Here is our draft response to the government’s consultation. If you’re reading this, we would welcome your comments. This will help us finalise our response before the deadline of April 6th. You can send your comments to us at 



At Health Action Campaign our guiding principle is that prevention is better than cure. As the government’s 2018 vision paper on Prevention identified:

  • Prevention means stopping problems arising in the first place; focusing on keeping people healthy, not just treating them when they fall.
  • There is role for government to create the environment that makes healthy choices as easy as possible, and to address the conditions that lead to poor health.

Our own research has identified that eating too much food high in sugar, salt and saturated fat:

  • Increases the risk of people becoming overweight or obese but undernourished, with what we eat and how much (rather than physical inactivity) being the single biggest cause of obesity.
  • Increases the risk of diabetes, heart disease, stroke, some cancers and depression and may weaken the body’s immune system.

This research includes our 2015 report Healthy and Wealthy? which explored the health and economic implications for the UK of mass-producing food high in sugar, salt, saturated fat and refined carbohydrates.

In this context we very much welcome the Government’s consultation on restricting the promotion of food and drink which is high in sugar, salt and fat. We see this as a positive step towards the Government’s ambition of halving childhood obesity by 2030.

Making healthy choices the easy choices

To achieve the changes in food consumption necessary to improve public health it will be important to make healthy choices the easy choices. We therefore agree that action needs to be taken in relation to each part of the food and drink marketing mix i.e.


We consider the 2004/5 Nutrient profiling model (NPM) developed by the Food Standards Agency for Ofcom provides a recognised and established way of defining products high in sugar, salt and fat. It was specifically designed to determine whether individual products should or should not be advertised to children and is therefore particularly relevant in the context of prevention being better than cure.

The Nutrient Profiling Score is derived by comparing the 'healthy' content of a food product (protein + dietary fibre + fruit and vegetables) with the 'less healthy' content (energy + saturated fat + sugar + sodium). We consider this to be an appropriate approach.


Retailers should be required to ensure that all their volume-based price promotions on food and drink (including BOGOF) are on products which are low in sugar, salt and fat.

This means these price promotions should not apply to pre-packaged products which fall into the categories included in Public Health England’s (PHE) sugar and calorie reduction programmes and in the Soft Drinks Industry Levy (SDIL), and are classed as high in fat, sugar or salt (HFSS).

This means that such price promotions should not apply to:

  • Breakfast cereals, yoghurts, biscuits, cakes, confectionery, morning goods (e.g. pastries), puddings, ice cream, sweet spreads, fruit-based drinks and milk based drinks with added sugar.
  • Ready meals, pizzas, meat products, savoury snack products, sauces and dressings, prepared sandwiches and composite salads.


We support restricting the promotion of food and drinks high in sugar, salt and fat from prominent locations typically chosen to boost sales by encouraging impulse buying and pester power i.e. shop entrances, aisle ends and checkouts.


Less than 2% of food advertising in the UK is currently for fruit and vegetables. It is now time to begin to redress the balance, including by limiting the promotion of food high in sugar, salt and fat - which is currently the main focus of foood advertising in the UK.   

To ensure a level playing field and avoid the exploitation of loopholes we believe that restrictions on the promotion should apply across the board, including:

  • to all retail businesses in England that sell food and drink products, including franchises
  • to retailers that do not primarily sell food and drink, for example newsagents
  • to online shopping

 15th March 2019


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