Faced with a conversation about the ‘nutrient profiling model’ it is likely that most people’s eyes would glaze over. Even more so if we started to explain that it is a complex algorithm based on a scoring system that weighs up the contribution of seven different nutrients in foods and drinks and assigns individual products a score.
But despite its unassuming and rather wonkish name, the nutrient profiling model (or NPM) is an important tool in health and food policy. Originally developed by the Food Standards Agency in 2004-2005 to guide advertising policy, it categorises food and drinks as ‘healthier’ or ‘less healthy’ based on the score they receive. Since 2007, products classed as less healthy (or high in fat, sugar and salt – HFSS) have not been allowed to be advertised directly to children.
From next year, the NPM will become incredibly important. Its use will be extended to identify which products are subject to new marketing restrictions on TV, online and by retailers. Food and drinks that are part of a category that contributes to children’s excess calorie or sugar intake (such as confectionery, biscuits, pizza, cereal, yoghurts etc) will have to show they pass the NPM before they can be advertised on TV before 9pm, promoted on social media or displayed at shop aisle ends and checkouts.
Like any model that makes a binary categorisation of a food product, it is not perfect. It doesn’t take portion size into account meaning foods like mayonnaise (which is high in fat, but typically consumed in small quantities) is rated less healthy, while some pizzas (typically consumed in larger portions) will be ‘healthier.’ But given the complexity of the task, it is a pragmatic tool and broadly identifies the products that those of us working in health policy are comfortable referring to as ‘junk food.’
The main issue with the NPM is that it is now well over fifteen years old and no longer encompasses more recent additions to UK dietary recommendations, in particular those for free sugars and fibre. Way back in August 2016, one of the commitments in the first chapter of the Government’s child obesity plan was to review the existing NPM and develop and test options for a new model that reflects current UK evidence-based dietary guidance.
A significant amount of work was undertaken by Public Health England with the input of an expert group and a reference group, to develop a modified version of the NPM that reflects dietary guidance. A consultation was opened in 2018, receiving 42 responses from companies, trade bodies, NGOs and four individuals. A summary of responses has been published by the Government, but over three years later they are yet to formally respond to the consultation, let alone publish the new model.
Why the lack of response? It’s clear from the industry responses that they pushed back hard on the modified version of the NPM. Reducing the sugar threshold of the NPM would affect many cereals and yoghurts (which have been previously reformulated to just squeak through the current NPM). Likewise, the revised model would also significantly limit advertising of fruit juice and juice-based drinks, due to their high free sugar content.
The Government’s own ‘Consultation Principles’ state that government departments should publish responses within 12 weeks of the consultation or provide an explanation why this is not possible. Over 160 weeks on with no response or an explanation, that ship has long sailed.
What the Government has been clear about is that the current NPM will be used to apply to incoming restrictions on food marketing, rather than the updated but unpublished version. In our view this will weaken the impact of the policy. This decision is also receiving additional parliamentary scrutiny as amendments accepted to the Health and Care Bill (the legislative vehicle for the new restrictions) have now made it a binding requirement of government to hold a full consultation before any changes can be made to the marketing rules to use anything other than the current NPM to define which products are in scope of the restrictions.
We agree that that the food industry needs certainty around the rules without moving the goalposts constantly. But to be effective, policy must evolve to reflect the changing environment and new evidence. Given the age of the NPM and its lack of alignment with the most up to date evidence based dietary guidance, the Government must now publish the updated model and give serious consideration to how it can be integrated into current and new policies. One option would be to apply it to children’s programming and online content. As children’s consumption of sugar is significantly higher than daily limits and fibre consumption below daily recommendations, it makes sense to use the updated model to ensure they receive the most protection. Publishing the revised NPM would also allow assessment of the volume of advertising focused on foods and drinks that are still likely to contribute significant sugar to our diets.
With PHE now joined up with DHSC as part of the new Office for Health Improvement and Disparities, now is the perfect time to retrieve the updated NPM from the long grass and publish it, signaling a commitment to evidence-based policy to improve everyone’s health.