The FSA has finally published its draft report on how to reduce the average amount of fat and sugar in people's diets. It wants suppliers to reduce the saturated fat and sugar levels of products, to make lower- fat alternatives more readily available, and to produce smaller portions of high-fat foods. It also wants to set 'voluntary targets' for levels of fat, saturated fat and sugar.
All noble stuff, but the industry has hardly been dragging its heels. Big names such as RHM, PepsiCo, McCain, Kraft, Heinz, Kellogg and Dairy Crest have made huge positive changes to their portfolios in the past couple of years.
Given this, is the latest move by the FSA necessary? Will introducing targets help the industry - or just derail some of its good work?
Dairy Crest, for example, launched Cathedral City Lighter, which contains 30% less fat, while RHM has brought out a lower-fat range of its Mr Kipling cakes called Delightful. PepsiCo has switched production of Walkers crisps, and more recently its snacks brands, to Sunseed oil, slashing their saturated fat content by 70%. Last year, Leaf UK launched Red Band, a confectionery brand with up to 55% less sugar.
The introduction of any guidelines could belittle this hard work, says the Biscuit Cake Chocolate and Confectionery Association (BCCCA). "We have demonstrated that self-regulation can work and our sectors continue to respond to the health debate with substantial changes being made without regulatory intervention," says a spokeswoman. "We have to look at how much companies decide what consumers should be eating and how much consumers need to decide for themselves."
Government intervention could hamper future reformulation, agrees George Yarrow, director of the Regulatory Policy Institute. He says the FSA should not be imposing any types of guidelines on manufacturers. "The FSA was set up to deal with food safety issues and shouldn't get involved with diet issues," he says. "It is the wrong way to tackle obesity."
Commercial reasons are already driving reformulations, says Yarrow and will continue to do so irrespective of government targets. "The food industry can take care of itself. It is good commercial practice."
PepsiCo, after all, says its switch to Sunseed oil for its Walkers brand was to turn around a decline in the market. RHM's Delightful range was also developed to reverse a fall in sales across the Mr Kipling portfolio.
The BCCCA is also concerned that targets could cause more problems than solutions. When the FSA introduced salt targets in 2004 it had little difficulty persuading consumers about the problems of salt intake, says the spokeswoman, but there will always be a demand for indulgent lines that require sugar and fat. "To change the recipe of a product that has been around for 100 years is quite drastic," she says. "Consumers will revolt if they can't buy the biscuit they want."
The role of sugar and fat in foods means cuts will also be harder to implement than those previously made to salt, she adds. "It would be very difficult to cut fat and sugar from bakery products. Salt is a preservative but it is mainly used for taste whereas sugar and fat have technical qualities."
And while reductions will be easy to do in some categories it will be much harder in others, raising the question of whether guidelines could actually work at all. Dairy, confectionery, meat and bakery manufacturers will take the biggest hit, says Geoff Talbot, who prepared a summary report for the FSA on possible reduction of saturated fat. He says cutting fat in pastry and bakery products, for example, would mean the addition of emulsifiers and preservatives. Chocolate and chocolate confectionery also poses a problem because of EU regulation on the amount of cocoa solids, a high source of saturated fat, that chocolate must contain. Without changes to the chocolate regulations it is almost impossible to make any improvements into the fat level in chocolate, he says.
A bigger headache will be on what basis targets will be set. The FSA is again consulting on whether to base them on the 100g portion (the basis of the notorious Nutrient Profiling Model), serving size or as a percentage of energy.
The FSA adds that its report will take into account the views of the industry - the deadline for responses is 19 June. No doubt it will also ask why targets must be set in the first place.How voluntary?
The FSA's draft report talks about setting 'voluntary' guidelines and targets for saturated fat and sugar reduction. But if guidelines are set, many companies could find themselves forced into making the cuts or risk being seen as acting irresponsibly.
In its draft report, the FSA says it would consider naming and praising companies that comply with any guidelines, but there is a danger this will also mean companies that don't make the required cuts will be taken to task, says the BCCCA. "We welcome naming and praising best practice but if it moves into naming and shaming it will be hard for some companies," says a spokeswoman.
A major concern is that smaller companies that rely on traditional baking to set their products apart from the major players, such as traditional shortbread manufacturers, will be hardest hit, because they will find product reformulation particularly difficult. "Smaller companies that have one or two key lines that rely on the use of butter, for example, will struggle to meet the targets," the spokeswoman says. "They will really suffer."
"If it is voluntary it is fine, but if it goes any further there will be big problems. We will need to see what happens next."
The FSA asserts that all targets will be voluntary. In its draft report it says that voluntary action is a more effective approach than the introduction of legislation. It will, however, monitor the progress of industry organisations in reaching the targets.