The Healthy Food Partnership Voluntary Industry Best Practice Guide aims to provide practical solutions to support the food industry to reduce serving sizes. It covers 11 discretionary foods and beverages for the retail and out of home sectors.
Summary
The Global Obesity Centre (GLOBE) aligns its responses with those of Cancer Council Australia.
We support, in principle, a move to encourage smaller portion and serving sizes as a measure that may reduce consumption of kilojoules and nutrients of public health concern such as saturated fats, sodium and added sugars. However, such guidance would require certain conditions in order to deliver meaningful public health benefit. This includes:
- corresponding reformulation targets for reducing kilojoule, saturated fats, sodium and added sugar content
- clear timeframes for implementation
- monitoring changes to the food supply
- reporting on uptake of the guidelines
The current proposal does not adequately address these issues and is likely to have minimal impact on public health.
This Voluntary Industry Best Practice Guide for Serving Sizes is for foods classified as discretionary foods in the Australian Dietary Guidelines. Consumption of these foods should be limited in order to maintain a healthy weight. The Dietary Guidelines state that “there is limited capacity for including energy-dense discretionary foods in nutritious dietary patterns within the energy requirements of many Australians”.1 Yet Australians are eating too many discretionary foods. In 2011-12 over a third (35%) of total energy consumed by Australians was from discretionary foods. After alcoholic beverages, the foods listed in this consultation were the highest contributors proportionally.2 The greatest public health impact would be achieved if people avoided these foods completely.
We note that the voluntary nature of the guidelines means that they are much less likely to result in meaningful population health benefits compared to mandatory standards. It can be challenging for industry to make changes when there is a risk that they could lose customers to a competitor. Mandatory standards would ensure a level playing field. At the very least there should be provisions to mandate the initiative unless there are significant uptake levels within a short timeframe (12 months).
Public health initiatives must be based on best practice in order to achieve meaningful public health benefits. The Healthy Food Partnership (formerly the Food and Health Dialogue) has thus far not achieved significant improvements in improving the healthiness of the food supply, let alone meaningful public health benefit.3
In addition, monitoring and evaluation should be included in the development stages and therefore form part of this proposal, not be added on later. The food manufacturing and services sector must take responsibility for removing excessive portion sizes from the market. The Australian Dietary Guidelines outline that an appropriate portion size for discretionary foods should provide no more than 600kJ. This should underpin all portions for discretionary snack foods and meals. A muffin that is equivalent to 4 discretionary serves, a single portion of French fries equivalent to 2.5 serves and 450 ml drinks (equivalent to 1.5 serves), as outlined in the guide, are far from best practice.
Excess bodyweight and poor diet contribute to a significant burden of non-communicable disease in Australia. In 2013, approximately 5% of cancer deaths (2329 people) and 5% of cancer cases (6714 people) were attributable to dietary factors and overweight or obesity was linked to 1990 deaths and 5371 cases.4 To address the rates of overweight and obesity and poor diet, particularly low vegetable and wholegrain intake, Australians should be encouraged to eat more foods from the five food groups and limit their discretionary food consumption. Efforts should be focused on dramatically improving the food available and limiting the promotion of energy-dense, nutrient-poor foods so that Australian diets can improve. The guidance in this document appears will do little to reduce intake of excess kilojoules, added sugars, saturated fats and sodium and will provide limited benefit in reducing diet-related disease. It is also unlikely to address the primary problem with our food system – the proliferation and promotion of energy dense, nutrient poor foods.
We encourage government commitment to evidence-based initiatives to address unhealthy diets and obesity rates. This includes:
- Comprehensive regulation to protect children under 18 years from exposure to unhealthy food marketing,
- Mandating the Health Star Rating,
- Strengthening the Nutrition Content and Health Claims Standard,
- A sugar-sweetened beverage levy,
- Restricted promotion (including discounting and multi-buy offers) of unhealthy food and drinks, and increased promotion of healthy food options.
GLOBE’s feedback can be read here.
