Data collection on healthiness of product portfolios

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 Food Data Transparency Partnership. 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 %  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 partnership 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 (2020) found investor pressures as a potential driver of effects, consistent with Bolton and Kacpercyk (2021) whilst Tomar (2021) and Grewal (2021) found emission reductions were likely associated with peer benchmarking.

Considerations for implementing policy

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 Government on this issue through membership of the Food Data Transparency Partnership.  The governments 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.

Cost and benefits

TBD