Obesity Health Alliance the Soft Drinks Industry Levy – Policy Briefing the Obesity Health Alliance (OHA) Is a Coalition of Or
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Obesity Health Alliance The Soft Drinks Industry Levy – Policy Briefing The Obesity Health Alliance (OHA) is a coalition of organisations committed to share expertise and support Government to tackle the issue of overweight and obesity in the UK. Obesity is a complex problem and there is no single silver bullet. A comprehensive range of population level policy interventions is required to tackle it. Policy Summary Excessive free sugar consumption is a driver behind the obesity epidemic in the UK. The OHA welcomes Government’s proposals for a soft drinks industry levy to combat obesity. An effective soft drinks industry levy to reduce free sugar consumption is a vital part of a comprehensive strategy which tackles the price, promotion and formulation of food and drink within the obesogenic environment. In order to achieve an effective levy that promotes reformulation as well as reduces consumption of sugar-sweetened drinks, the Government should consider: a) A workable definition of sugar based on health guidance; b) Making the tax bands more proportional to the sugar content; c) Reviewing which products are subject to the levy; and d) Funding a comprehensive, rigorous and independent evaluation of the levy. 1. Our view of the Soft Drinks Industry Levy We welcome the Government’s levy to help children and adults cut down on their sugar from sugar-sweetened beverages (SSBs). The soft drinks industry levy is a vital measure in the fight against overweight and obesity in the UK. The levy should result in a significant reduction in the consumption of sugar from SSBs. Our full support is subject to details being confirmed in the consultation and our concerns being addressed and failure to do so may lead the OHA to change this position. 2. The Problem Obesity and health One in five children in England is overweight or obese before they start primary school, and by the time they leave, this increases to almost one in three.1 Children are also eating too much sugar, salt and saturated fat. 2,3 We know that eating too much can lead to weight gain and obesity. This is putting our children’s future health at risk of developing serious health conditions such as Type 2 diabetes, heart disease, cancer as well as other conditions. If current trends continue, we can expect millions of extra cases of disease.4 In addition to this 6 in 10 adults in the UK are overweight or obese5. If current trends continue, this is likely to increase to 7 in 10.6 Obesity has been identified as the biggest threat to public health in the 21st century.7 Obesity is recognised as a complex interplay between diet, increasing physical inactivity and changing environments. But recent evidence from the World Health Organization (WHO) has found that increases in the food energy supply alone are sufficient to explain the weight gain over recent decades, especially in high income countries.8 Consumption of free sugars Caloric intake through free sugars remains staggeringly high.9 Every age group in the UK exceeds the maximum recommended intake from free sugars of 5%. Children consume at least double more free sugar than the new guidelines, and sugary drinks remain their number one source of sugar and 11-18 year-olds consume around three times more than is recommended by Government guidelines. 10,11 For this group, sugary drinks are their biggest source of free sugars, making up 26% of their total intake and more than double the next biggest source of sugar. Across all age groups, over 5.6 million litres of sugary drinks were consumed in the UK in 2014.12 Households with children consume around 50% more of their added sugars from carbonated and non-carbonated soft drinks, compared to households without children (25% and 17% of total processed free sugar respectively).13 Free sugars and health Excessive consumption of free sugar has become recognised as a leading source of extra calories and thus a cause of obesity. In particular, work by the Scientific Advisory Committee on Nutrition (SACN) and the WHO have led both to recommend that free sugar consumption should be reduced. Moreover, given the high rate of consumption and health consequences of consumption of SSBs, SACN has also recommended that consumption of these products should be minimised for both children and adults. Trials conducted in children and adolescents indicate that consumption of SSBs, as compared with non-calorically sweetened beverages, results in greater weight gain and increases in body mass index.14 There are also concerns that calories consumed through drinks have a weak impact on satiety (feeling full) and may be consumed in addition to, rather than instead of, calories from solid foods.15 Tooth decay is now the number one reason for hospital admissions among young children aged 5-9.16 It has been reported that half of eight year olds have visible signs of tooth decay and a third of children start school with visible signs of tooth decay.17 Greater consumption (i.e. the amount) of total sugars and sugars-containing foods and beverages is associated with a greater risk of dental caries. 3. The Solution Mechanisms of a soft drinks industry levy The levy is a tax paid by the producers and importers of soft drinks containing added sugar. Currently the levy excludes pure fruit juices and milk-based drinks. We believe that this levy can be an effective mechanism to promote reformulation and reduce consumption of SSBs, and an effective levy should include the recommendations below. The OHA welcomes the proposed soft drinks industry levy, subject to details being confirmed in the Please see p6 for definitions September 2016 2 consultation and our concerns being addressed. a) A workable definition of sugar We believe that for the purposes of the levy a definition of sugar added to SSBs should be based on the definition of ‘free sugars’ used by SACN and the World Health Organization (a full definition is provided on page 6). However, we acknowledge and support the exemption of unsweetened fruit juice from the levy (despite its status as a free sugar) due to their contribution to a healthy diet inparticular for some sub-groups of the population. This should be taken into account when adapting the SACN definition for use in the levy. b) The levy tax bands should be more proportional to the sugar content The expected current bands of the levy are 18p per litre cost for soft drinks with 5g of added sugar per 100ml and 24p per litre for those 8g of added sugar per 100ml. In their critique of the current tax bands, the Institute for Fiscal Studies note that drinks containing more sugar per 100ml will attract a relatively lower tax per gram of sugar.18 Lessons can be learned here from discrepancies in alcohol taxation, which currently does not systematically tax stronger products more heavily than weaker ones.19 The expected current bands of the levy should be revised to ensure the cost of the higher band is at least 1.6 times that of the lower (8g/5g = 1.6). As an example, we suggest the price of the upper band should increase from the expected 24p to a minimum of 29p per litre (1.6*18p) to ensure consistency. This can increase the efficacy of the tax by providing a clear signal and a larger incentive for reformulation. A more proportionate rate for the higher band may also reduce the risk of producers undershifting the tax i.e. not passing it on in full through the retail price. A low rate could be absorbed by producers or be passed onto all product lines made by the producers. The latter option would minimise the increase in retail prices for those subject to the levy and would also eliminate the positive effects of substitution away from unhealthy products subject to the levy to healthier products which are not subject to the levy. Review products that are subject to the levy a) Fruit juices We believe the following fruit juices as defined in The Fruit Juices and Fruit Nectars (England) Regulations 2013 should be exempt from the levy as currently proposed Fruit Juices are recognised as part of healthy diet through the Eatwell Plate and can contribute to a person’s fruit and vegetable consumption.20,21 To prevent the excessive intake of sugar from fruit juices, we support recommendations made by Public Health England that people should not consume more than 150ml from fruit juice per day. The impact of the levy on fruit juice consumption should be closely monitored. We also think that industry use of fruit juice and fruit nectars (as defined in the Fruit Juice and Fruit Nectar regulation 2013) as additions to SSBs should be monitored. b) Ready to drink milk-based drinks and probiotic yoghurt drinks Please see p6 for definitions September 2016 3 Whilst there are clear reasons to exclude pure milk from a soft drinks levy given its nutritional benefits, we believe that on balance ready to drink milk-based drinks with free sugar should be subject to the levy. The benefits of dairy products could be obtained through substitute products such as yogurt and pure milk and other products which do not have free sugar. Moreover, unlike fruit juices as defined above, reformulation of milk-based drinks to reduce levels of free sugar is likely to be technically easier than it is for fruit juices. Therefore we recommend that milk-based drinks and yoghurt drinks where they include free sugar should be subject to the levy. The impact of the levy on milk and ready to drink milk-based drinks and yoghurt drinks sales should be closely monitored.