Last updated: 10/09/2024
Mandate retailers and manufacturers to implement maximum calorie limits
Mandate large retail and manufacturing businesses to implement calorie reduction targets to reach the maximum calorie guideline for products in categories specified in Public Health England's (PHE’s) 2020 guidance
- High impact on obesity
A percentage estimate of how much the policy would reduce national obesity rates
- Relative reduction in obesity prevalence: 6%
- Moderate evidence quality
A rating of the strength of evidence, accounting for both reliability and validity of the evidence
- Reliability and validity rating: 3/5
- Very low cost to governments
Cost to UK and devolved governments over 5 years
- Costs to governments over 5 years: £0.2m
- Benefit to governments per year: £4bn
What is the policy?
This policy would mandate the maximum guideline for calories per portion across food categories reported in PHE’s calorie reduction technical report. Currently targets to reduce the calorie content of retail and manufacturer product portfolios are voluntary. This policy would mandate this target to all large food retailers providing own-brand and manufacturer-branded products.
The targets apply to food categories that have the greatest contribution to excess energy consumption, including but not limited to: ready meals, breaded and battered products, and chips/potato products. View full details of food categories (see page 12). This policy would be implemented by the UK Government, with penalties applied to large retailers that do not comply. In order to enforce this, retailers would be required to sign up to the Food Data Transparency Partnership (FDTP).
Recent context
There are no mandatory calorie reduction schemes in the UK for retailers or manufacturers. In August 2017, the Department of Health and Social Care (DHSC) commissioned PHE to develop a UK-wide voluntary calorie reduction programme, which was one of the key commitments in all chapters of the UK Government’s Childhood Obesity Plan. The programme’s scaled-back targets set 10% calorie reductions for retailers and manufacturers for categories including ready meals, breaded and battered food, family meals, chips and potato products and a 5% reduction target for crisps. The programme also recommends maximum guidelines for calories per portion across several categories (summarised in table 1). Approximately 8% of product sales are currently over the maximum guideline for calories per portion.
| Category | Maximum guideline for calories per portion (kcal) |
| Complete main meals (ready meals) | 570 |
| Breaded and battered products | 320 |
| Meal centres | 410 |
| Chips and potato products | 270 |
| Garlic/cheesy bread | 320 |
| Crisps and savoury snacks | 205 |
| Pizzas | 1,230 |
| Pastry products | 670 |
The retail sector has since been monitored against the voluntary targets. In February 2024 an update on the calorie reduction programme was published by the Office for Health Improvement and Disparities (OHID), finding limited progress towards achieving the target between 2017 and 2021. The results showed that almost all products saw changes of 2% or less.
The voluntary calorie reduction guidelines are UK-wide, however, responsibility for monitoring progress towards calorie reductions is shared across different agencies in different nations. The Welsh Government has stated that it is fully supportive of the calorie reduction programme, led by PHE. While the Scottish Government could enact legislation on this matter, there is currently no guidance for retailers and manufacturers regarding maximum calories per single portion.
Case studies
Regulating nicotine concentration in e-cigarettes, UK
The regulation of e-cigarettes provides an example of where governments have imposed restrictions that forced a reduction in the quantity of a specific ingredient in a product sold for human consumption. In 2016, the Tobacco and Related Products Regulations (TRPRs) introduced new product standards for e-cigarettes in the UK via an amendment to Article 20.
The regulation stipulates a maximum nicotine content of 20mg per ml of e-liquids in nicotine vapes, in addition to limiting the maximum tank capacity of a single e-cigarette to 2ml, with the maximum capacity of e-cigarette refills capped at 10ml. This has resulted in differing nicotine content for products in the UK versus other countries (eg, the nicotine content in Juul branded products in the UK and the US are 18 mg/mL and 59 mg/mL respectively). Manufacturers are expected to amend product composition to ensure these limitations are met.
Other countries with similar restrictions on the nicotine concentration of e-cigarettes include China, Israel, Jordan, Kazakhstan, Kyrgyzstan, Saudi Arabia, and the United Arab Emirates.
Considerations for implementation
Mandatory calorie reduction targets would need to be established in legislation and may need to be resolved differently for different nations. The policy would require monitoring and enforcement from an appropriate agency which would be shared across different agencies in different nations. Clarity regarding portion sizes may impact the implementation of the policy. Consensus around the size (in weight and energy density) needs to be established to ensure that the portion sizes are not underestimated, undermining the purpose of calorie reduction targets.
Estimating the population impact
We estimated that this policy would reduce the prevalence of adult UK obesity rates by approximately 6%
Estimating the per-person impact
We estimated that this policy would reduce average daily calorie intake by approximately 22 kcal per person
- We assumed that this policy would implement the maximum calorie per portion guidance reported in PHE’s calorie reduction technical report (see table 3 on page 18). We did not model this policy for children.
- We assumed that only large businesses would be in scope of this policy.
- For estimating the reduction in calories per person per day, we use the data used for Nesta’s report – The future of food: opportunities to improve health through reformulation. The data source for our analysis is from 2021. The data covers over 36 million transactions for purchases of all food and drinks brought into the home by a sample of 30,000 households living in Great Britain, alongside demographic and socio-economic background data. This dataset does not cover out of home purchases such as takeaways, on-the-go food, or restaurants/cafe meals.
- Our analysis using this data focussed primarily on large retailers. The different products in this dataset were recategorised by their name, description and nutritional content into product categories listed in the PHE guidelines. Then, we identified products whose calorie content was above the maximum calorie thresholds prescribed for each product category in the guidelines. We then set the calorie content such that a percentage reduction prescribed in the PHE calorie reduction guidelines is achieved. Then, we recalculated the average calories per person per day purchased from the large retailers.
- Through this modelling, we find that the calories purchased per person per day from large retailers are reduced by approximately 22 kcals.
- We then apply a compensation effect of 23% to find the reduction to be approximately 16 kcals per person per day.
- Note: All analysis and interpretation was conducted independently of Kantar Worldpanel. Kantar has not independently verified the findings.
Estimating the population reach
- In our analytical model, we applied the effect sizes to people living with overweight or obesity. For adults, that is people aged 18 or above with a BMI of 25+.
- Modelling the effects of this policy for children is currently in progress and we plan to publish this once complete.
Changes in the prevalence of people living with obesity
| Adults (England and Wales) | Children (England and Wales) | Adults (Scotland) | Children (Scotland) |
| 6% | Analysis in progress | 5% | Analysis in progress |
Cost and benefits
Cost over 5 years
We estimated that this policy would cost the governments approximately £0.2 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 3 below shows a breakdown of costs. The direct costs to the governments are approximately £31,000 per year. The costs to the food industry are estimated at approximately £6 million over five years. This policy would require the implementation of the FDTP, the costs of which are not included in this breakdown. For more information about the cost breakdown, please see our cost modelling technical appendix.
| Group affected | Cost | Horizon | Detail |
| Costs | |||
| Government | £0.2m | Annual (5 years) | Monitoring and enforcement costs |
| Industry (Manufacturers) | £4.3m | Annual (5 years) | Policy implementation and reformulation |
| Industry (Manufacturers) | £2m | One-off | Familiarisation costs |
| Industry (Retailers) | £13k | One-off | Familiarisation costs |
Total annual benefit
We estimated that this policy would have an annual benefit of approximately £4 billion
Using analysis conducted by the Tony Blair Institute and Frontier Economics we estimate this policy would result in benefits of approximately £4 billion per year. Approximately two-thirds of this saving would benefit individuals (via quality-adjusted life years, and informal social care). The remaining third relates to savings that benefit the state via NHS treatment costs, productivity and formal social care. See our Technical Appendix for more information about the cost breakdowns.
Impact on disease incidence
We commissioned HealthLumen to report disease incidence avoided if the policy were implemented. These estimates do not represent the total health benefits. The specific diseases selected are those where there is good evidence that living with obesity is associated with the development of the disease.
Table 4 presents a summary of incidence avoided (rounded to the nearest 100).
| Disease | Incidence avoided |
| Type 2 diabetes | 17,800 |
| Hypertension | 12,700 |
| Coronary heart disease | 4,600 |
| Colorectal cancer | 1,300 |
| Gall bladder disease | 25,700 |
| Ovarian cancer | Not statistically significant |
| Stroke | 2,300 |
| Liver cancer | Not statistically significant |
| Depression | 500 |
| Musculoskeletal disease | 7,000 |
Behind the averages: impact on inequalities
Mandating calorie reduction targets for retailers and manufacturers shifts the responsibility from individuals to the food industry, making it easier and more achievable for all consumers to make healthier choices regardless of income group, ethnicity, or geography.
This policy has less focus on individual responsibility and therefore it is unlikely to exacerbate the prevalence of weight stigma.
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 Medium evidence base.
Introduce healthiness targets for large retailers
Regulate large retailers to change their sales-weighted converted NPM score to ≥ 69 across their entire food product portfolio