Last updated: 10/09/2024
Data collection on healthiness of product portfolios
Mandate data collection of sales and nutritional information for large businesses (in a data reporting framework such as the FDTP)
- Very low impact on obesity
A percentage estimate of how much the policy would reduce national obesity rates
- Relative reduction in obesity prevalence: 0%
- Low evidence quality
A rating of the strength of evidence, accounting for both reliability and validity of the evidence
- Reliability and validity rating: 2/5
- Very low cost to governments
Cost to UK and devolved governments over 5 years
- Costs to governments over 5 years: £1m
- Benefit to governments per year: £0
What is the policy?
This policy proposes that medium to large food retailers in the UK must annually disclose the ratio of healthy to unhealthy food products sold. Eligible companies would be obligated to submit these reports each year through a government portal administered by the FDTP. Non-compliance would result in substantial government-imposed commercial and/or financial penalties.
Increased transparency can be a powerful mechanism for changing corporate behaviour. The proposed policy can drive change in two significant ways. Firstly, it serves as a crucial mechanism for supporting the implementation of government-sanctioned health targets within the food industry. Secondly, by fostering transparency and accountability, it could shed light on the biggest contributors to unhealthy diets, putting pressure on them to improve, whilst positively contributing to the reputation of the healthiest players in the industry.
Recent context
Transparency within the UK food industry is limited and there is no impetus for companies to publish data on their contribution to the sales of unhealthy food in the UK. According to The Food Foundation’s 2023 benchmark assessment of 27 major UK retail and out-of-home food companies, only eight companies (Aldi, Asda, Greggs, Lidl, M&S, Sainsbury’s, Tesco and Waitrose) have a target and publish data on the percentage of their sales coming from foods high in fat, salt and sugar (HFSS), whilst six companies (Compass Group UK & Ireland, Sodexo, Lidl, Sainsbury’s, Tesco and Waitrose) have a target to disclose data on the proportion of income derived from sales of fruit and vegetables.
The UK FDTP was established in response to the National Food Strategy’s recommendation for increased data transparency on metrics related to sustainability and health in the food system on the part of the food industry. The FDTP is tasked with agreeing comprehensive data-sharing frameworks and standards amongst the food industry. This includes data on a variety of key health metrics for the food consumed in the UK.
Currently, plans for data sharing under any proposed FDTP agreements are purely voluntary, meaning companies may pick and choose which, if any, of those agreed metrics they wish to report on. The implementation of this policy would require the UK FTDP to change their reporting requirements to make them mandatory. Such a policy change would facilitate the establishment of an effective data collection and monitoring system for food-related health metrics, serving as an essential foundation for enforcing any mandatory health targets elsewhere in the food environment.
Similar to England, no such reporting requirements exist in Wales and Scotland. The implementation of mandatory reporting via UK Government legislation would not automatically apply to Wales, Scotland and Northern Ireland, as health-related policies are a devolved matter in these nations.
Case studies
Mandatory environmental reporting requirements
The implementation of mandatory environmental reporting requirements provides a good evidence-based example to show how mandatory reporting and data transparency can positively influence corporate behaviour. Evidence in this sector has indicated that voluntary reporting regimes do not tend to boost environmental performance. For instance, Haque and Ntim (2018) found that companies adhering to voluntary reporting guidelines, although more inclined to engage in carbon reduction initiatives, do not necessarily improve their carbon performance.
In contrast, accumulating evidence indicates that when government mandates companies to disclose their environmental impact data, such as emissions levels, waste generation, and/or energy consumption, it leads to positive outcomes in several key areas, including improved environmental performance, stakeholder trust and engagement, market differentiation and competitive advantage. Research indicates that companies subject to mandatory environmental reporting tend to reduce their environmental footprint over time.
The impact of the UK’s introduction of mandatory reporting on greenhouse gas emissions in 2013 has been examined in four separate studies. The findings from all studies indicated that mandatory reporting was associated with reduced carbon emissions in UK companies relative to control companies not subjected to the law. In a review, Christensen (2021), highlighted that several mechanisms may have driven the reductions. Jouvenot and Krueger (2019) found investor pressures as a potential driver of effects, consistent with Bolton and Kacperczyk (2021), whilst Tomar (2023) and Grewal (2021) found emission reductions were likely associated with peer benchmarking.
Considerations for implementation
Legislative change would be needed to create the legal instrument for making reporting mandatory. This could be achieved for example via secondary legislation using the Food Safety Act 1990. It would also necessitate establishing a body, or co-opting an existing body, to undertake responsibility for monitoring and enforcing compliance with reporting requirements.
Implementation in the devolved nations
To ensure consistent application across the UK, Westminster should work collaboratively with the Scottish and Welsh Governments to establish a unified approach. This could be through replicating the legislation with adaptations or through formal consent for its application. There is already good cooperation between the Scottish and UK Governments on this issue through membership of the FDTP. The government of each devolved nation would need to be asked to replicate the Westminster legislation or consent would need to be provided for any new legislation to be applied to them.
Estimating the population impact
There is currently no evidence on whether increasing the availability of data on health metrics for the sales of food has an impact on the healthiness of food sold, dietary behaviour or obesity-related outcomes.
We therefore assume no impact if this policy was implemented in isolation, without subsequent implementation of mandatory targets to increase the healthiness of product portfolios.
Changes in the prevalence of people living with obesity
There is no evidence that this policy alone would impact on national obesity rates, however implementation of this policy is necessary to facilitate the implementation and monitoring of other policies in this toolkit (for example, implementing maximum calorie guidelines, mandating retailer healthy food portfolio targets).
| Adults (England and Wales) | Children 5-18 (England and Wales) | Adults (Scotland) | Children 5-18 (Scotland) |
| 0% | 0% | 0% | 0% |
Cost and benefits
Cost over five years
We estimated that this policy would cost the governments approximately £1 million over five years.
We commissioned HealthLumen to estimate the cost of the policy to both industry and governments over a five-year period.
Table 2 below shows a breakdown of costs. The annual cost to the national governments is estimated at approximately £0.2 million. The costs to the food industry are estimated at £2.5 million. Please see cost calculations appendix for more details.
| Group affected | Cost | Horizon | Detail |
| Costs | |||
| Government | £1m | Annual (5 years) | Annual cost of reporting |
| Industry (Retailer) | £2.6m | One-off | One-off cost of inspection and reporting to Food Standards Agencies. |
Total annual benefit
We estimated that this policy would have an annual benefit of approximately £0
Implemented alone, there is no evidence that this policy would lead to decreasing the prevalence of obesity. Hence, this policy would not lead to monetary benefit for governments.
Impact on disease incidence
Based on our analysis and analysis conducted by HealthLumen, there is no evidence that this policy would impact disease incidence avoided after five years.
Behind the averages: impact on inequalities
On average, individuals with lower incomes and residing in areas with lower Index of Multiple Deprivation (IMD) scores tend to purchase larger quantities of HFSS products. Consequently, the mandatory reporting of sales data comparing healthy and unhealthy foods might result in long-term increases in the prices of HFSS products, disproportionately affecting lower-income groups.
However, it is equally plausible that enforced transparency could prompt companies to enhance the proportion of their sales attributed to healthier options, such as fresh whole foods, by offering reduced prices and increased promotions. This could potentially enhance the affordability of the healthiest food choices.
Rating the strength of evidence
We asked experts working in the fields of obesity, food, and health research to rate the strength of the evidence base for each policy, taking into account both reliability (size and consistency) and validity (quality and content) of the evidence. Policies were rated on a Likert scale of 1–5 (none, limited, medium, strong, and very strong evidence base). The Blueprint Expert Advisory Group rated this policy as having a Limited evidence base.
Incentivise reformulation of HFSS
Reduce energy density by 10% in HFSS by providing reformulation grants to retail and OOH businesses (repayable if conditions not met)