A Healthier Future: analysis of consultation responses

7. Support for reformulation and innovation (Q6)

7.1 The consultation paper described the current situation across the UK to change consumer preferences and to encourage businesses to reformulate their products in favour of healthier food options. ^[30] It then went on to explain that while large food and drink manufacturers might have the resources to invest in reformulation and innovation, it would be more difficult for small and medium enterprises ( SMEs) – which make up 98% of Scottish food businesses – to follow suit.

7.2 The paper set out the Scottish Government’s commitment to investing £200k over the next three years to assist SMEs with this task, and went on to ask (at Question 6) about the specific support which would be required for Scottish food and drink SMEs.

Question 6: What specific support do Scottish food and drink SMEs need most to reformulate and innovate to make their products healthier?

7.3 A total of 241 respondents (109 organisations and 132 individuals) provided comments at this question. Advertising and media organisations did not comment, so the response from private sector and business organisations was, in effect, a response from the food and drink industry.

7.4 Respondents made a series of general points at this question, especially about the (lack of) affordability of healthier foods, the importance of changing the eating habits and preferences of consumers, and the inclusion of alcoholic products in the discussion around (obesity and) reformulation. Both individual and organisational respondents thought it was important to understand and incentivise consumer demand for healthier food, so that there is a market for (reformulated) products. This would involve educating the public in relation to healthier choices.

7.5 As regards specific support to SMEs, respondents focused their comments on (i) the availability of and access to guidance and expertise, (ii) staff training, (iii) the importance of incentives including financial incentives, and (iv) issues relating to reformulation. These points are discussed in turn below.

7.6 In relation to the Scottish Government’s proposal to invest £200k in Scottish food and drink SMEs over the next three years, respondents from all groups considered this to be much too small a sum (‘a drop in the ocean’), given that – as set out in the consultation paper – 98% of all Scottish food and drink businesses are SMEs. However, respondents did not make any specific suggestions about alternative sums.

Availability of and access to advice, guidance and expertise

7.7 There was widespread agreement about the importance of advice, guidance and expertise being available and accessible to all SMEs. Individuals and organisational respondents from all sectors focused on the importance of being able to access (i) written guidance and online materials, (ii) nutritional expertise including access to practical expertise and advice in the workplace, and (iii) opportunities for networking and sharing.

7.8 Respondents identified a wide range of topics for which advice and guidance was required including: the evidence on healthy eating / healthy foods / nutrition; the nutritional requirements of different groups and the veracity or otherwise of claims about the nutritional value of specific products; consumer demand; diversification options if some product lines are to be reduced or withdrawn; labelling; recipe development; choice of ingredients; cooking methods; and portion sizes.

7.9 Respondents from the food and drink industry, and particularly those involved in the OOH sector, discussed the importance of being able to access help and input from nutritionists in the workplace. Respondents talked specifically about accessing advice from a ‘registered nutritionist’, ‘Food Law Officer’, ‘food technology specialist’, or someone who was ‘suitably qualified’. Moreover, environmental health officers participating in the FSS engagement event saw a potential role for themselves in working with OOH establishments and manufacturers to advise on nutrition, signposting to information, and organising local training seminars.

7.10 Organisational respondents from larger food and drink manufacturing businesses suggested that the types of – highly productive – partnerships which they were able to have with research institutes and universities should be extended to SMEs. More generally, those in the research and academic sector thought it was vital that SMEs were aware of ongoing work in developing novel sugar substitutes and low salt alternatives.

Staff training

7.11 Respondents from the OOH sector, as well as public health and partnership bodies suggested that opportunities for (low cost) staff training and development should be made widely available to SMEs. These respondents said that staff would need to acquire new knowledge and skills in a wide variety of areas including diet and nutrition, cooking methods (frying techniques and temperatures were mentioned in particular) and (the nutritional quality and composition of) ingredients.

Incentives including financial incentives and funding support

7.12 Paragraph 7.6 above has already discussed the (perceived inadequacy of) the Scottish Government’s proposal to invest £200k in SMEs over the next three years. More generally, respondents from all sectors and groups talked about the need for ‘additional funding’ or ‘grant funding’ for SMEs. For example:

• Some partnership bodies suggested the use of ‘tax exemptions’, including rent and rate reductions. These suggestions were especially mentioned in the context of SMEs who were producing locally sourced food.
• Among public sector and third sector organisations and individual respondents, there was discussion of the use of ‘tax subsidies’ and / or ‘advertising subsidies’ to support the production and / or marketing of ‘healthy food’ (as established by testing against an established Nutrient Profiling Model).
• Some individual respondents also talked about using the soft drinks levy as a subsidy to SMEs, which (they thought) would also increase the transparency of the use of the soft drinks levy. They also suggested introducing a levy on larger businesses which could be distributed to SMEs.

7.13 As far as the specific purposes for additional financial support were concerned, respondents from all sectors suggested that the support should be used to undertake reformulation. In addition, a range of respondents (both individuals and organisational respondents from different sectors) suggested that financial support could be used for other purposes including to: incentivise (more) SMEs to introduce traffic light labelling; test new products; set up ‘taste panels’; allow SMEs to audit their current practice and to produce an improvement plan; and to improve their understanding of consumer preferences in order to market / advertise new products effectively. As regards this latter point, it was suggested that it would be worthwhile to provide greater support for the promotion of healthy Scottish produce through supermarkets, SMEs and food outlets.

7.14 In addition to financial incentives, it was suggested that the introduction of a ‘logo’, ‘charter mark’, ‘local award’ or ‘national award’ for ‘healthy, locally produced products’ might be useful in promoting innovation and reformulation.

Reformulation

7.15 Retailers, manufacturers and OOH outlets all made a positive case that much had already been achieved in relation to reformulation; indeed some retailers thought that they were reaching the limits of what could be achieved through reformulation. Respondents from the academic and research sector echoed this point and agreed that there were technical barriers (relating to taste, food safety, and product integrity) in relation to ever-increasing reformulation efforts. More generally, respondents from both the food and drink industry as well as from the public health and research communities, emphasised (i) the varying scope for reformulation that exists across different product categories, and (ii) the complexity of the task and the need for multidisciplinary teams (including all parts of the supply chain) to work on reformulation.

7.16 Respondents from across the food industry indicated that their efforts were often linked to the ongoing Public Health England reformulation programme. Respondents from all groups asked that those already engaged in reformulation (especially the larger manufacturing businesses) should be required to share their experience and expertise with SMEs.

7.17 A broad range of respondents, but third sector and public health respondents in particular, emphasised the importance of taking a wider view of reformulation and seeing it in a more ‘holistic’ context; removing or reducing specific ingredients was only one aspect – it was thought to be equally important to increase the use of nutrients and other ‘healthy’ ingredients.

7.18 Respondents disagreed in their responses about the role of artificial sweeteners in the reformulation process. While some manufacturers urged the government to give its explicit backing and support to artificial sweeteners (and argued that the general public needed to be reassured about the safety of these), other respondents, particularly those from the public health sector, were against any reformulation process which removed natural ingredients (including sugar) and replaced these with artificial substitutes. These latter respondents thought that the overall goal of the reformulation should be to reduce the overall sweetness of the product (not replace one form of sweetness with another), and they also objected to the introduction of ‘an artificial element into the diet’ which could affect the taste of a product.

7.19 Finally, and less commonly, respondents discussed whether a mandatory approach to reformulation was required. While a mandatory approach was supported by a range of public health and third sector organisations, and by respondents involved in large food and drink businesses (who wished to ensure ‘a level playing field’), it was not supported by those retailers or OOH sector respondents who commented.