Dr Belinda Reeve Alexandra Jones Senior Lecturer, Sydney Law School PhD Candidate, Charles Perkins Centre Research Fellow (Food Law and Policy), The George Institute for Global Health
5 July, 2018
Committee Secretary Department of the Senate PO Box 6100 Parliament House Canberra ACT 2600
Phone: +61 2 6277 3228 Fax: +61 2 6277 5829 [email protected]
Dear Committee Secretary,
Submission to the Select Committee into the Obesity Epidemic in Australia from the Charles Perkins Centre’s Food Governance Node
Thank you for the opportunity to make a submission to this inquiry into the obesity epidemic in Australia.
More than a quarter of Australian children aged 5-17 years are overweight or living with obesity.1 Childhood obesity has increased by 50% since 1980,2 and while increases in the rate of obesity may have slowed, the prevalence remains high, particularly among children in lower socioeconomic groups,3 and among Aboriginal and Torres Strait Islander children.4
1 Australian Institute of Health and Welfare, ‘Australia’s Health 2018’ (Australia’s Health Series No 16 Cat No AUS 221, Australian Institute of Health and Welfare, 2018)
Obesity increases children’s risk of a range of health problems, including elevated blood pressure and insulin resistance, as well as the likelihood of psychosocial problems such as low self-esteem and bullying.5 As importantly, childhood obesity is linked to obesity and overweight in adulthood, and associated non-communicable diseases (‘NCDs’) such as diabetes, heart disease and musculoskeletal problems,6 which are leading, yet preventable causes of death and illness in Australia.7
It is critical to address the current burden of childhood obesity if we want to avoid the economic and personal costs of obesity to a future generation of Australian adults and their families, to Australia’s healthcare system, and to taxpayers. While this is self- evident, it cannot occur if governments insist on delegating responsibility for rising population weight gain to individuals and/or industry alone. Past government policies have failed to reverse or even stabilise weight gain in Australian adults and children. In some cases, governments have shown remarkable devotion to policy approaches that have not worked. This cannot go unchallenged. If we want to change population health outcomes, we need new approaches.
Charles Perkins Centre, University of Sydney
We are writing on behalf of the Food Governance Node, located in the Charles Perkins Centre at the University of Sydney. The Charles Perkins Centre was established in 2012 with the mandate of generating innovative and workable solutions to easing the global burden of diabetes, obesity, and cardiovascular disease. The Charles Perkins Centre is
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based on a collaborative approach, bringing together multidisciplinary teams of researchers to identify new solutions to the challenges of diabetes, obesity, and cardiovascular disease. One of the ways in which the Charles Perkins Centre facilitates collaboration is through the creation of Project Nodes, of which the Food Governance Node is one.
The Food Governance Node was created by Dr Belinda Reeve from Sydney Law School and Alexandra Jones from the Charles Perkins Centre in 2016, with the aim of creating a cross-disciplinary platform for the development and evaluation of new legal, policy, and regulatory strategies for improving diet and nutrition in Australia. The Node includes researchers from faculties and research centres across the University, as well as from other academic and non-government organisations in Australia. It draws on members’ expertise in law, business, public health, and health policy in seeking solutions to NCDs that lie at the junction of law, regulation, and public health.
While the Select Committee has called for submissions on range of matters related to childhood obesity, our submission will focus on two of the matters that are the subject of the inquiry:
• the effectiveness of existing policies and programs introduced by Australian governments to improve diets and prevent childhood obesity (focusing on laws, policies, and regulations relevant to diet-related health); and
• the role of the food industry in contributing to poor diets and childhood obesity in Australia.
1. Effectiveness of existing policies and programs introduced by Australian governments to improve diets and prevent childhood obesity
While childhood obesity has been recognised as an issue of concern by all Australian governments, the response to the issue has varied significantly across the different jurisdictions. Some governments have acknowledged that a comprehensive, whole-of- government (and whole-of-community) approach must be taken to address this problem, leading to comprehensive programs of action. For example, the New South Wales Premier has set the target of reducing overweight and obesity rates of children by 5% over ten years and has created a delivery plan that includes education and information to
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enable informed choices, as well as measures that aim to create environments supportive of healthy eating and active living.8
Overall, however, government action on childhood obesity in Australia has been neither comprehensive nor sustained. Research by the Global Obesity Centre at Deakin University (GLOBE) (supported by the Australian Prevention Partnership Centre) benchmarked each Australian governments’ performance against recommendations for action to address obesity and improve diet-related health, created by an international network of experts.9 It found that while there were some areas where Australian governments were progressing recommended actions, there were a number of areas where they were significantly lagging behind other countries in their efforts to address unhealthy diets and obesity.
Key gaps in implementation
a) Regulation of unhealthy food marketing to children
One area in which the report identified a gap is regulation of unhealthy food marketing to children. Australia currently relies on two self-regulatory initiatives developed by the Australian food industry to regulate unhealthy food marketing to children: the Responsible Marketing Children’s Initiative (RCMI) and the Quick Service Industry Initiative for Responsible Marketing and Advertising to Children (QSRI).10 Companies that sign on to these initiatives agree to market only “healthier dietary choices” in media that is directed primarily to children, among other commitments.
While the food industry claims that these initiatives have been effective in reducing the amount of unhealthy food marketing that directly targets children, independent scientific research shows that the initiatives have not reduced children’s total exposure to
8 NSW Government, Tackling Childhood Obesity
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unhealthy food marketing11 – the objective recommended by the World Health Organisation for policies and regulations that restrict unhealthy food marketing to children.12
Research has also demonstrated that there are a number of gaps and “escape clauses” in the substantive rules contained in the RCMI and QSRI which substantially undermine their credibility and impact. These include: • The exclusion of a number of key marketing techniques, including product packaging and labelling, premium offers (the offer of a free toy or gift with the purchase of a food product), equity brand characters (characters developed and owned by food companies), apps, brand marketing, and sponsorship (with some limited provisions on sponsorship found in the QSRI);13 • A narrow definition of media that are “directed primarily to children”, which excludes the vast majority of television and other media viewed by children, including the programs with the largest child audiences;14 and • The RCMI permits companies to choose which nutrient profile model they use to identify “healthier dietary choices” that are permitted to be marketed to children. Some of these models permit a wide range of unhealthy products to be marketed to children.15
This research has also identified a series of limitations in the governance processes established by the RCMI and QSRI. These include a lack of consultation with the wider community in the creation of the initiatives, no meaningful external representation
11 Lesley King et al, ‘Industry Self Regulation of Television Food Advertising: Responsible or Responsive?’ (2011) 6 International Journal of Pediatric Obesity e390; Lana A Hebden et al, ‘Advertising of Fast Food to Children on Australian Television: The Impact of Industry Self- Regulation’ (2011) 195 Medical Journal of Australia 20; Lesley King et al, ‘Building the Case for Independent Monitoring of Food Advertising on Australian Television’ (2013) 16 Public Health Nutrition 2249; Wendy L Watson et al, ‘Advertising to Children Initiatives Have Not Reduced Unhealthy Food Advertising on Australian Television’ (2017) 39 Journal of Public Health 787. 12 World Health Organization, Set of Recommendations on The Marketing of Foods and Non- Alcoholic Beverages to Children (WHO, 2010). 13 Lana Hebden et al, ‘Industry Self-Regulation of Food Marketing to Children: Reading the Fine Print’ (2010) 21 Health Promotion Journal of Australia 229; Belinda Reeve, ‘Self-Regulation of Food Advertising to Children: An Effective Tool for Improving the Food Marketing Environment?’ (2016) 42 Monash University Law Review 419. 14 Belinda Reeve, ‘Self-Regulation of Food Advertising to Children: An Effective Tool for Improving the Food Marketing Environment?’ (2016) 42 Monash University Law Review 419. 15 Lana Hebden et al, ‘Regulating the Types of Foods and Beverages Marketed to Australian Children: How Useful Are Food Industry Commitments?’ (2010) 67 Nutrition & Dietetics 258.
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in the initiatives’ administration (which is largely managed by the Australian Food and Grocery Council, a trade industry body), a lack of independent, systematic, monitoring, few penalties for non-compliance, and no government oversight.16
In short, these initiatives lack many of the features that are required for effective self- regulation. The failure of the food industry to introduce any substantive changes to these schemes following an independent review in 2012 suggests that government intervention is needed.17 This is particularly the case given the increasing prevalence and sophistication of digital marketing for unhealthy food products targeted to children, and the lack of regulation in this area.18 Further, there is a strong argument that unhealthy food marketing to children infringes rights contained in the United Nations Convention on the Rights of the Child (which Australia has ratified), particularly article 6, on the right to life, survival and development, and article 24, on the right to health.19 Accordingly, the Federal Government should take steps to protect children from exposure to unhealthy food marketing as a child rights-protection measure.
b) The Health Star Rating System
16 Lesley King et al, ‘Building the Case for Independent Monitoring of Food Advertising on Australian Television’ (2013) 16 Public Health Nutrition 2249; Belinda Reeve, ‘Private Governance, Public Purpose? Assessing Transparency and Accountability in Self-Regulation of Food Advertising to Children’ (2013) 10 Bioethical Inquiry 149; Belinda Reeve, ‘Self-Regulation of Food Advertising to Children: An Effective Tool for Improving the Food Marketing Environment?’ (2016) 42 Monash University Law Review 419. 17 Belinda Reeve, ‘Self-Regulation of Food Advertising to Children: An Effective Tool for Improving the Food Marketing Environment?’ (2016) 42 Monash University Law Review 419. 18 Nicolla Confos and Teresa Davis, ‘Young Consumer Brand Relationship Building Potential Using Digital Marketing’ (2016) 50 European Journal of Marketing 1993. 19 Boyd Swinburn et al, ‘The “Sydney Principles” for Reducing the Commercial Promotion of Foods and Beverages to Children’ (2008) 11 Public Health Nutrition 881; Richard Ingleby, Lauren Prosser and Elizabeth Waters, ‘UNCROC and the Prevention of Childhood Obesity: The Right Not to Have Food Advertisements on Television’ (2008) 16 Journal of Law and Medicine 49; Elizabeth Handsley et al, ‘A Children’s Rights Perspective on Food Advertising to Children’ (2014) 22 International Journal of Children’s Rights 93; Louise Thornley, Louise Signal and George Thomson, ‘Does Industry Regulation of Food Advertising Protect Child Rights?’ (2010) 20 Critical Public Health 25; Elizabeth Handsley and Belinda Reeve, ‘Holding Food Companies Responsible for Unhealthy Food Marketing to Children: Can International Human Rights Instruments Provide a New Approach?’ (2018) 41 UNSW Law Journal 449; Amandine Garde et al, A Child Rights-Based Approach to Food Marketing: A Guide for Policy Makers (UNICEF, 2018)
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The GLOBE report identified the Health Star Rating (HSR) System as an example of best practice in food labelling. Australia is now one of at least 20 countries worldwide that have implemented this kind of front-of-package nutrition labelling, with the aim of enabling consumers to make healthier packaged food choices.20 In June 2018, four years since HSR implementation commenced, the government reported that more than 10,000 products have carried an HSR.
Consumer awareness of HSR is growing,21 and there is now a significant body of evidence suggesting both adults and children alike can understand and use HSR,22 and that they prefer it to both a Multiple Traffic Light model, and the industry-led Daily Intake Guide.23 There is also research from New Zealand suggesting that HSR is leading to small but significant improvements in the recipes of packaged foods.24 Despite continued media attention to high profile anomalies, recent evidence also suggests that the HSR algorithm produces results consistent with the Australian Dietary Guidelines in the vast majority of cases.25
This notwithstanding, important suggestions have been made for how HSR’s performance as a public health intervention must be improved. For example, well-known anomalies such as the ‘as prepared’ rules which allowed Milo to display 4.5 stars, still remain unclear despite multiple rounds of public consultation. It is also incumbent that the five- year review of HSR currently underway properly address key consumer concerns, such as increasing the weighting and treatment of sugar in the HSR algorithm.
20 Rebecca Kanter, Lana Vanderlee and Stefanie Vandevijvere, ‘Front-of-Package Nutrition Labelling Policy: Global Progress and Future Directions’ (2018) 21 Public Health Nutrition 1399. 21 Health Star Rating Advisory Committee (HSRAC), Two Year Progress Review Report on The Implementation of the Health Star Rating system - June 2014 - June 2016 (HSRAC, 2017). 22 Zenobia Talati et al, ‘The Impact of Interpretive and Reductive Front-of-Pack Labels on Food Choice and Willingness to Pay’ (2017) 14 International Journal of Behavioral Nutrition and Physical Activity 171. 23 Bruce Neal et al, ‘Effects of Different Types of Front-of-Pack Labelling Information on the Healthiness of Food Purchases—A Randomised Controlled Trial’ (2017) 9 Nutrients 1284. 24 Cliona Ni Mhurchu, Helen Eyles and Yeun-Hyang Choi, ‘Effects of a Voluntary Front-of-Pack Nutrition Labelling System on Packaged Food Reformulation: The Health Star Rating System in New Zealand’ (2017) 9 Nutrients 918. 25 Alexandra Jones, Karin Rådholm and Bruce Neal, ‘Defining “Unhealthy”: A Systematic Analysis of Alignment between the Australian Dietary Guidelines and the Health Star Rating System’ (2018) 10 Nutrients 501.
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Perhaps most importantly from a governance perspective, HSR remains voluntary. Research suggests this allows the system to be used selectively, with manufacturers predominantly displaying HSR on products that achieve higher ratings, including those that the Dietary Guidelines classify as ‘discretionary’ or junk foods.26 This undermines its utility to consumers, who deserve transparent information on all products to enable them to make healthier choices. Once the algorithm is reviewed, HSR must be made mandatory to enable consumers to receive the full benefit of the system’s performance across the food supply. This, together with stronger government leadership and visibility in the associated HSR information campaign are critical to addressing consumer perception that HSR is only a marketing tool for industry.
c) Product reformulation programs
Another key Federal Government initiative to improve diet-related health is the Healthy Food Partnership. The Healthy Food Partnership follows a similar format to a product reformulation initiative introduced under the prior Federal Labour Government, the Food and Health Dialogue. The Dialogue acted as a “non-regulatory” platform for the Federal Government, public health organisations and food industry actors to collaborate on a set of voluntary targets for sodium reduction in twelve product categories. While the Dialogue achieved some success in reducing the salt content of targeted products, researchers found that targets were only partially achieved and that there was substantial variation in what was achieved by the participating food companies.27
Researchers also identified significant limitations in the design and implementation of the Dialogue, including its voluntary nature, the small number of product reformulation targets, a failure to set a greater number and more demanding targets as the Dialogue matured, and the lack of mechanisms to enhance its transparency and accountability, for
26 Mark A Lawrence, Sarah Dickie and Julie L Woods, ‘Do Nutrient-Based Front-of-Pack Labelling Schemes Support or Undermine Food-Based Dietary Guideline Recommendations? Lessons from the Australian Health Star Rating System’ (2018) 10 Nutrients 32. 27 Helen Trevena et al, ‘An Evaluation of the Effects of the Australian Food and Health Dialogue Targets on the Sodium Content of Bread, Breakfast Cereals and Processed Meats’ (2014) 6 Nutrients 3802 ; Tamara Elliott T et al, ‘A Systematic Interim Assessment of the Australian Government’s Food and Health Dialogue’ (2014) 200 Medical Journal of Australia 92; Alexandra Jones et al, ‘Designing a Healthy Food Partnership: Lessons From the Australian Food and Health Dialogue’ (2016) 16 BMC Public Health 651.
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example a failure to implement systematic monitoring and reporting of results, or any penalties for non-compliance.28
In November 2015, the Federal Liberal Government announced that the Dialogue would be succeeded by the Healthy Food Partnership. The functions of the Partnership are similar to those of the Dialogue, although the scope of the Partnership’s activities is broader, encompassing portion size and social messaging in addition to product reformulation. While the Partnership has yet to release its draft reformulation goals and targets, researchers have identified governance features that will be necessary if the Partnership is to be effective. These include: strong government leadership supported by adequate funding; a credible expectation that government will escalate its level of oversight or introduce more demanding measures – a ‘responsive regulatory approach’ - to accelerate action if voluntary efforts fail;29 clear overarching targets; successful management of conflicts of interest; and objective, independent monitoring and evaluation.30 Modelling of mandatory product reformulation programs suggests that they are much more effective than voluntary schemes.31
Two and a half years since the Partnership commenced, there has been little visible progress. The latest Communique suggests that reformulation targets are still to be consulted on, with voluntary targets proposed to come into effect in 2019.32 No evaluation or monitoring plans have yet been publicly released. This lack of progress suggests that without real government leadership, the Partnership is unlikely to
28 Helen Trevena et al, ‘An Evaluation of the Effects of the Australian Food and Health Dialogue Targets on the Sodium Content of Bread, Breakfast Cereals and Processed Meats’ (2014) 6 Nutrients 3802; Roger Magnusson and Belinda Reeve, ‘Food Reformulation, Responsive Regulation and “Regulatory Scaffolding”: Strengthening Performance of Salt Reduction Programs in Australia and the United Kingdom’ (2015) 7 Nutrients 5281; Alexandra Jones et al, ‘Designing a Healthy Food Partnership: Lessons From the Australian Food and Health Dialogue’ (2016) 16 BMC Public Health 651. 29 Roger Magnusson and Belinda Reeve, ‘Food Reformulation, Responsive Regulation and “Regulatory Scaffolding”: Strengthening Performance of Salt Reduction Programs in Australia and the United Kingdom’ (2015) 7 Nutrients 5281 30 Alexandra Jones et al, ‘Designing a Healthy Food Partnership: Lessons From the Australian Food and Health Dialogue’ (2016) 16 BMC Public Health 651. 31 Linda J Cobiac, Theo Vos and J Lennert Veerman, ‘Cost-Effectiveness of Interventions to Reduce Dietary Salt Intake’ (2010) Heart doi:10.1136/hrt.2010.199240. 32 Healthy Food Partnership Executive Committee Communique (11 May 2018)
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achieve any meaningful results, instead acting as a façade to give the appearance of action.
2. Prominent gaps in Australia’s response to obesity and diet-related risk factors
In addition to gaps in policies, as discussed above, there are several critical areas in which Australia has taken no action at all: this includes a tax on sugary drinks – a regulatory policy for which there is a growing evidence of effectiveness.33
Further, Australia has no overarching policy framework for adult or childhood obesity at the federal level, or for nutrition.34 The previous Federal Labour Government agreed to create a National Nutrition Policy (accompanying a new National Food Plan), but this was never released, despite the completion of a scoping study by researchers at Queensland University of Technology.35
The Australian National Preventative Health Agency (established in 2011) provided an important platform for action on obesity prevention and took some promising steps, such as the creation of a framework for monitoring unhealthy food marketing to children. However, it was abolished by the Abbott Government in 2014. In addition, the abolition of the National Partnership Agreement on Preventive Health in the 2014 budget removed almost $370 million in funding for state-based preventive health programs, including those relating to smoking, poor diet, and unhealthy weight.
There is very little in the way of Federal Government policy on nutrition and diet- related health among Aboriginal and Torres Strait Islanders. While the National
33 See, e.g., M Arantxa Cochero et al, ‘In Mexico, Evidence of Sustained Consumer Response Two Years After Implementing a Sugar-Sweetened Beverages Tax’ (2017) 36 Health Affairs 564; World Health Organisation, Taxes of Sugary Drinks: Why Do It? (WHO, 2017). 34 Belinda Reeve and Alexandra Jones, ‘Time to Commit to Good Food Policy’, MJAInsight (online), 4 July 2016
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Aboriginal and Torres Strait Islander Nutrition Strategy and Action Plan 2000-2010 provided a framework for nutrition interventions, the strategy lapsed in 2010. There is no mention of food or nutrition in COAG’s most recent Closing the Gap health strategy, nor does nutrition feature strongly in the National Aboriginal and Torres Strait Islander Health Plan 2013-2023. The 2018 Implementation Plan for the National Aboriginal and Torres Strait Islander Health Plan 2013-2023 includes only two deliverables on nutrition of the 97 listed.36
Yet diet remains the single most important factor in the chronic disease epidemic facing Aboriginal and Torres Strait Islander communities.37 Aboriginal and Torres Strait Islander people suffer the worst diet-related health of all population groups in Australia,38 and Indigenous Australians continue to have higher rates of obesity than non-Indigenous Australians, with Aboriginal and Torres Strait Islander people 1.6 times as likely as non- Indigenous Australians to be living with obesity.39 Dietary factors alone contribute to the overall disease burden at over three times the rate for than non-Indigenous Australians,40 and diet-related chronic diseases (including diabetes, and cardiovascular disease) are the major contributor to the substantial ‘gap’ in health.41 Aboriginal and Torres Strait Islander Australians are three and a half times more likely to suffer from diabetes and experience coronary heart disease (CHD) at younger ages and increased morbidity, with
36 Department of Health, Implementation Plan For The National Aboriginal And Torres Strait Islander Health Plan 2013-2023 (Australian Government, 2015). 37 Stephen Simpson, ‘We Can’t Close the Gap on Health Unless We Talk About Nutrition’, Sydney Morning Herald (online), 10 February 2016
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those in the 35 to 44 year age group nearly five times more likely to suffer from CHD than non-Indigenous Australians.42
In summary, the Federal Government has taken what can most kindly be referred to as a “light touch” approach to obesity prevention,43 favouring industry self- regulation, and voluntary or collaborative approaches with the food industry over statutory regulation or hard-hitting measures such as taxes. While the current voluntary initiatives are an important step in the right direction, they contain significant flaws that undermine their efficacy, transparency, and accountability. It is unclear what, if any, impact they have had on population weight gain in Australia.
Debate about federal government action on obesity is not new. This is not the first federal government inquiry into obesity.44 What is remarkable is the steadfast resolve with which the government has pursued non-regulatory, “light touch” policies despite the lack of evidence of results.
If Australia is to make significant progress on halting and reversing the rise in childhood obesity, there is a need for a much stronger regulatory approach on issues such as the marketing, labelling, content, and pricing of unhealthy foods and beverages.45 This must take place within a comprehensive policy approach that addresses the social, economic and cultural drivers of unhealthy diets, and is underpinned by a national obesity strategy, accompanied by appropriate federal government infrastructure, monitoring and
42 Australian Institute of Health and Welfare, ‘Australia's Health 2016’ (Australia’s Health Series No 15 Cat No AUS 199, Australian Institute of Health and Welfare, 2016)
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surveillance of food, nutrition, physical activity, and obesity, and substantial, sustained funding.46
3. The role of the food industry in contributing to poor diets and childhood obesity in Australia
Research demonstrates that the food industry (specifically large, multinational food manufacturers and retailers, and their representative bodies) uses many of the same tactics as other health-harming industries (including tobacco), including shaping the evidence base on diet and public-health related issues, employing health experts as way of coopting the scientific conversation around diet-related health, and opposing public health policies, laws, and regulatory approaches that are likely to have a positive impact on obesity.47
Although food is not tobacco, and although the food industry and the tobacco industry are not the same, careful consideration is needed, by governments, of their vulnerability to food industry lobbying when it comes to taking action to improve diets and prevent obesity. Governments should take the lead in protecting public health and should create
46 The Australian Prevention Partnership, Deakin University and INFORMAS, Policies for Tackling Obesity and Creating Healthier Food Environments; Scorecard and Priority Recommendations for Australian Governments (February 2017)
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clear processes for identifying and managing conflicts of interest that minimise inappropriate industry influence on regulation and policy making.48
Overall, it seems more likely that regulatory approaches with strong government engagement and oversight will produce more effective results in obesity prevention than voluntary or self-regulatory initiatives. Yet it is the absence of strong government engagement that characterises the Federal Government’s approach to obesity prevention to date. International experience heavily favours statutory regulation, but researchers have also identified co-regulatory and other regulatory arrangements that could achieve meaningful progress if designed and implemented effectively.49
Urgent action is needed to reverse the trend that is seeing increasing numbers of people becoming overweight and obese. We endorse the recommendations of the Tipping the Scales report, including:
1. Legislation to implement time-based restrictions on exposure of children (under 16 years of age) to unhealthy food and drink marketing on free-to-air television up until 9:30pm. 2. Setting clear reformulation targets for food manufacturers, retailers and caterers with greater government oversight and regulation to encourage compliance if targets are not met. 3. Making adjustments to improve the Health Star Rating System and making it mandatory by July 2019. 4. Developing and funding a comprehensive national active travel strategy to promote walking, cycling and use of public transport.
48 World Health Organisation, Approach on the Prevention and Management of Conflicts of Interest in the Policy Development and Implementation of Nutrition Programmes at Country Level
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5. Funding high-impact, sustained public education campaigns to improve attitudes and behaviours around diet, physical activity and sedentary behaviour. 6. Placing a health levy on sugary drinks to increase the retail price by 20% and committing to ploughing a credible percentage of revenues back into preventive health and to reducing health inequalities in Australia. 7. Establishing obesity prevention as a national priority with a national taskforce, national targets, sustained funding, and regular and ongoing monitoring and evaluation of performance. 8. Developing, supporting, updating and monitoring comprehensive and consistent diet, physical activity and weight management national guidelines.
We urge you to recommend these actions as a priority so that all Australians, including children can look forward to living productive and healthy lives.
Please do not hesitate to contact us if there is any further information we can provide in relation to this submission.
Yours sincerely,
Dr Belinda Reeve Alexandra Jones
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