensure greater
levels of adherence to reduction targets.
Voluntary reformulation programmes

352. Both the Salt Reduction Programme and the Sugar Reduction Programme
set voluntary reformulation targets for certain processed foods. Voluntary
salt reduction targets have been in place since 2006 and sugar targets were
first set for industry in 2016.482
Salt reduction
353. The salt reduction programme was cited as an example of a successful
reformulation programme. Professor Susan Jebb told us that: “Reformulation
has been a huge success story, in which the UK has had real leadership.
It started with the salt reduction programme, which continues today and
has been extraordinarily effective.”483 Similarly, the Nuffield Council on
Bioethics told the Committee that:
“There have been a number of voluntary initiatives directed at the
food industry to create healthier products, primarily aimed at reducing
sugar, salt, saturated fats, and/or trans-fats. Many of these voluntary
initiatives have shown that much can be achieved through self-
regulation. For example, seven-to-eight years after the introduction of
the Food Standards Agency’s voluntary salt reduction programme, the
salt content of many food products was reduced through reformulation,
alongside the introduction of a number of low-salt versions of products
to the market.”484
354. Jenny Oldroyd from the Department of Health and Social Care told us that:
“The salt reduction programme has also made gains in reducing salt in
foods. Between 2005 and 2011 we saw salt decrease in foods by 11%,
from 8.8 grams to 8 grams per day on average. We saw really big gains in
particular foods. Bread, for example: that programme resulted in 40%
less salt on average in bread in this country.”485
355. It was suggested that the initial success of the programme was due to
effective monitoring by the Food Standards Agency, which allowed it to hold
companies to account and to drive improvements in salt reduction. Mhairi
Brown from Consensus Action on Salt, Sugar and Health, stated that the
Food Standard Agency’s salt reduction programme was:
“ … robust and well monitored, and it became a model for salt reduction
programmes around the world. We saw transparent and publicly
482 Public Health England, Salt Reduction Programme, PHE’s first assessment of the food industry’s progress
towards meeting the government’s salt reduction targets (December 2018): https://publichealthengland.
exposure.co/salt-reduction-programme [accessed 30 June 2020]
484 Written evidence from Nuffield Council on Bioethics (ZFP0045)
published monitoring reports, which made it much easier to hold the

food industry to account …”
“It was so successful that the salt content of many products decreased by
about 40% and the public were not aware of that. They still continued
to buy the same products. It had a huge impact on population blood
pressure.”486
356. The support expressed for the salt reduction programme was, however,
frequently caveated by the assertion that initial progress made by the
programme in the early 2000s was not subsequently sustained. Susan Lloyd,
Executive Lead for Policy at the Faculty of Public Health, stated that:
“Our view at the faculty is that the salt and sugar levies have been
effective. However, they have now stalled, primarily because they were
voluntary agreements … The salt reduction process has stalled, certainly,
when it comes to reductions in formulated salt in products.”487
357. A number of witnesses expanded on this and identified the transfer of
responsibility from the FSA to the Department of Health, (which placed
salt reduction under the Public Health Responsibility Deal) and eventually
to Public Health England, as a turning point when the momentum on salt
reduction was lost. The Nuffield Council on Bioethics was amongst the
organisations that noted this shift, stating that:
“… seven-to-eight years after the introduction of the Food Standards
Agency’s voluntary salt reduction programme, the salt content of
many food products was reduced through reformulation, alongside the
introduction of a number of low-salt versions of products to the market.
However, later figures published by Public Health England showed
a more mixed picture for the food industry’s progress in meeting the
Government’s salt reduction targets.”488
358. It was argued that the transfer of responsibility resulted in a decline in
pressure from the Government on the food industry. The key criticism to
emerge was that, while the FSA publicly monitored industry progress on salt
reduction, the bodies that have subsequently overseen salt reduction have
not. The Public Health Responsibility Deal was criticised for lacking robust
or independent target setting, monitoring and enforcement mechanisms as
it made “the food industry responsible for making progress by itself without
giving it the leadership and support to enable that.”489 Consensus Action on
Salt, Sugar and Health claimed that:
“Salt reduction has stalled since the removal of strict monitoring by the
Food Standards Agency to be replaced by little to no monitoring under
the Public Health Responsibility Deal in 2011”490
359. Jenny Oldroyd told the Committee that:
“The salt reduction programme has also made gains in reducing salt
in foods. Between 2005 and 2011 we saw salt decrease in foods by

487 Q 61 (Susan Lloyd)
488 Written evidence from the Nuffield Council on Bioethics (ZFP0045)
490 Written evidence from Consensus Action on Salt, Sugar and Health (ZFP0053)
11%, from 8.8 grams to 8 grams per day on average. We saw really big

gains in particular foods. Bread, for example: that programme resulted
in 40% less salt on average in bread in this country.”491
360. In March 2020, Public Health England published its 2018/19 urinary sodium
survey, which looks at population salt intake, rather than the industry’s
progress on meeting salt targets. The latest PHE report revealed that salt
intakes had not significantly changed since they were last measured in 2014.
The report found that the mean estimated salt intake for adults was 8.4
grams per day (40% higher than the Government recommended maximum
of 6 grams a day).492
361. PHE’s latest report does appear to support the assertion the progress on salt
reduction has slowed, though we acknowledge the possibility that success
is easier to achieve earlier on in a reformulation programme. What is more
certain is that reporting against progress on population salt intake has been
patchy. Until the 2019 urinary sodium survey, UK population salt intake
had not been measured since 2014.493 If urinary sodium levels were cross-
referenced against information on the salt content of products, it could be
ascertained whether the apparent stalling in progress relates to reformulation
or to consumer behaviour.
362. Public Health England stated that its first assessment of the food industry’s
progress towards meeting the government’s salt reduction targets (published
in December 2018) showed a “mixed picture overall”. In the in-home sector,
PHE reported that:
• Just over half (52%) of all the average salt reduction targets set were
met by 2017. Retailers made more progress than manufacturers
towards achieving average targets, meeting 73% of these compared
with manufacturers meeting 37%;
• All average salt targets were met in 9 food categories, including

breakfast cereals and baked beans, however, meat products met none of
these targets; and
• Overall (for retailers and manufacturers combined), where maximum

targets were set, 81% of products had salt levels at or below their target
(retailers 86%, manufacturers 72%).494
363. The Government told us that it is revising its targets for the salt reduction
programme. The Department of Health and Social Care acknowledged that:
“While our consumption has decreased over the last decade, we are still
having too much salt and there is a long way to go. To achieve this, we will

492 Public Health England, National Diet and Nutrition Survey, Assessment of salt intake from urinary sodium
in adults (aged 19 to 64 years) in England, 2018–2019 (March 2020), p 6: https://assets.publishing.
service.gov.uk/government/uploads/system/uploads/attachment_data/file/876252/Report_England_
Sodium_Survey_2018-to-2019__3_.pdf [accessed 30 June 2020]
493 Action on Salt, ‘Action on Salt Position: UK Salt Reduction Strategy’: http://www.actiononsalt.org.
uk/about/position-statements/uk-salt-reduction-strategy/ [accessed 30 June 2020]
494 Public Health England, Salt target 2017: Progress report, A report on the food industry’s progress towards
meeting the 2017 salt targets (December 2018), pp 4–5: https://assets.publishing.service.gov.uk/
government/uploads/system/uploads/attachment_data/file/765571/Salt_targets_2017_progress_
report.pdf [accessed 30 June 2020]
publish revised salt reduction targets in 2020 for industry to achieve by mid-
2023 and we will report on industry’s progress in 2024.”495
Sugar reduction
364. The evidence on the progress of the sugar reduction programme was
similarly pessimistic. The Government has set a target for the food industry
to reduce the sugar in its products by 20% by 2020, with 5% in the first year
of the programme (August 2016 to August 2017).496 Public Health England
published its second-year report on the industry’s progress on meeting the
government targets on sugar reduction in 2019. It stated that:
• Between 2015 and 2018 there has been an overall 2.9% reduction in
total sugar content (sales weighted average in grams per 100 grams)
among retail and manufacturer branded products (in-home sector).
• More progress has been achieved in specific food categories, particularly

for breakfast cereals (8.5% reduction), and for yogurts and fromage
frais (10.3% reduction);
• Overall the total tonnes of sugar sold in foods included in the

reformulation programme from the in-home sector has increased by
2.6% between 2015 and 2018 (excluding cakes and morning goods),
whereas the sugar sold in soft drinks subject to SDIL has decreased by
21.6%.497
The Public Health Minister, Jo Churchill MP, referring to the sugar reduction
programme said:
“Some categories are lagging behind. The most notable is that we have
not seen much advance in confectionery at all.”498
365. In fact, according to Public Health England’s progress report in the retailer
own brand and manufacturer branded products there were small increases
for some categories (puddings and ice cream, lollies and sorbets). In the
out of home sector products there were some more significant increases,
including a 21.9% increase reported for chocolate confectionery.499
366. Speaking about the likelihood of the Government meeting its target of a 20%
reduction by 2020, Professor Jebb stated that: “There is no way we are going
to achieve that.”500
367. Echoing criticisms levelled at the salt reduction programme, efforts to
reduce levels of sugar in the population’s diet were criticised for lacking any
mechanism to encourage adherence to the targets. Dr Hilda Mulrooney
from the Obesity Group of the British Dietetic Association, stated that:

496 Public Health England, Sugar Reduction Programme, Progress made by industry in the first year (22 May
2018): https://publichealthengland.exposure.co/sugar-reduction-programme [accessed 30 June 2020]
497 Public Health England, Sugar Reduction: Report on progress between 2015 and 2018 (September 2019)
file/839756/Sugar_reduction_yr2_progress_report.pdf [accessed 30 June 2020]
“With the voluntary sugar programme, all that was said was that, if
sufficient progress had not been achieved by 2020, additional levers
might be used. There is no clarity about what those levers are, so it is
perhaps more difficult for industries to engage with it, or they do not
see the need to engage with it. So far there is no stick. You either engage
with it or you do not.”501
368. Mhairi Brown later emphasised that: “A voluntary programme is only
effective if it is well monitored and there is buy-in across the sector.”502
Voluntary reformulation programmes: conclusions

369. Overall, the potential for voluntary reformulation programmes to deliver
improved health outcomes was not dismissed entirely in favour of mandatory
approaches. It was, however, made clear that voluntary reformulation
programmes can only be effective if they are supported by close monitoring
and clear leadership from the Government. Given that the salt reduction
programme was able to demonstrate significant success in the past, there is
a reasonable case to be made that it could be revived, through introducing
more transparent and regular monitoring and stronger accountability for
industry to adhere to the targets set. Getting the food industry to commit
to the voluntary programmes is also critical. The limited evidence on the
success of the Government’s voluntary reformulation programmes on salt
and sugar reduction show that, as a whole, the industry is a significant way
off meeting the Government’s reduction targets. This suggests that some
in the industry will not make the effort to participate in the programmes,
or will even avoid participating in them entirely, unless they are made to.
This point is further reinforced by the evidence on the success of the Soft
Drinks Industry Levy in reducing the amount of sugar in drinks, versus the
limited progress that has been made with other products that fall under the
voluntary sugar reduction programme.
370. Many witnesses made the case that voluntary measures will always be limited
as they cannot effectively incentivise all companies across the industry.
Witnesses (including some industry representatives) expressed the need for
a level playing field, which many argued could only be achieved through
regulation. The Nuffield Council on Bioethics, for example, concluded that:
“Much can be achieved through self-regulation of the industry. However,
where self-regulation fails to deliver, regulation can be necessary as an
effective driver of change.”503
Mandatory reformulation
371. A number of witnesses cited their support for the Soft Drinks Industry Levy
(SDIL). Sustain were one of many to highlight the successes of the levy,
stating that: “The key measure to be implemented has been the introduction
of the Soft Drinks Industry Levy which has removed 90 million kg of sugar
from drinks since 2017.”504
372. Public Health England’s assessment of the SDIL found that there had been:

503 Written evidence from Nuffield Council on Bioethics (ZFP0045)
504 Written evidence from Sustain (ZFP0071)
• A 28.8% reduction in total sugar content per 100ml between 2015 and
2018 for the drinks subject to be included in the SDIL among retailer
own brand and manufacturer branded products;
• An increase in sales of drinks subject to the levy of 10.2%, but a

reduction in the total sugar content in the drinks sold of 21.6%;
• A shift in the volume of sales towards low sugar products (below 5g per
100ml) with no levy attached;
• A decrease in total sugar purchased from drinks subject to the SDIL

per household among all socio-economic groups.505
373. Some witnesses also highlighted that the Government received far less
revenue from the levy than had been anticipated, an indication that it had
been successful in incentivising manufacturers to reformulate their products
to avoid paying the fee.506A study, supported by the National Institute for
Health Research (NIHR), which analysed stock market returns of soft-
drink companies listed on the London Stock Exchange, found that they
have continued to experience positive growth in their share prices during the
implementation of the SDIL.507 Dr Hilda Mulrooney stated that:
“The soft drinks industry levy has shown that, with the 28.8% reduction
in sugar between 2015 and 2018, there has at the same time been an
increase in the soft drinks that are being consumed. More of them are
being consumed from the lower no-sugar category, so that suggests that
it is possible to achieve meaningful gains while still protecting the right
of industry to make a profit. It is an important market for the country. It
is an important part of the economy of the country, so industry must be
protected, but not at the expense of children.”508
374. Many concurred with Mhairi Brown’s view that: “the scale of progress that
has been made under the levy shows what kind of progress is possible if the
Government are able to show leadership and state their priorities clearly.”509
There were consistent calls to extend the SDIL in line with the Government’s
proposals to include a wider range of products, and for the Government to
assess where fiscal measures might be applied elsewhere to help drive public
health improvements. Cancer Research UK asked that:
“When the [Soft] Drinks Industry Levy (SDIL) is reviewed in 2020,
the UK Government should commit to extending the levy to sugar-
sweetened milk-based drinks and consider tightening current sugar
thresholds to encourage further reformulation. The UK Government
should also work with devolved administrations to continue to build
the evidence on fiscal measures and explore how these policies can aid
reformulation and change business and consumer behaviour.”510
506 HM Treasury, Soft Drinks Industry Levy comes into effect, (5 April 2018): https://www.gov.uk/
government/news/soft-drinks-industry-levy-comes-into-effect [accessed 30 June 2020]
507 National Institute for Health Research, Sugar tax had no lasting negative impacts on the UK soft drinks
industry, (25 February 2020): https://www.nihr.ac.uk/news/sugar-tax-had-no-lasting-negative-
impacts-on-the-uk-soft-drinks-industry/24156 [accessed 30 June 2020]
510 Written evidence from Cancer Research UK (ZFP0043)
375. The Public Health Minister, Jo Churchill MP, informed the Committee that:
“The Government has also committed to consider the sugar reduction
progress achieved in sugary milk-based drinks as part of its 2020 review
of the milk drinks exemption from the SDIL. Sugary milk drinks may
be included in the SDIL if insufficient progress on sugar reduction has
been made.”511
376. The evidence also included calls for the Government to reconsider the zero-
rated VAT status of some food products. Professor Susan Jebb argued that:
“The obvious immediate place you could take action would be on VAT.
There are ridiculous anomalies that do not help the health agenda. Why
do cakes not have VAT on them? That seems to me very easy to fix. If
the price of cakes went up by 20%, you would probably see something of
the order of a 15% to 20% reduction in consumption.”512
Dr Hilda Mulrooney highlighted that extending taxation on certain foods
could impact on consumer practices, stating that:
“If the product price is raised by about 20% due to taxation, it seems to
effect behaviour change in consumers. That will generate less income
from taxation because people stop buying products that are subject to the
levy. As regards income for the Government it is not a great approach,
but in consumer behaviour it seems to be.”513
377. Following the UK’s exit from the European Union we consider that there
is a clear opportunity for the Government to review VAT rates on food and
drink to help to rebalance the cost of food and drink in favour of healthier
products.
378. The Government should review the current zero-rated VAT
arrangements on some food products which are known to be energy
dense, and contain high levels of salt, sugar and unhealthy types of
fat. It should commence this review before the end of the transition
period in 2020.
The Industry View

379. There was broad agreement that that the food industry should be taking
more responsibility for promoting healthy and sustainable diets. We consider
this an entirely reasonable argument, given that it is the food processors
and manufacturers that create and produce highly processed food products.
However, with both voluntary and mandatory approaches to reformulation,
it was clear that some level of industry buy-in is required. Industry
representatives were able to highlight some of the difficulties and limitations
of reformulation from their perspective.
Barriers to reformulation
380. Industry representatives and others highlighted that reformulation is different
across different food products, with some products easier to change than
others. Professor Susan Jebb highlighted, for example, that: “Sugary drinks
are relatively easy. You can replace the sugar with artificial sweeteners or just
511 Supplementary written evidence from DHSC (ZFP0097)
make the drinks less sweet”514 but other products are not as easy to change.
Dr Hilda Mulrooney explained that “sugar in other foods has structural
properties as well.”515 Kate Halliwell from the Food and Drink Federation
explained the success of the SDIL might not be able to be replicated in other
products, stating that: “Trying to translate that to a cake, where sugar has a
much more structural role, would be much more difficult.”516
381. Industry representatives also suggested that two components of the
government obesity proposals—reformulation targets and restrictions on the
advertising of HFSS products—were, in some cases, working against each
other. Nestlé UK&I highlighted that the Government’s restrictions on the
advertising of products categorised as HFSS:
“… do not distinguish between those whose nutritional profile have been
improved and those that have not, meaning producers are faced with the
possibility of being unable to showcase the healthier alternatives.”517
It was suggested that this deters companies from reformulating their
products, posing a dilemma for companies when considering whether to
invest in reformulation. Kate Halliwell from the Food and Drink Federation
explained that:
“A company trying to decide now what to do, given how long it takes
to reformulate, would not be able to promote or advertise 30% reduced
confectionery. If you were trying to develop a product and invest a lot of
money in it, it would raise a question as to whether you should or not.
How do you successfully bring something to market?”518
382. There were also concerns expressed over the lack of clarity over what
measures will be introduced next, caused in part by the fact a number of
government proposals on improving dietary health have been announced
through the three Childhood Obesity chapters, but not yet implemented.
Kate Halliwell highlighted that: “We have had three childhood obesity plans
in two years. Inevitably, that means that civil servants are processing that
work, and we are just catching up with the announcements all the time.”519
383. Various witnesses referred to Scottish and Welsh efforts to support businesses
(particularly SMEs) to reformulate their products in a healthier way. The
Food and Drink Federation told us that:
“In Scotland, they fund a reformulation manager post to engage with
those companies. In Wales, there are food centres that look across the
piece more broadly. It is not just reformulation but sustainability issues,
and packaging comes into it as well. They have specifically said that they
are going to uplift the money to help companies on reformulation. In
England, we do not have an equivalent for that.”520
384. Given that the food industry is made up of a complex range of businesses, with
a significant number of SMEs, the argument that the Government should

517 Written evidence from Nestlé (ZFP0051)
invest in support for business to reformulate effectively, was compelling.

David Morris, the Deputy Head of Food, Agriculture, Fisheries and Rural
Strategy in the Welsh Government, explained the support it offers to help
industry meet its targets on reformulation:
“We believe it is about providing the right support at the right time. To
go back to our SME cohort, the largest part of the food manufacturing
sector, a number of them—particularly the smaller SMEs and the
micro businesses—do not have in-house resources for things such as
reformulation. In our food centre network, under our Project Helix
umbrella, we have a food centre in north Wales at Coleg Menai, in west
Wales at Horeb and in south-east Wales at Cardiff Metropolitan. It is an
outreach programme for all food manufacturers. It is heavily supported
and costs them very little, if anything, and they have access to all the
food technologists they need. They have the production facilities they
need. They have tasting suites and access to virtual reality grocery retail
experiences. There is a suite of support and programmes to aid their
development. That makes concepts such as reformulation much easier
for businesses.”521
Creating a level playing field

385. Although the industry representatives did highlight some of the barriers
they felt existed for industry to reformulate certain products, there was
some support expressed for mandatory reformulation measures. Andrew
Opie, Director of Food and Sustainability at the British Retail Consortium,
stressed that the food market is very competitive, and suggested:
“That bites on things such as reformulation at points where a retailer
may go so far to reformulate a product, but eventually it may not have
the quality or taste that a consumer might perceive to be what they want
to buy. It is a competitive market, and not having some mandatory levels
around things such as reformulation or labelling is a handicap and holds
back further progress across the food industry.”522
386. There was some agreement that regulation on content would represent a fair
method of encouraging the industry to reformulate products to make them
healthier without putting them at a competitive disadvantage. Andrew Opie
went on to suggest that mandatory regulation:
“sets a level playing field in many areas. With issues such as salt
reduction, for example, it is a bit of a mystery why retailers have managed
to remove so much salt and other manufacturers have not. I just put that
as a question. That is a choice issue because it is a voluntary area.”
“There are other things that would underpin that. We need education
for consumers so that they know when to make the right choices and
build the right diet. That is a more complex thing than just choosing
the right individual product. I am not sure that we see as much of that
as we could.”
“Similarly, to help SMEs to participate in this, particularly in some of the
food-to-go sector, there probably needs to be help from local authorities,
which have responsibility for public health, so that some of those smaller
521 Q 115 (David Morris)
522 Q 94 (Andrew Opie)
businesses can make changes that they probably could make without
costing them business. There are lots of other areas that underpin it.”523
387. We listened to the concerns from industry and we acknowledge calls for
clear direction from the Government on the issue of reformulation. We
were concerned, however, that the evidence we received from the retail and
manufacturing industries did, at times, direct responsibility for reducing
the availability and accessibility of less healthy food elsewhere, either to
Government, local authorities, schools or to the consumer. During the oral
evidence session with retailers, the Committee asked witnesses to respond
to its concerns that blame for the population’s poor dietary health is often
shifted onto others by the food industry. Andrew Opie responded by stating
that:
“The point we are making is that we are not here to blame anybody else.
I am here to accept the responsibility for retail, but if we want to make
a real difference, we have to see everybody in the food industry taking a
more progressive approach to the issue”.524
Mr Opie went on to state that:
“It will be a comprehensive answer if we really want to make a difference.
I am certainly not here to say, “It’s them, it’s them, it’s them”. What I
am here to say is, “This is what is possible”. We have shown what is
possible in labelling, reformulation, removal of trans fats and healthier
promotions. All of those things are absolutely possible. We just need
universal application of those and support from government.”525
Portion sizes
388. Another area where it was argued that Government regulation could be
effective in encouraging healthier choices was in mandating responsible
portion sizes. Both Nestlé and Sainsbury’s supported this as an approach.
Judith Batchelar, Director of Sainsbury’s Brand, told us:
“We have done all this work on reformulation but it hasn’t really worked.
If you think we have been reformulating products for 20 years, we still
have a massive problem in terms of nutrition, health, wellbeing and at
the extreme, obesity and that’s because we have been unable to create
an equivalence on portion size. If you look over the same period of time,
portion size has grown and one of things we have been lobbying for ….is
portion size guidance, which years ago we used to have.”526
389. The Centre for Diet and Activity Research raised the issue of portion size and
highlighted that: “An extensive body of research illustrates the contribution
of increasing portion sizes to the prevalence of obesity and overweight.”527
City Harvest suggested that: “Portion sizing also has a huge impact on the
average consumer leading to obesity and excess waste. Around 70% of all
food waste happens in the home and most of this is down to portion size and
date labels.”528

524 Ibid.
526 Q 94 (Judith Batchelar)
390. Mark Laurie from the Nationwide Caterers Association highlighted that
large portion sizes were an issue in the catering sector. He told us that
“A lot of people buy based on size. I guess that size is relative to value
in people’s minds, especially if they do not have very much money. A
massive portion of chips will probably seem like great value, whereas, in
the nutrition they are getting from it, it is terrible value.”
“I had a chat with someone from the fish friers’ association. I said, “Why
do you guys always sell massive portions of chips?” Whenever we buy
fish and chips, we get a massive portion that would feed a whole family.
I said, “Why do you do it? No one eats them; they just throw them all in
the bin. It is a waste of food and money”. He said, “It is a race to give the
biggest portions because that is what people want”.529
391. The Government’s sugar reduction programme states that businesses are
able to take action to reduce the levels of sugar in their products through
reformulation, reducing portion size or shifting consumers purchasing
patterns towards lower/no added sugar products.530 Similarly, the
Government’s calorie reduction programme states that industry has the
option to reduce the portion size of its products to meet the Government’s
target to reduce calories.531 The Government has not yet indicated that it will
consider measure to mandate portion sizes in the published chapters of its
childhood obesity plan or through any other current public health proposals.
392. As part of any future measures the Government sets out to tackle
obesity and poor dietary health, it should develop and publish a
consultation with industry on the issue of mandating maximum
calories per portion. This consultation process must involve active
engagement with SMEs and the catering sector.
The case for reformulation: conclusions

393. It was suggested that reformulation has limits as an approach. Overall,
witnesses were sceptical of the Government’s apparent dependency on
reformulation measures to deliver public health improvements.
394. There have, however, been signs that both voluntary and mandatory measures
can deliver results. Consistently throughout the evidence, programmes that
aim to encourage, or mandate, manufacturers to reformulate their products
to make them healthier, were cited as an important component of the solution
to deliver better health outcomes.
395. In her report, Time to Solve Childhood Obesity, Professor Dame Sally Davies
called on the Government to: “Rebalance the food and drinks sold to favour
healthy options, through regulation” and stated that:
“Ministers are in a unique position of influence to shape the
environment. They can set the scene for nudging positive outcomes or
they can continue to allow the flow of unhealthy options to dominate
a child’s upbringing. Political apathy will mean that negative health
531 Public Health England, Plans to cut excess calories consumption unveiled (6 March 2018): https://www.
gov.uk/government/news/plans-to-cut-excess-calorie-consumption-unveiled [accessed 30 June 2020]
consequences for children continue—limiting their life chances whilst

restricting economic productivity and the viability of the NHS.”532
396. The success of the SDIL demonstrates that regulatory action on reformulation
can deliver results, without impacting on economic viability in the sector.
This is a clear indication to us that that the Government should do more to
explore further mandatory and fiscal measures to compel the food industry
to act. The Public Health Minister, Jo Churchill MP told us that:
“I would like to see reformulation go on at pace. We have been incredibly
clear that where progress isn’t being made, we will consider what further
action can be taken. I think that the SDIL lays down a very strong marker
to the industry that the Government is willing to take regulatory action.
We need to send a strong message that this isn’t about reducing sales
it is about reducing sugar and ultimately about helping people make
healthier choices.”533
397. Reformulation is an important part of overall efforts to drive
healthier diets. The Government must maintain the pressure on
food manufacturers to reformulate their products. The Government
must recognise that the fact that Government-led reformulation
programmes are required at all, points to wider and more serious
failings in the food system as a whole.
398. For voluntary programmes to be successful it is imperative that
targets are transparently monitored and regularly reported on.
Voluntary approaches may be successful if the Government sets out
the right support to ensure industry stays engaged.
399. We recommend that all reformulation programmes, both voluntary
and mandatory, should be subject to transparent and regular
monitoring. Progress reports need to be carried out on a regular
basis by the responsible body and should include details of the
companies that have successfully made reductions in the levels of
salt and sugar in their products, to aid industry-wide reformulation.
400. We recommend that where voluntary approaches are adopted,
the Government should make clear that if the industry does not
respond comprehensively and swiftly then regulatory action will
follow. Both the sugar and salt reduction programmes are unlikely
to meet their stated targets. To ensure that necessary and significant
public health improvements are actually achieved, the Government
needs to face the reality of the situation and start to plan now for
how further progress on reformulation might be delivered. The
Government should set out now what mandatory action would look
like, if sufficient progress is not made on the existing reformation
programmes in the near future. Industry can then prepare. We ask
that the Government does this by the end of 2020.
401. Mandatory (fiscal) approaches can be highly successful, as evidenced
by the Soft Drinks Industry Levy. As there is a proven mechanism
532 Professor Dame Sally Davies, Time to Solve Childhood Obesity. An Independent Report by the Chief Medical
Officer (2019), p 2: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/
June 2020]
for delivering successful reductions in harmful ingredients, in a way

which has not had a significant detrimental impact on the industry,
the Government must not delay in exploring the application of fiscal
measures (such as further levies or changes to VAT) to other product
categories where reformulation is not in line with Government
guidance or targets.
402. We recommend that the Government stands by its commitment
to review the Soft Drinks Industry Levy in 2020, and commits to
extending the levy to other drinks containing added sugar, including
sugary milk-based drinks. It should also conduct work to explore
the impact of lowering the current sugar thresholds to encourage
further reformulation. It should rapidly determine which other food
products high in sugar could be subjected to a similar levy.
Chapter 6: FOOD AND THE NATURAL ENVIRONMENT
403. We have concluded that a food system: “encompasses everything from

production at the farm through manufacture, retail, use in the home and the
waste that goes on along the way”.534 We were established to investigate the
links between public health, inequality, and food sustainability. In previous
chapters, we have outlined how these elements of the food system interrelate.
Our report has so far focussed on how consumers experience food insecurity,
the food environment and on the health impacts of UK diets. The Committee
also received evidence relating to the primary production side of the food
system, and the impact of agriculture on the environment. To achieve a
healthy and truly sustainable food system, the Government must address
some fundamental questions about what and how much the nation should be
producing, and how it should be producing it.
404. Agriculture employs almost half a million people in the UK, 1.5% of the total
workforce, and in 2016, generated £23 billion worth of produce with a net
contribution to the UK’s economy of £8 billion.535 Around half of the food
eaten in the UK is produced in the UK.536 The UK’s production to supply
ratio—which measures the farm-gate value of raw food production (including
for export) divided by the value of raw food for human consumption—is
75% for indigenous-type foods (that is, those food that can be produced in
the UK) and 61% for all foods.537 More than 60% of the UK’s agricultural
production comes from livestock, which in 2016 was worth £12.7 billion.538
405. Our evidence indicated that economic forces requiring farmers to produce
food as cheaply as possible can act as an inhibitor to producing in an
environmentally sustainable way, and that there was a resultant negative
impact on various environmental measures. We were told that sustainability
included three strands: environmental, economic and social sustainability,
and may require a fundamental shift in consumption, which could also hold
health benefits.
406. Witnesses highlighted changes that will be brought in with the Agriculture
Bill’s new Environmental Land Management Scheme, and the necessity of
appropriately defining ‘public goods’ which would be rewarded with public
money. Standardised and mandatory reporting of certain environmental
metrics is crucial to allow this scheme to operate effectively, and the

535 Department for Environment, Food and Rural Affairs, The future Farming and Environment Evidence
Compendium (February 2018): https://assets.publishing.service.gov.uk/government/uploads/system/
uploads/attachment_data/file/683972/future-farming-environment-evidence.pdf [accessed 29 June
2020]
536 Department for Environment Food and Rural Affairs, National Statistics: Food Statistics in your pocket
2017: Global and UK supply, (9 October 2018): https://www.gov.uk/government/publications/food-
statistics-pocketbook-2017/food-statistics-in-your-pocket-2017-global-and-uk-supply [accessed 29
June 2020]
537 Department for Environment Food and Rural Affairs, National Statistics: Food Statistics in your pocket:
Global and UK supply’, (30 March 2020): https://www.gov.uk/government/publications/food-statistics-
pocketbook/food-statistics-in-your-pocket-global-and-uk-supply#uk-food-production-to-supply-
ratio-1988-to-2018 [accessed 29 June 2020]. Production to supply ratio is calculated as the farm-
gate value of raw food production (including for export) divided by the value of raw food for human
consumption.
538 Department for Environment, Food and Rural Affairs, The future farming and environment Evidence
compendium (February 2018): https://assets.publishing.service.gov.uk/government/uploads/system/
uploads/attachment_data/file/683972/future-farming-environment-evidence.pdf [accessed 29 June
2020]
Government must ensure that payments are truly conditional on meeting

the targets for progress.
407. Agricultural technology and innovation pose opportunities for more efficient
farming, but only if appropriately supported by funding for Research and
Development and a stable funding and policy environment, and they must
not be allowed to damage biodiversity or animal welfare. We heard views
on post-Brexit trade agreements and were convinced of the economic,
environmental, and moral imperatives to ensure that imported food reaches
the same environmental, health and animal welfare standards as food
produced in the UK.
408. The UK’s population does not consume enough fruit or vegetables.
Low national consumption is due, in large part, to issues with the food
environment and the complicated factors which shape consumer choice.
Increasing consumption will therefore require a comprehensive action plan;
this should sit within the National Food Strategy. We have called for actions
that farmers take to enhance and improve public health to be supported
and rewarded under the new Environmental Land Management Scheme.
These measures could include those which work to increase consumption:
local marketing; partnerships with procurers; educational schemes and the
quality and variety of produce.
Impact of food production on the environment

409. Farmers are the custodians of the British countryside. Around 72% of the
land in the UK is used for agriculture.539 UK landscapes and understanding
of those landscapes are shaped and maintained by farming activities. We do
not diminish the importance of this role, nor ignore some of the excellent
examples of good practice from farmers who take their role as countryside
stewards extremely seriously. It is, however, clear that food production can
have significant and negative effects on the environment.
410. The damage is wide-ranging (see Figure 9). Agriculture impacts negatively
on a variety of different environmental measures. It accounts for 10% of
the UK’s greenhouse gas (GHG) emissions, contributes to water and
nutrient pollution, soil degradation, huge usage of water and is: “the major
driver of ecosystem damage.”540 Professor Andrew Balmford, Professor of
Conservation Science at the University of Cambridge, summarised these
impacts, stating that:
“It is important to acknowledge that food production has the greatest
set of impacts on the planet of any human activity by a long way, across
the piece and across different types of impact. Agriculture uses up a
lot of space. It uses up and redirects water. It emits greenhouse gases.
It emits other pollutants. It results in the loss and degradation of soils.
Beyond farming, in fisheries, it also causes direct mortality of creatures.
That means that it has impacts on biodiversity, on climate, on soils,
on flooding, on eutrophication, on the acidity of the oceans, on water
availability and even on sea-level rise”.541
539 Department for Environment, Food and Rural Affairs, Agriculture in the United Kingdom (2018)
file/741062/AUK-2017–18sep18.pdf [accessed 29 June 2020]
411. A report of the EAT-Lancet Commission found that: “Many environmental

systems and processes are pushed beyond safe boundaries by food
production.”542 Professor Tim Benton, Director of the Energy, Environment
and Resources Programme at Chatham House, pointed to the economic
impacts of food production on pollution and ill health. Professor Benton
said: “Defra’s own figures suggest that pollution costs from nitrogen and
phosphate fertiliser are about £5 billion. The carbon cost of agriculture is
about £2 billion at European carbon trading prices. I have not found a good
estimate for how much food waste costs.”543
412. Farming will inevitably have some impact upon the natural environment.
It is possible, however, to significantly reduce these impacts. If the UK is
to achieve a sustainable food system, or to meet the Government’s target to
become a Net Zero economy by 2050, it must do so.
413. One theme to emerge was that, currently, farming systems focus on producing
food as cheaply as possible and that this places costs, or externalities, on
the natural environment. It was suggested that these externalities were
an inevitable outcome of a system which favours low cost food products
over environmental sustainability. Producing food in sustainable ways can
require investment, increase costs and possibly decrease yields. Alongside
the difficulty in farming sustainably, and notwithstanding some instances
of good practice, those who purchase food from farmers are keen to get the
lowest price. A producer who spends their money and time on mitigating
environmental impact may need to raise prices to cover their costs, thus
losing competitive advantages.
414. It is clear that many farmers are themselves keen to ensure that they produce
in a sustainable way, taking care of land and wildlife. We note, for example,
the ambitious target set by the National Farmers’ Union to achieve net zero
GHG emissions by 2040, and the creation of the Nature Friendly Farming
Network. Frustration was expressed at the difficult situation that producers
find themselves in. The Sustainable Food Trust told us that farmers: “are
trapped in an economic paradigm where they have little control of their method
of production, since they understand that farming in an environmentally
damaging way is the only way to make profit.”544 A former dairy farmer who
submitted written evidence had found it extremely difficult to balance the
costs of environmental protections and livestock welfare with the price paid
by a leading retailer for his produce, and had ultimately felt “compelled to
call time on the business”.545
415. The true cost of food production includes the cost that is borne by the
natural environment, which is not included in the price paid for the food by
the purchaser. Philip Hambling, Head of Food and Farming Policy at the
National Farmers’ Union, told us that: “There is an area that has not been
fully cracked as a challenge, which is trying to bring in externalities in the
food system that are not necessarily covered by our traditional economic
model.”546
542 Professor Walter Willet MD, et al, ‘Food in the Anthropocene: the EAT-Lancet Commission on
healthy diets from sustainable food systems’, The Lancet, vol 393, (2019), pp 447–492: https://www.
thelancet.com/journals/lancet/article/PIIS0140–6736(18)31788-4/fulltext
543 Q 82 (Professor Tim Benton)
545 Written evidence from Martin Lovegrove (ZFP0003)
546 Q 88 (Philip Hambling)
Figure 9: Percentages of UK pollution from ammonia and greenhouse

gases derived from agriculture in 2017
Agriculture
87% of UK ammonia
and
I0% of UK GHG emissions
Source: Department for Environment, Food and Rural Affairs, The future farming and environment Evidence
compendium (September 2019): https://assets.publishing.service.gov.uk/government/uploads/system/uploads/
attachment_data/file/834432/evidence-compendium-26sep19.pdf [accessed 29 June 2020]
What is a sustainable food system?

416. A key theme to emerge was that the term ‘sustainable’ is not as simple as
‘environmentally friendly’. We were told that sustainable food systems would
encompass three factors: environmental; social (covering nutrition and health);
and economic (ensuring that agriculture provides a sustainable income for
farmers). Philip Hambling from the National Farmers’ Union referred to
these elements as “the traditional three-legged stool of sustainability”.547
417. If a food system (including both home-grown and imported food) is not
providing for those considerations—for example if the food system is driving
poor health outcomes or is not providing affordable healthy food—then it
cannot be considered ‘sustainable’. Sustainable systems must, therefore:
• Be socially positive. Enough healthy food, including whole grains, fruit

and vegetables, would be available and accessible to all. Diet related ill
health would fall. The NHS and wider society would benefit.
• Be economically viable. Farmers would be able to consistently and

reliably sell produce at a fair price, enabling them to invest in processes
and infrastructure to expand or improve their operations.
• Be environmentally sustainable. Land must be managed to ensure that

it is used appropriately, continues to be viable for food production,
and negative impacts on GHG emissions, water and air pollution
and habitats and biodiversity must be substantially reduced whilst
enhancing carbon sequestration and flood management.
It is crucial that the upcoming National Food Strategy considers all these
factors in conjunction.

418. The evidence we received indicated that the way in which food is currently
produced is environmentally unsustainable and that primary production is
inflicting damage on the natural environment. Generally, ‘environmental
sustainability’ means not compromising the environment for future
generations. Many of our witnesses emphasised that it would be insufficient
to maintain the status quo. Mr Percival for example, emphasised that change
was absolutely necessary: “what we actually need is farming that puts value
back into the system so that it replenishes our soils, brings wildlife back on
to farms, brings more social value than it extracts and helps to resolve the
climate and nature crisis and turn around the dietary ill health trends that
we have seen.”548
The Agriculture Bill

419. We were told that: “Farmers in some cases receive less than the costs
of production making them dependent on other sources of income or
Government subsidies”549; in 2016/17, around 20% of UK farms fitted this
description.550 Subsidies from Government (which were expected to be
worth £2.7 billion in 2017/18)551 predominantly come under direct payments
from the EU’s Common Agricultural Policy (CAP). A 2019 report from the
National Audit Office found that these payments account for an average of
61% of farms’ net profit and without direct payments, 42% of farms would
have made a loss.552 As many of these payments are based on acreage, they
benefit larger holdings.
420. Following the exit of the UK from the EU, the CAP, the framework for most
farming subsidies, will cease to apply. It will be replaced by provisions under
the Agriculture Bill to draw up a new Environmental Land Management
scheme (ELMS) which promises to reward public goods with public money.
These public goods will include: “better air and water quality, higher animal
welfare standards, improved access to the countryside or measures to reduce
flooding.”553
421. Alison Ismail, Acting Director for Agri-Food Chain Directorate, Department
for Environment, Food and Rural Affairs, suggested that the replacement
scheme will effect substantial change:
“Environmental land management will offer the opportunity for farmers
and land managers to produce different kinds of goods, including
environmental public goods. For some of them that may mean moving
away from more traditional agricultural activity and, indeed, may mean
new entrants coming to the market seeking to provide not just, we hope,

549 Written evidence from Martin Yarnit (ZFP0002)
550 Department for Environment, Food and Rural Affairs, Agriculture in the United Kingdom (2018) p
10: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/
file/741062/AUK-2017–18sep18.pdf [accessed 29 June 2020]. This figure encompasses those farms
which failed to make a positive Farm Business Income.
551 Ibid.
552 National Audit Office, Early Review of the new farming programme (5 June 2019) p 8: https://www.nao.
org.uk/wp-content/uploads/2019/06/Early-review-of-the-new-farming-programme-Summary.pdf
553 Department for Environment, Food and Rural Affairs, ‘Agriculture bill to boost environment and
food production’ (16 January 2020): https://www.gov.uk/government/news/agriculture-bill-to-boost-
environment-and-food-production [accessed 29 June 2020]
a full range of environmental goods but potentially different types of

agriculture and horticulture from what we have seen up until now.”554
422. Many of our witnesses spoke about the potential of the Agriculture Bill to
effect positive environmental change. Professor Balmford captured the view
of much of our evidence when he described the Bill and the ELMS as: “very
refreshing and exciting”.555 Although there is, as we discuss in paragraphs
446–455, a significant missed opportunity for the Bill to incentivise and
support improvements to public health, the incorporation of environmental
goods into the list of things for which farmers can be financially rewarded is
certainly a positive step.
423. The Bill provides an historic opportunity to incentivise a host of public
goods, but as Kath Dalmeny said: “Obviously, the detail still has to be
worked out”.556 The Bill outlines high-level aims which ‘could’ be rewardable
under the scheme, but provides very little detail of which measures would
be rewardable, and how these will be determined. Professor Sir Charles
Godfray, Director of the Oxford Martin School and the Oxford Martin
programme on the Future of Food at Oxford University, pointed out that:
“We have not decided what a public good is. Economists will take a technical
definition of what a public good is, and many other people will take different
definitions. We have to have a discussion about what that is.”557
424. British Growers emphasised the current uncertainty, saying that it was
unclear: “how a public good attracting public funding will be defined. It
would be good to see more detail on the definition of a public good and get
an indication of the amount of funding available to support this element of
the future agricultural support system. Without adequate funding it could
become little more than a catchy slogan.”558 The Government says that it is
working with farmers to ‘co-design’ the system, but we are concerned that
the full list of rewardable public goods, is not yet available. A consultation
published in February 2020 on the scheme provided some indication of what
is being considered, but it is clear that much integral information is still
under consideration: the document sets out different tiers of payments but
asks: “What could this tier pay for?”559
425. Our evidence was clear on the need to ensure that this scheme is planned
appropriately because, as we have seen, there is a ripple effect of any change
made to the food system. Professor Balmford was keen to emphasise that
rewarding farmers for producing environmental goods would need to be
tailored in some way and: “coupled with incentivising yield improvements
and yield increases elsewhere within UK farmland”.560 Any effect of changes
in production must be mitigated so that it does not decrease the availability
of food. If, as Alison Ismail said, the ELMS might mean that farmers move
away from traditional agricultural activity, there must be a plan to mitigate
that.

557 Q 87 (Professor Charles Godfray)
558 Written evidence from British Growers (ZFP0090)
559 Department for Environment, Food and Rural Affairs, Environmental land management: policy discussion
(April 2020), p 20: https://consult.defra.gov.uk/elm/elmpolicyconsultation/supporting_documents/
ELM%20Policy%20Discussion%20Document%20230620.pdf [accessed 29 June 2020]
426. We note that the Government’s transition plan includes a commitment

for largely unchanged funding for farmers until at least the end of
the current Parliament. During this time, we urge the Government
to undertake full and transparent consultation when considering
the public goods that will be rewarded under the ELMS.
The need for better metrics

427. If the ELMS is to reward producers for creating environmental goods, it
must be abundantly clear what those public goods are, how to create them,
and how to measure them. Without this clarity, confusion could arise about
targets, farmers could miss out on their payments, (or these payments could
be incorrectly paid), and ultimately, less will be achieved. Mr Percival from
the Soil Association made the key point that targets must be realistic and
practicable. He stated that: “You need to make sure that it is practical and
achievable with no extra burden on farmers”.561
428. Measuring the environmental effects of production methods can be
extremely complicated. We were told, for example, that there were over
50 different models for measuring carbon, designed for different kinds of
enterprises, and that there was “still quite a low degree of agreement on
what constitutes soil health.”562 As it stands, the Agriculture Bill contains no
frameworks to measure the environmental ‘goods’ it intends to reward. The
Soil Association and the National Farmers’ Union agreed that there must
be standardised frameworks in place to measure progress towards public
goods, particularly those identified as rewardable in the Agriculture Bill.563
This is an eminently reasonable request and will allow the UK Government
to circumnavigate a number of predictable pitfalls which would arise from
a lack of standardisation. The Government told us that it will continue to
use current evaluations alongside developing “other scheme indicators and
evaluation frameworks that relate to our 25 Year Environment Plan, Net
Zero and other policy ambition.”564 This work must be completed as soon as
possible.
429. The Government must ensure that every public good outlined in the
Agriculture Bill is accompanied by a standardised framework to
allow measurements and targets to be clear, consistent and easy to
use.
Enforcement
430. It is encouraging that the Agriculture Bill includes provision to ensure
adherence to some environmental standards through a system of conditional
payments. The explanatory notes to the Agriculture Bill state that it
includes: “the ability to establish an enforcement and inspection regime for
the new financial assistance payments including powers to set out terms and
conditions of future financial assistance.”565 It is vital that progress is robustly
and consistently measured, and that this assessment has weight.
431. The Government must ensure that the ability to stipulate conditions
for payments under the Environmental Land Management Scheme

563 Q 92 (Philip Hambling and Rob Percival)
565 Explanatory Notes to the Agriculture Bill [Bill 112 (2019–21)-EN]
is both rigorously and fairly deployed. Where conditions are not

met, enforcement action in the form of withholding payment must
reliably follow.
The case for a dietary shift

432. Our report has already emphasised that, for reasons of public health, there
is a need for a substantial dietary shift. There is another compelling case for
dietary change—the types of food the population currently consumes are
having an extremely detrimental effect on the planet.
433. It was made clear to us that, environmentally speaking, not all diets are
equal. Certain food types have higher negative impacts upon the natural
environment, particularly those arising from ruminant animals such as
cattle and sheep. The dietary change that would deliver the most positive
impact was, we were told, a reduction in meat consumption. Anna Taylor of
the Food Foundation told us that meat consumption was “at the heart of the
issue”. She said that:
“If we can reduce our consumption of animal products, it would provide
a big lever for reducing the greenhouse gas emissions attached to our
diet. It is important to highlight that we are not just talking about moving
away from eating red meat to eating white meat, because we know that
the white meat we eat is fed largely on soy, which in and of itself has a
big land-use footprint.”566
434. A variety of witnesses, including Dr Garnett567, and the Soil Association568
emphasised the environmental benefits of reducing meat consumption. Dr
Morley told us:
“We can be sure that there are certain principles that contribute to a
sustainable diet, such as lower rates of red meat consumption than we
currently have and higher levels of consumption of pulses, alternative
forms of protein and vegetables. There is consensus around what a
sustainable diet looks like.”569
435. This evidence, calling for a decrease in meat consumption, is in line with calls
from a variety of organisations. In January 2020 the Committee for Climate
Change called for the consumption of beef, lamb and dairy, to be reduced by
at least 20%.570 Similarly, the EAT-Lancet Commission’s ‘Planetary Health
Diet’ favours smaller amounts of meat and dairy.571
436. Some evidence has indicated that a change in the nation’s diets could deliver
both health and environmental improvements. Academic research on the
environmental implications of nationally recommended diets (which may
involve a reduction in red meat and dairy) found that national adherence

568 Written evidence from the Soil Association (ZFP0016)
570 Committee on climate Change, ‘Land use: Policies for a Net Zero UK’ (January 2020), p 9: https://
www.theccc.org.uk/publication/land-use-policies-for-a-net-zero-uk/ [accessed 29 June 2020]
571 Eat Forum, The Planetary Health Diet and You: https://eatforum.org/eat-lancet-commission/the-
planetary-health-diet-and-you/ [accessed 30 June 2020]
could reduce food related GHG emissions by up to 17%.572 Professor Balmford

referred to a comprehensive study of different health and environmental
impacts which found that: “foods that were good for the environment
tended to be good for people as well.”573 Dr Garnett agreed that there was
a correlation between healthy and environmentally sustainable diets but
emphasised the need for careful planning to ensure that both outcomes were
achieved. She described the double benefit of a dietary change as “possible
but not inevitable. It is an arranged marriage rather than a love match.”574
437. We agree with Dr Garnett’s view on careful planning. A reduction in
meat consumption could have significant environmental and nutritional
implications, which must be considered carefully. Issues include:
• Residence times of GHGs in the atmosphere;
• Land use and carbon storage;
• The relative environmental and health impacts of different kinds of

meat;
• The nutritional value of meat and dairy;
• Available alternatives (including the development of new artificially

designed proteins)575 and their cost and consumer acceptability; and
• The environmental implications of producing alternatives to meat and

dairy.
438. Henry Dimbleby warned us that: “it is almost impossible to act on [the
food system] in any way without creating winners and losers”.576 This is
undoubtedly true but in no way represents an argument for inaction. It
appears clear that a move towards a more plant-based, balanced diet, is
becoming an increasingly pressing environmental imperative. In order
to achieve this, the Government must carefully work through the health,
social and environmental implications (including for biodiversity) of a move
towards a more plant-based, balanced diet which balances environmental
and health considerations.
439. In order to protect the natural environment and public health,
there is a need for a fundamental shift in national consumption
patterns towards a more plant-based, balanced diet in line with the
recommendations of the Government’s Eatwell Guide.
440. The Government’s White Paper on the National Food Strategy must
include a definitive outline of what constitutes a sustainable diet
with regards to health, social and environmental impacts. It must
572 Paul Berhens, Jessica C. Kiefte-de Jong et al, ‘Evaluating the environmental impacts of dietary
recommendations’, Proceedings of the National Academy of Sciences of the United States of America, vol
114 no 51, (December 2017), pp 13412–13417: https://www.pnas.org/content/114/51/13412. See also:
Carbon Brief, UK could cut food emissions by 17% by sticking to a healthy diet, (December 2017): https://
www.carbonbrief.org/uk-could-cut-food-emissions-17-per-cent-by-sticking-to-healthy-diet [accessed
30 June 2020]
575 RethinkX, Rethinking Food and Agriculture 2020–2030, (September 2019): https://static1.
squarespace.com/static/585c3439be65942f022bbf9b/t/5d7fe0e83d119516bfc0017e/1568661791363/
RethinkX+Food+and+Agriculture+Report.pdf [accessed 30 June 2020]
be accompanied with a graded action plan and communications

strategy to move towards this diet.
Food production and public health

441. A key question for our inquiry was how actors at every level of the food
system can be empowered to help make healthier diets more accessible to
all. It is clear that a major goal should be increasing the consumption of fruit
and vegetables across all sectors of society. Figures from the 2018 National
Diet and Nutrition survey indicated that: “only 31% of adults … and 8%
of teenagers meet the 5 A Day recommendation for fruit and vegetables.”577
This rate falls among those in lower-income brackets578, so a deficiency in
fruit and vegetable consumption is not only a crucial weakness in the nation’s
diets, but a factor in health inequalities.
442. There were strong calls in our evidence for a strategy or an action plan to
increase production and consumption of fruit and vegetables in the UK.
Anna Taylor for example, when asked for her key policy suggestion, argued
for a: “comprehensive strategy for driving up fruit and veg consumption
right the way from production, the horticultural end, to consumption and
advertising.”579 Suggested interventions work either to increase what we
have viewed as ‘the demand side’, or to address problems on ‘the supply
side’. Many of our witnesses were keen to argue that the food system is to a
large extent, driven by demand. Dr Adrian Morley argued for example that
necessary consumption shifts: “will be achieved only by shifting consumer
demand”.580
443. Both the 2010 report of the Fruit and Vegetables Task Force581 and a 2020
report by the Food Foundation582 identified that reform of public messaging
programmes, better practise in marketing, changes to the Healthy Start
scheme, and support for education schemes would increase consumption of
fruit and vegetables. These suggestions tally with what we have learnt about
the food environment, outlined in Chapter 4 of this report.
444. We are hopeful that, with appropriate governance and sufficient commitment
(issues we address in Chapter 7), the National Food Strategy can take the
proposals for increasing fruit and vegetable consumption forward and
develop them into concrete actions. There should be a dedicated section in
the review addressing this topic.
445. The National Food Strategy should outline a comprehensive action
plan to increase the demand for and consumption of fruit and
vegetables.
577 Public Health England, PHE publishes latest data on nation’s diet, (16 March 2018): https://www.gov.uk/
government/news/phe-publishes-latest-data-on-nations-diet [accessed 29 June 2020]
578 The Food Foundation, Food system challenges: https://foodfoundation.org.uk/food-system-challenges/
581 Fruit and Vegetables Task Force, Report of the Fruit and Vegetables Task Force (August 2010): http://
www.appg-agscience.org.uk/linkedfiles/Fruit%26VegTaskForceReport.pdf [accessed 29 June 2020]
582 The Food Foundation, Veg Facts 2020 In Brief (10 June 2020), p 10: https://foodfoundation.org.uk/
wp-content/uploads/2020/06/Pease-Please-Veg-Facts-2020-In-Brief-spreads-1.pdf [accessed 29 June
2020]
Financial support for horticulture

446. At the moment, only 1.9% of UK land is used to produce fruit and vegetables.583
The Government told us that in 2018, 53% of marketed vegetables were
produced in England and that the figure for home-produced fruit was at
16.7%.584 Shirley Cramer referred to one report which found that if all
suitable land in England was used to grow fruit and vegetables we “could by
2030 have 18,000 fewer deaths from cardiovascular disease.”585
447. Several witnesses suggested that horticulturists should benefit from a
specific subsidy to be incorporated within the Agriculture Bill. The idea
is that by providing additional funding to fruit and vegetables, farmers
could increase the supply, and this would feed through the supply chain and
increase consumption. Nourish Scotland stated that there is: “huge potential
for much more high quality, nutritious food to be grown by smaller scale
farmers—currently excluded from any advice or assistance due to being
below the minimum land requirement for the Basic Payment Scheme.”586
Kath Dalmeny proposed a national programme for “subsidising fruit and
vegetable production, or at least supporting more land for that kind of use
and perhaps more entrants to small-scale horticulture, diverse crops and
all those kinds of things” and stated that this would: “give ingredients to a
food industry that would then make good use of subsidised ingredients that
bear health in them.”587 Philip Hambling of the NFU told us that: “there is
certainly an opportunity for UK agriculture and horticulture to be part of a
solution to deliver healthy fruit and veg for the nation.”588
448. We note that, historically, subsidy schemes have excluded horticulturists—
aside from the legacy Fruit and Vegetable Aid Scheme, they have largely been
left to stand on their own financial feet. On average, in 2018/19, horticulture
farms received just over 1% of their income from subsidies, compared to 11%
for all farm types.589
449. Some contributors felt that the Agriculture Bill presented an opportunity
to rectify this shortfall and reward famers for measures that would improve
public health. Sustain, for example, has proposed that measures which
“increase the availability, affordability, diversity, quality and marketing of
fruit and vegetables and pulses”590 could be rewardable under the ELMS
proposed by the Bill.

585 Q 63 (Shirley Cramer). Ms Cramer was referring to Paraskevi Seferidi, Anthony a Laverty, Brendan
Collins et al, ‘Potential impacts of post-Brexit agricultural policy on fruit and vegetable intake and
cardiovascular disease in England: a modelling study’, BMJ Nutrition, Prevention & Health (2019):
https://nutrition.bmj.com/content/early/2020/01/14/bmjnph-2019–000057 [accessed 30 June 2020]
589 Department for Environment, Food and Rural Affairs, Farm accounts in England—Dataset (December
2019): https://www.gov.uk/government/statistics/farm-accounts-in-england. Based on analysis of
tables 5.17 and 5.23. [accessed 29 June 2020]
590 Sustain, ‘Public Health and Agriculture Policy: Why we need a new clause linking public health
and farming’ (October 2018) p 1: https://www.sustainweb.org/resources/files/other_docs/Public%20
health%20amendment%20briefing%20on%20Agriculture%20Bill.docx [accessed 29 June 2020]
450. This could be interpreted to mean area-based or blanket subsidies to

incentivise increased growth of fruit and vegetables. There are, however,
some limitations to this simple subsidy approach:
• The quantity of fruit and vegetables grown in the UK is not necessarily

the limiting factor in consumption. Given the many barriers we
identified to a healthy diet in Chapter Four, we believe that subsidising
production would be unlikely to solve many of the accessibility problems
that prevent people from eating the recommended quantities of fruit
and vegetables. Henry Dimbleby felt that subsidising producers was
likely to be ineffective:
“If you look at the total environmental subsidy of £3.4 billion, that is
£50 per household, but if you put all your subsidies into veg I do not
think you are going to get people eating more veg. I do not think that is
going to do it. There might be areas where you can encourage it and that
you could link, but I do not think putting it in at the production end is
going to work.”591
• Another argument against directly subsidising the production of

fruit and vegetables in the UK is that the use of natural capital to
increase food production in the UK might backfire by driving further
environmental degradation and: “make things worse generation by
generation”.592 Growing non-indigenous fruit (aside from apples, the
most popular fruits—bananas, oranges and grapes—are not generally
grown in the UK), is more resource intensive. Analysis from the Food
and Climate Research Network found that much overseas grown
produce transported by sea was fairly low in greenhouse gas intensity.
It argued that growing all fruit and vegetables in the UK “is unlikely
to be ‘the’ optimal answer since there are trade offs between import-
related transport and mobile cold storage emissions on the one hand
and waste and stationary cold storage emissions through the storage of
indigenous food on the other.”593
• There are concerns around the availability of labour to harvest these

plants. Given the reported shortage of farm labourers in the weeks and
months following the outbreak of COVID-19,594 and the impending
exit from the European Union, it is possible that subsidies which do not
address labour shortfalls are likely to be ineffective.
• There is some opposition in the agricultural industry towards fruit

and vegetable subsidies. British Growers told us that they would prefer
action by supermarkets and consumers and that: “the fresh produce
industry would prefer to operate without subsidies which it believes can
have a distorting effect”.595
451. The Government’s written evidence told us that the Agriculture Bill could
provide support to help growers increase the productivity of fruit and vegetable

593 Tara Garnett, Centre for Environmental Strategy, University of Surrey, Food and Climate Research
Network, Fruit and vegetables and UK Greenhouse Gas emissions: exploring the relationship (22 September
2006) p 7: https://fcrn.org.uk/sites/default/files/fruitveg_paper_final_0.pdf [accessed 29 June 2020]
594 ‘Coronavirus: Furloughed staff replace overseas farm workers’, BBC News (15 April 2020): https://
www.bbc.co.uk/news/uk-england-hereford-worcester-52294856 [accessed 29 June 2020]
production.596 If properly managed to ensure that they do not cause further

damage to land, animal welfare or biodiversity, increases in productivity are
welcome.597 Consideration of the issues outlined here suggests however, that
a simple subsidy for horticulturists (whether a blanket subsidy or one based
on acreage) may be an ineffective mechanism to increase the consumption of
fruit and vegetables.
452. There is flexibility in the Agriculture Bill as to how farmers could be
supported598, and if the Bill were to enable rewards for some measures to
improve public health, farmers could be incentivised, enabled and supported
to increase demand for fruit and vegetables. These measures could include
but are not limited to:
• Facilitating educational visits (including visits to and from schools);
• Measures to increase the quality and diversity of fruit and vegetables;
• Measures to promote fruit and vegetables. This could take the form
of general marketing, or running events in partnership with local
organisations or local authorities; and
• The formation of partnerships with procurers. In this area, Government

support in changing wider procurement frameworks and guidelines
are likely to be most effective, but other forms of facilitation, such as
guarantees or loans, could play an important role.
453. In the list of activities eligible for financial assistance, the Agriculture Bill
includes “supporting ancillary activities carried on, or to be carried on, by
or for a producer”599 and the explanatory notes state that this could include
financial assistance for support to selling or marketing activities. Given
the potential for horticulturists in particular to improve public health, we
recommend that agricultural policy in general recognises and rewards this.
Specifically, the Agriculture Bill should identify public health as a financially
rewardable ‘Public Good’ and the measures we have listed above as activities
eligible for financial assistance.
454. Rewarding and supporting farmers in increasing demand for fruit and
vegetables could increase consumption. Simple economics would suggest
that increasing demand will eventually increase supply; if there is a market
for produce, farmers will grow it.
455. We recommend that Government should list Public Health as a
‘Public Good’ under Clause One of the Agriculture Bill. Measures
eligible for financial assistance to improve public health should be
focussed on (but not necessarily limited to) those activities which
increase demand for fruits and vegetables.
Resilience and continuity of supply

456. Throughout our inquiry, we considered whether it was desirable to produce
more food in the UK. The Government told us that, in 2018, the UK had
53% of home-produced marketed vegetables and 16.7% of home-produced
597 See paragraphs 484–488.
598 Agriculture Bill, Clause 2 [Bill 112 (2019–21)]. The bill allows for farmers to be supported by way of
“grants, loan, guarantee or in any other form”.
599 Agriculture Bill, Clause 1
marketed fruit.600 A model where more of the UK’s food was produced ‘in-
house’ could support smaller producers, enhance animal welfare standards,
reduce air-miles and increase resilience to global shocks that disrupt food
supply. In addition, Henry Dimbleby’s consultation found that there was
a strong emotional desire for localised production: “The one thing that
everyone seems to share is the idea that they want their food to be nearby …
There is a very strong sense of us as a food-growing nation”.601
457. Of the utilised agricultural area in England, only around 0.3% is used for
growing fruit crops602, which might suggest the potential for using more
land for growing important crops. The Government has acknowledged this:
“There is potential that the UK could increase its home-produced marketed
share and it is likely that the industry would be keen to do this”.603 There
was some suggestion that producing more ‘in-house’ could increase the
consistency of national supply. Professor Benton stated: “Under a resilient
food system, there is a much more natural argument to have a discussion
about how much we produce at home versus relying on importing.”604
458. Another point that was raised by Henry Dimbleby was that trading is crucial
for ensuring resilience in the food system “because it protects us from bad
harvests”.605 The Government also argued that many products cannot be
produced in the UK, and that supply would fail to meet demand for year-
round access to certain foods.606
459. The empty shelves in supermarkets and the unpicked food in fields following
the outbreak of COVID-19 demonstrate that there are certainly discussions
to be had about the resilience of the food supply. A House of Lords Select
Committee recently urged the Government to develop a comprehensive food
security policy for the UK.607 We are inclined to support this recommendation
and are hopeful that the upcoming National Food Strategy will address this
important piece of work.
Trade
460. Following Britain’s exit from the European Union, the Government’s
decisions about trade policy with regard to food have the potential to enhance
food security through a strong and resilient agricultural sector. Trade in this
sector could deliver a healthier diet, continue the UK’s strong record on
high animal welfare standards, encourage sustainable practices elsewhere,
and support the broader agri-environment.
461. Trade featured in many of our discussions and much of our evidence.
There was strong agreement that, whatever environmental standards are
implemented following Brexit, trade arrangements must support these

602 Department for Environment, Food & Rural Affairs, Farming Statistics: Land Use, Livestock Populations
and Agricultural workforce at 1 June 2019 : England (October 2019) p 5: https://assets.publishing.service.
gov.uk/government/uploads/system/uploads/attachment_data/file/868945/structure-jun19-eng-
28feb20.pdf [accessed 29 June 2020]. Small fruit and orchards account for 32,000 hectares , 0.35% of
the total utilised agricultural area (9 million hectares).
607 European Union Committee, Brexit: food prices and availability (14th Report, Session 2017–19, HL
Paper 129)
standards rather than undermine them. Several of our witnesses spoke of the
need to apply the same environmental standards to imports as are applied
to food produced in the UK. This is partly a competitive requirement for
British farmers who may otherwise be undercut by cheaper food produced
with lower environmental standards, and partly a moral imperative not to
encourage poorer standards elsewhere. Dr Garnett said: “We cannot export
or import the problem”.608 Evidence from British Growers emphasised that:
“The UK needs to guard against ‘off shoring’ production in the interests
of keeping prices low but without proper concern for the impact on the
environment in those countries exporting produce to the UK.”609
462. If trade agreements allow for the import of cheap food, produced according
to lower environmental standards, this would put UK producers at a
competitive disadvantage; they would be internalising the costs of food
production to the environment, while the producers of the imports would not
be doing so. Nothing in the Agriculture Bill as it stands would prohibit this.
Professor Benton argued that this would: “undercut the profit margins of our
farmers”, potentially leading to the loss of many smaller or less intensively
producing farmers.610 The Nature Friendly Farming Network agreed. It
emphasised that: “The risks posed by a model that allows environmentally
sensitive farmers in the UK to be ‘undercut’ by cheap, damaging imports
are numerous and could see the loss of many of our most environmentally
beneficial farmers.”611 Another possible scenario is one where UK farmers
are compelled to lower their production standards on sustainable farming,
safety, and animal welfare in order to remain competitive.
463. There was also serious concern that access to cheaper food (which may be
produced with lower environmental protection or animal welfare standards)
would: “undercut our ability to do everything else we want to do in this
space”.612 If we are, as a nation to aim to encourage sustainable production,
then it stands to reason that we ought to ascribe: “the same values that we
ascribe to production in the UK through trade and procurement policy.”613
The very least the Government can do to protect British producers and
the natural environment is to import food products following the same
standards as applied in the UK. The Food Ethics Council has estimated that
since: “70% of the UK’s environmental food footprint is based overseas”,614
there is an obligation to support sustainable growing and production in
other countries. This could be achieved by requiring the same levels of
environmental integrity from imported products as those produced in the
UK.
464. There could also be health implications in importing food made to different
health and safety specifications. When asked whether retailers would rule
out importing food made to lower safety standards, Mr Opie from the
British Retail Consortium and Ms Batchelar from Sainsbury’s focussed
on consumer acceptability, stating that they did not anticipate consumers
lowering their standards. We are, however, concerned that if food produced
to lower health and safety standards can be imported cheaply, some retailers

611 Written evidence from the Nature Friendly Farming Network (ZFP0089)
614 Written Evidence from the Food Ethics Council (ZFP0054)
will sell it. Not all consumers would necessarily buy food produced to lower
health standards, but if it were available more cheaply, the most vulnerable
in society may not be able to avoid it.
465. We understood that the requirements to import only food that meets current
UK standards on environmental, health, and animal welfare standards will
be difficult to achieve. One difficulty arises when we consider the differing
priorities of Government Departments. We were told by Henry Dimbleby that:
“DEFRA and Trade have very different objectives in our trade negotiations
with other countries. There is a constant running battle between BEIS and
Health on proper regulation of retailers and food producers.”615 We recognise
the difficulties inherent in this, but it is crucial that the Government obtain
the right trade deals for the future.
466. In a joint letter to MPs and Peers, dated June 5 2020, the Secretary of State
for International Trade, the Rt. Hon. Elizabeth Truss MP, and Secretary
of State for the Department for Environment, Food and Rural Affairs, the
Rt. Hon. George Eustice MP, stated that in all of its trade negotiations, the
Government “will not compromise on our high environmental protection,
animal welfare and food standards.”616 The same phrase was used in the
Government’s evidence to our inquiry which added: “We are committed to
supporting global decarbonisation and we are clear that trade will not come
at the expense of the environment.”617 It is unclear at the time of writing how
the Government intends to honour these commitments.
467. When asked in a House of Lords debate about trade deals which could
allow imports farmed to less rigorous standards, Lord Agnew of Oulton, the
Minister of State at the Cabinet Office and Treasury stated that: “there has
to be a balance between keeping food affordable… to ensure that they are
able to eat healthily, while not undermining in any way the quality of the
food we eat.”618 This statement falls far short of the commitment we were
told was necessary: to refuse to export the problem.
468. An amendment to the Agriculture Bill which aimed to ensure that future
imports adhered to the same standards of environmental and animal welfare
protection as is mandated in the UK was defeated in the House of Commons
on 15 May 2020.619
469. Food imports must be required to adhere to the same health,
environmental and animal welfare standards as food produced
in the UK. To fail to do so would make a mockery of our stated
environmental values, and irrevocably undermine British
producers. The Government must set out how it intends to ensure
that current standards are maintained in future trade agreements,
and what safeguards will be in place to guarantee this.

616 Letter to MPs and Peers from the Rt. Hon. Elizabeth Truss MP, and Secretary of State for the
Department for Environment, Food and Rural Affairs, the Rt. Hon. George Eustice MP, 5 June 2020.
Letter referred to by Lord Gardiner of Kimble, Parliamentary Under-Secretary of State, Department
for Environment, Food and Rural Affairs, HL Deb, 10 June 2020, cols 1753-1754.
618 HL Deb, 6 May 2020, col 518
619 HC Deb, 13 May 2020, cols 276–339
Production efficiencies
470. We were also told that farming practices could be made substantially more
productive and efficient, and that farming that uses fewer resources or less
land to produce the same or higher yield could be more environmentally
sustainable. Professor Balmford explained this to us in terms of land use:
“Any systems that are relatively low yielding tend to have disproportionate
impacts. In order to produce the same amount of food, you need a larger
area, so the [negative] impacts tend to be greater.”620 The aim is to increase
efficiency, which Dr Garnett described as: “producing more with less, more
with the same amount or more with only a little bit more.”621 A more efficient
system could have a reduced environmental impact and could potentially free
up resources to be used in the production or preservation of environmental
goods.
471. We were warned that, while production efficiencies can be positive, other
needs must also be considered to ensure that this does not lead to negative
consequences. Dr Garnett said: “If we are producing more food that is
making more people fatter and sicker, that is not necessarily a result.”622
Henry Dimbleby raised the example of a low-carbon cattle farm: “The most
carbon-efficient systems are the feedlots of the United States. By feeding a
cow hormones and keeping its life as short as possible by growing it quickly,
you reduce the methane emissions, but that obviously has implications for
animal welfare and health.”623
472. Ideally, farming ought to be as efficient as is possible without undermining
environmental or animal welfare considerations. We were told that technology
holds some potential for enabling this shift. Witnesses also, however,
identified a number of barriers to the development of the technology which
could increase production efficiency without damaging the environment.
These included that:
• There has been, effectively, a “brake” on R&D investment in agriculture

over the past 20–30 years, causing a “plateauing of yields in some
areas”;
• There has been considerable investment uncertainty in the last few

years; and
• There is limited clarity on the ‘vision’ for sustainable agriculture
Research and Development

473. Some evidence discussed the potential of research and development (R&D)
in enabling production efficiencies.624 The Government recognised that
technological advances in AI, data and robotics were key to: “unlock the
potential of farming by improving productivity … we can also use our
resources more sustainably and reduce environmental impact.”625 There
has been some investment in agricultural technology towards this aim. The

622 Ibid.
624 Written evidence from the Crop Protection Association (ZFP0021), UK Research and Innovation
(ZFP0039) and the Food and Drink Federation (ZFP0009)
2013 Agri-Tech Strategy dedicated £160 million to support R&D626 and

the Industrial Strategy Clean Growth challenge supported programmes to
stimulate the use of low carbon technologies. This includes the £90 million
‘transforming food production’ challenge fund (operated through UK
Research and Innovation) which largely focusses on precision agriculture.627
Countryside Productivity Grants provide funding for projects focussed on
improvements to farming productivity. 628
474. There was some suggestion that there had been a brake on R&D investment.
Professor Balmford told us that: “technologists would tell us that there has
been a brake on R&D investment in agriculture over the past 20 or 30 years,
which is playing through into a plateauing of yields in some areas.”629 This
was not widely echoed within the evidence we received, and there are several
avenues of funding available. The inclusion of a technological ‘good’ in the
Agriculture Bill is also a positive step. Funding must, however, be reliable
and predictable in order to drive progress.
475. One concern that was raised within the evidence around investment in R&D
was that for too long it has been inconsistent and unpredictable. One example
of Government inconsistency in funding was the coalition Government’s
2015 Food Enterprise Zone Scheme. This scheme provided grants to:
“unleash the entrepreneurial spirit of the countryside and food producers”630
but according to Martin Yarnit, a Churchill fellow, the funding was limited
and, eventually, “quietly parked”.631
476. Progress in the development of impactful technologies can be slow and
sometimes expensive. In order to make meaningful strides, funding needs to
be predictable: it must not be introduced and then withdrawn. This applies
on a large scale, in research and development to produce technologies, and
on a smaller scale, on individual farms using technologies and infrastructure.
477. New ways of producing food such as vertical farming632 and the development
of meat-free proteins have great potential to fundamentally change the way
food is produced: support and funding for research and development must
not exclude these non-traditional forms of food production.
478. The Government must provide sufficient and stable funding for
research and development into agricultural technology and new
ways of farming if sought after progress in increasing farming
efficiency is to be made.
479. We were told that uncertainty and inconsistency in Government budgets
prevented producers from making their own investments. Farmers, who may
626 Department for Business, Innovation & Skills, £160 million technology boost for UK agricultural
industries (22 July 2013): https://www.gov.uk/government/news/160-million-technology-boost-for-uk-
agricultural-industries [accessed 29 June 2020]
627 UK Research and Innovation, Transforming food production: https://www.ukri.org/innovation/
industrial-strategy-challenge-fund/transforming-food-production/ [accessed 29 June 2020]
628 Department for Environment, Food & Rural Affairs, Countryside Productivity Scheme (27 March 2020):
https://www.gov.uk/guidance/countryside-productivity-scheme [accessed 29 June 2020]
630 Department for Environment, Food and Rural Affairs, Food Enterprise Zones created to drive growth,
(12 February 2015): https://www.gov.uk/government/news/food-enterprise-zones-created-to-drive-
growth [accessed 30 June 2020]
631 Written evidence from Martin Yarnit (ZFP0002)
632 Vertical farming is the practice of growing crops in vertically stacked layers and often incorporates
controlled-environment agriculture.
consider investing in physical infrastructure or better farm operations may

be reluctant to do so without knowing the direction of travel or what the
budgets might be in the next decade. Philip Hambling from the NFU stated
that: “multiannual budgeting is really welcome for long-term investments.
Nothing in agriculture happens in a short space of time. That consistency
is key.”633 Mr Percival from the Soil Association agreed, arguing that the
Government must: “provide the long-term reassurance that farmers need to
invest in strategic changes. We need multiannual budgets and clarity about
the long-term direction of travel in policy.”634
480. We were pleased that the Government intends to: “support farmers to
invest in equipment, technology and infrastructure to help to improve their
productivity, as well as deliver environmental benefits.”635 A key part of this
support must be a stable policy environment where funding and investment
from Government is predictable; uncertainty and inconsistent funding is
chilling to the long-term planning and innovation we were told is crucial to
increasing productivity and protecting the natural environment.
481. The Agriculture Bill will require the publication of multi annual financial
assistance plans and require the Secretary of State to have regard to the
priorities therein when determining financial assistance budgets or schemes.636
This is necessary, but not enough. The Nature Friendly Farming Network
emphasised the need for “Greater certainty about long-term funding under
the Bill. We welcome additions to the Bill that require Ministers to establish
a multi-annual financial assistance plan, but we would like to see these
plans strengthened.”637 As it stands, the publication of financial assistance
plans only requires an outline of strategic priorities and “such detail as the
Secretary of State considers appropriate”.638 This is, we suggest, inadequate,
and adds to our concern that the Bill may not offer sufficient guarantee of
the information or the long-term surety that farmers will require to make
investment decisions.
482. The policy environment for farming has often been insufficiently
stable to enable individual farmers to make investment decisions on
improving efficiency or on the use of agricultural technology.
483. The Government must ensure that the multi-annual financial
assistance plans to be published under the Agriculture Bill are stable
and not subject to substantive change: providing a sufficient amount
of detail to allow farmers to make investment decisions.
Agroecology
484. Whilst agricultural technologies and investment in research and development
present great potential for efficiencies, Government must be clear that any
increase in productivity must not compromise biodiversity, animal welfare,
human health, or the ability of land to continue producing food for the
future. Dr Garnett told us that:

637 Written evidence from the Nature Friendly Farming Network (ZFP0089)
“In itself, it is not a bad goal, but efficiency is a ratio and therefore has
no boundary. We live in a world with limits—environmental limits of
many kinds—so we have to think about these technologies partly in the
context of limits and partly in the context of what our end goals are.”639
485. We were told that investment in research and development and new
technologies must include consideration of the possibilities of agroecology,
which incorporates ecological considerations into agriculture. Increases in
productivity must not come at the cost of environmental damage. There
was some debate for instance, around conserving (or in some cases, re-
introducing) wildlife in the natural environment. The majority of our
witnesses argued that a model which enabled existing farms to enhance
nature on their land by, for example, introducing ponds and planting hedges
at boundaries, would be a positive first step. This could have the double
benefit of reducing the net emissions of carbon dioxide. A January 2020
report by the Committee on Climate Change stated that an increase in tree
planting by at least 17% was necessary if the UK was to achieve the target set
to produce net zero emissions by 2050.640
486. A different approach would be to intensively farm some pieces of land and
leave some land unfarmed to allow the development of wildlife and habitats.
Professor Balmford suggested concentrating food production in particular
areas: “Then in other parts, perhaps within the same landscape, we could
have large-scale areas set aside for the ecosystem services that we rely on for
nature.”641.
487. It was not for us to determine between this approach and the land ‘sharing’
approach outlined in paragraph 485. It is only one example of where the ‘end
goal’ must be carefully considered. We are clear that there is a balance to be
struck, where new agricultural technology can allow for a more productive
and efficient use of land, without undermining the natural environment or
biodiversity.
488. Any investment in or policy change related to farming productivity,
including investment in agricultural technology or land use must
take account of the imperatives to avoid undermining the ability to
produce food in the future, and to protect biodiversity and animal
welfare.
Food industry reporting

489. There is huge untapped potential for industry bodies—including retailers,
caterers and manufacturers—to encourage sustainable production practices
by raising internal procurement standards. It is discouraging that, aside from
a few examples of good practice,642 this is not yet happening. In the absence of
responsible industry behaviour, the Government could encourage a ‘race to
the top’ by mandating bodies to report on their sustainability performance.

640 Committee on Climate Change, Land use: Policies for a Net Zero UK, (23 January 2020): https://www.
theccc.org.uk/publication/land-use-policies-for-a-net-zero-uk/ [accessed 30 June 2020]
642 For example, the sustainable fishing practices outlined in written evidence from Sainsbury’s
(ZFP0034).
490. A Food Foundation Report was highly critical of gaps in reporting on some
sustainability and health metrics, most of which are voluntary.643 Some of
our evidence argued for a consistent and mandated sustainability reporting
regime. Requiring data from local businesses such as supermarkets, large
processors and large public procurers could encourage more pro-sustainability
behaviour in supply chains and would provide a way of holding the industry
to account. This data could be publicly available to NGOs, Government
and, crucially, consumers. There is a possibility that this reporting would
encourage a race to the top, with industry competing–if not to be the best,
then at least to avoid being labelled the worst.
491. Dr Morley highlighted the “importance of data and mandating reporting
from the food system”644 as a key priority. He told us that: “if we can mandate
certain parts of the food system to report different sustainability metrics and
incentivise other smaller businesses to do the same, it would go a long way
towards identifying a route to manage the transition to a more sustainable
food system.”645
492. Supermarkets, public procurers, and manufacturers could be required to
publish a measurement of performance against a variety of relevant metrics.
These could include (among many others): carbon impact, food waste, the
use of water-stressed regions, the percentage of products produced under
sustainable production practices, the percentage of products certified to
high animal welfare standards, the price of a basket of sustainably produced
basics and the price of a basket of healthy basics.
493. Government must implement a mandatory reporting regime for
adherence to clear and consistent sustainability and health metrics,
as well as adherence to procurement standards. This should apply
to all supermarkets, major food and drink manufacturers, public
procurers and their contracted suppliers, and food outlets.
Food waste
494. Food production produces waste at every stage: both pre and post-farm gate.
Dr Morley told us that: “between a third and perhaps a half of all food that
is produced does not get to its end consumer.”646 Steve Butterworth, CEO of
Neighbourly, stated that: “if global food waste was a country it would be the
third largest contributor to the climate crisis in CO2 emissions globally, after
the US and China.”647
495. British Growers told us that the demand (from retailers and consumers) for
consistent supply and ‘perfect’ produce means that farmers often cannot
avoid food wastage.648It is another example of farmers being trapped in the
‘economic paradigm’ discussed in paragraph 414. Clearly, this is a problem
that cannot be resolved by Government alone, it will require a shift in retailer
behaviour.
643 The Food Foundation, Plating Up Progress: Part 2, ‘Must-Have’ Metrics, (September 2019): https://
foodfoundation.org.uk/wp-content/uploads/2019/08/Plating-up-Progress_Report2_DIGITAL.pdf
[accessed 30 June 2020]. Voluntary disclosures are often assisted by the work of the Carbon Disclosure
Project and often include reports on GHG emissions, energy use and contribution to deforestation.
645 Ibid.
647 Q 50 (Steve Butterworth)
496. Efforts to reduce food waste have largely focused on food waste that occurs
after the food has left the farm (post-farm gate). In 2016 the DEFRA-backed
Waste and Resources Action programme (WRAP) launched the Courtauld
Commitment, a voluntary agreement with a target to reduce post-farm gate
food waste by 20% per capita.649 The Government, however, told us that
progress towards cutting food waste has “plateaued”650 in recent years. The
Government’s evidence to the Committee pointed to its 2018 Resources
and Waste Strategy,651 and highlighted two separate attempts to redistribute
surplus food: the appointment of a champion, and the introduction of a
£15 million fund for the redistribution of surplus food.652
497. The Sustainable Food Trust (SFT) called for more concerted effort on
waste. They argued for a new ambitious target which would include pre-
farm gate food waste. “In line with SDG 12.3, the SFT believes that the UK
Government should cut food waste per capita by 50% before 2030, starting
from post-harvest losses and going through production and supply, all the
way to consumption.”653
498. The tight specifications on the shape and size of produce that can be sold
and the practise of overproduction mean that farmers are compelled to
throw away a substantial amount of produce. Evidence from British Growers
argued that: “the big issues for growers is around retailer programming”.
They gave the example of lettuce production which must be grown to meet
possible demand but “can’t be turned off” if demand reduces as a result of
cold weather or other factors which may influence consumer demand.654
499. The House of Commons Environment, Food and Rural Affairs Select
Committee recommended that retailers should relax quality standards to
allow “wonky vegetables”655 as part of their main range to avoid the situation
where good food is thrown away because it does not fit narrow supermarket
specifications. We endorse the 2014 findings of the House of Lords European
Union Committee which recommended renewed effort by businesses to
promote cooperation and shared financial responsibility for food waste early
in the supply chain. They said efforts should, amongst others, include:
“careful consideration of contractual requirements in the sector,
including much wider use of long-term contracts and ones where the
relationship between different ends of the supply chain does not encourage
overproduction; the encouragement of whole-crop purchasing; and
improvements to forecasting.”656
500. The Environment Bill rightly includes provision to reduce household food
waste. It also enables the Government to introduce producer responsibility
649 WRAP, ‘The Courtauld Commitment 2025’: https://www.wrap.org.uk/food-drink/business-food-

waste/courtauld-2025 [accessed 29 June 2020]
651 Department for Environment, Food and Rural Affairs, Resources and waste strategy for England (18
December 2018): https://www.gov.uk/government/publications/resources-and-waste-strategy-for-
england [accessed 30 June 2020]
655 Environment, Food and Rural Affairs Committee, Food waste in England, (Eighth Report, Session
2016–17, HC 429)
656 European Union Committee, Counting the Cost of Food Waste: EU Food Waste Prevention (10th Report,
Session 2013–14, HL Paper154)
schemes in the future under the polluter pays principle.657 We welcome these
inclusions but there is limited focus on food waste which can arise before the
food leaves the farm (“pre-farm gate”). The Courtauld targets account only
for “post-farm gate” waste but pre farm gate waste is estimated to exceed that
from hospitality and food service and retail combined.658 In the instance of
pre-farm gate food waste, the retail industry must take some responsibility.
501. Progress in tackling food waste will not be achieved without
meaningful action from the retail sector. The Government should
embark on a concerted effort to encourage sustainable purchasing
behaviour from retailers. Consideration should be given to financial
disincentives for retail or purchasing practices which lead to
excessive pre-farm gate food waste.
657 Department for Environment Food and Rural Affairs, Waste and resource efficiency factsheet, part 3
(13 March 2020): https://www.gov.uk/government/publications/environment-bill-2020/10-march-
2020-waste-and-resource-efficiency-factsheet-part-3 [accessed 29 June 2020]
658 WRAP, Food surplus and waste in the UK - key facts (January 2020) p 4: https://wrap.org.uk/sites/files/
wrap/Food_%20surplus_and_waste_in_the_UK_key_facts_Jan_2020.pdf [accessed 30 June 2020]
Chapter 7: GOVERNANCE, ACCOUNTABILITY AND FOOD

POLICY
502. We heard repeatedly of the need for ‘whole system change’. We recognise
that this call reflects the serious concerns that individuals and organisations
have about the state of the food system; to many, a systemic shift is required.
It was also evident that what ‘whole system change’ might look like, what it
might involve and how it might be realised, are issues that many organisations
are still grappling with. We agree that a radical shift is required but have
avoided simply calling for whole system change without quantifying what
that means. In previous chapters, we have outlined points at different stages
of the system where positive change could be realised—primary production,
food manufacturing; and the food environment—to help ensure that more
people can access a healthy, sustainable diet.
503. The most compelling arguments about how to stimulate broader system
change were about how food policy might be better coordinated, and how
the Government can be held more accountable for achieving improvements
in food, health and sustainability. Witnesses criticised the absence of a
coherent strategy on food and the lack of coordination there has been in
tackling the interrelated issues of food insecurity, diet-related ill health and
food sustainability.
504. As we have detailed elsewhere in the report, the outbreak of COVID-19 has
exacerbated the serious, systemic problems with the food system that our
inquiry has focused on. The crisis will have serious and long-term effects
on the economy and on public health. It also appears that COVID-19
disproportionately affects groups with poor dietary health, and those living
in more deprived areas. It is, therefore, more important than ever that an
overarching strategy for the food system is put in place, one that is effectively
coordinated and rigorously monitored, so that progress on the issues of food
insecurity, poor diet and environmental sustainability can, at last, be realised.
505. The prospect of the National Food Strategy provides us with a great deal
of optimism that the challenges relating to the role and impact of the food
system might finally be addressed under an overarching strategy, allowing for
a coordinated approach to the multi-disciplinary issues that exist. While we
do not wish to pre-empt the findings of Mr Dimbleby’s review, the evidence
we received allows us to offer some insight into what might help to support
and secure any future national strategy for food. The key themes to emerge
were that:
(a) There needs to be a clear ambition set, by the Government, for what it
wants the food system to achieve. That ambition should be supported
by a comprehensive understanding of the scale of the issues involved,
and the links between them;
(b) Any ambitions set for a national food strategy need to be underpinned
by strong accountability measures, with progress against targets
reported on by Ministers to Parliament on a regular basis; and
(c) There is a need for stronger coordination and integration of the policies
that govern what the UK population eat and the ability to access a
healthy, sustainable diet.
506. In recognition of the central role played by food manufacturers, retailers and
the food services sector in influencing both the composition of food, and the
environment in which is it made available to the consumer, the Government
must ensure that as the National Food Strategy takes shape, it continues
to engage with these sectors, to ensure that they play their part in effecting
positive change within the food system.
Setting an ambition for the food system

507. A prominent concern raised was that the Government has not yet set an
overarching ambition for what the food system should achieve in this country.
When asked what the most significant challenge facing the food system is,
Professor Lang (amongst others) stated: “The problem is lack of vision. We
do not have a national food policy.” Anna Taylor agreed with this assertion,
stating:
“Particularly when it comes to diet, we have a situation now where the
lack of collective vision for the food system across government, citizens
and business gets in the way of our developing good and coherent
policy.”659
508. We were told that the lack of a unifying ambition or strategy on food prevents
interrelated issues such as hunger and health, and the food environment
and food sustainability, from being considered in parallel, meaning that
opportunities are missed to develop coherent policies that could stimulate
positive change. Importantly, stronger coordination and integration would
allow for a more comprehensive analysis of the inevitable trade-offs involved
in achieving health, environmental and food security ambitions. UK Research
and Innovation, referring to food insecurity specifically, highlighted that:
“UK food insecurity is caused by a complex network of factors,
including the types of food being produced and manufactured, local
food infrastructure, physical access to food outlets, the purchasing power
of individual consumers and socially acceptable consumption norms,
however, poverty is the key driver which impacts the other factors. A
food systems approach is essential for considering the inter-relationship
between these factors, identifying win-wins, managing trade-offs and
helping to mitigate less desirable outcomes.”660
509. In one of its follow-up reports on the Sustainable Development Goals, the
House of Commons Environmental Audit Committee concluded that food
insecurity and hunger had “fallen between the cracks in Government plans.”
It criticised the Government for failing to understand the relationship
between food insecurity, hunger and malnutrition and stated that:
“The issues of food insecurity, hunger, malnutrition and obesity should
be considered in parallel in the UK context. They are often co-located
and share causal factors. For example, insufficient access to food may
lead to risk-averse purchasing habits and prioritisation of low-priced,
filling foods with long shelf lives - which are often nutrient poor but
calorie-rich.”661

660 Written evidence from UK Research and Innovation (ZFP0039)
510. In our inquiry, we were tasked with taking a broader view, to consider the
issue of food insecurity and its links to public health, but also to factors
within the wider food system, the impact of the food environment and food
sustainability. Our frustration is that the Government is failing to consider
the links between these issues.
511. We were made aware of the ongoing work in both Scotland and Wales to
develop national food policies. We have outlined the work that is being done in
Scotland and Wales in more detail later in this chapter but broadly, there was
recognition within the evidence of the benefit of the coordinated approach
taken by both countries in drawing together food, health, the environment
and inequalities under one overarching strategy. Professor Lang commented
that:
“In Wales, the Well-being of Future Generations (Wales) Act has had a
fundamental impact on getting the Wales Government to think about
their rural policy in relation to their health policy in relation to their
schools policy. In Scotland, the good food nation process, very ably
pushed and promoted by an extremely articulate and well-organised civil
society movement that goes from public health professions to straight
NGOs has been trying to think about what a small country can do …”662
Professor Lang went on to comment that:
“I would not have mentioned them [Scotland and Wales] if they were not
addressing exactly the agenda of this Committee. Both are addressing
health, environment and inequalities, because both those countries—
they are countries—have major problems on those fronts.”
National Food Strategy: England

512. When Henry Dimbleby’s review was announced in June 2019, the
Government acknowledged that there had not been a national food strategy
in England for 75 years (since the post-war 1947 Agriculture Act). DEFRA
stated that the purpose of the National Food Strategy is to: “set out a vision
for the kind of food system we should be building for the future, and a plan
for how to achieve that vision.”663
513. We recognise that COVID-19 may have an impact on the timings of the
publication of the review but Mr Dimbleby told us that when his final review
is published, the Government had made a commitment to respond within a
defined timescale. He explained:
“The Government have already said that they will respond to the report
with a White Paper six months after it is published. They have asked
me to come back to review progress another 12 months after that. The
ambition for what we recommend is to try to get as much embedded as
agreed action on publication.”664
514. There was strong support for work that is underway to develop the National
Food Strategy. This support was generally based on the assertion that the
663 Department for Environment, Food and Rural Affairs, Developing a national food strategy: independent
review 2019 : terms of reference (updated 17 August 2019): https://www.gov.uk/government/publications/
developing-a-national-food-strategy-independent-review-2019/developing-a-national-food-strategy-
independent-review-2019-terms-of-reference [accessed 30 June 2020]
absence of an overarching policy was undermining any progress that could

be made to tackle the negative impacts of the way the food system currently
functions. The Government has stated that work on the review has been
temporarily paused so that the team can concentrate on supporting the
COVID-19 response, but that its work does remain a priority.665
515. A national food strategy for England is long-overdue. It provides a
much-needed opportunity to initiate a strategic, joined-up approach
to food policy.
516. We recommend that the Government should remain committed to
responding to the National Food Strategy review with a White Paper
within six months of the review’s publication. It should commit to
action the review’s recommendations on publication.
517. We were also directed to consider the work that is being taken in the devolved
nations to develop their own national food strategies. This provided us
with examples of what kinds of policy strands should be brought under the
banner of “food policy” and informed us about the overarching ambitions
these countries have set for their food systems. This evidence focused on
Scotland and Wales and we have briefly outlined the approaches taken by
the two countries below.
Scotland
518. In 2009, the Scottish Government published Recipe for Success–Scotland’s
National Food and Drink Policy.666 In 2014, it published its national food
and drink policy: Becoming a Good Food Nation.667 This articulated a new
aspiration, to make Scotland by 2025: “a Good Food Nation, where people
from every walk of life take pride and pleasure in, and benefit from, the food
they produce, buy, cook, serve, and eat each day.”668
519. In setting out the activities that it is undertaking to meet the aims of the
Good Food Nation policy, the Scottish Government has been clear that it
does not consider legislation “essential to delivering action” on its Good
Food ambitions but that “legislation may help to underpin key measures and
activity. As such, it has committed to introducing a Good Food Nation Bill
to “underpin the significant work already undertaken across Government in
terms of key measures and activity to deliver a Good Food Nation.”669 The
Scottish Government have said that in work on their Good Food Nation Bill
they will: “focus on embedding processes for ensuring that the substance of
the right to food has effect as a matter of everyday good practice.”670
520. To help develop its policy, a non-statutory Scottish Food Commission was
established to “provide advice on the existing and future challenges facing
Scotland’s food culture and how these might be addressed.” The Commission
identified five key priorities for the Good Food Nation policy: health, social
666 Scottish Government, Recipe for Success: Scotland’s national food and drink policy (18 June 2014): https://
www.gov.scot/publications/recipe-success-scotlands-national-food-drink-policy/ [accessed 30 June
2020]
667 Scottish Government, Good Food Nation Policy: https://www.gov.scot/policies/food-and-drink/good-
food-nation/ [accessed 30 June 2020]
668 Ibid.
669 Scottish Government, Good Food Nation: consultation (21 December 2018): https://www.gov.scot/
publications/good-food-nation-proposals-legislation/pages/3/ [accessed 30 June 2020]
670 Ibid.
justice, knowledge, environmental sustainability and prosperity.671 Having

also developed recommendations for the scope of the related legislation, the
Commission has now disbanded.
521. George Burgess, Head of Food and Drink at the Scottish Government, told
us that: “All the work within the Scottish Government is informed by our
national performance frameworks, a set of outcomes and indicators that we
use across the whole of Government.”672 These performance frameworks
measure progress or regression against 81 metrics (including several on
hunger, health and environmental sustainability) based upon the United
Nations Sustainable Development Goals.673
522. The Scottish Programme for Government 2019–2020 contained a
commitment to bring forward a Good Food Nation Bill in this term and we
understand that work was underway to prepare the Bill for introduction.674
The Scottish Government has recently stated, however, that due to the need
for parliamentary time to debate and implement emergency COVID-19
legislation, the Bill will not now be introduced in this parliamentary term.675
523. There was support expressed for the approach taken by the Scottish
Government. Dr Koldo Casla from the Institute of Health and Society at
Newcastle University, for example, said:
“While it is too early to tell what the Bill will look like in practice, if done
properly it could provide a new framework for a coherent food policy,
facilitating a transition to a fair, healthy and sustainable food system
that ensures access to nutritiously adequate, accessible and affordable
food, as expected in international human rights law.”676
Wales
524. The Welsh Government published its food strategy ‘Food for Wales,
food from Wales 2010–2020’ in December 2010. The strategy aimed to
consider: “health, food culture and education, food security, environmental
sustainability and community development to provide the basis for an
integrated approach to food policy in Wales.”677 The strategy identified four
key principles: sustainability, resilience, competitiveness; and profitability.678
The foreword for the strategy stated that: “The direction here is radical
and faces up to the challenges of ensuring that people have access to the
affordable and healthy food they need whilst ensuring that this does not
impact adversely on the natural environment.”679
671 Scottish Food Commission, Interim Report (February 2016), p 6: https://www.gov.scot/binaries/

content/documents/govscot/publications/corporate-report/2016/06/food-commission-interim-report/
documents/scottish-food-commission-interim-report-pdf/scottish-food-commission-interim-report-
pdf/govscot%3Adocument/Scottish%2BFood%2BCommission%2Binterim%2Breport.pdf [accessed
30 June 2020]
672 Q 112 (George Burgess)
673 Scottish Government, National Performance Framework, What it is: https://nationalperformance.gov.
scot/what-it [accessed 30 June 2020]
674 Scottish Government, Good Food Nation Policy: https://www.gov.scot/policies/food-and-drink/good-
food-nation/ [accessed 30 June 2020]
675 Ibid.
676 Written evidence from Dr Koldo Casla (ZFP0012)
677 Welsh Assembly Government, Food for Wales, food from Wales 2010–2020 (December 2010) p 5:
https://gov.wales/sites/default/files/publications/2018–05/food-strategy-for-wales-2010-to-2020.pdf
678 Ibid., p 2
679 Ibid., p 3
525. David Morris, deputy head of the food division in the Welsh Government
explained to us:
“Our current action plan, which was the operational way to deliver
the food for Wales and food from Wales strategy, was published about
10 years ago and completes in 2020. It had a number of overriding
objectives: to establish a food industry board in Wales; to grow the
Welsh brand; and to upscale the industry, in the food manufacturing
sector workforce primarily. It had lots of initiatives and actions to grow
business and trade development, and a number of actions around the
area of food safety and food security, which included some public health
and nutrition actions.”
526. Mr Morris confirmed, when asked, that the primary objective of the strategy
was growing the food industry in Wales.680 Mr Morris stated:
“That strategy is complete. We had an overall growth turnover target of
£7 billion for what was the food and farming priority sector. That was
the way it was defined. We aimed to achieve that target by 2020 from a
baseline of just over £5 billion in 2013. We have exceeded that target. At
the end of 2019, we had reached £7.473 billion.”681
527. The Food for Wales strategy ends in 2020. The Welsh Government and the
Food and Drink Wales Industry Board are jointly producing a new plan to
support the sector. Mr Morris confirmed that a follow-on food strategy was
consulted on in 2019, and that a new food strategy would be announced later
in 2020.682
528. Wales has also introduced The Well-being of Future Generations (Wales)
Act 2015, that requires public bodies in Wales to “think about the long-term
impact of their decisions, to work better with people, communities and each
other, and to prevent persistent problems such as poverty, health inequalities
and climate change”.683 Mr Morris explained how the Well-being Act
impacted on the development of its food strategy:
“For example, when we are developing our food strategy, we must go
through a policy gateway process. There is a mapping exercise of our
proposals in relation to the well-being goals. There are seven well-being
goals: a prosperous Wales; a healthier Wales; a more resilient Wales; a
Wales of cohesive communities; a Wales of vibrant culture; a thriving
Welsh language; and a globally responsible Wales.”684
529. Mr Morris also explained the role of the Future Generations Commissioner
whose role is to ensure that policy, including food policy, adheres to its goals.
Mr Morris said:
“Public bodies have to identify their own future generations actions to
deliver on the Act. They have to report annually to the commissioner
on what they are doing and what they have achieved. The commissioner
will then provide feedback and may make recommendations for change.

681 Ibid.
682 Ibid.
683 Future Generations Commissioner for Wales, Well-being of Future Generations (Wales) Act 2015: https://
futuregenerations.wales/about-us/future-generations-act/ [accessed 30 June 2020]
There is quite a lot of governance around it. Public service boards in

each of the local authorities take an active role for the local authority
in delivering and taking forward actions appropriate to delivering the
future generations Act and its well-being goals.”685
530. We recognise that work in both nations is still ongoing and that there are
challenges remaining for both countries. The examples, however, were useful
in considering what priorities the Government may want to consider in any
future national food strategy for England. Most notably, both strategies
brought together different strands of food policy, both approaches are
underpinned by some form of legislation and by accountability frameworks.
Monitoring and accountability

531. If the Government wants to set ambitions for the food system, through a
national food strategy, it will be imperative that there are robust mechanisms
in place for judging progress against those goals. Amongst others, the Food
Foundation, LSHTM and SHEFS, suggested that the Government needs
a revised set of metrics to drive improvement across the food system. The
submission advocated for the introduction of:
“a number of metrics and targets which government and businesses
operating in the food system should report on to parliament on a
periodic basis. These could include levels of childhood obesity, levels
of household food insecurity, greenhouse gas emissions associated with
our diets etc.”686
Similarly, Dr Adrian Morley emphasised the importance of data and
mandating reporting from the food system, stating that:
“If we had a lot more information, with information publicly available
for NGOs and different stakeholders in the system, to understand
the consequences of individual dietary and purchasing choices, and
if we can mandate certain parts of the food system to report different
sustainability metrics and incentivise other smaller businesses to do the
same, it would go a long way towards identifying a route to manage the
transition to a more sustainable food system. In a nutshell, it would be
data.”687
532. Kate Halliwell from the Food and Drink Federation highlighted that there is
not, at present, a mechanism for measuring overall progress towards health
and sustainability goals. Ms Halliwell stated that:
“As far as I am aware, the Government do not have an overarching
metric for healthy and sustainable diets. I know it is work that the Food
Foundation has looked at, specifically in retail and out of home. It is
something that my members are interested in, so at the start of the year
we had the Food Foundation in to talk through its work, and about what
metrics might be appropriate for industry to look at to cover the issue as
a whole.”

“We have various sustainability metrics, some of which are government

led and some of which are ours, but there is no overarching one. For
example, our company’s report was about carbon and water use.
We know that the Environment Bill is going to look at metrics, and
presumably the national food strategy will look at the metrics that cover
this piece. At the moment, we are not aware of an overarching one.”
“Specific to health, we have reports about sugar and salt in the Kantar
datasets that the Government look at, so it is not an overarching health
metric; it is quite nutrient specific.”688
533. The Scottish Government highlighted how progress for meeting it target’s on
food policy were monitored though its national performance framework. In
addition, Mr Burgess detailed proposals outlined in the Good Food Nation
proposals for legislation consultation (2018), the central component of which
was that “the focus of any legislation could be a clear framework that placed
responsibilities on Scottish Ministers and specified bodies to publish and
adhere to statements of policy on food.”689 This statement would be required
to cover food production and consumption issues, and compatibility with
relevant EU obligations. Mr Burgess explained that:
“We consulted on a proposal that Ministers and a range of public bodies
would have to set out a statement of their policy on food, with a holistic
approach to their policies. They would have to report on that and, to
make sure that it is not just a policy that once written sits on a shelf,
take it into account in delivering relevant functions. That applies to the
Scottish Government themselves, and to local authorities and other
key bodies. That is the proposal. It was pretty widely welcomed by the
stakeholders and respondents to our consultation.”690
534. The consultation set out that Scottish Minsters would also need:
• To include indicators or measures of success.
• To publish the statement of policy and to lay it before the Scottish

Parliament, for information rather than approval.
• To report every two years on implementation of the policy and to set

out information on the indicators or measures of success. This report
would be published and laid before the Scottish Parliament in order to
ensure transparency and accountability.
• To have regard to relevant international obligations and guidance;

relevant instruments and guidance would be specified in secondary
legislation.691
535. We are convinced by the need for strong accountability measures to support
the aims of any national food strategy: without it the Government may miss
the opportunity to develop coherent policy to address overarching issues, and
689 Scottish Government, Good food nation proposals for legislation: analysis of consultation responses (11
September 2019): https://www.gov.scot/publications/good-food-nation-proposals-legislation-
consultation-analysis-report/ [accessed 30 June 2020]
691 Scottish Government. Good Food Nation proposals for legislation: analysis of consultation responses (11
September 2019): https://www.gov.scot/publications/good-food-nation-proposals-legislation-
consultation-analysis-report/pages/3/ [accessed 30 June 2020]
to stimulate widespread change. There are a number of targets for driving

improvement in the food system (including reformulation targets, targets on
reducing obesity, and some targets that relate to reducing the environmental
impact of food production) and some notable omissions (such as targets
to reduce food insecurity and food waste). It is clear that current policies
relating to food are too fragmented. As Kate Halliwell noted:” It would be
helpful for [the Government] to focus on trying to deliver across the whole
range of interventions that have so far been proposed.”692
536. The development of a national food strategy provides an important
opportunity to bring all policies related to the food system under
an overarching aim to provide equitable access to healthy and
sustainable diets.
537. In advance of the publication of the National Food Strategy review’s
final report, the Government should review levels of reporting on
health and sustainability across the food system, to identify where
gaps might exist in the current data sets that are available.
538. We propose that underpinning any national food strategy should be a strong
accountability framework; the framework should have precise objectives,
targets and timescales. A range of targets relating to the food system could
be brought under the umbrella ambition of making a healthy and sustainable
diet accessible to everyone. Based on the evidence we received, we suggest
that the Government should review and reset targets in the following areas:
• Reducing levels of household food insecurity (based on improved

monitoring as referred to in chapter three, Poverty and food insecurity).
• A reduction in childhood obesity rates. The Government should review

its target to halve childhood obesity by 2030 and potentially set interim
targets before 2030 to help drive progress.
• A reduction of inequalities in diet-related ill health. The most recent

Marmot review of health inequalities concluded that little progress has
been made on reducing the gap in health outcomes between income
groups.
• The Government should consider setting mandatory reporting metrics

aimed at monitoring the performance of businesses in the food system
towards making healthy and sustainable food more accessible (as
outlined in paragraphs 492 and 493).
539. The Government should develop and introduce a standardised set of
mandatory reporting metrics aimed at monitoring the performance
of Government departments and assessing progress made by
the industry towards making healthy and sustainable food more
accessible. The Government and the industry should be required to
report on progress against those targets on a regular basis.
The ‘right to food’

540. In discussions around how the Government might be better held accountable
for driving wider system change to the food system, the concept of the ‘right to
food’ was advanced by a number of the organisations who provided evidence.

Its advocates, including Sustain693 and Nourish Scotland694, believe that the
right to food should be embedded into UK law.Although this approach was
primarily related to addressing food insecurity and hunger, some suggested
that such a right would drive concerted and co-ordinated action towards
enabling access to a healthy diet for all, by:
• Establishing the norm that everyone in the UK should have access to a

healthy diet;
• Obliging Government to assess progress against this target;
• Establishing transparency in progress made;
• Providing a ‘benchmark’ against which future legislation and policy

could be assessed for impact on food matters; and
• Providing the opportunity for redress and opportunities for other

bodies to intervene within a rights framework.
541. We were grateful to Sustain, who invited members of the Committee to a
roundtable discussion on 3 March 2020, with academics and representatives
from different interested organisations, to discuss the merits of the ‘right
to food’ being enshrined in UK law. Over the course of the discussion,
participants suggested that a ‘right to food’ could provide a benchmark in
order to assess potentially negative effects of other policy decisions on food
provision, and that it could set a basic and consistent norm that people (and
particularly children) are entitled to food. Participants also suggested that it
could act as an accountability framework to ensure that governments must
fulfil certain minimum standards. It was highlighted that the right to food
is recognised in 16% of countries globally. However, there were concerns
raised that there would be difficulties in interpretation and enforcement,
particularly for local authorities, and there was some discussion about
difficulties of embedding the right to food constitutionally.
542. The right to food has featured in considerations about the Good Food Nation
Bill in Scotland. Dr Donald Macaskill, Chief Executive at Scottish Care,
representing the Scottish Food Coalition, argued that:
“We see the good food Bill as a prime opportunity for Scotland to
incorporate the right to food in areas that are devolved to the Scottish
Parliament, recognising that it does not include all areas, and we would
argue that that provides consistency of application. It would enable
read-across to, for instance, the right to social security, which is being
much embedded in the new social security practice in Scotland, and the
right to health that, through our national frameworks and standards, is
embedding itself in health and social care.”695
543. George Burgess from the Scottish Government offered a counter to this
argument, suggesting that existing legislation on standards of living provide
sufficient cover. Mr Burgess told us that:
“Our consultation did not propose that a right to food would be contained
in the good food nation legislation. We recognise the existence of a
693 Written evidence from Sustain (ZFP0071)

695 Q 133 (Dr Donald Macaskill)
right to food as part of wider rights to an adequate standard of living,

as Donald mentioned, in some of the international instruments. Our
Bill will require Ministers and others, when setting their policy, to have
regard to existing international instruments.”696
544. Anna Taylor offered another perspective, stating that:
“In some ways, whether or not you badge it as rights does not matter
too much. The point is that you need to be able to enshrine something
around your aspirations for a healthy and affordable diet that creates a
reference point for other areas of government intervention.”697
545. On balance, although the intentions of the ‘right to food’ are laudable, the
same aims could be achieved through strengthened national governance
around food policy, improved monitoring of food insecurity (as outlined in
Chapter three) and by ensuring that the aims of any national food strategy
are supported by robust accountability measures.
Co-ordination of food policy

546. Another key criticism to emerge about the Government’s approach to food
policy was that there was a lack of coordination across Government for
food policy. The argument was rehearsed that issues such as poverty, food
insecurity and poor health are often co-located and often share causal factors,
and because those relate and are impacted by the wider food environment,
the Government should take a more strategic approach to the co-ordination
of food policy across government departments. To repeat Henry Dimbleby’s
point:
“There are very specific ways in which government’s objectives are
not aligned. At the moment, DEFRA and Trade have very different
objectives in our trade negotiations with other countries. There is a
constant running battle between BEIS and Health on proper regulation
of retailers and food producers.”698
547. Several other witnesses expressed frustration that there was no one body that
takes overall responsibility for food at a governmental level. The Sustainable
Food Trust raised concerns about the lack of coordination, and argued that:
“Westminster should prioritize working across departments to create
an integrated approach to nutritional recommendations and encourage
diets that are aligned with the environmental capacity of the ecosystem
and the productive capacity of the UK …”
“ … Currently, this type of integrated Government policy is not the case,
as the Department of Health and the Department of the Environment,
Food and Rural Affairs (DEFRA) work separately from each other.
This type of siloed working minimizes the opportunity for collaboration
and a synergistic approach to nutrition and healthy diets. “699
548. Representatives from Government departments were questioned on the
extent to which the issues of food insecurity, poor dietary health and food

sustainability are tracked at a cross-departmental level. Alison Ismail detailed

some co-ordination between departments:
“The first thing I would stress is that we are lucky enough to have
informal relationships between ourselves and our teams, so there
would be very frequent interactions just by picking up the phone and
making sure that we have the same line of sight on developments and
testing things informally with each other. That is really important, but
I would also reference our developing plans for a food strategy, which
is absolutely in its terms of reference set out to be a cross-Whitehall
endeavour, owned by all of us, and indeed by other departments.
We have a governance infrastructure around that, including a group
supported by Permanent Secretaries, where directors-general represent
each department to ensure that we have that absolute senior level buy-in
and support for what we are bringing together.”700
Ms Ismail confirmed, however, that there was no formal ministerial group
set up to consider these issues.701
549. Some organisations have sought to expose the issue of Government
coordination on food policy even further by questioning where the
responsibility for food insecurity rests within the Government. The
Environmental Audit Committee has previously highlighted what it saw as
a gap in ministerial responsibility and had called for a Minister for Hunger
to be appointed “to ensure cross-departmental understanding and action
on this important issue”.702 When questioned as to whether there was any
further clarity as where the responsibility for food insecurity lay, Alison
Ismail told us that:
“ … if you are thinking about governance, this is an area where there
is a bit of a trade-off between accountability in the sense of one named
Minister or department and genuinely shared ownership of a problem
or a phenomenon. Food insecurity is with DEFRA. It is probably a bit
of a philosophical question as to whether food insecurity is an exact
synonym for hunger. That would be an interesting question to get into.
I would not want to overstate the progress made on that particular
question since it was last considered by you. It is a good challenge for us
to take away for this time next year, to see whether we have a clear story
on whether that particular issue is jointly or individually owned.”703
550. We were told that in Scotland, efforts have been made to ensure a degree
of coordination across departments with regards to food policy. George
Burgess, Head of Food and Drink at the Scottish Government explained:
“Within government, we have established a ministerial working group
on food, to help to ensure that we have join-up across government.
A good number of our senior Ministers are directly engaged in that.
Under the good food nation proposals we referred to earlier, the Bill, as
well as setting out the policy on food, will require regular reporting by

701 Ibid.
the Scottish Government and other authorities on their progress against

their policies.”704
551. We see the establishment of a ministerial working group as essential
to improving the level of coordination across Government on the
interrelated issues of food insecurity, poor dietary health and food
sustainability. This group should be chaired by a senior member of
the Cabinet.
552. The Government must ensure that the appropriate Whitehall
infrastructure is in place to ensure that the aims of the forthcoming
National Food Strategy can be co-ordinated effectively across
Government departments.
553. Concerns around the lack of coordination on food policy led some witnesses
to advocate for an individual or an independent body to bring greater
coherence across Government on food policy. Many contributors have
suggested that there is a need for a body to hold the Government to account
over progress on food policy.
554. A good deal of support was expressed for the work of the Food Standards
Agency’s oversight of the salt reduction programme. It was praised for its
ability to demonstrate how, when programmes are introduced that aim to
compel the food industry to make meaningful change, with transparent
and robust monitoring of industry progress, and firm oversight, the food
industry can be held to account effectively, and change that will result in
improvements to public health can be achieved.
555. Given the success of the salt reduction programme under the Food
Standards Agency, if industry fails to make the necessary progress
against Government reformulation targets, the Government should
return the responsibility for nutrition, labelling and reformulation
programmes to the FSA, and provide it with the appropriate
resources.
556. Some called for an independent food commission, which would report
annually to Parliament, on progress against agreed plans and targets, and
issue recommendations on how to avoid regression with new policies.705 Dr
Donald Macaskill said:
“Food is fundamental to our well-being and our health as a nation and
as individuals. It deserves a holistic, overarching prioritisation that
counters sectoral interests wherever they may be. It is not sufficient to
have good legislation. It necessitates the force that an independent food
commission would deliver in Scotland and, I suggest, elsewhere.”706
557. We were also made aware of the work of the Welsh independent Future
Generations Commissioner who is tasked with considering the long-term
impact that policies and decisions have, and who is empowered to make
recommendations to avoid regression. David Morris from the Welsh
Government stated that the Commissioner did not have formal powers to
require changes but that local authorities had “tended to comply.”707
706 Q 118 (Dr Donald Macaskill)
558. When asked about his views as to whether some form of independent
oversight would be required to help deliver the aims of a future national food
strategy, Henry Dimbleby responded:
“It is clear to me that we need some structure to ensure ongoing co-
operation, but whether that is a law, a department, an ALB [arm’s length
body] or a set of targets that the Government have to put together, I do
not know yet. It is clear that we need something. If it just remained in
DEFRA, the energy would dissipate very quickly.”708
559. Advocates for such a body stated that it would increase accountability and
transparency, and drive action., we consider that such a body could:
• Advise the Government on the implications of policy proposals as they

relate to access to a healthy diet;
• Collate, and have oversight of, data, relating to the food system (including
those relating to health, food insecurity and food sustainability) and
the progress made against targets set in those areas.
• Report to Parliament on progress made against agreed plans and

targets.
560. We consider that the Committee on Climate Change, as an independent,
non-departmental public body which provides independent advice to the
Government, and reports regularly to Parliament, could provide a blueprint
for how an independent body, with responsibility for oversight of the National
Food Strategy might operate.
561. The Committee asked DEFRA Ministers to outline what mechanisms will
be put in place for the interdepartmental coordination of the delivery of the
National Food Strategy, and whether DEFRA considered there was any
case for an independent body to advise the Government on the progress of
delivering the strategy. Victoria Prentis MP, Parliamentary Under Secretary
of State for DEFRA responded by stating that:
“Although DEFRA has lead responsibility for food, many Departments
right across Government have a very strong interest; and as such, Henry
and his team are engaging across Whitehall, as well as with partners
across the whole food system, including academics, farmers, businesses,
civil society and the general public, to develop their recommendations.”
“Government will respond to the Independent Review’s recommendations
when they have been submitted, including what interdepartmental and/
or independent structures may be needed to support the strategy’s
delivery and monitor progress; the intention is that this will be in the
form of a White Paper to be published within 6 months of the release of
Henry Dimbleby’s final report.”709
Based on this response, it appears that the Government have not yet given
any thought as to how the recommendations of the National Food Strategy
will be coordinated across the relevant Government departments, nor how

709 Letter to the Chair, Lord Krebs, from Victoria Prentis MP, Parliamentary Under Secretary of State for
DEFRA, 17 June 2020 (ZFP0096)
it will ensure that progress against the Strategy’s recommendations will be

overseen.
562. Given the importance of food policy and its overriding impact across
a range of sectors, we feel that there is a compelling argument for
independent oversight of all aspects of food policy in England. As
the National Food Strategy is a key opportunity for food policy to
be embedded into other related policy areas, its recommendations
should not be enacted by DEFRA alone, and some form of independent
oversight is required to review the future implementation of its
recommendations. The Government, however, does not appear to
have given consideration as to how this might be achieved.
563. We recommend the establishment of an independent body,
analogous to the Committee on Climate Change, with responsibility
for strategic oversight of the implementation of the National Food
Strategy. This should include the monitoring and reporting on
progress made against the health and sustainability targets outlined
in paragraph 538. This independent body should have the power to
advise the Government and report to Parliament on progress.
SUMMARY OF CONCLUSIONS AND RECOMMENDATIONS
Below is a list of all of the Committee’s conclusions and recommendations

(recommendations appear in italics).
Chapter 3: Poverty and food insecurity

1. The relationships between dietary quality and food insecurity must be fully
understood. The Government must commit to continuing to run the food insecurity
measurement questions currently contained within the Family Resources Survey. To
better understand the impacts of food insecurity on diet and related outcomes, the
Government must determine how best to collect data on food insecurity and dietary
intake in the same individuals. (Paragraph 82)
2. The need for charitable food aid is a clear sign that the welfare system is
failing to provide adequate support to people in the lowest income groups.
The Government should not be reliant on charitable food aid to plug the
holes in the welfare system. (Paragraph 96)
3. The five-week wait for Universal Credit presents acute difficulties and requires
urgent overhaul. While we cannot anticipate the findings of two Parliamentary
reports dedicated to this topic, the Government must fully respond to the reports of
both Committees. A replacement scheme must have regard to:
• The recommendations of the House of Commons Work and Pensions

Committee and the House of Lords Economic Affairs Committee;
• Analysis of the impact of repayments over a period of time on the ability to

afford a healthy diet;
• The imperative to avoid a situation where a person awaiting benefits has no

choice but to visit a food bank;
• Analysis of data pertaining to the increase in UC claims following the outbreak

of COVID-19;
• The possibility that different groups of claimants may require different

arrangements for advances and their repayment; and
• A continual and effective system of training to help claimants manage their

money. (Paragraph 104)
4. We note that a group of the most vulnerable people, those with no recourse
to public funds, are conspicuously absent from policy discussions on food
insecurity. (Paragraph 109)
5. We recommend that the Government produce an action plan to ensure that the
gathering of data on food insecurity includes and records the situations of those
with no recourse to public funds. Urgent planning must begin now to establish a
Government-funded programme to ensure that all those with no recourse to public
funds are able to access sufficient, nutritious food. (Paragraph 110)
6. For many in low income groups, meeting the costs of the Eatwell Guide is
unrealistic. Given the sizeable proportion of disposable income that many in
lower income groups would have to spend to meet the recommendations of
the Eatwell Guide, it is wholly unsurprising that so few people are doing so.
(Paragraph 124)
7. The Government should be fully aware of the cost of eating the diet it recommends,
and the ability of different demographic groups to access this diet. To underpin any
national food strategy, the Government must, in its 2021 review of benefits rates,
commit to giving its dietary guidance—the Eatwell Guide—a firm place in the
development of policy. (Paragraph 127)
8. The Government should embed consideration of the cost of the Eatwell Guide into
calculations of benefit payment rates. (Paragraph 132)
9. We recommend that the Government should undertake a fuller assessment of the cost
of a healthy and sustainable diet. The cost of the Government’s dietary guidance
should be built in as a reference point to consideration of government interventions,
including those relating to welfare and public food provision. (Paragraph 133)
10. For many, particularly those in the lowest income groups, food choices are
about whether they will produce a feeling of being satiated. Choices made by
people in lower income groups to prioritise food that is reliably satiating and
prevents waste over a nutritionally balanced diet should be understood as a
reasonable response to the economic reality they face. (Paragraph 140)
11. There are a series of hurdles to overcome to access a healthy diet. These
hurdles are particular to lower income groups, and their combined effect
means that it is significantly harder for people with a lower income to access
a healthy diet. The current food system requires much more of people with
fewer resources. (Paragraph 150)
Chapter 4: The Food Environment

12. 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. (Paragraph 159)
13. 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. (Paragraph 165)
14. 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. (Paragraph 176)
15. 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. (Paragraph 184)
16. 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. (Paragraph 194)
17. 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. (Paragraph 201)
18. 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. (Paragraph 206)
19. 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. (Paragraph 212)
20. 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. (Paragraph 228)
21. 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. (Paragraph 229)
22. 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. (Paragraph 241)
23. The National Schools Breakfast Programme must support and train facilitators to
enable schools to access future external funding. (Paragraph 242)
24. 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. (Paragraph 243)
25. 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. (Paragraph 253)
26. 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. (Paragraph 265)

27. 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. (Paragraph 278)
28. 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. (Paragraph 287)
29. The Government must, by the end of 2020, act on their proposals to restrict price
promotions on HFSS products. (Paragraph 293)
30. The planning environment must support the efforts of local authorities to
limit the proliferation of fast food outlets around schools. (Paragraph 304)
31. 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. (Paragraph 305)
32. 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. (Paragraph 306)
33. 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. (Paragraph 312)
34. 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. (Paragraph 316)
35. 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. (Paragraph 324)
36. 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. (Paragraph 333)
37. There is potential for increased investment in targeted public health

messaging to help to encourage a shift towards healthier consumption
patterns. (Paragraph 336)
38. 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. (Paragraph 339)
Chapter 5: Reformulation and regulation

39. The Government should review the current zero-rated VAT arrangements on some
food products which are known to be energy dense, and contain high levels of salt,
sugar and unhealthy types of fat. It should commence this review before the end of
the transition period in 2020. (Paragraph 378)
40. As part of any future measures the Government sets out to tackle obesity and poor
dietary health, it should develop and publish a consultation with industry on the
issue of mandating maximum calories per portion. This consultation process must
involve active engagement with SMEs and the catering sector. (Paragraph 392)
41. Reformulation is an important part of overall efforts to drive healthier
diets. The Government must maintain the pressure on food manufacturers
to reformulate their products. The Government must recognise that the
fact that Government-led reformulation programmes are required at all,
points to wider and more serious failings in the food system as a whole.
(Paragraph 397)
42. For voluntary programmes to be successful it is imperative that targets are
transparently monitored and regularly reported on. Voluntary approaches
may be successful if the Government sets out the right support to ensure
industry stays engaged. (Paragraph 398)
43. We recommend that all reformulation programmes, both voluntary and mandatory,
should be subject to transparent and regular monitoring. Progress reports need to be
carried out on a regular basis by the responsible body and should include details of
the companies that have successfully made reductions in the levels of salt and sugar
in their products, to aid industry-wide reformulation. (Paragraph 399)
44. We recommend that where voluntary approaches are adopted, the Government
should make clear that if the industry does not respond comprehensively and swiftly
then regulatory action will follow. Both the sugar and salt reduction programmes are
unlikely to meet their stated targets. To ensure that necessary and significant public
health improvements are actually achieved, the Government needs to face the reality
of the situation and start to plan now for how further progress on reformulation might
be delivered. The Government should set out now what mandatory action would
look like, if sufficient progress is not made on the existing reformation programmes
in the near future. Industry can then prepare. We ask that the Government does this
by the end of 2020. (Paragraph 400)
45. Mandatory (fiscal) approaches can be highly successful, as evidenced by the Soft
Drinks Industry Levy. As there is a proven mechanism for delivering successful
reductions in harmful ingredients, in a way which has not had a significant
detrimental impact on the industry, the Government must not delay in exploring
the application of fiscal measures (such as further levies or changes to VAT) to other
product categories where reformulation is not in line with Government guidance or
targets. (Paragraph 401)
46. We recommend that the Government stands by its commitment to review the Soft
Drinks Industry Levy in 2020, and commits to extending the levy to other drinks
containing added sugar, including sugary milk-based drinks. It should also conduct
work to explore the impact of lowering the current sugar thresholds to encourage
further reformulation. It should rapidly determine which other food products high in
sugar could be subjected to a similar levy. (Paragraph 402)
Chapter 6: Food and the environment

47. We note that the Government’s transition plan includes a commitment for largely
unchanged funding for farmers until at least the end of the current Parliament.
During this time, we urge the Government to undertake full and transparent
consultation when considering the public goods that will be rewarded under the
ELMS. (Paragraph 426)
48. The Government must ensure that every public good outlined in the Agriculture Bill
is accompanied by a standardised framework to allow measurements and targets to
be clear, consistent and easy to use. (Paragraph 429)
49. The Government must ensure that the ability to stipulate conditions for payments
under the Environmental Land Management Scheme is both rigorously and
fairly deployed. Where conditions are not met, enforcement action in the form of
withholding payment must reliably follow. (Paragraph 431)
50. In order to protect the natural environment and public health, there is a
need for a fundamental shift in national consumption patterns towards a
more plant-based, balanced diet in line with the recommendations of the
Government’s Eatwell Guide. (Paragraph 439)
51. The Government’s White Paper on the National Food Strategy must include a
definitive outline of what constitutes a sustainable diet with regards to health, social
and environmental impacts. It must be accompanied with a graded action plan and
communications strategy to move towards this diet. (Paragraph 440)
52. The National Food Strategy should outline a comprehensive action plan to increase
the demand for and consumption of fruit and vegetables. (Paragraph 445)
53. We recommend that Government should list Public Health as a ‘Public Good’
under Clause One of the Agriculture Bill. Measures eligible for financial assistance
to improve public health should be focussed on (but not necessarily limited to) those
activities which increase demand for fruits and vegetables. (Paragraph 455)
54. Food imports must be required to adhere to the same health, environmental and
animal welfare standards as food produced in the UK. To fail to do so would make
a mockery of our stated environmental values, and irrevocably undermine British
producers. The Government must set out how it intends to ensure that current
standards are maintained in future trade agreements, and what safeguards will be
in place to guarantee this. (Paragraph 469)
55. The Government must provide sufficient and stable funding for research and
development into agricultural technology and new ways of farming if sought after
progress in increasing farming efficiency is to be made. (Paragraph 478)
56. The policy environment for farming has often been insufficiently stable
to enable individual farmers to make investment decisions on improving
efficiency or on the use of agricultural technology. (Paragraph 482)
57. The Government must ensure that the multi-annual financial assistance plans to
be published under the Agriculture Bill are stable and not subject to substantive
change: providing a sufficient amount of detail to allow farmers to make investment
decisions. (Paragraph 483)
58. Any investment in or policy change related to farming productivity, including
investment in agricultural technology or land use must take account of the
imperatives to avoid undermining the ability to produce food in the future, and to
protect biodiversity and animal welfare. (Paragraph 488)
59. Government must implement a mandatory reporting regime for adherence to
clear and consistent sustainability and health metrics, as well as adherence to
procurement standards. This should apply to all supermarkets, major food and drink
manufacturers, public procurers and their contracted suppliers, and food outlets.
(Paragraph 493)
60. Progress in tackling food waste will not be achieved without meaningful action from
the retail sector. The Government should embark on a concerted effort to encourage
sustainable purchasing behaviour from retailers. Consideration should be given to
financial disincentives for retail or purchasing practices which lead to excessive pre-
farm gate food waste. (Paragraph 501)
Chapter 7: Governance, accountability and food policy

61. A national food strategy for England is long-overdue. It provides a much-
needed opportunity to initiate a strategic, joined-up approach to food policy.
(Paragraph 515)
62. We recommend that the Government should remain committed to responding to
the National Food Strategy review with a White Paper within six months of the
review’s publication. It should commit to action the review’s recommendations on
publication. (Paragraph 516)
63. The development of a national food strategy provides an important
opportunity to bring all policies related to the food system under an
overarching aim to provide equitable access to healthy and sustainable diets.
(Paragraph 536)
64. In advance of the publication of the National Food Strategy review’s final report,
the Government should review levels of reporting on health and sustainability across
the food system, to identify where gaps might exist in the current data sets that are
available. (Paragraph 537)
65. The Government should develop and introduce a standardised set of mandatory
reporting metrics aimed at monitoring the performance of Government departments
and assessing progress made by the industry towards making healthy and sustainable
food more accessible. The Government and the industry should be required to report
on progress against those targets on a regular basis. (Paragraph 539)
66. We see the establishment of a ministerial working group as essential to
improving the level of coordination across Government on the interrelated
issues of food insecurity, poor dietary health and food sustainability. This
group should be chaired by a senior member of the Cabinet. (Paragraph 551)
67. The Government must ensure that the appropriate Whitehall infrastructure is in
place to ensure that the aims of the forthcoming National Food Strategy can be co-
ordinated effectively across Government departments. (Paragraph 552)
68. Given the success of the salt reduction programme under the Food Standards Agency,
if industry fails to make the necessary progress against Government reformulation
targets, the Government should return the responsibility for nutrition, labelling
and reformulation programmes to the FSA, and provide it with the appropriate
resources. (Paragraph 555)
69. Given the importance of food policy and its overriding impact across a
range of sectors, we feel that there is a compelling argument for independent
oversight of all aspects of food policy in England. As the National Food
Strategy is a key opportunity for food policy to be embedded into other
related policy areas, its recommendations should not be enacted by DEFRA
alone, and some form of independent oversight is required to review the
future implementation of its recommendations. The Government, however,
does not appear to have given consideration as to how this might be achieved.
(Paragraph 562)
70. We recommend the establishment of an independent body, analogous to the Committee
on Climate Change, with responsibility for strategic oversight of the implementation
of the National Food Strategy. This should include the monitoring and reporting on
progress made against the health and sustainability targets outlined in paragraph
538. This independent body should have the power to advise the Government and
report to Parliament on progress. (Paragraph 563)
Appendix 1: LIST OF MEMBERS AND DECLARATIONS OF

INTEREST
Members
Lord Krebs (Chair)
Baroness Boycott
The Earl of Caithness
Lord Empey
Baroness Janke
Baroness Osamor
Baroness Parminter
Baroness Ritchie
Baroness Sanderson
Baroness Sater
Lord Whitty
Declarations of interest
Baroness Boycott
Chair, Veg Power
Co-Chair, Feeding Britain
Trustee, Food Foundation
Trustee, StreetSmar
Patron, Sustain
Advisory panel, National Food Strategy
President, British Guild of Agricultural Journalists
Earl of Caithness
No relevant interests declared
Lord Empey OBE
Baroness Janke
Lord Krebs
Advisor to Marks & Spencer Plc
Chair, LEAP, programme advisory board
Advisor, Ajinomoto Co Inc
Trustee, Nuffield Foundation
Baroness Osamor
Baroness Parminter
Baroness Ritchie of Downpatrick
Baroness Sanderson of Welton
Baroness Sater
Patron, StreetGames
Lord Whitty
Vice President, Chartered Trading Standards Institute
Vice President, Local Government Association
A full list of Members’ interests can be found in the Register of Lords Interests:
https://www.parliament.uk/mps-lords-and-offices/standards-and-financial-
interests/house-of-lords-commissioner-for-standards-/register-of-lords-interests/
Specialist Adviser - Professor Martin White
Research leader of food systems and population health, MRC Epidemiology
Unit, University of Cambridge.
Director of Public Health Research Programme, National Institute of Health
Research (weekly Secondment).
Specialist Adviser- Professor Elizabeth Robinson
Head of Applied Economics and Marketing, School of Agriculture, Policy
and Development, University of Reading
Appendix 2: LIST OF WITNESSES
Evidence is published online at: https://committees.parliament.uk/committee/408/

food-poverty-health-and-environment-committee/
It is available for inspection at the Parliamentary Archives (020 7219 3074).
Evidence received by the Committee is listed below in chronological order of oral
evidence session and in alphabetical order. Those witnesses marked with ** gave
both oral evidence and written evidence. Those marked with * gave oral evidence
and did not submit any written evidence. All other witnesses submitted written
evidence only.
Oral evidence in chronological order

** Anna Taylor, Executive Director, The Food QQ 1–8
Foundation
* Professor Tim Lang, Professor of Food Policy, City
University of London
* Professor Tim Key, Professor of Epidemiology & QQ 9–16
Deputy Director, Cancer Epidemiology Unit, Nuffield
Department of Population Health
** Dr Christina Vogel, Principal Research Fellow
in Public Health Nutrition at the University of
Southampton
* George Butterworth, Senior Policy Manager at Cancer
Research UK
** Jenny Oldroyd, Deputy Director Obesity, Food and QQ 17–29
Nutrition, Department of Health and Social Care
** Julia Gault, Deputy Director Labour Market, Families
& Disadvantage, Department for Work and Pensions
** Sarah Lewis, Director System Leadership and Strategy
(Early years and schools) Department for Education
** Alison Ismail, Acting Director for Agri-Food Chain
Directorate, Department for Environment, Food and
Rural Affairs
** Helen Barnard, Deputy Director of Policy and QQ 30–36
Partnerships, Joseph Rowntree Foundation
* Garry Lemon, Director of Policy, External Affairs and
Research, The Trussell Trust
** Alison Garnham, Chief Executive, Child Poverty
Action Group (CPAG)
* Professor Greta Defeyter, Professor of Psychology at QQ 37–45
University of Northumbria
* Dr Mary Bousted, Joint General-Secretary of the
National Education Union
** Alysa Remtulla, Head of Policy and Campaigns, Magic
Breakfast
* Tom Andrews, Programme Manager, Sustainable QQ 46–52

Food Cities
* Steve Butterworth, CEO, Neighbourly
* Alex Holt, Programme Lead, Food Active
** Nicky Dennison, Public Health Specialist, Blackpool QQ 53–60
City Council
* Dr Katie Cuming, Public Health Consultant, Brighton
and Hove City Council
* Shirley Cramer, Chief Executive, Royal Society for QQ 61–66
Public Health
* Dr Louise Marshall, Senior Public Health Fellow,
Health Foundation
* Professor Susan Jebb, Professor of diet and population
health, University of Oxford
* Susan Lloyd, Executive Lead for Policy at the Faculty
of Public Health
** Mhairi Brown, Policy and Public Affairs Coordinator, QQ 67–73
Consensus Action on Salt, Sugar and Health
** Dr Hilda Mulrooney, Associate Professor in Nutrition,
Obesity Group of the British Dietetic Association
** Kate Halliwell, Head of Diet and Health Policy, Food
and Drink Federation
* Dr Tara Garnett, Food Climate Research Network QQ 74–79
Leader, University of Oxford
* Professor Andrew Balmford, Professor of Conservation
Science, University of Cambridge
* Dr Adrian Morley, Manchester Metropolitan
University
** Kath Dalmeny, Chief Executive of Sustain QQ 80–87
* Professor Sir Charles Godfray, Director of Oxford
Martin Programme on the Future of Food
* Professor Tim Benton, Director, Energy, Environment
and Resources Programme, Chatham House
* Philip Hambling, Head of Food and Farming Policy, QQ 88–93
National Farmers’ Union
** Rob Percival, Head of Policy (food and health), Soil
Association
** Judith Batchelar OBE, Director of Sainsbury’s Brand, QQ 94–99
Sainsbury’s
* Andrew Opie, Director of Food and Sustainability,
British Retail Consortium
* Henry Dimbleby, National Food Strategy Review Lead QQ 100–105
* Mark Laurie, Director at Nationwide Caterers QQ 106–111

Association
** David Morris, Deputy Head of Food, Agriculture, QQ 112–118
Fisheries and Rural Strategy at Welsh Government
* George Burgess, Head of Food and Drink at Scottish
Government
* Donald Macaskill, Chief Executive at Scottish Care,
Scottish Food Coalition
** Jo Churchill MP, Parliamentary Under Secretary of QQ 119–130
State (Minister for Prevention, Public Health and
Primary Care) at the Department of Health and Social
Care
* Will Quince MP, Parliamentary Under-Secretary in
the Department for Work and Pensions
Alphabetical list of all witnesses
A Menu for Change ZFP0081
* Tom Andrews, Programme Manager, Sustainable
Food Cities
Association of Convenience Stores (ACS) ZFP0050
* Professor Andrew Balmford, University of Cambridge
** Helen Barnard, Deputy Director of Policy and ZFP0099
Partnerships, Joseph Rowntree Foundation (QQ 30–
36)
Bags of Taste Limited ZFP0029
** Judith Batchelar OBE, Director of Sainsbury’s Brand, ZFP0034
Sainsbury’s (QQ 94–99) ZFP0091
Dr Dave Beck, The University of Salford ZFP0001
* Professor Tim Benton, Director, Energy, Environment
and Resources Programme, Chatham House
Birmingham Food Council CIC ZFP0057
Dr. Megan Blake ZFP0030
* Dr Mary Bousted, Joint General-Secretary of the
National Education Union
Dr Mhairi Bowe, Dr Juliet Wakefield, and Nottingham ZFP0078
Civic Exchange (QQ 67–73)
Anthony Bown ZFP0037
Miss Hannah Bown ZFP0042
Hannah French, Bristol City Council ZFP0047
British Growers Association ZFP0090
** Mhairi Brown, Policy and Public Affairs Coordinator, ZFP0053
Consensus Action on Salt, Sugar and Health
* George Burgess, Head of Food and Drink at Scottish

Government
** George Butterworth, Senior Policy Manager at Cancer ZFP0043
Research UK
** Steve Butterworth, CEO, Neighbourly ZFP0066
Dr Koldo Casla, Institute of Health and Society, ZFP0012
Newcastle University
Central England Co-operative ZFP0060
Centre for Diet and Activity Research ZFP0038
Church Action on Poverty, Food Foundation, Nourish ZFP0031
Scotland, Oxfam and Sustain: the alliance for food and
farming
** Jo Churchill MP, Parliamentary Under Secretary of ZFP0097
State (Minister for Prevention, Public Health and ZFP0097
Primary Care) at the Department of Health and Social
Care (QQ 119–130)
Mrs Wilfrid Crawford ZFP0063
City Harvest ZFP0055
Dr Frances Cossar (co-authored with Prof. Dominic ZFP0005
Moran, Prof. Mark Rounsevell, Dr Peter Alexander,
and Dr Roslyn Henry), University of Edinburgh
* Shirley Cramer, Royal Society for Public Health
The Crop Protection Association UK Ltd. ZFP0021
* Dr Katie Cuming, Public Health Consultant, Brighton
and Hove City Council
Exeter Foodbank ZFP0059
** Kath Dalmeny, Chief Executive of Sustain: The ZFP0071
Alliance for Better Food and Farming (QQ 80–87)
* Professor Greta Defeyter, Professor of Psychology at
University of Northumbria
** Nicky Dennison, Public Health Specialist, Blackpool ZFP0036
City Council (QQ 53–60)
** Department for Education ZFP0098
** Department for Environment, Food and Rural Affairs ZFP0096
ZFP0098
** Department of Health and Social Care ZFP0097
ZFP0098
** Department for Work and Pensions ZFP0098
* Henry Dimbleby, National Food Strategy Review Lead
Professor Louise Dye, University of Leeds, Cross ZFP0058
Faculty Food Theme
Faculty of Dental Surgery at the Royal College of ZFP0010

Surgeons
FareShare ZFP0085
ZFP0095
Fareshare Yorkshire ZFP0103
Feedtest ZFP0086
Helen Crawley and Victoria Sibson, First Steps ZFP0044
Nutrition Trust
Food Ethics Council ZFP0054
** The Food Foundation, London School of Hygiene and ZFP0073
Tropical Medicine and Sustainable and Healthy Food
Systems (SHEFS)
Foodshare Maidenhead ZFP0013
Foodwise Leeds ZFP0102
Dr Sinéad Furey ZFP0019
** Alison Garnham, Chief Executive Child Poverty ZFP0100
Action Group (QQ 30–36)
* Dr Tara Garnett, Food Climate Research Network
Leader, University of Oxford
Dr Kayleigh Garthwaite ZFP0022
** Julia Gault, Deputy Director Labour Market, Families ZFP0098
& Disadvantage, Department for Work and Pensions
(QQ 17–29)
Professor Sir Charles Godfray, Director of Oxford
Martin Programme on the Future of Food
Greater Manchester Poverty Action ZFP0049
Royal Borough of Greenwich Council, Corporate ZFP0015
Services
** Kate Halliwell, Head of Diet and Health Policy, Food ZFP0009
and Drink Federation (QQ 67–73) ZFP0094
* Philip Hambling, Head of Food and Farming Policy,
National Farmers’ Union
John Harding ZFP0028
Professor Dominic Harrison, Director of Public Health ZFP0027
and Wellbeing, Blackburn with Darwen Council and
Emma Savage, Specialty Registrar in Public Health
Health Action Campaign ZFP0046
Kevin Higgins, Advice NI ZFP0020
Hinckley Area Foodbank ZFP0004
** HM Government ZFP0079
ZFP0098
* Alex Holt, Programme Lead, Food Active

Valerie Hutson ZFP0072
** Alison Ismail, Acting Director for Agri-Food Chain ZFP0098
Directorate, Department for Environment, Food and ZFP0096
Rural Affairs (QQ 17–29)
Ian. E. Ivory ZFP0088
* Professor Susan Jebb, Professor of diet and population
health, University of Oxford
* Professor Tim Key, Professor of Epidemiology &
Deputy Director, Cancer Epidemiology Unit, Nuffield
Department of Population Health
LACA ZFP0048
Labour Hunger Campaign ZFP0052
Lady Iveta Kurpniece ZFP0011
Dr Hannah Lambie-Mumford, Lecturer, Department ZFP0041
of Politics and International Relations at University of
Sheffield
* Professor Tim Lang, Professor of Food Policy, City
University of London
* Mark Laurie, Director at Nationwide Caterers
Association
Leeds City Council ZFP0101
Leeds Community Foundation ZFP0104
Leeds Food Aid Network ZFP0018
ZFP0105
* Garry Lemon, Director of Policy, External Affairs and
Research, The Trussell Trust
** Sarah Lewis, Director System Leadership and Strategy ZFP0098
(Early years and schools) Department for Education
(QQ 17–29)
* Susan Lloyd, Executive Lead for Policy at the Faculty
of Public Health
Dr Rachel Loopstra and Dr Aaron Reeves ZFP0065
Martin Lovegrove ZFP0003
Dr Nadina Luca ZFP0032
* Donald Macaskill, Chief Executive at Scottish Care,
Scottish Food Coalition
* Dr Louise Marshall, Senior Public Health Fellow,
Health Foundation
Professor Jon May, Dr Andrew Williams, Professor ZFP0082
Paul Cloke, Dr Liev Cherry
* Dr Adrian Morley, Manchester Metropolitan

University
** David Morris, Deputy Head of Food, Agriculture, ZFP0092
Fisheries and Rural Strategy at Welsh Government
(QQ 112–118)
** Dr Hilda Mulrooney, Associate Professor in Nutrition, ZFP0035
Obesity Group of the British Dietetic Association
(QQ 67–73)
Nature Friendly Farming Network (NFFN) ZFP0089
Nestlé UK&I ZFP0051
Nourish Scotland ZFP0064
Nuffield Council on Bioethics ZFP0045
** Jenny Oldroyd, Deputy Director Obesity, Food and ZFP0098
Nutrition, Department of Health and Social Care ZFP0097
(QQ 17–29)
Jamie Oliver ZFP0075
The Office for National Statistics (ONS) ZFP0087
* Andrew Opie, Director of Food and Sustainability,
British Retail Consortium
Dr Ruth Patrick, University of York, Department of ZFP0093
Social Policy and Social Work
People First Keighley & Craven ZFP0083
** Rob Percival, Head of Policy (food and health), Soil ZFP0016
Association (QQ 88–93)
Dr Clare Pettinger assisted by members of the Food ZFP0033
Plymouth partnership
Project 17 ZFP0008
* Will Quince MP, Parliamentary Under-Secretary in ZFP0098
the Department for Work and Pensions
** Alysa Remtulla, Head of Policy and Campaigns, Magic ZFP0076
Breakfast (QQ 37–45)
Doctor Christian Reynolds ZFP0077
Dr Manu Savani ZFP0070
Dr Rebecca Sandover ZFP0056
The Institute of Developmental Sciences, Faculty ZFP0080
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
South Wales Food Poverty Alliance (SWFPA) ZFP0084
Cllr Evelyn Akoto, Cabinet Member for Community ZFP0024

Safety and Public Health, Southwark Council
Susan Hedley ZFP0069
Sustainable Food Trust ZFP0007
Professor Isabelle Szmigin, University of Birmingham ZFP0017
** Anna Taylor, Executive Director, The Food ZFP0073
Foundation (QQ 1–8)
Transition Town Wirksworth ZFP0067
Elif Emma True ZFP0074
Laura Holland, Venner Finland ZFP0006
Visformatics ZFP0061
** Dr Christina Vogel, Principal Research Fellow ZFP0080
in Public Health Nutrition at the University of
Southampton
Martin Yarnit, Churchill Fellow ZFP0002
UK Research and Innovation ZFP0039
University of York, IKnowFood Programme ZFP0040
Appendix 3: CALL FOR EVIDENCE
Call for evidence

The Select Committee on food, poverty, health and the environment was
appointed by the House of Lords on 13 June 2019 to “consider the links between
inequality, public health and food sustainability”. It has to report by 31 March
2020. A central question for this inquiry is how to make a healthy, sustainable diet
accessible and affordable for everyone.
Questions
1. What are the key causes of food insecurity in the UK?710 Can you outline any
significant trends in food insecurity in the UK? To what extent (and why)
have these challenges persisted over a number of years?
2. What are some of the key ways in which diet (including food insecurity)
impacts on public health? Has sufficient progress been made on tackling
childhood obesity and, if not, why not?
3. How accessible is healthy food? What factors or barriers affect people’s ability
to consume a healthy diet? Do these factors affect populations living in rural
and urban areas differently?
4. What role can local authorities play in promoting healthy eating in their
local populations, especially among children and young people, and those
on lower incomes? How effectively are local authorities able to fulfil their
responsibilities to improve the health of people living in their areas? Are
you aware of any existing local authority or education initiatives that have
been particularly successful (for example, schemes around holiday hunger,
providing information on healthy eating, or supporting access to sport and
exercise)?
5. What can be learnt from food banks and other charitable responses to
hunger? What role should they play?
6. What impact do food production processes (including product formulation,
portion size, packaging and labelling) have on consumers dietary choices
and does this differ across income groups?
7. What impact do food outlets (including supermarkets, delivery services,
or fast food outlets) have on the average UK diet? How important are
factors such as advertising, packaging, or product placement in influencing
consumer choice, particularly for those in lower income groups?
8. Do you have any comment to make on how the food industry might be
encouraged to do more to support or promote healthy and sustainable diets?
Is Government regulation an effective driver of change in this respect?
710 There is no universally accepted definition of food insecurity, but the most commonly used is: “limited
or uncertain availability of nutritionally adequate and safe foods or limited or uncertain ability to
acquire acceptable foods in socially acceptable ways (e.g. without resorting to emergency food
supplies, scavenging, stealing or other coping strategies).” (The Food Foundation, Too Poor to Eat:
Food insecurity in the UK, (May 2016): https://foodfoundation.org.uk/wp-content/uploads/2016/07/
FoodInsecurityBriefing-May-2016-FINAL.pdf. This definition was also used for the UK’s 2007 Low
Income Diet and Nutrition Survey.)
9. To what extent is it possible for the UK to be self-sufficient in producing

healthy, affordable food that supports good population health, in a way that
is also environmentally sustainable?
10. Can efforts to improve food production sustainability simultaneously offer
solutions to improving food insecurity and dietary health in the UK?
11. How effective are any current measures operated or assisted by Government,
local authorities, or others to minimise food waste? What further action is
required to minimise food waste?
12. A Public Health England report has concluded that “considerable and
largely unprecedented” dietary shifts are required to meet Government
guidance on healthy diets.711 What policy approaches (for example, fiscal or
regulatory measures, voluntary guidelines, or attempts to change individual
or population behaviour through information and education) would most
effectively enable this? What role could public procurement play in improving
dietary behaviours?
13. Has sufficient research been conducted to provide a robust analysis of the links
between poverty, food insecurity, health inequalities and the sustainability
of food production? How well is existing research on the impact of existing
food policy used to inform decision making?
14. What can the UK learn from food policy in other countries? Are there
examples of strategies which have improved access and affordability of
healthy, sustainable food across income groups?
15. Are there any additional changes at a national policy level that would help
to ensure efforts to improve food insecurity and poor diet, and its impact on
public health and the environment, are effectively coordinated, implemented
and monitored?
711 Scarborough, P, et al. Eatwell Guide: modelling the dietary and cost implications of incorporating new
sugar and fibre guidelines, 2016, https://bmjopen.bmj.com/content/6/12/e013182
Appendix 4: ACRONYMS AND ABBREVIATIONS
AHC After housing costs

BAME Black, Asian and Minority Ethnic
BHC Before Housing costs
CAP EU’s Common Agricultural Policy
CPAG Child Poverty Action Group
DEFRA Department for Environment, Food and Rural Affairs
DFID Department for International Development
DHSC Department of Health and Social Care
DWP Department for Work and Pensions
EFB Exeter Foodbank
ELMS Environmental Land Management Scheme
FAO Food and Agriculture Organisation
FRS Family Resources Survey
FSA Food Standards Agency
FSM Free School Meals
GBSF Government Buying Standards for Food and Catering Services
GHG Greenhouse gas
GVA Gross Value Added
HFSS High in fat, salt or sugar
IFS Institute for Fiscal Studies
JRF Joseph Rowntree Foundation
LACA The Local Authority Caterers Association
LSHTM London School of Hygiene and Tropical Medicine
NEU National Education Union
NIHR National Institute for Health Research
NFS National Food Strategy
NGO Non-Governmental Organisation
NHS National Health Service
NRPF No recourse to public funds
NSBP Government National School Breakfast Programme
PHE Public Health England
R&D Research and development
SACN Scientific Advisory Committee on Nutrition
SDIL Soft Drinks Industry Levy
SFT Sustainable Food Trust
SHEFS Sustainable and Healthy Food Systems

SMC Social Metrics Commission
SMEs Small and Medium enterprises
UC Universal Credit
UIFSM Universal Infant Free School Meals
UNICEF United Nations Children’s Fund
WRAP Waste and Resources Action Programme
Appendix 5: EXPERIENCES OF FOOD INSECURITY
Introduction
1. This note provides a summary of a series of telephone calls with people who
have experienced poverty and food insecurity. It contains a report of each
conversation.
Background
2. On 17 March 2020, the Committee was due to hold an informal engagement
session with people who have experienced food insecurity. Food Power,
an initiative run by Sustain and Church Action on Poverty had helped to
organise the event. Due to COVID-19 crisis, this event had to be cancelled.
3. In place of the session, on Friday 22 May and Wednesday 25 May 2020, the
secretariat undertook a series of phone calls with the individuals who had
planned to attend the original event. The secretariat was put in touch with
these witnesses by Simon Shaw, Programme Manager at Sustain, and Ben
Pearson, Empowerment Programme Officer at Church Action on Poverty,
who identified and contacted witnesses. The Clerk and the Policy Analyst
of the Committee led the phone calls, asking a set of questions that had
been circulated to the individuals beforehand, with the Committee Assistant
of the Committee taking notes. Ben Pearson also took part on the calls
and occasionally asked follow up questions (the note indicates where this
occurred).
4. All participants were informed of the purpose of the phone calls and gave
consent for their testimony and names to be published. The views outlined
in this note are those of the individuals we spoke to.
5. The team based each phone call around the following questions:
(a) How do you choose what to eat? What is most important?
(b) What does a healthy diet mean to you? Do any difficulties get in the
way of that? What would make it easier?
(c) How easy is it for you to cook? What would make it easier for you to
cook at home?
(d) What does food poverty look like for you or people in your community?
What effect does it have on daily life?
(e) What effect has coronavirus had on your diet or ability to access food?
What effect has it had in your community?
(f) Do you have any suggestions for what government, councils or other
public services could do to help?
(g) The Committee will be making suggestions to enable more people to
access a healthy diet. Is there anything you think they should understand
that they may not know?
Session 1: Penny, Newcastle

Q. How do you choose what to eat? What is most important? What does a healthy
diet mean to you? Do any difficulties get in the way of that? What would make it
easier?
• Penny reported that price was the overriding factor in choosing food and
stated: “It is what you can afford.”
• Penny referred to supermarkets reducing their prices at certain times and
said that she would choose from this section, looking at the reduced food to
plan what meals could be made from them.
• When asked about accessing healthy foods, Penny referred to price being the
main factor.
• She wondered whether people knew about healthy food and how to prepare
it.
• Penny told us that she would buy some kinds of food (for example, chicken
nuggets and chips) because she could be confident children would eat it, as
opposed to vegetables which would not be eaten, wasting money.
• She believed that healthy food costs more than other food.
Q. How easy is it for you to cook? What would make it easier for you to cook at
home?
Q. What does food poverty look like for you or people in your community? What
effect does it have on daily life?
Penny told us that:
• The amount of energy on the meter can limit what you cook: soup only
requires one pan, whereas a full meal requires more energy.
• Equipment is important: some people are only able to eat things that can be
heated in the microwave
• Food poverty has a big effect on daily life.
• There is a limited choice in the content of food parcels at food banks—you
get what you are given. You can also get given things in a food parcel that
you don’t have equipment to cook
• A lot of dietary requirements are not always considered in food parcels.
Penny told us that she has a dairy intolerance and cannot drink the long-life
milk in the food parcels
• Penny questioned the point of giving tins to homeless people—to eat tins you
need a tin opener, a pan, and a hob.
• Penny suggested that food can be more expensive if you have an intolerance.
She estimated that non-dairy milk is 40p more expensive than cows milk.
Q. What effect has coronavirus had on your diet or ability to access food? What
effect has it had in your community?
• Penny has two key workers in her home.

• She felt that delivery slots are not working and that there didn’t seem to be a
priority for NHS staff getting deliveries, in her experience.
• Penny told us that printing vouchers is a barrier for accessing food, there is
nothing in place for those who cannot do so.
• Attending schools to collect meal vouchers is an added inconvenience
• She said that stockpiling had reduced the range of products available in the
shops. She believed that people on higher incomes have bought lots during
the pandemic, but waste more, so lots will spoil.
• Penny has extra food in her house and will give it to people on her estate who
are struggling: people will ask others in the community for help rather than
accessing help elsewhere. She told us: “It is a pride thing too, just because
you have no money does not mean you have no pride”.
Q. Do you have any suggestions for what government, councils or other public
services could do to help?
• Penny said that the Government should look at Universal Basic Income, so
everyone has same amount whether working or not. It would give enough
money to buy the food needed to stay alive. Penny praised nearby councils
for being connected: she believes they aim for people to be thought of as
people and not just a statistic.
• Penny said that Universal Credit is all online but that many people are
not tech-savvy or cannot afford to be. She pointed out that public WiFi is
unavailable at the moment, but if you don’t have access to WiFi you cannot
do the job searches required by Universal Credit
• Penny mentioned “next day shops” where you can bulk buy food about to go
out of date. Includes McDonalds and Greggs.
• Penny said she thought education on cooking and budgeting is important.
Schools need to: “Teach kids how to cook, especially on a budget”
• She said that Government funding cuts have diminished general support,
including citizens advice, which was great but has had cuts. Council used to
run drop-ins and tea sessions. She said that more support should be available
via phone for people who do not know how to fill in forms.
• Penny said that charities are taking on the bulk of responsibility over the
councils: “Charitable people have come in and propped it up, they’ve had
to take on more and more”. Penny said her local food bank closed before
lockdown due to the age of volunteers—leaving a provision gap of around a
month.
• When Ben Pearson asked about the impact of the COVID-19 outbreak on
her mental health, Penny said lockdown has had a big impact on mental
health. Her interactions with people have changed. She gets a phone call
from her mental health nurse every 6 weeks and her operations are delayed
until possibly next year.
• When asked if lockdown impacts on her dietary choices, Penny said: “Yes! If
you haven’t got it in, you aren’t going to risk going out and getting it.”
• Penny said that it is sometimes cheaper for her to buy a takeaway than to
cook. She said that the local chippy can feed three people for a fiver: cheaper
than in shops, especially when accounting for energy usage to prepare food.
She said that takeaway options are very unhealthy, fried and processed food,
full of fats and grease. She said that as long as kids are not crying because
they’re hungry–fast food is what you are going to do.
• Penny said that schools can give children fruit and vegetables, because they
can afford waste: but you can’t do that, you will give your kids food they are
going to eat
• Penny told us that three quarters of people on her estate use pre-payment
meters which are more expensive than paying by direct debit.
• Penny said that more people need to speak out. She believed that there has to
be more people like this who say: “I think this is wrong, we need the support”.
People who live like this shouldn’t have to live like this. She believed that
people should be shown that they can have a voice and can speak out, they
can be heard, and that this will show the Government that there are more
people in poverty than in wealth
Session 2: Tia, Blackburn with Darwen
Q. How do you choose what to eat? What is most important?
Q. What does a healthy diet mean to you? Do any difficulties get in the way of
that? What would make it easier?
home?
• Tia told us that she distinguished between good weeks and bad weeks. If
it’s a good week, she will try to get ingredients to make a whole meal such
as curry (which is good because there will be leftovers for another meal).
On a bad week, she will have frozen food as it is a meal all in one, making it
cheaper overall than making a homemade meal. She said that if you buy a
frozen lasagne you can wait to cook it any night of the week but using fresh
ingredients a fresh one needs cooking within days so there is less flexibility.
• Tia has had free school meals. She was given £2. A hot meal is £1.50 so
she had to get the selected meals: she could not choose to add or mix the
elements of the meal. Tia told us that there are separate lines and tables for
free school meals and lunchboxes and different tables, so she feels like the
stigma starts very early on.
• Tia told us that if you have a choice of drink from the shops, a smoothie is £4
and coke is £1 so she thinks that healthy food is more expensive than cheap
food.
• Tia told us that school didn’t start until 9am and that you could get a free
piece of toast and tea at 8.30am but that lots of people didn’t come in early
for a piece of toast.
• Tia told us that to get free school meal vouchers during lockdown, children
have been asked to wear their school uniform and have to walk across town.
• Tia told us that she feels lots of people in her community are struggling with
food insecurity, but they don’t want to talk about it because there is such a
stigma.
• Tia told us that there are informal support networks for those who don’t have
family and that there is a Facebook group to get support. Otherwise friends
get food from friends to avoid being judged by anyone else.
• Tia told us that at the start there was panic buying before her mum had been
paid, so there were limits on how much they could get. At first, they couldn’t
get pasta. She said that usually her grandparents will provide lifts to get to
the shop. During lockdown, this couldn’t happen, so Tia’s mother now goes
out more often and does more trips to carry everything she will need for the
next few days.
• In the area where Tia lives there is one tiny ASDA, one Iceland and a giant
Sainsburys which she says is too expensive. Tia said that because the ASDA
is so small, people have to go to multiple shops to get what they need: there
are not as many deals or reduced items.
• Tia believed that there should be more awareness of the people who are
struggling: not everyone is experiencing the same problems.
• Tia explained some problems at school related to poverty and food insecurity.
Teachers might give detentions which take over half of lunchtime, and lunch
might be the first meal of the day for some children. She also provided
the example of a bake sale for a charity at school, where not everyone can
realistically donate. Tia said she felt like teachers were “picking on” students
who come in in their trainers, haven’t eaten and are misbehaving, rather
than wondering what else is going on. She said she felt like unhealthy food
options also affect behaviour and energy levels.
• Tia had cooking lessons in secondary school but she said that they are not
taught how to budget for the ingredients. She said that you are expected to
bring in the ingredients, and that students get a detention if you don’t have
the ingredients, but that their parents might not have been paid yet. Tia also
said that non-uniform days at school are £1 each. Tia is one of three siblings,
so her family has to spend £3.
Q. The Committee will be making suggestions to enable more people to access a
healthy diet. Is there anything you think they should understand that they may
not know?
• Ben Pearson asked Tia if the Government should do something differently

to promote a healthy diet to make it more in line with people’s experiences.
Tia said that she feels the Government creates a stigma, suggesting that
everyone can eat a healthy diet, but they can’t: it is more expensive.
• Tia told us that people are shown the negatives of the food they eat, for
example, the video of what goes into a chicken nugget. She said she feels
that this does not address the problem that a chicken nugget may be all their
parents can afford.
• Tia said she felt like the Government talk about all the options people have
but don’t talk about how they are going to do it or carry out it.
Session 3: Monica, Oxford

• Monica told us that it is what is the cheapest and what is available at the
time—things that are easy to cook. She said that she thinks fresh food is
more expensive so choosing what is cheap, including frozen, despite knowing
what is in it.
• Monica has to eat healthily because she has IBS, but has to really budget to
make do. When asked if anything other than price would make it easier to
choose the healthy food, Monica said no, only price. She said every penny
has to be budgeted on benefits.
home?
• Monica told us that not having cooking equipment gets in the way of
cooking—people make do or use a microwave. The right equipment would
make it easier to cook food, and a lot of people haven’t got access to a cooker
or cooking equipment at all.
• Monica said, when cooking, you have to make sure you have enough gas and
electric on the meter asking yourself if that is going to finish this meal. Then
it is a choice putting gas on with your last £10 or buy food with your last £10.
She said it can be very difficult at times.
• Monica works with people in extreme food poverty, and at the moment she
is seeing a lot of in-work poverty in Oxford, even more so since COVID
because people have lost their jobs, having to rely on foodbanks.
• When asked by Ben Pearson if in-work poverty is overlooked, Monica said
that people assume people in-work are ok, but some people are working three
or four jobs to keep a roof over their heads and food on the table. This gets
over-looked because they are working.
• Monica had previously been homeless. She said that when she had been
homeless, the idea of healthy food was not a priority compared to getting
enough food. She had known what a healthy diet was but couldn’t access
the facilities to be able to cook a healthy meal. Ben Pearson asked about
the impact of hunger on Monica’s mental health, she said that hunger does
impact on your mental health and on your tiredness, as well as on behaviour.
• Monica said that some of the people she works with don’t have a cooker or a
microwave just a single hob for beans and toast.
• Monica said that lots of children are going without a meal, as the only meal
of the day was at school. These children might just have a sandwich and a
packet of crisps.
• Monica works for a charity which has delivered 500 food parcels to the
vulnerably housed during April. When asked if there was support for this
charity from the Government to provide food during lockdown, Monica said
that there was hardly anything, and that charities and groups have formed
to fill the gap: this relies on the goodwill of the people of Oxford to come
together.
• When asked about the Free School Meal vouchers during coronavirus,
Monica said that the vouchers have not been accessible for a lot of people,
and that is what they rely on to purchase food. She said that the facilitator
was struggling to keep up with demand. The vouchers had taken weeks to
come through, then, when received, they often do not work in the shop.
Families then go back to the issuer, and the vouchers get resent. She said that
some schools just made up packs and delivered them to students.
• Monica told us that many adults are going without food because they would
rather their children eat. She thinks that this is more common now during
COVID-19 lockdown. She said that more people have been pushed to ask for
help, which they do not usually do because of shame and stigma.
• She spoke of some difficulties in applying for Universal Credit. She spoke
about job centre staff as being hit and miss with whether they are helpful
or truthful. She said Universal credit leaves very little money to buy healthy
food after bills. Many of her clients buy food and then don’t pay bills, getting
themselves into arrears.
Q. The Committee will be making suggestions to enable more people to access a
healthy diet. Is there anything you think they should understand that they may
not know?
• Monica said that the Government should look at how little people get on
benefits and that it is not much once you’ve paid your bills.
• When asked about budgeting, Monica said that the job centres provide very
little help. There is a programme where job centres can “money manage”,
taking charge of the benefits received, paying bills, and paying small amounts
daily to recipients, which works in some scenarios but not in others. Monica
said that UC is a difficult system to navigate.
• Monica suggested more provision for breakfast clubs and afterschool clubs.
She said children go without breakfast and have to wait until lunch to get
food. After school clubs have been cancelled because of cuts to funding.
Session 4: Cath, Newcastle
• When asked about priorities for food choices, Cath said that “full tummies
are at the top every time.”
• Cath said that the ‘yellow sticker’ reduction aisle is important. Cath waits
for items to be reduced by supermarket staff and doesn’t know anyone who
doesn’t do this. She buys minced meat and chicken as it can be used for
multiple dishes - people on a budget will have left over meat for another dish.
• Cath said that she buys frozen vegetables as they are a lot cheaper than fresh.
This affects the variety of what one eats.
• When asked about food labelling, Cath stated that labels were not important:
fortnightly money arrives, bills are paid, then shopping has to be as economic
as possible. She said: “You just want to make sure tummies are full - you
don’t care about labels”.
• When asked about the logistics of shopping, Cath said that you might learn
times and places for reductions: that knowledge is shared with others in the
community. Cath does not drive, so she cannot do a full fortnightly shop.
home?
• Cath told us that equipment in social housing can mean that cooking takes
much longer. When asked by Ben Pearson about energy costs, Cath stated
that she replaces cooked meals with sandwiches o-r porridge with water.
• Time was also an issue. She questioned why she would make her own pizza
when pizza can be bought for £1 and 15 minutes in the oven.
• Cath said that in the last few days before money arrives, she might only eat
one meal a day.
• Cath said that she thinks many people may not know they are in food poverty.
Taking food from donations, projects giving out food, and people sharing
food is very common and normal, it is just seen as people being kind.
• Cath spoke of disappointment from sharing information with charities and
completing surveys. “They’ve been surveyed to death”. People want to see
outcomes, and something change.
Q. What would you say is the most important effect of coronavirus for you? What
effect has coronavirus had on your diet or ability to access food? What effect has
it had in your community?
• Cath said she has had to admit she cannot navigate day to day life without
a mobility aid, so she has obtained one. She said that her mental health has
been bad during this time. She is worried she is putting a lot on her partner.
• She said that people are not aware of the support available, which is itself
sporadic. Cath stated that access to support is like a lottery, it is dependent
on having the right telephone number. People do not want to knock on
doors because of the virus, so many people have slipped through the net,
particularly those who do not have internet. She suggested that organisations
should do a leaflet drop, providing telephone numbers.
• When asked about the school meals vouchers, Cath stated that these now
have to be collected from the school on particular days.
• Cath mentioned three local initiatives which she thought could be learnt
from and perhaps extended.
• The Pantry. This is an example of a social supermarket, to give dignity to
people using foodbanks. £1 joining fee, then donated food is purchased at
half-price. One can get extra big boxes of food.
• The Food Forest, Middlesbrough. Allowing people to grow their own food.
• Feeding Families. This organisation feeds people via social services and
job centres. Cath suggested that this organisation could tap into more local
groups, allowing them to access wider client groups. There should be some
way of combining that with other voluntary groups who are just as valuable.
Q. The Committee will be making suggestions they hope will allow more people
to have access to a healthy diet. Is there anything that you think they should
understand that they might not know?
• Cath suggested that Government appears to “live in a bubble” and does

not take in the reality of how much things in supermarkets cost. She said:
“working families are having to access food banks, do they not hear that?”
• She stated that interpersonal support is crucial and that people need a
friendly face and someone external to talk to. Support groups play a part
in encouraging people. They might, for example, encourage someone to try
gardening and growing food, or to take part in a group such as Food Power.
• When Ben Pearson asked whether social welfare support provides enough to
have a healthy diet, Cath said that she did not think it did.
Session 5: Heather, Newcastle
• Heather said that price and time were the key points, and that it has to be
cheap and quick. She also said time was a factor and that she “doesn’t have
time to ‘chop everything individually”.
• Heather said she would only buy shop brands. Frozen vegetables are cheaper
in larger quantities. She gave the example of stir fry which uses frozen, pre
prepared food.
• When asked if she uses take-aways, Heather said she does, because it is
cheaper. She said that a standard portion of fish and chips will feed three
in her household. She said that this is around £5-£7 and can feed three for
a meal. Making it yourself can cost more, if not around the same. When
energy costs are factored in, it is more expensive to cook it yourself.
• Heather spoke about energy costs. She uses the electric cooker, rather than
gas. She had to change to electric cooker after having moved house and this
was an extra expense. She said sometimes she might have to choose between
cooking or putting the heating on. She talked about having to keep warm
without heating.
• Ben Pearson asked about logistics of shopping. Heather does one big shop
a month. For her, shopping on her own isn’t something she can do due
to disability as she needs help carrying things. Said she is lucky to have a
big Asda which is in theory within walking distance. She told us that she
does get deliveries but there is a minimum required spend on delivery, so
she sometimes has to go to the corner shop, which she thinks is far more
expensive. She said that a can of tomatoes can be 50p more in corner shop
than Asda.
• Heather thought that fresh fruit and vegetables are more expensive. She
stated that you cannot eat healthily if living in food poverty. Focussing on
trying to get fruit and veg can waste money, leaving nothing for staples such
as pasta and bread. She said that with nuggets and chips, you get more for
your money—it lasts longer and feeds you more. Fruit and vegetables go off,
people need food that lasts.
• She said that, in the social supermarket (the Pantry), it is a ‘lucky dip’. She
said that there were lots of potatoes but not much in way of other vegetables
and fruit, which were also rare to see in the food surplus distribution centre.
She says that it is a struggle to eat healthily when using food surplus centres,
and that you can’t plan in the same way. Food choice depends on where she
can go shopping.
• She said that food is more expensive in the city centre (where she works), and
she cannot always bring food into work.
home?
• When asked by Ben Pearson about energy costs, Heather suggested that if
essential uses of electricity (light, cooking etc) could be distinguished from
non-essentials, the essentials could be free. She said that people have to
choose between these things. She stated that it was depressing to be always
aware, she felt like had to ration the heating and always had to be conscious
of putting heat on for an extra half hour. She has had to give blankets to
friends visiting her, and felt like this put people off coming round. She felt
isolated because of this.
• Heather spoke about mental health getting worse when everything is
‘spiralling’.
Heather spoke about some techniques she has to follow to deal with food
poverty. These were:
• Choosing only own brands.

• Shopping in reduced section for fresh fruit, vegetables and meat.
• Putting as much as possible in the freezer to keep it for as long as possible.
• She said this was draining as you had to go out every day to get reduced
sticker items. She said what you can eat depends on what you could get.
• Heather mentioned fuel poverty, and of trying to find food that doesn’t need
to be cooked. She said that this is hard for people on pre-paid meter, who
have to constantly check how much energy they have and working out if its
more expensive to boil kettle for pot noodle, or cheaper to freeze or use oven.
Heather said she was constantly having to make choices, but that you don’t
have a choice whether to think this way. It is ‘mentally draining’ having to
think about energy costs and cooking.
• When asked what she does when there isn’t enough food in the cupboard,
Heather said that: “Most people just don’t eat.”
• Heather stated that “no one wants to admit it, they feel like failures”. It is
only when you have relationships with people that it is possible to admit food
poverty. One of her friends at the same place at work regularly has to say to
her, ‘I haven’t eaten in two days’. It took her friend a long time to ask for help.
“She is a proud woman and doesn’t want people to know she is struggling”.
• Heather referred to in-work poverty. There are 3 people in her household,
working most of the time, (one is part-time), but they still can’t afford food
all month round. She said: ‘there is always something going on which is
ruining their ability to get them through the month’
Q. What would you say is the most important effect of coronavirus for you? What
effect has coronavirus had on your diet or ability to access food? What effect has
it had in your community?
• Heather said that the 20% of pay that furloughed people are not receiving
might be their food budget for the month. She suggested that this could be
the difference between paying one bill and paying the food, then ending up
in debt, extra letters and stress on them. Then they have to choose bills over
food.
• Heather said that people in her community have always lived pay-check to
pay-check: she thinks that most people are about 2 bad months from being
homeless.
• Heather said she thinks that people don’t have money to save for a rainy day,
so there are no savings. For example, if the fridge or freezer breaks, they
won’t get a replacement for a long time.
• Heather said it is cheaper to buy frozen mince in bulk than fresh. Not
everyone has the space to store bulk bought products, so people are forced to
buy smaller, more expensive things (eg mince). They cannot stockpile.
• She can only buy some kinds of meat. For example, while she really likes
lamb, she would never buy it as it is always expensive. She always went
without lamb because she can make more with equivalent mince, which will
last longer, for less than the price of one leg of lamb. It also takes longer to
cook.
• Heather said she would like to grow vegetables but has never been able to
afford an allotment. If there were more space, growing vegetables would be
a good idea, providing this food to the community.
• When Ben Pearson suggested that local councils should provide more
community gardens, Heather liked this idea. The allotments near her aren’t
owned by the council any longer, they are owned by a private group in
Newcastle area. “You don’t get a response from councils either”.
• Heather said it would be good if the community could use spare plots of land
near them, they could grow some vegetables, and, if not vandalised, it would
look nice.
Q. The Committee will be making suggestions they hope will allow more people
to have access to a healthy diet. Is there anything that you think they should
understand that they might not know?
• Heather said that a lot of people don’t want to be on benefits. She said people
feel like failures but sometimes they can’t help it, for example physical or
mental illness. Making PIP (Personal Independence Payments) easier to
access would be helpful for people with disability. She thought that universal
basic income would be a good idea, and give people the “ability to live, not
just survive”.
• She said that she thinks people working in DWP do not understand people’s
position because they have always got pay-checks coming in. She understands
the reality of people not knowing when next payment is going to come in, or
whether they are going to sanctioned if their baby’s ill: “they have never lived
it so they don’t know”.
• She spoke about “People having some humility”, and that people should
realise that not everyone getting benefits is a “scam artist”. She spoke about
the third generation of families not working, but this can be to do with ill
health or poor mental health. She feels that relationships should be built to
try and understand the reasons behind not working. She said that workers in
job centre should have more empathy for people who are not having a good
time but are trying to do the best they can.
• Heather sits on the financial exclusion group in her local council. She said
she “tells them how it is”. She passes on the experiences of others, providing
a voice: “we are not there to look at figures but they can put figures where
they need to” She said that: “Unless people tell them they won’t know!”
• Asked by Ben Pearson if all councils should have this function, Heather said
that she thinks this should be mandatory. She said all councils should have a
group of people who can state ‘grass roots’ views. Every council should have
this interaction with people.
Appendix 6: LEEDS VISIT
Members of the Committee and the secretariat were due to travel to Leeds on
18 March 2020 to understand the work done by Leeds Council and by local
organisations in tackling issues regarding food insecurity in the area. Unfortunately,
due to the COVID-19 outbreak, this trip had to be cancelled.
The Committee was due to meet with members of Leeds Council and representatives
from local organisations. The visit would have included a visit to the Compton
Centre, which is one of the Council’s Community Hub sites. The Committee
delegation was also due to visit Neruka’s Soup Kitchen, a project providing meal
provision for people in need of food, and CATCH, a community café and Healthy
Holidays Programme Leader.
We are grateful to Emma Strachan and Nick Hart of Leeds Council who helped to
plan the visit and who have very kindly shared the planned presentations from the
organisations we would have met, as well as a briefing712 detailing their response
to the coronavirus crisis.
The following organisations supplied presentations as written evidence to the
Committee:
• Leeds Food Aid Network713
• Foodwise Leeds714
• FareShare Yorkshire715
• Leeds Community Foundation716
712 Written evidence from Leeds City Council (ZFP0101)

714 Written evidence from Foodwise Leeds (ZFP0102)
715 Written evidence from FareShare Yorkshire (ZFP0103)
716 Written evidence from Leeds Community Foundation (ZFP0104)

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HOUSE OF LORDS

Select Committee on Food, Poverty,

Report of Session 2019–20

Hungry for change:

Ordered to be printed 23 June 2020 and published 6 July 2020

Published by the Authority of the House of Lords

Evidence is published online at https://committees.parliament.uk/

Q in footnotes refers to a question in oral evidence.

trends in food insecurity can be linked to wider socioeconomic reforms, and

2 In relative low income before housing costs.

16 Q 123 (Jo Churchill MP)

1. The future configuration, resilience and efficiency of the UK food system is

The inquiry and the Committee’s work

and Activity Research and MRC Epidemiology Unit, at the University of

Box 1: A note on definitions

Chapter 2: THE CURRENT SITUATION

The food system at a glance

• In 2018 the agri-food sector contributed £121 billion or 9.4 %

• The UK food and drink manufacturing sector contributes more than

• Agriculture and fishing employs almost half a million people in the

• The supermarket industry is dominated by four large companies. The

Agri-food Agriculture and Fishing £10.4bn

Food and Drink Manufacturing £28.6bn

Agriculture and Fishing 0.44m

Food and Drink Manufacturing 0.43m

Food and Drink Retailing 1.17m

Largest food manufacturing category in 2017:

Figure 2: UK Trade in different food groups, 2018

Fruit and veg

• In 2017, the largest manufacturing category (with a value of £6 billion,

• UK households have been shown to purchase the highest proportion of

• The proportion of advertising spend on less healthy foods is significantly

38 The Food Foundation, Food System Challenges: https://foodfoundation.org.uk/food-system-challenges/

healthy food products, compared to £16 million spent on fruit and

• The UK population’s fruit and vegetable consumption is low. The

• While consumption of fruit and vegetables is low, consumption of less

Figure 3: UK grocery market shares, 2017/18

Diet and health

• It is estimated that the NHS spent £6.1 billion on overweight and

• Excess calorie consumption (in relation to energy expenditure) is the

• In 2018, the majority of adults in England were overweight or obese

• According to the Organisation for Economic Co-operation and

• A study using data from over 400,000 patients aged 40 to 69 from UK

• A study by the OpenSAFELY collaborative used a dataset of 17 million

• In 2017, prevalence of excess weight was 11 percentage points higher

• Children living in deprived areas are around twice as likely to be obese.

landmark report on health inequalities. The report examined the progress

• Life expectancy follows the social gradient—the more deprived the

• The gradient in healthy life expectancy is steeper than that of life

impacts on health and wellbeing; likely contributing to inequalities in

Diet and food production

• Agriculture is responsible for 87% of UK ammonia emissions (mainly

• Evidence from the Food Foundation, the London School of Hygiene

Current Government intervention

or sustainable to facilitate the change in levels of childhood obesity needed to

72 Q 65 (Professor Susan Jebb)

National Food Strategy

The ‘real’ cost of food

77 Q 29 (Alison Ismail)