Lifestyle Economics

Food reformulation by stealth designed to please Public Health England, not consumers, says new IEA report


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New report on food reformulation plans which seek to reduce the per capita consumption of sugar, salt, and calories

The government’s food reformulation agenda encourages companies to design recipes that please Public Health England (PHE) and ignore the tastes and preferences of consumers, in a move labelled as “the largest extension of state control over the British diet since rationing” in a new report from the Institute of Economic Affairs.

The report, Cooking for Bureaucrats, sets out the extent of the government’s food reformulation plans which seek to reduce the per capita consumption of sugar, salt, and calories. Author of the report Josie Appleton reveals how the plans ignore the wide variety of healthy options made available to consumers in the current market and seeks to push what PHE says consumers ‘need’ rather than what they want.

Overview of the food reformulation agenda:

  • Food reformulation has occurred naturally over the decades as technology and public tastes change.

  • The PHE agenda for encouraging companies to reformulate by stealth is designed to “improve” the health of the nation without the public noticing. This comes from a conception of the public as infantile and unable to make informed choices about their own health.

  • Beginning with salt reduction targets in 2006, the government has led a decade-long campaign against salt, sugar, fat, and now calories.

  • Since 2017, there have been 220 different active salt and sugar targets.

  • The food reformulation programme is a blunt tool, with no appreciation of individual health needs or the different compositions of the food items. The targets are full of inconsistencies, as a result of industry influence:

    • Naturally occurring lactose from drink is excluded from sugar reduction targets for yoghurt drinks, but not for ice cream, custard, or rice pudding.

    • Dried fruit in cakes and buns is included in the sugar reduction target, dried fruit in cereals are given an additional allowance for the natural sugars.

    • Jam was initially subject to a sugar reduction target, until it was pointed out jam needed to contain a certain amount of sugar to be legally defined as jam rather than a preserve.

    • Similarly, PHE recommends sweets should contain less than 50% sugar, which is impossible for boiled sweets (comprised almost solely of sugar), and for fudge (the recipe for which requires a fine balance of sugar and fat).




Flaws with the reformulation agenda:

  • There is no evidence reformulation works – PHE projections for weight loss – following a reduction in calories or sugar – relies on the assumption there will be no “calorie offsetting”; but studies have shown substituting low-sugar products can lead to higher consumption of other, additional, foods.

  • Reformulation can reduce taste and sabotage classic brands – Rather than market-led reformulation, which respond to customer demands, state-led reformulation has the potential to change foods in a negative fashion and lead to falling sales or even boycotts.

    • Following changes under the reformulation programme: customers reported Coco Pops tasted “stale”; Lucozade suffered an 8.4% drop in sales; AG Barr issued a profit warning and share prices collapsed after reformulated Irn-Bru failed to sell as well as expected.



  • Reformulation can reduce the nutritional value of foods, and often fails to reflect the complexity of human diets – When Greggs switched to skimmed milk powder in porridge in an effort to please PHE, they reduced calories but also the protein content.

  • Reformulation can reduce portion sizes and lead to an increase in price – One of the easiest ways to reduce sugar or calories per portion is to reduce the portion size, an approach often encouraged by PHE. However, prices rarely reduce in line with size, meaning customers pay more to purchase the original quantity of food or drink.

  • Reformulation can have a negative impact on children – PHE’s advice to eat low-fat and low-milk foods could be beneficial for inactive adults but for active and growing children, fatty foods and dairy are essential for brain and bone development. Children are also at risk of developing an unhealthy relationship with food – including eating disorders – if there is a fixation on strict calorie guidelines.


The report also examines the role of interest groups as drivers of reform. Through Freedom of Information requests submitted by the author, Appleton discovered close links between PHE and NGOs like Action of Sugar and the Obesity Health Alliance (OHA).

One on occasion, OHA were briefed on the calorie reduction programme in August 2017, seven months before industry food bodies were involved in consultations. On another, Action on Sugar congratulated PHE on their latest campaign, committing to “reinforce [AOS] support” on social media.

Such communications show how intertwined semi-independent bodies and the public health arm of the state have become, with the apparent aim being to represent state regulation and restriction of the food sector as a response to public demand, without substantial evidence for this being the case.

Commenting on the report, author Josie Appleton said:

“These new food reformulation plans go way beyond even the existing Orwellian limits.

“There is a shocking lack of evidence behind them, it seems the main motivation for the changes is a belief the public are too infantile to make informed choices about their own diet so ‘improvements’ must be made for them.”

Christopher Snowdon, Head of Lifestyle Economics at the IEA, said:

“The government, through Public Health England, is seeking to extend its control over the British public by stealth.

“Working closely with external campaign groups, PHE is coercing the food industry to change recipes and portion sizes to suit the interests of the health lobby, rather than the preferences of the consumer.”
Notes to editors:

For media enquiries please contact Emma Revell, Communications Manager, on 07931 698 246.

Download the report, Cooking for Bureaucrats: Why the policy of food reformulation is hard to stomach here.

Josie Appleton 
is the director of the Manifesto Club civil liberties group. She specialises in research and campaigning on the hyper-regulation of everyday life, authoring dozens of reports on issues ranging from leafleting bans to the regulation of public spaces.

Related IEA research: What is junk food? and Killjoys: A critique of paternalism

The mission of the Institute of Economic Affairs is to improve understanding of the fundamental institutions of a free society by analysing and expounding the role of markets in solving economic and social problems and seeks to provide analysis in order to improve the public understanding of economics.

The IEA is a registered educational charity and independent of all political parties.



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