Welcome to the Health and Social Care Committee. This is our third session on food and weight management. To our witnesses, thank you so much for being here today. May we start with your introducing yourselves and your organisations?

I am Jim Cathcart, policy director at UK Hospitality. We are the industry body representing restaurants, pubs, bars, hotels and the wider hospitality sector, so around 700 companies and over 150,000 individual businesses or venues; overall the sector employs 3.5 million people.

I am Kate Halliwell, chief scientific officer at the Food and Drink Federation, which means I have responsibility for our nutrition and food safety policy. I am a registered nutritionist. I also sit on the board of SALSA, which is a food safety audit system aimed at supporting small and medium-sized businesses; and I chair the Institute of Food Science and Technology nutrition and food science special interest group. FDF is the trade body for UK food and non-alcoholic drink manufacturers. We have large global multinationals as well as small local businesses in our membership; overall, our sector is about 98% SME.

Kate, I will start with you but then, Jim, I will be grateful if you answer as well. What are your members doing in this space? We have heard some pretty punchy evidence about the impact that food right now is having on people’s diets and there have been some charges put to the industry to say they are not going far enough. What would your answer to that be? What are they actually doing?

Absolutely, obesity is a big problem, as you have been hearing at the Committee, and we recognise, of course, that the food that people eat contributes towards that. In terms of what the industry has already done, we buy Kantar stats, which basically shows what is in your shopping basket. Over the last 10 years for our membership we have seen a reduction of around about 30% in sugar, 30% in salt, and about a quarter in calories of what is in the basket. So more broadly, I would say that the industry recognises there is still more it needs to do. Obviously, we still have a problem with obesity and health but looking at what we can do as manufacturers, we tend to talk about it in sort of three chunks. One is around the products we sell, so reformulation or healthy product development alongside, obviously, the staples that our companies also make and sell, by which I mean frozen peas and oats and those sorts of things. The second chunk is looking at the people we employ; I know that is taking it away from food, but we employ around about 500,000 people across the UK in every constituency, so we are actually piloting some schemes in factories to look at how you can work with people to improve their health, and how that links to the local community. The third chunk is how we communicate to people about what they should be eating and how you constitute a balanced diet.

In the hospitality sector, our members are taking a number of specific actions. I will probably return to this but it is important to note when we talk about the hospitality sector that it is not one sort of homogenous business model. The majority of our members are small businesses with a variety of ways of preparing food and offering foods to our customers across a range of different business types. In terms of practicalities, I guess there is the reformulation piece. Although in hospitality, a lot of meals are made on site from ingredients, it is a different picture from other methods of food production. It is practical things such as looking at what oils we are using in the food, looking at portion sizes, looking at fruit, fibre and vegetables, as well as offering new healthier choices on menus. There is menu design as a concept as well, where healthier options are placed and promoted on menus, and ways of talking to the customer on site. We and our members look to this in a number of ways, such as obviously the advertising piece, voluntary restrictions on where people advertise and that sort of thing, as well work at a bigger scale. So there is a range of actions that members undertake.

How many of those actions would you have taken if Government had not intervened?

We would continue to do a number of them because a lot of what we do is customer-driven. Certainly over the last few years, we have seen customers in a lot of places looking for healthier choices, to align with their lifestyles, so a lot of it is going that way anyway. In terms of other elements such as the piece around portion size, people are looking hard at sustainability, food waste, that sort of thing, so that is a factor coming into it as well. As I say, a number of these different options are customer-driven as much as they are regulation-driven.

Would you say as much as 50%?

I could not put a number on it.

Kate, how much of what has happened in the businesses that you represent would have happened anyway?

I would say it is absolutely a mix. As Jim said, there are multiple reasons why people would—

What I am trying to get to is, what are the drivers here? I understand there are several drivers, but I am also trying to understand what is more important: what the customer wants, or Government intervention?

I would say it is a mix; again, I could not put a number on it. And those two things can drive each other as well. So if I take us back to when the salt reduction programme was really active, there was customer demand partly because Government were being very clear about the impacts of salt and ran advertising—you might remember Sid the Slug, for example. Government policy was working with companies to reformulate; they were also advertising and there was an active charity at the time talking about salt. Those things are not necessarily mutually exclusive. What customers want would drive it, but also clear policy direction from Government, whether that is mandatory or voluntary, will help because it sets a clear direction of travel.

We will come back to that point in more detail.

Thanks very much for coming, Kate and Jim. In your evidence, Kate, you explained that companies invested £180 million in healthier product innovation, which we all really welcome, but the industry has an annual turnover of £148 billion. Do you think this level of investment matches the scale of the public health challenge confronting the people of this country?

Obviously we are proud that companies are investing in healthier product development over the last year. In terms of companies’ turnover as opposed to profit, they are profitable, they are commercial—

Just taking Tesco’s profit alone, which is in the billions, do you think £180 million in healthy product innovation across the industry is enough? And we could take the other companies’ profits as well, if you want.

No, that is fine. Companies make profits, obviously, but in terms of is it enough? No, more needs to happen. One of the things we recognise across all the innovation that companies make is that, actually, health is just one aspect—

Just to come back to the previous question. I am very aware it is tough when Governments sometimes say, “Oh, we would like you to be nice,” when your competitor might not be as nice and why would you be the first prime mover before anyone else? Is that because there is too much voluntary requesting—why do you not, could you do, how about—and there is not enough straightforward regulation so you are all on the same level playing field? Would it help if you were?

No, in terms of the investment that we would see there are quite a few things that would help. In fact, we had an investment summit with Government a couple of weeks ago to talk about what could help drive investment in the sector so that we can support both growth alongside health and sustainability goals.

I do not understand; that was not my question. My question was, you have a choice: you either follow the law or you do not follow the law; you do it because you feel it is the right thing to do or because your consumers ask you to do it. We have had a huge amount of evidence and I am very grateful for your evidence as well, but looking at it all, it suggests that what has really worked is when the Government intervene to say something has to happen or cannot happen. Then you are all on the same level playing field. I have had spoken to individual supermarkets about this too. Asking one of your members to jump before the others is kind of tough, so if the Government regulate, clearly, precisely and at greater depth than they have done already for your industry, does that not help?

As is generally the case with these things, it will depend on the exact policy you are talking about. I would say that clear direction is absolutely helpful. There are mandatory programmes across the world; we have a voluntary programme. In the UK we have about 85 targets and those targets, generally speaking, are lower than the mandated targets. That is because they can be slightly aspirational when they are set, whereas if you are mandating it, it has to be something that all companies can meet. Typically, around the world where you have mandated targets, you would normally have two or three, sometimes up to about 13, 14. So there are certainly instances where if you have the voluntary approach, you can drive the innovation and people can move quicker because you can be aspirational within that.

Jim, what do you think?

It is an interesting one. I can speak for my sector here: one of the things we have seen in government policy, be it voluntary or mandatory, is a lack of understanding of how our sector operates. Again, there is talk of a level playing field and that sort of thing—

Give an example of what is difficult. What difficulties are caused by the fact that there is not an understanding of how your sector operates?

If mandatory legislation is designed in such a way that is based on a single type of business model and then read across to the hospitality sector, it can—

Yes, but how is that problematical? Chicken shops are popping up everywhere. I cannot go down the high street where I live, or anywhere nearby, without one; it seems every third shop is a chicken shop. Stuffed full of salt, fats, chickens themselves probably stuffed full of antibiotics that encourages resistance and things like that, why would the Government be wrong? Why would the salt and sugar reformulation requirements not be appropriate for your industry when we are talking about chicken shops?

We are not querying whether it would be inappropriate or not, it is more about how that is delivered and how it works for the hospitality sector.

What is wrong with the way it is delivered that you would improve?

When it comes to regulation, it has to be designed to actually reflect how the sector—

No, I get the generalities, a couple of specifics would be helpful. More specifically, what is wrong about what has happened as far as your sector goes? We can all abstract and philosophise, but specifics are really helpful.

With our sector, where 90% are small and individual businesses, our role as a trade association is to take the learnings from our larger businesses and educate those smaller businesses.

I do not understand the problem and I keep asking you to give some specifics. Can you give me some specifics? You are just talking general.

We need some clear, concise examples, please.

Forgive me for being so direct with you, but it is probably better that I am direct with you than not; you are talking very floppily. Give some specifics of how it is causing a problem to your sector.

What we would like to see for our sector is better data across the piece to understand what is happening to build regulation on.

What is the problem at the moment?

At the moment, if you are talking to those smaller businesses, it is going back to getting a better understanding of data about the sector, what—

I am going to have to leave that there; maybe you could write to us. I have asked you to provide specific examples of what is not working and you keep saying rather general things. If you can tell me more specifics afterward, it would be lovely to hear from you. I would appreciate that. Can I just ask a question about foods generally? Kate, are unhealthy products more profitable than healthy ones? Products full of fat, sugar and salt are cheaper than healthy ones; are they generally more profitable?

If you cheat by on an energy density measure, I assume you mean calories per pence—

No I am not talking calories, I am talking—

To give you an example, as in a chocolate bar versus an apple—

No, I am talking about a pre-prepared food that is full of sugar, salt and fat, as opposed to one which is not. I am not talking about chocolate and stuff; I am talking about actual food that people might eat before they have something sweet.

So ready meals and sauces and those sorts of things?

Yes, that is right.

The honest answer is I do not know because we do not talk about profitability with our companies.

You do not know if healthy food is less or more profitable than unhealthy food?

It would depend on things such as the brand range. I do not think it would be a straight line. Let me give an example, which is a hypothetical example but it is also true, if that makes sense. I am not using brand names. If you take something such as a lasagne, for example, a luxury brand range would probably have more cheese in there and maybe butter and cream in the béchamel sauce. There is probably a bit more red meat in there too because they are all quite expensive ingredients. So your overarching nutritional profile may well be higher in saturated fats and salts and energy density, whereas a cheaper ready meal may well have more chopped tomatoes, maybe a little more veg in there, maybe more pasta to cheese sauce—

More salt and sugar? Preservatives?

The preservative—

Just a yes or no.

Well it would not just be a yes or no answer, so I cannot give you a yes or no on that. It would depend, for example, whether it is in the chilled, frozen or ambient range; that would impact your additives.

I get that. Just talking about cost to business again, if I may. At the moment there is a lot of focus on improving regulation to protect people’s health. We had the three shifts in public health and one is prevention. Food is—and you can start with baby food—damaging people’s health; there is increasing evidence of that. Do you think that if your members do not reduce reliance on unhealthy products, they are exposing themselves to regulatory risk, and indeed financial risk? And in straightforward city terms, do you not think it makes sense for them to be taking more action, otherwise the regulation that comes in might be tougher? Surely, they are exposing themselves by risk if they do not do enough. If they are just spending 0.12% of their annual turnover of £148 billion on healthier product innovation, do you not think they are exposing themselves to regulatory risk eventually?

Well we already have regulation, obviously. Companies are aware that more needs to happen in the health space and that we need to look at the array of products that are on sale. What I would agree with is that the products that people eat absolutely impact their health, and we need to look at how we can support people moving towards eating more fruit and veg.

I keep asking one question and sort of getting a side answer. With your members, have you actually looked at the potential regulatory risk of not doing more to improve the healthiness and the nutritional value of your foods? Have you actually talked about regulatory risk? I would think that is fundamental.

Yes, we would talk about that in a whole policy horizon scanning aspect of what might be something they should be aware of.

Jim, I am sorry to ask you fewer questions; I am very curtailed on time but there will be more coming to you from my colleagues. I want to ask about a Guardian investigation into lobbying by food and drink companies. How much do your organisations lobby to alter, weaken or delay measures to improve public health and reduce obesity? How much do you lobby to try to get the Government to be less restrictive, perhaps, in terms of what is permitted in order to make food healthier?

We certainly talk to Government in order to make sure that policy is right, works, and reflects the sector that we operate in.

Is there anything that you think the Government have done wrong and you have tried to change?

The Food Strategy that is in place now is one we were keen to talk to Government about and get hospitality representation on that strategy group in order to ensure that when Government are looking at voluntary or mandatory regulations, whatever it might be, it works and is practical for our sector.

You mentioned the group; how many times has the group met in the last few years?

The Food Strategy Council? I do not think hospitality is formally on that group yet, although we have asked to be.

Kate, I noticed that you used to work for Government and, if I am right, you used to work for the Department of Health and then the Food Standards Agency.

Yes, I did.

How much gap was there between you leaving Government and joining the Food and Drink Federation?

About one week. I was an official in the Department of Health actually working on voluntary calorie labelling approaches.

Did you say a week between you leaving Government and joining the big lobbying organisation for the food industry?

It would have been, yes—

Did nobody in Government insist that there should be more of a gap?

No.

Extraordinary. How many meetings have you and the Food and Drink Federation had with Ministers and civil servants over the past four years? Would it be 50 or 60?

Across all policy areas?

The Food and Drink Federation having meetings with Ministers across any areas, yes.

You can write to us with that information if you do not have a precise answer.

Yes, I do not have a precise answer to that.

Jim, because of time, if you would not mind, would you write to us with that same information?

Yes.

We are going to come back to this area in later questions but we now need to move on. Thank you very much.

I am going to continue Ben’s line of questioning really, looking at one regulation that has come into force that is mandatory: the soft drinks industry levy, or the sugar tax. As I am sure you know, it successfully reduced the average sugar content of a can of sugar-sweetened soft drink by 46% between 2015 and 2020. The number of children being admitted to hospital for tooth extractions would be 12% higher today if this levy had not been introduced, so we can all agree that it has been a success for our children. The Government have announced that they will be making further changes to the soft drinks industry levy; what is your initial reaction to that announcement.

With respect to the overall announcement, we were pleased that Government had listened to some industry concerns.

Could you outline those concerns, Kate?

Of course. One was around the initial implementation, which was originally for 2027 in the consultation but has been delayed by eight or nine months to January 2028.

Sorry, why is that a good thing? Bearing in mind that we are talking about the health of children. Can you just explain this to us, please?

The reason we asked for that was because the deposit return scheme is being implemented at the same time, which is around setting up an approach so that bottles and cans can be recycled. So companies have already spent a few hundred million on that; it will be committed up to £1 billion on that. The delay would mean that companies would have the money to then invest into further reformulation.

Sorry, out of the £147 billion, the companies are saying that they need more time to find the money to do the sugar reformulation and the deposit return scheme; it is simply not possible with the money that they have within the time scheme?

That few months delay would help the investment, yes.

Thank you. Any other issues that they had?

There was a going to be move from 5 grams of sugar down to 4 grams, and the Government have settled on 4.5 grams, which is still driving sugar down. Officials talked to companies around the technical issues; obviously you can do zero sugar, and more than 50% of our market is zero sugar drinks, but where you have a blend, effectively of sweeteners and sugars, that is where the drinks just below 5 grams currently sit. It was previously found when drinks at 4 grams were launched that customers rejected them. They do not take it.

That is interesting, Kate, because during the passage of the levy last time there were similar claims that this levy would lead to massive price rises and harm jobs in the industry, but actually, sales of soft drinks increased after the levy. You are saying that the 4 grams issue would mean that consumers would drink fewer soft drinks? That is what you are saying this time, is it?

I am not saying they would necessarily drink less, but I am saying if the 4 grams drink is not acceptable to consumers then they would either drink a higher sugar one or they would drink a zero sugar one. If they do not choose the 4 grams one, it will not stay in market. So it is not necessarily they will drink less; they could go higher sugar or they could go zero.

So just to be very clear for the record, the argument to not go to 4 grams but to go to 4.5 grams is that consumers then would choose a 0% soft drink, still sold by the same soft drink industry, or potentially a higher sugar drink? That is the argument?

Where companies feel sweetener technology is at the moment, they can sit at around 4.5 grams, so we can still bring the sugars down. As sweetener technology progresses, in time it may be possible to bring it down further. Sweeteners are progressing—if you have tasted something such as a Coke Zero compared to Diet Coke, you will see that it is a much, much closer match to actual Coca-Cola, for example, and all the drinks have that. So as technology progresses it may be possible. At the moment, where companies feel the technology is and where they have tried with consumers, that 4.5 grams seems to be where the blended drinks with sugars and sweeteners get refused.

Forgive me, but from a public health point of view, that extra 0.5 grams could affect quite a lot of children and tooth decay, yet due to reformulation issues and time delays, the industry is simply saying, “This isn’t possible at the moment.” That is what the industry is saying?

We are saying that we do not think 4 grams would stay in market, so it would not be there as an option.

But the previous levy did not seem to affect soft drink sales at all. The previous evidence is that actually there was an increase in soft drink sales, so the reasoning to me does not seem entirely clear—but we will move on. Jim, what is your response to this?

In terms of the soft drinks industry levy, obviously our businesses do not pay it as we are at the end of the supply chain, if you like. But it is just worth making the point that when it comes to restaurant food, relative to the EU, that is quite highly taxed anyway; when you are eating at a restaurant it pays 20% VAT rate compared to 12% on average in EU countries. I just make the point that the hospitality business is highly taxed on the food and the experience they offer already.

That is interesting to hear. I do not know if this is for Jim or Kate; maybe to you both. Sugar reduction in soft drinks has come in and been shown to be successful; it has reduced tooth decay and it has reduced sugar consumption across the population. Are there any other policies that you think we should be targeting to reduce the nation’s intake of sugar? Jim, do you have any thoughts from a hospitality point of view?

Again, for the hospitality industry our foods are made on site. We produce guidance and we advise our members in terms of reducing sugar in a dish, or whatever it might be. At the moment, we are looking at what we can do to get that message out to our members.

Specific to sugars, our companies have been working on reducing sugars, I have already quoted those figures to you. Generally speaking, where reformulation works and where it is technically possible to do it, we would. Picking up on Jim’s theme, I would have a different answer for large and small companies. For smaller companies, we believe that they need more support to understand how they can approach this and tackle it, and we have an approach in Scotland that aims to do just that.

Okay, sorry to interrupt: my colleague is going to talk about voluntary and mandatory approaches, but just before I hand back to the Chair, a small thing around voluntary approaches. Looking at the evidence of past issues, when we had an industry led partnership programme to get companies to change the sugar content of other food products voluntarily, it was essentially a dismal failure. It averaged only a 3.5% average sugar reduction and the target was 20%. Do you have any thoughts around that at all?

I would say that is actually more to do with what is possible. Milk-based drinks have now been brought into the levy, but they were not subject to it previously. We saw more than a 30% sugar reduction between 2017 and 2024, I think, I can check that year, but—

Of course it varies across the industry and you sound like that is quite positive now it has been brought into the levy. I suppose what I am saying is, going back to my previous colleague’s questions, Government regulation sounds like it is a good thing: it allows the industry to have clear guidelines about what is and is not acceptable.

I would say that when it was voluntary but possible with clear guidelines, which is what happened with the milk-based drinks under the Public Health England’s voluntary sugar reformulation programme, they hit more than 30% reduction. With the foodstuffs within the voluntary programme, something such as breakfast cereals saw a 15% reduction, but then chocolate and desserts were very low. I cannot quite remember what they actually were but that evidence is all published. I would say that it is positive where it is possible to reduce the sugar and targets that are set are achievable. So within the salt reduction programme, Government worked much more closely with both the third sector and industry to understand what could be done within each category.

Sorry, Kate, we are running out of time. I hear what you are saying. Again, the coalition Government tried it with the public health responsibility deal and people walked away saying that the industry had successfully weaponised it. I think there is more to discuss around this. I hear what you are saying, and I will pass back to the Chair.

Thank you very much.

I am going to make the assumption that most of your members are businesses; there will be some that are more voluntary and charitable, but the vast majority will be businesses. If you are a business in the food industry or in hospitality at the moment, it is difficult to make money by cutting your costs because things are going up in price. It is difficult to make money by making products more expensive because there is a lot of competition out there. So the way that businesses will make money is by selling more products, fundamentally. Would you say that there is a motive in continuing the obesity crisis? Because as people get fatter, they are going to eat more food.

What we have actually seen over the last few years is that fewer products by volume have been sold, even as the population grows. So certainly the evidence over the last few years is that that has not happened.

But fundamentally, for a chocolate company, a crisp manufacturer, if you are making ready meals, you need people to eat more of your product. Obviously £180 million spent on research into healthier products is great, but how much money is spent on research in making sure that with the products, “Once you pop, you just can’t stop”? We have seen reports that people are being hooked up to brain scans to work out what the response is to food and whether they want another one. We have seen that food is being made softer so that people can eat more of it without tiring themselves out and consume more calories in a single sitting. How much money is spent on researching those aspects of our food production versus making our foods healthier for people to eat? If you do not have that answer to hand then please do—

I would have to write to the Committee on that.

What is defined as a healthy food by the federation? For example, we have received evidence that a box of Coco Pops has 10 health signs on it saying how healthy it is. Personally, I do not think that is a healthy breakfast for my child; it is a good treat—don’t get me wrong, we have all had Coco Pops and no one is talking about banning Coco Pops—but I would not class it as a healthy breakfast. Would you class that as a healthy food product as part of the research?

On Coco Pops specifically, as you have raised that one, they have reformulated to reduce the sugar by about 50% over the last few years. It is high in fibre so it would pass the Government’s nutrient profile model. Breakfast cereals more generally contribute to a balanced diet. Yes, there is a range, as you have indicated, but they contribute to the fibre and micronutrient content of children’s diets. Generally speaking, around about 25% to 30% of kids iron and about 20% of vitamin D comes from breakfast cereals.

We will call Coco Pops healthy going forward. What about protein bars? There has been a big television exposé on protein bars. A lot of organisations are introducing protein ranges as part of their drive to be healthier but a lot of the ingredients that are going into these are not what I would call food; they seem to be more scientific substances than actually what people on a day-to-day basis would call food. Are they healthy? Are we happy that people are being sold products that contain a long list of ingredients they cannot pronounce for the sake of calling it a health food?

If I go kind of broad brush and talk around health, the clear steer from Government at the moment is to use the nutrient profile model in terms of ingredients decks, so the list of ingredients that is in there. Obviously, any ingredient that is used is looked at and approved for use by the Food Standards Agency as being safe for use in food, so you can only put stuff in there that is safe and is approved. That evidence is monitored both by the FSA as the regulator here in the UK and by equivalent regulators in Europe and indeed globally.

What is your response to the documentary that Joe Wicks and Chris van Tulleken made showing that, effectively, we are able to sell products that have been linked to causing health problems such as cancer?

All the additives that are approved for use are approved by the Food Standards Agency. So it will look at the risk and the amount that you can eat. With any ingredient, even water, the amount that you have is really, really important. If I look at additives, generally speaking what happens is that the evidence base is assessed as what is safe to eat, and there is a safety factor built into that. So it may determine that you can have a certain amount of a sweetener, or whatever it might be, every day of your life and that would be safe to eat, then there is usually about 100-fold safety factor built into that as well. So when they assess the science, they look at the—

These questions are about what is healthy, but you are talking about safety. Are you equating health with safety?

I was talking about safety because I was asked about the ingredients list and having a long ingredient list of chemicals. And that then is around additives—or that was my understanding—and that is food safety; that is looked at by the safety regulator.

I am going to move on to advertising in and out of the home for a moment. Obviously there has been a lot of discussion around advertising restrictions and regulations, and we have seen development where well-known, takeaway chains are now designing products that are non-HFSS, so they can be advertised. Obviously their brands are going to continue to be advertised, but funnily enough, when you go into those stores and you go to their nice new big tablet screens to order, the non-HFSS burger seems to be right at the very bottom—below the bargain bucket, below the box meals, below the 2,500 calories for £9. Do you think people are going to watch an advert for a healthy burger and then not order the bargain bucket?

Brands advertising non-HFSS products as a result of new regulations shows that those new regulations are working in the sense of what is being advertised to people. In terms of menu display in venues, a lot of brands and businesses experiment with where those go on the menu and the healthy choices are there. If you go back 10 to 20 years ago, what the customer is able to choose from on offer at those businesses today is wider than it has been in the past.

Do you think customers are aware that if they are tucking into some hot wings, for example, they are also consuming an ingredient that is shared with condom lubricant?

I do not know about the specifics of that, but for a number of brands, obviously for those businesses over a certain size, the calories that are in that product have to be mandated and displayed in front of the customer. A lot of businesses will provide background and further information about the health and other content of the food.

One final question before I hand back to the Chair and this is for you both. Do you genuinely think, hand on heart—crikey, I am sat here as an obese man who enjoys takeaways and chocolate far more than I should—that we should be banning any of these foods? Companies are making hundreds of millions, if not billions, of pounds of profit, while at the same time we are spending £17 billion a year on obesity-related illnesses in our NHS. Do you think we have the balance right, or do you think that there could be a better balance in terms of those businesses contributing a bit more to tackling obesity?

Companies have already done some, but yes, I would agree that absolutely there is more that needs to be done because we do not have a healthy population; in the same way that there is more that needs to be done on sustainability. There is a lot of work generally on food systems and how we achieve that, while still producing food every day so people still have food while we make that change.

I would agree with that; there is definitely more to be done on that front. The sustainability point is well made; there is some really interesting sort of read-across from what is going on in that agenda, potentially to the health element of food as well.

Kate, having worked on both sides of the fence, as it were, do you think there is any role that a Government can play in helping to address weight management, obesity and healthy eating?

Yes, I do. I will take that very specifically as the interaction to industry rather than, obviously, broader things that Government can do as well in terms of the health service and support. But what is really important for companies is having a clear goal and then the regulatory certainty that that is what we are aiming for; or the policy certainty, depending on if it is voluntary or regulated. Where that becomes maybe difficult is for companies to understand what the thing is that Government really want us to aim at. What has been determined to be the most important thing? Investment takes quite a while to sign off, so if you are looking to invest in healthier product development, that will typically take several years. If I give you an example from a breakfast cereal company that reformulated all products, that was over a two-year span after the investment had been signed off because you have different recipe trials, you have to do pilot factory trials, factory trials and so on, and it takes two to three years for a larger company.

My question was, can the Government have a constructive role in this area? Your answer was yes, and then you followed that with a lengthy no, so I do not quite understand. I think actually you are saying no, but you are presenting a façade of yes, so really you do not think that the Government have any role in contributing to health eating and weight management.

Apologies if I made that sound like a no; it was not meant to.

Perhaps it was me; it is on the record anyway.

If Government can provide certainty, such as a policy that we are aiming at, that is one thing. Government can support companies within the investment side, which I mentioned previously. One of our aims is to make the UK a centre for healthy product development. For larger companies, the R&D tax credits that are given for innovation do not cover reformulation at the moment, we think it would be helpful if those R&D tax credits could actually look at that. For smaller companies, we think they need specific tailored support that would help them.

One example of tailored support to SMEs is in Scotland’s Reformulation for Health programme; would you say that has been a success?

Yes, I would.

What, specifically, do you think has been the success? And what do you think in terms of its outcome for the health of the population, rather than just reformulation of the food?

The programme is still building and I cannot give you specific health outcomes as the programme is not funded to look at that. It is funded by Scottish Government and Food Standards Scotland, but it is specifically only funded to do the outreach from companies. But in terms of the outreach, it is successful as it bridges a gap that we currently have between a lot of knowledge within ingredients companies and academic institutions, and small companies that know the product they make but do not necessarily know how they would start to look at developing a healthier product. It does that in a range of ways: it has very small grants targeted at specific sectors that the Scottish Government identify as sectors that they would like to see reformulation in. Those grants are typically £5,000 or less; they give the company tailored advice such as. “This is what other competitors in the marketplace have, so actually your salt level is a bit high. Maybe salt is the area for that thing you want to focus in on.”

So helping them in a competitive sense?

The programme helps them with market analysis, how they might run a recipe trial, what a small scale consumer testing trial might look like, and provides links to academic institutions as well. We have academics who run webinars and write guidance that means that you get that wider reach.

Presumably one of the big attractions is that it is a voluntary not a mandatory programme. Has the FDF undertaken any kind of modelling or estimates of what rolling it out across the UK would involve and how much public resource and so on?

Yes, we would say that for England to scale it up—obviously we have far more manufacturers here in England—it is about £3 million, and about £4 million for the UK.

Okay. Thank you very much.

I want to talk a bit about the nutrient profiling model and the application of the 2018 NPM, which the Government have said that they will consult on. Ms Halliwell, from your perspective, what concerns do the industry have about this and, if the Government were to move to a new model, what might you be willing to accept in terms of a timeframe?

My assumption is the new nutrient profile model that Government are looking to introduce will be the same model that went to consultation in 2018, as the model has not yet been published. Those regulations have basically just come into force; the current promotions and advertising regulation will come into force in January—in fact, promotions in Scotland and Wales will come in next year. In terms of that being a clear signal, obviously companies are reformulating to that model. The new model is basically much stricter on sugars, and there are some differences on fibre that reflect our new dietary guidance. My understanding is that part of the purpose of the policies on promotions and advertising is to drive reformulation in those product categories, but in the new model the sugar levels for a lot of those categories is set at a level where reformulation will not be possible. In terms of it being a mechanism to support reformulation and to give that clear signal of where Government would want it to go, the sugar level just simply is not achievable. Slightly connected to that is what are defined as free sugars, which are a variant of added sugars, if you like. Again, it is our dietary guidance, but free sugars are not something we can analyse for; they basically look at fruit and vegetables, and it counts if the fruit is puréed but not if it is not. In things such as ready meals, sauces or puréed fruit and yoghurt it becomes really hard to calculate, because effectively that sugar level depends on how lumpy that food is. That is a technical difficulty, and I accept that if the new model comes in, Government will find a way to work around that or use some sort of assumption, but it is difficult if you do not actually know the level when it is in legislation.

What I am really trying to get to is what the consequential knock-on impact is for you, your members in the food and drink industry and consumers if they were to introduce the new nutrient profile model?

If the new model comes into the promotions and advertising as stated in the NHS 10-year health plan, many categories will not be able to hit it, as I said. In all likelihood what that will mean is that some of the healthier products that have been innovated to meet the current model will no longer sell to consumers because they cannot be promoted or advertised to them. There is quite a strong likelihood that some of those will go off-shelf. Let us take biscuits, for example. Of course we understand that even a healthier biscuit is still a biscuit, but actually those small changes in category can make a difference. With the Nesta modelling that Lauren Bowes Byatt spoke about previously, actually those small changes in category to a healthier variant can make a big difference, and it has modelled that that could halve obesity over five years. If the new nutrient profile model starts to become a barrier to those healthier products being successfully marketed and sold, there is a chance that actually those products will come off-shelf and then you just do not have that healthier end for consumers to move to within a category.

Again, I am not trying to put words in your mouth, but I want to make sure that I am understanding you correctly. So first you are saying there could be a lack of consumer choice due to this, but also that the unintended consequence is that some products that in your opinion are healthier will no longer be able to sell as well, therefore reducing not just general choice, but the actual choice of healthier products. Is that what you are saying?

That is a potential consequence. To give an example of the scale, last year we produced a booklet that looked at reformulations over the previous year. Of those products that pass the current model that were in the innovation that just happened, only 25% would pass the new model, so there is potential there for products to go off-shelf. What is always really important with nutrient profile models generally, when they go into policy areas, is that you have to look at the actual policy they go into. There is not one universal NPM that works everywhere: you have to consider the policy that it is going into, and what the end result of the policy is that you actually want to see. As I said, my understanding is that at least a good part of that policy is to drive reformulation, and we do not believe that the model that was at consultation would drive that.

Just going back to something I asked earlier as part of a very much wider question: imagine that the Government push ahead with this, what would you describe as a reasonable period of time for you to be able to apply the new model to the existing regulation? As an industry, what sort of timeframe would you need to be able to do the work to get to that point?

I would say that for many categories I simply do not think that they would get to that point.

That is helpful. We have seen evidence to this inquiry that has called for the nutrient profile model to be updated when scientific evidence evolves. I assume you would agree that we should follow the science on this, but where would the balance lie between ensuring regulatory certainty for your industry, for investment and so on, and the regulation reflecting the latest scientific and dietary advice? I suppose that is really me asking the timing question from a different point of view, or in a different way.

Yes, of course. It is absolutely reasonable that policies should be based on the scientific evidence, and actually our dietary guidance does not tend to change that often either. But again, in terms of the outcome, is the current policy driving towards that? At the moment we know from research that Leeds University has undertaken that the first year of the promotional restrictions has moved some people towards healthier products. I think it is 2 million products a day that are non-HFSS compared to HFSS, if you look at the years. If that drive is still happening, and it is moving people towards our dietary goals, then that is the assessment we should look at and, given that those regulations have just come in, we should consider how we should make best use of those. I have obviously talked about the regulatory certainty, but is there a way that we could support consumers to better understand which are those healthier products on-shelf? For example, is there a way we can indicate that through labelling? It would have to be a Government approach for that to happen.

We are coming back to labelling.

It is about ensuring that there is absolutely a role for those policies to be assessed. I know that there is an assessment during the regulation, which is great, but I would say that if they are working towards moving the dietary targets, then let us work with those and help shift people’s diets.

Very quickly, just to finish: do I take it that the Food and Drink Federation and your colleagues in the industry are very keen to work with Government to get this policy right, but at the moment you just do not think they have quite got there, or they are going down the wrong path?

Absolutely, we are always very happy to collaborate with Government as policy is designed. We understand there will be a consultation for this in the early spring.

The nutrient profile model takes a balance across the different nutrients. As I said, Coco Pops has reduced its sugar content by 50%, and it is a source of fibre. The current nutrient profile model basically looks across different nutrients to give an overarching score, which determines if something is healthy or not.

Your reply should be just a yes or no. Would you, every day?

It is a cereal that gives a child fibre, you generally have it with milk.

You are trying very hard not to say yes, but why? If you feel that Coco Pops is healthy, say it is healthy.

I would say it is a healthy product as defined by the nutrient profile model.

Any breakfast cereal, including Coco Pops, is not an energy dense product and typically does not contribute very many calories into the diet.

I think you are being clear that you feel that it is healthy?

I would say—

You keep defending it—

Breakfast cereals generally are healthy and I would include—

Okay, thank you. I am afraid we are going to have to move on.

Jim, I am coming to you now to talk about the out-of-home sector and calorie labelling regulations, which were introduced by the previous Government. What is your sense of the level of uptake and compliance of relevant businesses?

Uptake is high. It is the law, so if you have 250-plus employees, you have to be doing it. In terms of compliance, I can only speak for our member businesses, but it is high. We provide guidance on this.

Is there any data? You said compliance is high, it is the law, so they will be doing it—I am paraphrasing, it might not be exactly that—but do you have any data about the percentage uptake, the level of compliance?

This is an interesting point. I do not have data, unless there are some stats out there from those who are actually enforcing it, i.e. local authorities. But the data and evidence piece around calorie labelling in general is lacking to some extent, and that is definitely part of it.

Does there need to be better data?

Yes.

What is the sector’s view about the impact on consumer behaviour that this change has had?

That is again an interesting question, which goes back to where it came from. As you say, the policy intention was made to make this legislation back in 2020 and it was eventually introduced in 2022. This is an example of where we worked quite closely with Government and officials to make sure that the policy and the regulations worked for the sector and consumers as well—that it was practical and people could do it. We turned that around in covid times quite quickly. Obviously we put out guidance to our members, that this is how you do it, and there were numerous discussions about what was a menu, because not everywhere just has a piece of paper on the table, there were chalkboards, and that sort of thing, so we went through all that. In terms of impact on customers we had some anecdotal feedback when it first came in, in April 2022, that some people were forgoing desserts and maybe going for a starter, and some people were doing vice versa.

I suppose what I am hearing is that, as a sector, you do not have any comprehensive information or data about the impact, what businesses reported or anything in that regard?

No, we do not, and we would like some because it was quite a big policy for out-of-home businesses in England, and there was quite a bit of mandatory regulation. I know the Department of Health and Social Care did some work with the University of Cambridge in the first year of the process to look at getting some data, and it would be good to see that. There have been a couple of reports in medical journals looking at this from an academic point of view, which have been helpful.

Going back to my colleague’s earlier point about lobbying and engagement, I take the point that the sector engaged on its views about changes, but is it fair to say that the sector opposed, or did not support, the introduction of this policy?

Yes, that would have been correct; at the time, we did not.

So you have no data about the application or about the impact, but as a sector body and a sector more broadly you strongly opposed and lobbied against it, based on a position of having no data and information. Is that not quite challenging, to advocate for something you have no data around?

But if we are going to make regulations around this area, it is about the measures the Government put forward that are going to have that impact on obesity. When we looked at mandatory calorie labelling, in our view the evidence that this would be an impactful measure was not there.

But you do not have any evidence and data, you just said there were some anecdotes, but did we not need to make evidence-based policy? Because academics have provided some data and evidence.

I totally agree there has to be evidence-based policy. What we were saying at the time was that for quite a big regulatory input on to the hospitality sector, where is the evidence that this will have an impact on obesity?

What has been the negative impact on businesses? You have alluded to the potential problem of implementation. What is that problem? What has been the negative profit related to this, or the negative consumer uptake? Do you have any data around those things?

None at all. When we talk to our members about it they say that it is another thing that they think—

It is another thing, that is true. In terms of issues with enforcement, we have had some strong evidence from people about issues with uptake compliance, both with businesses not doing it at all, but also the accuracy of information being provided. Do you have any response to that at all? You said there was no particular data, but I just wanted to put that to you as a sector body. Do you have any thoughts about what that might be?

As I say, it is a legal requirement and we make the need to follow the law clear to our members. Again, we have regular conversations with our group of nutritionists from within the sector, and everyone is aware of the law and is compliant with that, as far as we are aware.

Are you aware of any enforcement notices that have been issued?

I am not aware of any, no.

It is probably a question for us to put to local authorities, but I just want to ask you as a sector if any of your members are reporting that they have had an enforcement notice.

It is a really interesting one because you would naturally expect some to come through as part of new regulation. We have not been made aware of any. That would be a really interesting stat that we would be interested in as well. I understand that there are pressures on local authorities about enforcement.

Do you think the enforcement regime is up to scratch, given the fact that the local authority is underfunded, the fine is just £2,500 and it currently applies to fairly large businesses? Is that an adequate incentive for a business, to maybe get an enforcement notice about a £2,500 fine? It does not seem that many, if any, have been issued.

For our responsible businesses anyway, being found in breach of the law is in itself a problem, and they would not actively be seeking to do that. In terms of the local authority enforcement piece, yes that is a challenge. We have a lot of local authority enforcement across a variety of different areas, and we see the challenges they are under. That is why we are exploring with them, and the FSA in the food standards space, better ways that businesses and local authorities can work together to try to get a clear playing field.

The previous Government said the implementation would be reviewed in five years, with the consideration of a wider extension to beyond the 250 employee limit. What are your views about that review, and that possible extension?

It comes back to your point throughout, which is a really good one, about this lack of data and what the impact of this is. Where there have been a couple of studies on it, it said it was limited.

Will you be lobbying for or against the extension?

We would be lobbying against an extension.

Would you be gathering any data this time to inform that decision? Or again, is it just an anecdotal view?

We would certainly look at that to input into any review that happened after the five year period. But at the moment what we would like to see, and again going back to that point around evidence-based policy more generally, it would be good to see an independent assessment of whether this—

We have received a lot of evidence about this, to be fair, from different academics at Liverpool University and others. We have not received any from the sector, and you said there is none to provide. So there is evidence, there is some data. Just coming back to the principles, do consumers have a right to know what is in their food?

Absolutely.

Then surely this information should be available? Before this change is it not a fact that consumers could not know the calories and there is a potential argument whether it should be broader than calories. But I imagine you do not support a broader regulatory regime; you want less. So why should the out-of-home sector not provide more information about what is in people’s food on menus?

A number of companies provide the full breakdowns voluntarily, anyway. In terms of what is actually in your food, a business is required to have a matrix of all the ingredients and what is in those ingredients, and you can ask for that. So the information is there, both on the mandatory bit and on the voluntary bit. What it comes down to is about getting that balance right between what is practical from a business perspective, with a lot of hospitality businesses—

Do you know how much money your businesses spend on advertising a year as a sector?

As in the whole out-of-home sector? I do not have that information with me, but I can get it to you.

Would it be a few millions or billions, generally?

It would be a lot, I am sure.

Would that be more than it costs to put calories on menus?

Yes, it would.

Do you not think, if your sector is pumping out messaging to try to get people to buy things—probably often more unhealthy food than healthier food, I would argue—they also have a responsibility to tell consumers what is in the food when they come to buy it?

Again, it goes back to what I said: a number of the larger companies will have those larger advertising budgets, and will be providing this information to their customers.

These are larger businesses with 250-plus employees at the moment, not SMEs at this stage. Just lastly, you do not support the policy or the extension, you do not have any information to inform that particularly, it is just inconvenient. In terms of if there was an extension, what support would be needed to make it work better for businesses for them to support an extension? How could we get better compliance?

Do you mean the extension to smaller businesses?

Yes, to get better compliance, to support the businesses that may be coming into scope, should the requirements be extended. Is there any particular support the sector would want to see?

Yes. If Government were to make the decision to go down that route, then certainly when you are getting to that small individual single-site operator, that information flow is crucial. We find this all the time on all sorts of different things. So if you were to go down that line we would certainly welcome support from Government, be it guidance, practical step-by-steps and working with the sector to look at it, but certainly that support for SMEs—that are under a lot of pressure at the moment—would definitely be part of it.

Would that look like tools and guides to potentially count calories?

It would definitely be those things. In another food-related space, the allergens piece, we do a lot of work with the Food Standards Agency and ourselves with those smaller businesses, just to take them through what they need to do in terms of the allergens, and an education piece. So for this example you are giving here, that would certainly be exactly the sort of thing we would be after, yes.

Absolutely, there is obviously the work that companies will be doing themselves with their nutritionists, looking at products. As UKHospitality is a trade body, we have recently done a lot of work to develop a nutrition guide for chefs. This is going back to the point about talking to smaller businesses about how to get them thinking about making healthier dishes, and takes people through to that point around a hospitality kitchen being different to other types of food production. This is about practical steps such as changing oils that are used and, “Have you thought about swapping in X for Y?” Basically it’s like a how-to for a chef in a busy kitchen, maybe in a smaller business, who will pick it up, go through it and get some practical examples about what to do in their kitchen to make those products that bit more healthy and nutritious.

As Kate said earlier, it is a mixture, really. Some will definitely come from regulatory requirements and that piece of it, some will come through customers who are looking for healthy options, and some will come from the companies themselves who are looking at the whole piece here and making changes to products based on that.

I do not have any information to hand, but I can certainly write to you guys and see if we can source a breakdown of that.

That is a really interesting question because a couple of those sectors that you talked about such as indoor play centres, the leisure parks and that sort of thing have come into our membership. That is one area that has probably not had the attention—for want of a better word—on it from a sector perspective that other sectors have. Those are certainly businesses we are in conversations with, looking at and giving some examples of those healthier options being made available where you have a high proportion of children visiting, what their kids’ menus look like and so on, and where we can potentially help out and expand some of the work we are doing in your more traditional, if you like, restaurants and other spaces to those sorts of venues.

You are absolutely right; hospitality is under a lot of pressure at the moment. Margins are tight for a number of different reasons that people will have read about. If you are wanting to get good, responsible operators, such as the ones we represent, and if you want to get people coming to you and keep coming back, then the focus is on a quality product, to some extent. I cannot speak for every operator, or for those we do not represent, but if you are taking a hit in terms of the quality of your products in the current environment for purely cost reasons, then that has its risks as well.

I would have to look into that and write back to you, but it is really interesting you raise that actually because that is an area we have been thinking about and having a bit of a look into. Yes, we can certainly write back to you on the specifics of your question, but to highlight a focus on those businesses is really helpful.

In terms of the indoor play out-of-home sort of space?

Only anecdotally really, but we work closely with the Association of Indoor Play, the group for indoor play centres. Obviously there is a business element to their driving ethos as well, but they do a lot of work around promoting the health benefits of indoor play in general. That will be things such as the mental stimulation that kids get from the activities that they are doing, and food will be part of that as well.

Can I come back to you with some examples?

But it is a really interesting segment that you raised there, so thank you for that.

I am glad we are helping you to work through these issues. I need to now turn to front-of-pack labelling. As consumers we want to understand better, to be able to make our own choices. I am an old school Liberal; I believe that knowledge is power and I want it for myself and my family. We have heard repeated calls for mandatory front-of-pack labelling, potentially including South American style warning labels. Kate, what is your organisation’s view of that type of front-of-pack labelling?

Our view of the South American style?

Let us just start in the more general sense and then more specifically that, because it may be different.

We have had the traffic light, which is the front-of-pack approach in the UK.

We have had pretty strong evidence to show that there is some perversity around the way that works currently, so what would you say to those who say it is not working?

Government actually asked for a review of the evidence on this model in 2020, and it would be great to see what that evidence review brought up, and if that could be published. I am sure there are ways it can be made clearer. I would say the evidence generally on nutrition labelling is that having anything on the front is the biggest difference compared to the back-of-pack table, which is really quite detailed. So your big jump of consumers using it is that bit, and then the difference between any approach beyond that is quite small and variable. Sometimes it depends on market because how well they can use it depends on what people are used to seeing. But we absolutely support having front-of-pack labelling.

What is your view?

We support front-of-pack nutrition labelling.

It sounds like that is a thing that you are happy to see.

Yes.

Do you have any issues with the South American-style warning labels, more specifically?

To be clear, the warning labels are nutrition front-of-pack. They are effectively the high part of the traffic light. I would not support something being called a warning label because all food is safe to eat.

We are conducting this inquiry in the context of some being more safe than others, if I am going to be a bit Orwellian about it, but are you seriously saying that? The follow-through of that logic is that we should not be running this inquiry.

People should be informed of the nutrient levels clearly in the food product. Warning labels suggest that it is poisonous.

But some food is healthy and some food is not.

A nutrition label absolutely can help support that information. The evidence I have seen in terms of which one works better, if you like—they all work a lot better than nothing—was a review that looked at Nutri-Score warning labels and traffic lights, Nutri-Score being the European approach, and it was felt that both the Nutri-Score and traffic light performed slightly better in terms of the colour indicator supporting an understanding of what was unhealthy, but also an understanding of what was healthier. That review was published a couple of years ago, which will have come through since the Government’s evidence review. From that I would say that we would say traffic lights/Nutri-Score seem to perform better.

I was about to ask that. Would you support moving to a more European style Nutri-Score front-of-pack label? Presumably some of your companies already do that if they are operating in both markets.

We use both in both markets. Nutri-Score tends to update its profile fairly regularly. You generally need about two years to run a label change so that you do not end up with packaging you need to throw away, so that side of it could be problematic. But you are absolutely right, our companies obviously use the label that is in the market they are operating in, so some will be more familiar with Nutri-Score and some with traffic lights.

We want to understand the feasibility and the length of time it might take, and just for clarity’s sake, we are talking about mandatory front-of-pack labelling. Is there any issue with mandatory front-of-pack labelling, beyond what you have just said?

Mandatory front-of-pack will obviously ensure that it is everywhere. Where there would need to be consideration is in terms of trading with other markets; the current traffic light approach is legal in Europe as it stands.

There are regulatory niggles that would need to be ironed out, that is one of the issues. What else?

Trading into other markets is the main issue: us exporting, and ingredients that we import. If our market has a very specific requirement and we are not big enough to support that, obviously those products would not come in. But I would say that the main consideration around mandating a front-of-pack would be around the potential impacts in terms of exports and imports.

That is very helpful, thank you. Jim, you spoke about this a bit in a response to my colleague earlier. Just as a reflection, I often desperately try in bigger chains to work out what is in the food, not least because I am constantly on some kind of health kick or diet, and it is really hard to do. What more can they do to make this easier for consumers now? What are they actively discussing doing about it? I want it and I am sure I am not the only one. Huge amounts of money, billions of pounds, are spent by consumers trying to help themselves get healthier. But it does feel sometimes like the only answer is to not go because you just cannot get the information to make it work with whatever regime it is you are currently on. Are they even considering that?

Yes, we are, and businesses will be discussing in the round, like we have, what more can we do in this space? Let us look at all the different options, and so on. Absolutely, to your really good point there, we are hospitality businesses, we want to be welcoming to people, to get people through the door into our venues and that sort of thing. So that, alongside some other measures we are looking at such as how to make the dish healthier in the kitchen is definitely under discussion.

Just to finish off that lobbying point I have one quick question. There has been a lot of criticism in the evidence that we have received, basically saying that the food industry at large has undue influence over the policies that Government are creating. One of the suggestions for how that can be rebalanced would be to not have you as part of discussions related to the policy and food. By all means consulted, but not right in the centre of it, as is often portrayed. What would you say to that? I will start with Kate, please.

I would say that the Government do not make food, and so it is really important that Government talk to the people who grow, make and distribute the food, who understand.

But there is a difference between talking to, and the active lobbying that we are hearing about. What would you consider is the difference between consultation—talking and all that—versus the aggressive lobbying that we keep hearing about? Or do you just think there is no issue here?

To make successful policy it is appropriate for Government to talk to businesses, and for us to talk to Government to explain impacts of policy areas. At the end of the day the policies they take forward are obviously the Government’s decision. But, given that we make all the food and that we are the largest manufacturing sector, it is important to have an understanding of the potential impacts of those policies before decisions are taken.

Specifically to the upcoming TV and online advertising regulations, for example, how much lobbying went from your organisations into Government on watering those down?

We would have spoken to Government. The legislation took several years to come through, so I cannot give you an exact number on how often we would have spoken about it. Certainly in recent years our conversations with Government have been around bringing forward the guidance for the regulation, which we still do not have even though it is coming in in January. That was our area of focus once the policy was set. For example, we engaged with officials on things such as webinars, where we have been telling companies what they actually need to implement. We have consistently called for Government to publish the guidance, such that companies can implement the law correctly.

But it is not just officials, is it? It is parliamentarians and sponsorships; it is a wider landscape. Can I ask Jim the same question, specifically on the upcoming TV and online advertising regulations? I appreciate that you might have to write to us.

I can speak more to what we have seen this year, certainly the piece where Government decided to delay any sort of regulation this year to make clear the intent of the previous Government, this Government and Parliament. We supported the wider industry with that. But I will have to go back and write to you about some specifics about the earlier statements.

Yes, we would like to get an idea of scale. We are trying to assess, with evidence, if this is absolutely consultation, talking, feeding-in. As you say, you guys are the ones making the products; we also want to support the businesses and make sure that they thrive. We are all on the same page here, but actually the charge that is levelled is that public health interventions keep being watered down and delayed. There are, “Yes, buts” all the time, caused by aggressive lobbying of not just officials, but also parliamentarians and the wider landscape. We want to understand the scale of what is happening here, and whether we think it is a problem. So feel free to write to us, both of you. But I did promise that we would finish on time, and we nearly succeeded. Thank you both.