Consultation outcome

Assessment of the costs and benefits of updating the nutrition standards in the GBSF

Updated 9 August 2021

Executive summary

Policy change

In May 2019, the Department of Health and Social Care (DHSC) consulted on updating the nutrition standards in the government buying standards for food and catering services (GBSF) so they reflect the latest scientific dietary advice.

This includes the latest advice from the Scientific Advisory Committee on Nutrition (SACN) on recommended levels of sugar and fibre intake that has been accepted by government and incorporated into government policy and dietary messaging.

The consultation sought views on the proposed approach to update the existing nutrition standards in the GBSF to reflect new nutritional information to reduce the risk of dietary related disease. It was announced as part of childhood obesity: a plan for action – chapter 2, in June 2018.

The responses to our consultation generally supported our proposal to update the nutrition standards in the GBSF and did not provide evidence that the organisations affected would incur significant costs. As a result, we have decided to update the nutrition standards in the GBSF to reflect the latest scientific dietary advice.

Expected costs and benefits

Costs

The amendments to the GBSF will affect a wide range of bodies in the public sector, and companies who work with the public sector. All central government departments and their agencies are required to comply with the GBSF, as well as prisons, the armed forces, and NHS trusts and foundation trusts in England.

The wider public sector is encouraged, though not mandated, to apply the GBSF standards. Food and drink manufacturers and caterers which have contracts to supply the public sector are also likely to be impacted by these changes.

All the organisations affected will incur some transition costs. This includes familiarisation costs, with both businesses and government organisations needing to read and digest the new standards. In addition, organisations may be required to change menus, marketing materials, and train staff to prepare new recipes and alter products to meet the new standards.

The changes to the GBSF may also result in organisations affected incurring some ongoing costs, such as a reduction in revenue.

At the time of the consultation we expected the costs of amending the nutrition standards in the GBSF to be low, given an assessment of introducing the current nutrition standards in the GBSF expected the costs to be negligible.^{[footnote 1]} The assessment was based on evidence from DHSC’s informal Healthier Food Mark consultation, which suggested that, given current compliance levels with the then proposed nutritional standards, there would be no significant identifiable costs of compliance. Participants in the consultation also suggested that, where current compliance was not sufficient, the new nutritional standards could be achieved without significant additional cost.

As we considered the costs of amending the nutrition standards in the GBSF to be low we did not consider it proportionate to complete a full impact assessment. The consultation responses have suggested organisations affected would incur costs that we had previously not considered. However, they did not provide evidence to demonstrate that the equivalent annual net direct cost to business (EANDCB) of amending GBSF would be greater than plus or minus £5 million, the general threshold set out in the better regulation framework for completing a full impact assessment and Regulatory Policy Committee (RPC) scrutiny. We have instead updated the assessment of the costs and benefits of amending the nutrition standards in the GBSF to reflect the additional information we have received from stakeholders.

Benefits

The burden of dietary-related ill health in the UK is significant and places a substantial pressure on the NHS. Overweight and obesity related ill health alone is estimated to have cost the health service in England £5.1 billion in 2014 to 2015.^{[footnote 2]}

Given the size of this burden, we believe the benefits of improving individual’s diets and reducing the obesity epidemic are wide ranging and large. However, they will take time to accrue. These are summarised as:

• an improvement in average population nutrient intakes, such as a reduction in intakes of free sugars, salt, saturated fat and calories and an increase in fibre

• a reduction in obesity and dietary-related ill health, resulting in reduced costs for the NHS and an increase in economic output

• a potential increase in consumption of healthier items, such as portions of fruit and vegetables and oily fish, leading to further health benefits for individuals

No quantification has been undertaken of the magnitude of these benefits. This is because of the significant complexity and uncertainty in determining the change in diets that would result from the proposed amendments.

Introduction

The burden of dietary-related ill health in the UK is significant, causing considerable amounts of mortality and morbidity each year^{[footnote 3]} and placing substantial pressure on the NHS. Obesity, for example, is a major determinant of ill health in the UK, causing heart disease, stroke, type 2 diabetes and cancer.^{[footnote 4]} Females living with obesity are over 10 times more likely to develop type 2 diabetes than their healthy-weight counterparts are, with males living with obesity over 5 times more likely.^{[footnote 4]} This imposes a substantial burden on the NHS, with overweight and obesity costing the English health system £5.1 billion in 2014 to 2015.

In 2019, 64% of adults in England were classified as overweight or living with obesity, with 28% living with obese. Among children, the equivalent figures were 30% and 16%, respectively.^{[footnote 5]} Without action, the burdens of obesity and its related conditions are expected to grow substantially over time. Projections suggest that the proportion of the UK adult population who are living with obesity will increase significantly over the coming decades.^{[footnote 6], [footnote 7]}

Many people in the UK do not have balanced diets, and consume too many calories,^{[footnote 8]} more sugar than recommended^{[footnote 9]} and not enough portions of fruit and vegetables.^{[footnote 10]} Our diets are influenced by many drivers, including our behaviour, environment and culture. Therefore, the government is committed to pursuing a wide set of actions to improve people’s diets and is committed to the public sector leading by example in ensuring a healthy food environment for children and parents on their premises.

Policy context

The GBSF were originally introduced in 2011 as a means of meeting the Greening Government Commitments when buying and providing food and catering services.

All central government departments and their agencies are required to comply with the GBSF, as well as prisons, the armed forces, and the NHS trusts and foundation trusts in England. Schools must follow the school food standards legislation but may also choose to use the GBSF. The wider public sector is encouraged to apply these standards, including to food and drink offered in vending machines (for example, in leisure centres).

The proposal to update the nutrition standards in the GBSF was part of a wider set of policies included in the government’s childhood obesity: a plan for action – chapter 2, published in June 2018. The plan sets out the government’s national ambition to halve childhood obesity by 2030 and significantly reduce the gap in obesity between children from the most and least deprived areas. The proposals outlined in chapter 2 include consulting on mandatory calorie labelling in the out-of-home sector, ending the sales of energy drinks to children, encouraging further action in local areas and further restrictions on the marketing of high fat, sugar and salt (HFSS) products to children. The proposed policies will help individuals make better decisions by changing the food environment, so that healthier choices become the easiest choices.

In August 2016, the government launched the first part of its plan for action. This comprehensive plan aims to help children and families make healthier choices and be more active. Key measures in the plan included a Soft Drinks Industry Levy, a sugar reduction and wider reformulation programme, and a commitment to helping children enjoy an hour of physical activity every day. Chapter 2 builds on the first chapter of the plan, both to cement the action already taken, and to take action in other areas.

The Soft Drinks Industry Levy has been designed to incentivise reformulation and is charged on drinks with a total sugar content of 5 grams or more per 100 millilitres, with a higher charge for drinks that contain 8 grams or more per 100 millilitres. The Levy came into force in April 2018 and has already resulted in over 50% of manufacturers reducing the sugar content of drinks, equivalent to 45 million kg of sugar every year.

As part of the wider reformulation programme, in August 2017 the government announced an extensive calorie reduction programme. This programme aims to remove excess calories from the processed foods that children eat most, helping to make the healthy choice the easy choice for consumers. The calorie reduction programme challenges the food industry to achieve a 20% reduction in calories by 2024 in product categories that contribute significantly to children’s calorie intakes (up to the age of 18 years) and where there is scope for substantial reformulation or portion size reduction (or both). This requires work to be undertaken by retailers and manufacturers, restaurants, pubs, cafes, takeaway and delivery services and others in the eating out-of-home sector. The products covered by the calorie reduction programme have been announced, following engagement with stakeholders. They include:

• ready meals
• pizzas
• crisps and savoury snacks
• chips and potato products
• prepared sandwiches
• other ‘on the go’ foods and relevant meals and dishes served out of the home

In July 2020, the government launched tackling obesity: empowering adults and children to live healthier lives. The strategy demonstrates an overarching campaign to reduce obesity, takes forward actions from previous chapters of the childhood obesity plan, including our ambition to halve the number of children living with obesity by 2030, and sets out measures to get the nation fit and healthy and protect against COVID-19 and protect the NHS.

Policy outline

In May 2019, DHSC consulted on updating the nutrition standards in the GBSF so they reflect the latest scientific dietary advice. A summary of the changes is provided in annex 1.

This includes the latest advice from the SACN on recommended levels of sugar and fibre intake that has been accepted by government and incorporated into government policy and dietary messaging.

The consultation sought views on the proposed approach to update the existing nutrition standards in the GBSF to reflect the latest scientific dietary advice, including new recommendations on sugar and fibre that has been incorporated into government policy and dietary messaging to reduce the risk of dietary related disease. It was announced as part of childhood obesity: a plan for action – chapter 2 in June 2018. This is part of the government’s plan for action to significantly reduce childhood obesity by supporting healthier choices.

The feedback to the consultation generally supported the proposals to update the nutrition standards in the GBSF and did not provide evidence that the organisations affected would incur significant costs. As a result, we have decided to update the nutrition standards in GBSF to reflect the latest scientific dietary advice.

This document lays out the reasoning behind the decision to amend the GBSF and justification for the expected low costs.

Affected organisations and people

When the consultation was published an exact estimate of the number of businesses affected by any changes to the GBSF was unavailable. Feedback from the consultation did not provide additional information on the number of businesses involved in the GBSF.

However, annex 2 provides a list of all businesses we are aware of that are involved in the food and drink manufacturing sector and the food services sector. This provides an upper limit as a guideline. 151,105 businesses provide food in the UK, though the overwhelming majority of these will not supply their products to the public sector.

Bodies who will adopt the new standards include central government, prisons, armed forces, and hospitals. Local government is encouraged to adopt the new standards. There are 398 principal councils in the UK and across the UK there are 20 non-ministerial departments, 23 ministerial departments, 414 agencies and other public bodies, 13 public corporations (see departments, agencies and public bodies) and 123 prisons in England and Wales. Incorporating updated GBSF nutrition standards into existing catering contracts with public institutions would be subject to the conditions within individual contracts.

NHS and foundation trust hospitals are required to be compliant with GBSF in respect of activities which they undertake themselves, such as in-house catering, as they are mandated by NHS England within the NHS Standard Contract as one of the 5 mandatory hospital food standards. A report from DHSC in 2017 suggests that over 90% of hospitals are fully or partly compliant with the current GBSF criteria. There are 229 NHS and foundation trusts in England and Wales.

For services which trusts directly provide themselves, the wording of the NHS Standard Contract means that, as and when the GBSF are updated, the new updated version will technically be mandatory as soon as they are published on GOV.UK as the NHS Standard Contract requires compliance with the standards in their latest format.

Many trusts permit other organisations to operate catering or retail concessions on their sites, such as WHSmith and Marks & Spencer. Other trusts operate on premises covered by private finance initiative (PFI) arrangements, under which the PFI company has, in effect, long-term control over how such catering or retail concessions operate.

The terms of the NHS Standard Contract do not apply directly to such catering, retail or PFI companies, nor do they give a trust any power to amend, unilaterally, the terms of the commercial agreements it has reached with such companies. Rather, the NHS Standard Contract requires a trust, when procuring or negotiating contractual arrangements with a catering, retail or PFI company, to require those companies to comply with the mandatory elements of GBSF. As a result, the ability of a trust to ensure adoption of the updated GBSF in such situations will depend on the length of the contracts or leases it has with catering and retail companies – and the flexibility of these arrangements in terms of the scope they allow for re-negotiation prior to expiry. PFI arrangements are generally long term, and trusts operating on PFI premises may therefore have limited ability to ensure that their on-site caterers and retailers adopt the updated GBSF.

In practice, this means is that the adoption of updated GBSF, across the NHS estate, will be gradual, varying between trusts, depending on the extent to which each provides catering services in-house, the length and flexibility of the contracts and leases under which catering and retail companies on its premises operate, and whether it is operating on PFI premises.

It is not clear what level of current compliance there is with the current standards across all central government departments.

In terms of other organisations, we asked stakeholders in the consultation whether they are compliant with the current nutrition standards contained in the GBSF. In response, 17 stakeholders answered this question, including 2 individuals, 10 organisations and 5 businesses. Only one stakeholder said they were not currently compliant, 9 said they were partly, 6 said they were, including an NHS and foundation trust, and one was not sure the extent to which they are compliant. Stakeholders explained that several of the current standards are difficult to comply with, including:

• half of desserts must contain at least 50% of their weight as fruit
• serving a portion of oily fish once a week
• cooking vegetables and starchy foods without salt
• meeting the voluntary best practice nutrition standards for the amount of sugar in sugar-sweetened beverages

In terms of the people affected, civil servants, hospital workers, visitors and patients, military personnel and prison inmates will be affected by the changes to nutrition standards in the GBSF. All these groups of people will be affected by changes to the choice of products available. As hospital patients, military personnel and prison inmates do not pay for the food and drinks that are subject to the GBSF they will not be affected by any price changes. Although civil servants and hospital workers and visitors would be, given we expect the costs to organisations of the amended nutrition standards for the GBSF to be low we do not expect there to be any significant costs passed onto consumers. The impact on them is also less insofar as they will have other options available such as bringing their own food with them or accessing food off-site. These choices are not available to hospital patients, some military personnel and prison inmates.

In September 2019, there were 5.43 million people employed in the public sector.^{[footnote 11]} The prison population is around 84,000 people,^{[footnote 12]} and the British Armed Forces currently have 192,660 active personnel.^{[footnote 13]} Of all people in paid work, 16.5% were employed in the public sector and the remaining 83.5% were employed in the private sector.^{[footnote 11]} While not all people employed in the public sector will be directly affected, these number give a sense of the breadth of the impact.

The consultation sought views on including a 12-month implementation period before any updated standards became mandatory. Several respondents suggested that the implementation period would need to be longer than 12 months with suggestions of 18 months, 2 years and 5 years. The main reason stakeholders provided for suggesting a longer implementation period was that:

• they would need a 6-monthly range refreshment and development process to allow customers to change their menus in time
• manufacturers would need more than 12 months to either source new products, reformulate existing ones or make changes to packaging size

Despite these concerns, the majority of respondents agreed that a 12-month implementation period would be an appropriate implementation period, including 50% of businesses that responded.

As a result, in the government response to the consultation, we concluded that we intend the implementation period to be 12 months, to provide organisations sufficient time to meet the updated standards.

Expected costs and benefits to business, government and society

Costs

At the time of the consultation we considered the costs of amending the standards to be low, given that a previous assessment of introducing the current nutrition standards in the GBSF expected the costs to be negligible. Evidence for this comes from an informal consultation, carried out for DHSC’s Healthier Food Mark (HFM) impact assessment. The original nutrition standards for the GBSF come from the HFM nutrition criteria, and comments received during the piloting and evaluation of HFM. Stakeholders (including government departments) reported that, given current levels of compliance with many of the then proposed higher nutrition standards, there would be no significant identifiable costs of compliance.

Furthermore, it’s also important to note that the NHS did not need to comply with the standards until they were included in the 2017 to 2019 standard contract. As a result, the cost to the NHS of complying with the current standards was not previously assessed.

The feedback from the consultation provided additional information on both the transition and ongoing costs organisations affected would incur because of updating the nutrition standards for the GBSF.

Transition costs

All the organisations affected are expected to incur some familiarisation costs, with both businesses and government organisations needing to read and digest the new standards. The time taken for initial familiarisation will vary between organisations depending on the size and scale of operations. More information on estimates of companies affected is given in the section affected organisations and people above. Prior to the consultation we assumed that on average, it would take one manager one hour to read and become familiar with the standards. This assumption was not questioned in the consultation.

Feedback from the consultation highlighted several other transition costs that organisations affected may incur to meet the amended nutrition standards in the GBSF. These included:

• sourcing alternative products from suppliers

• changing marketing materials, recipes, menus and checkout till structures

• training staff to cook and serve new products

The consultation did not provide evidence on the scale of these costs. However, given they were not identified as significant costs in DHSC’s HFM impact assessment when the current nutrition standards in the GBSF were introduced, we assume they would be low for these amendments.

The DHSC’s HFM impact assessment did not consider the transition costs to the NHS or retailers within hospitals complying with the current standards. As explained above, evidence suggests over 90% of hospitals are fully or partly compliant with the current GBSF criteria. This assessment includes all catering and retail companies on hospital sites, with the exception of PFI hospitals, as the NHS Standard Contract requires a trust to require those companies to comply with the mandatory elements of GBSF. As a result, the NHS or catering and retailers within hospitals would face some transition costs, but we do not expect their transition costs to be higher than for any other organisations complying with these amendments.

The consultation feedback also mentioned that organisations affected would incur costs in designing and manufacturing new products or altering existing products to meet the new nutrition standards. Stakeholders commented that this would be necessary to meet the updated standards for reducing saturated fats in pre-packed sandwiches, reducing sugar intake, savoury snacks, confectionary and beverages.

For beverages, a consultation response from a trade body informed us that they expect drinks manufacturers to choose to produce new formats of existing products to meet the updated standards. However, we do not consider this a direct cost of the policy, as discussed further below.

To consider whether the policy required manufacturers to make significant changes to their products, following the consultation, we worked with Public Health England (PHE) to review the products already available on the market that stakeholders suggested would require new products to be developed or existing products altered. Specifically, we reviewed whether the range of currently available products that meet the new nutrition standards, would require manufacturers to make significant changes to their products or develop new ones. This included engaging with 2 large food service providers which have contracts to supply the public sector.

The review showed that there are a range of products already available that meet the updated standards for reducing sugar intake, savoury snacks, confectionary and beverages. It should be noted that this review did not capture all products currently on the market, therefore there are likely to be more products available that meet these updated standards.

The review was not able to identify the number of pre-packed sandwiches currently available that contain 400 kcals (1,680 kJ) or less per serving and do not exceed 5.0g saturated fat per 100g, the mandatory standard proposed in the consultation. As a result, we have decided to reduce the proportion of pre-packed sandwiches that meet this standard, from 75% to 50% for an implementation period of 18 months. After 18 months this proportion will increase to 75% with a further implementation period of 18 months. Although we are aware anecdotally of products currently available that do meet this standard, as this is a new mandatory standard we consider appropriate to provide businesses with additional time to make any necessary changes to meet this standard.

As there are already products readily available that meet the updated nutrition standards in the GBSF that stakeholders were particularly concerned about, not all manufacturers would be required to alter existing products or develop new products. If manufacturers did choose to alter existing products or develop new products we would consider this to be an indirect cost as it would be a business decision not imposed through these amendments.

In our initial assessment of the costs of updating the nutrition standards in the GBSF we expected there to be a small one-off cost to vending machine operators where changes to the nutrition standards necessitate changes to vending machine offerings. In the consultation one stakeholder, which has an arrangement with a vending machine operator, said it does not expect the changes to result in any additional costs.

Ongoing costs

In the feedback to the consultation, stakeholders commented that amending the nutrition standards in the GBSF could result in a loss of revenue for affected catering services, as customers may choose places that are not subject to the restrictions that GBSF places on the products served.

For example, a business with government and healthcare catering contracts noted that its annual sales growth of meal deals and average transaction value declined following the introduction of Commissioning for Quality and Innovation (CQUIN)^{[footnote 14]} and CQUIN 2.

However, there are significant differences between the GBSF and CQUIN. CQUIN makes a proportion of NHS trusts in England income conditional on demonstrating improvements in quality and innovation in specified areas of care. CQUIN part 1(b) provides a financial incentive to NHS trusts in England to provide healthier food options in hospitals for NHS staff, visitors and patients. For example, CQUIN part 1(b) incentivised NHS trusts in England to ban price promotions and advertisements of sugary drinks and HFSS foods. This is compared to the GBSF that contains mandatory and voluntary nutrition standards that all government departments and their agencies, prisons, the armed forces and the NHS trusts and foundation trusts in England must adhere to. These differences mean that GBSF is unlikely reduce revenue for all affected catering services by as much as the stakeholder experienced when CQUIN and CQUIN 2 were introduced.

In addition, we would only expect the amendments to the GBSF to decrease catering service providers revenue if it significantly limited the products they are able to offer customers. The majority of the GBSF standards are set at a percentage of these products procured or made available to reflect current product availability. Our review of the products already available that meet the updated standards to the GBSF suggests that this would not be the case as catering service providers would have a wide range of alternative products to offer.

Based on the assessment of the introduction of the previous nutrition standards in the GBSF and the information on the products already available that meet the updated standards we consider our assumption that there would be a small reduction in revenue for catering services affected to be reasonable.

The feedback to the consultation also noted that the amended nutrition standards in the GBSF would mean the catering services affected would be required to purchase more expensive ingredients. A specific concern was with the requirements on providing fruit as part of desserts and oily fish for lunch and evening meals.

Despite these concerns, we expect the additional ingredients costs for catering services following the changes to the nutrition standards for the GBSF to be low. The main reason is that the updated nutrition standards for the GBSF only make minor changes to the criteria on fruit in desserts and oily fish. The only change to the requirement that half of desserts available contain at least 50% of their weight as fruit is that it now excludes fresh fruit in the calculation. There are no changes to how often a portion of oily fish should be provided as a lunch or evening meal option.

Benefits

Many people in the UK do not have balanced diets, and consume too many calories,^{[footnote 8]} more sugar than recommended^{[footnote 9]} and not enough portions of fruit and vegetables.^{[footnote 10]} In particular, adults consume around twice the recommended maximum amount of sugar.^{[footnote 9]} Furthermore, on average, compared with those with healthy body weights, overweight or obese adults consume between 362 and 425 kcals more than they need per day for men, and between 251 and 297 kcals per day for women.^{[footnote 8]}

The burden of dietary-related ill health in the UK is significant, causing considerable amounts of mortality and morbidity each year^{[footnote 3]} and placing substantial pressure on the NHS. Too much salt consumption, for example, can raise blood pressure which increases the risk of heart disease and stroke and a lack of fibre in our diets has been linked to an increased risk of developing cancer and having a stroke.^{[footnote 15]} Being overweight or obese is now the second biggest preventable cause of cancer after smoking.^{[footnote 16]} Moreover, overweight and obesity related ill health alone is estimated to have cost the health service in England £5.1 billion in 2014 to 2015.^{[footnote 2]}

Given the size of the burden, we believe the benefits of improving individual’s diets and reducing obesity rates are wide ranging and large. However, they will take time to accrue. Given the breadth of effect of the GBSF the effect on society is substantial. These are summarised as:

• an improvement in average population nutrient intakes, such as a reduction in intakes of free sugars, salt, saturated fat and calories and an increase in fibre

• a potential increase in consumption of healthier items, such as portions of fruit and vegetables and oily fish, leading to further health benefits for individuals

• a reduction in obesity and dietary-related ill health, resulting in reduced costs for the NHS and social care and an increase in economic output. The personal benefit to individuals of avoiding ill health and premature mortality is also very significant

Although updating GBSF will benefit a wide range of the population, the main groups of people that are likely to benefit from healthier food and drink choices are civil servants, hospital workers, visitors and patients, military personnel and prison inmates.

There is insufficient evidence to help us accurately predict how businesses and consumers will respond to the updated standards, in terms of changes in consumption of different food items. The sort of evidence that would be required for this – for example, trials of the new regulations in a representative sample of locations – do not exist and would have been disproportionately burdensome to set up and monitor. For this reason, we have not attempted to quantify these benefits.

Summary

This document provides background to the changes to the nutrition standards in the GBSF. The cost to business was low when the regulations were originally introduced, and the feedback to the consultation has provided limited evidence to suggest that they would be significant for these amendments. We therefore expect the cost to business of updating the regulations to be low. The policy is expected to result in significant health benefits, though, due to lack of available evidence, these have not been quantified.

Annex 1: changes to the GBSF nutrition standards

Mandatory nutrition standards

1. Reducing salt

Vegetables and boiled starchy foods such as rice, pasta and potatoes, shall be cooked without salt.

Salt shall not be available on tables.

At least 75% of meat products, breads, soups and cooking sauces and ready meals procured by volume, and 75% of breakfast cereals and pre-packed sandwiches provided meet current core salt targets and any subsequent revisions to this target all stock preparations shall be lower salt varieties (that is, below 0.6g per 100mls reconstituted).

Note: The 75% applies individually to each food category described in the above specification, and not only to the combined provision or volume. The requirement relates to meeting maximum targets, or using an average target as a maximum where a maximum target is not set.

Changes

Change to current salt targets.

Increase from 50% to 75% of products with categories meeting targets and updated wording from procured by volume to available.

2. Increasing fruit and vegetable consumption

A portion of fruit shall be sold at a lower price than a portion of hot or cold dessert.

Half of desserts available should contain at least 50% of their weight as fruit – which may be fresh, canned in fruit juice, dried or frozen. This excludes whole fresh fruit as a dessert option. Whole fresh fruit can be a dessert option but should not be included as an option when calculating whether half of dessert options should contain at least 50% of their weight as fruit.

Main meals within a meal deal should include a starchy carbohydrate which is not prepared with fats or oils, and the meal deal options should include at least one portion of vegetables and one portion of fruit.

Changes

Excluding fresh fruit as a dessert for calculation purposes.

Change to the meal deal standard from the current: Meal deals include a starchy carbohydrate, vegetables and one portion of fruit.

Additional requirement of carbohydrate in meals not being prepared with fats or oils.

3. Meal deals

Any foods and drinks within a meal deal must also meet the relevant GBSF standards for the healthier options, for example, healthier sandwiches.^{[footnote 17]}

Changes

New mandatory standard to ensure food and drinks used within meal deals meet the healthier options in the GBSF standards.

4. Reducing saturated fat

Meat and meat products (procured by volume), biscuits, cakes and pastries (provided) be lower in saturated fat, where available.

At least 50% of hard yellow cheese procured by volume shall have a maximum total fat content of 25g per 100g.

At least 75% of ready meals procured by volume shall contain less than 6g saturated fat per portion.

At least 75% of milk procured by volume is lower fat (semi-skimmed, 1% or skimmed milk).

At least 75% of oils and 75% of spreads procured by volume are based on unsaturated fats.

At least 50% of pre-packed sandwiches and other savoury pre-packed meals (wraps, salads, pasta salads) provided contain 400 kcals (1,680 kJ) or less per serving and do not exceed 5.0g saturated fat per 100g for an implementation period of 18 months and will increase the standard to 75% thereafter with a further implementation period of 18 months.

Changes

Additional requirement around pre-packed sandwiches and other savoury pre-packed meals for decreasing saturated in pre-packed sandwiches.

Very slight rewording for clarity regarding milk.

At least 50% of pre-packed sandwiches and other savoury pre-packed meals (wraps, salads, pasta salads) provided contain 400 kcals (1,680 kJ) or less per serving and do not exceed 5.0g saturated fat per 100g for an implementation period of eighteen months and will increase the standard to 75% thereafter with a further implementation period of 18 months.

5. Increasing fibre

At least 50% of bread provided contains at least 3g fibre per 100g (that is, is a source of fibre), excluding pre-packed sandwiches.

At least 75% of pre-packed sandwiches provided contains bread with at least 3g fibre per 100g.

Changes

New mandatory standard for increasing fibre intake.

Additional requirement around bread available, and pre-packed sandwiches and other savoury pre-packed meals for increasing fibre.

6. Reducing sugar intake

At least 75% of products provided that are included in the following categories covered by the sugar reduction programme to not exceed the following:

• biscuits: 100 kcals

• cakes: 220 kcals

• morning goods: 220 kcals

• puddings: 220 kcals

• yogurts: 120 kcals

• ice cream: 220 kcals

Note: The 75% applies individually to each product category described in the above specification, and not only to the combined provision.

Changes

New mandatory standard for reducing sugar intake.

7. Breakfast cereals

At least 50% of breakfast cereals provided are higher in fibre (that is, at least 6g per 100g) and shall not exceed 12.3g per 100g total sugars (10g additional allowance for dried fruit in cereal).

Changes

Update to maximum sugar content for at least 50% of breakfast cereals – to bring in line with sugar reduction guideline.

Updated wording from procured by volume to available.

8. Fish

If caterers serve lunch and an evening meal, fish is provided twice per week (2 x 140g portions), one of which is oily. If caterers only serve lunch or an evening meal, oily fish (140g portion) is available at least once every 3 weeks.

Changes

No change

9. Savoury snacks

Savoury snacks are only provided in packet sizes of 35g or less.

Note: Savoury snacks include crisps and any product made from small pieces of potato, wheat, rice, corn or other base ingredient, which have been baked, extruded, cooked or processed in any way. Crisps are defined in this instance as products that comprise sliced whole, fried potato.

Changes

Moved from voluntary best practice to mandatory.

10. Confectionery

At least 75% of confectionery and packet sweet snacks provided are in the smallest standard single-serve portion size available within the market and do not exceed 200 kcals (maximum) for chocolate and 125 kcals (maximum) for sugar confectionery.

Changes

Moved from voluntary best practice to mandatory with new calorie caps, bringing in line with sugar reduction guideline.

11. Beverages

No more than 10% beverages provided can be sugar-sweetened beverages (SSBs).

At least 90% of beverages provided must be low-calorie or no-added-sugar beverages.

All SSBs to be no more than 330ml pack size. Any SSBs that are hot or cold milk-based drinks including milk substitute drinks such as soya, almond, hemp, oat, hazelnut or rice need to meet 300 kcals cap.

Any meal deals should not include any SSBs.

At least 75% fruit juice, vegetable juice and smoothies to be provided in single-serve packs.

For further guidance on how SSBs, low-calorie and no-added-sugar beverages are defined is available in the supporting documents.

Changes

Moved from the 330ml pack size for SSB from voluntary best practice to mandatory.

Moved from voluntary best practice to mandatory and increased to 90% from 80% (now 10% of beverages can be SSBs).

Change of wording from 90% of beverages procured by volume to made available.

New standard for fruit juices and smoothies.

New standard for milk-based drinks (including milk substitute drinks).

No SSBs to be included within a meal deal.

Voluntary (best practice) nutrition standards

12. Reducing salt intake

At least 75% of all products (procured by volume or provided) that are covered by the current core salt targets and any subsequent revisions to this target meet this target.

Note: The 75% applies individually to each food category described in the above specification, and not only to the combined provision or volume. The requirement relates to meeting maximum targets, or using an average target as a maximum where a maximum target is not set.

Changes

New voluntary best practice standard for reducing salt intake.

13. Increasing fibre

To ensure at least 50% of all bread provided contains at least 3g fibre per 100g (that is, is a source of fibre), as per the mandatory standard.

And, in addition to the mandatory standard:

• At least 25% of all bread provided contains at least 6g per 100g (that is, high in fibre), excluding pre-packed sandwiches

Additional voluntary best practice standard

To ensure main meals containing beans or pulses (or both) as a main source of protein are made available at least once a week.

Changes

New voluntary best practice standard for increasing fibre intake.

Additional voluntary best practice standard

To ensure main meals containing beans or pulses (or both) as a main source of protein are made available at least once a week.

14. Breakfast cereals

To ensure at least 50% of all breakfast cereals provided contain at least 6g per 100g of fibre (that is, high in fibre) and shall not exceed 12.3g per 100g (10g additional allowance for dried fruit in cereal), as per the mandatory standard.

And, in addition to the mandatory standard:

• At least 25% of all breakfast cereals provided contain at least 6g per 100g (that is, high in fibre) and shall not exceed 5g per 100g (10g additional allowance for dried fruit in cereal)

Changes

New voluntary best practice standard for increasing fibre and decrease sugar intake.

15. Savoury snacks

Savoury snacks are only provided in packet sizes of 30g or less.

Changes

No change to standard.

16. Confectionery

All confectionery and packet sweet snacks provided are in the smallest standard single serve portion size available within the market and do not exceed 200 kcals (maximum) for chocolate and 125 kcals (maximum) for sugar confectionery.

Changes

New voluntary best practice standard for reducing sugar intake.

17. Beverages

All beverages (100%) provided must be low-calorie or no-added-sugar beverages, that is, no SSBs are offered.

Changes

New voluntary best practice standard for reducing sugar intake.

18. Menu cycle analysis

Menu cycles are analysed to meet nutrient based standards relevant for the majority of customers using the catering provision.

Changes

No change to standard, very slight rewording for clarity.

19. Calorie and allergen labelling

Best practice requirement for menus for (food and beverages) to include calorie and allergen labelling where not stated in law.^{[footnote 18], [footnote 19]}

Changes

New best practice requirement for menus for (food and beverages) to include calorie and allergen labelling.

Annex 2: UK business counts – enterprises by industry and employment size band

Sourced from Nomis on 5 February 2020. This is an upper limit of the number of businesses that will be affected by the changes. Businesses that do not work with government or local authorities will be unaffected, however the proportion of this table that are involved with government is unknown.

It should be noted that the all figures in table 1 are rounded to avoid disclosure. Values may be rounded down to zero and so all zeros are not necessarily true zeros. As a result, the totals across tables may differ by minor amounts due to the disclosure methods used. Furthermore, figures may differ by small amounts from those published in Office of National Statistics outputs due to the application of a different rounding methodology.

Table 1: UK business counts by industry and employment size

Industry	Total	Micro (0 to 9)	Small (10 to 49)	Medium-sized (50 to 249)	Large (250+)
1011: Processing and preserving of meat	345	215	70	35	20
1012: Processing and preserving of poultry meat	100	45	25	15	10
1013: Production of meat and poultry meat products	550	320	160	55	15
1020: Processing and preserving of fish, crustaceans and molluscs	305	165	90	40	10
1031: Processing and preserving of potatoes	50	30	10	5	5
1032: Manufacture of fruit and vegetable juice	75	60	15	5	0
1039: Other processing and preserving of fruit and vegetables	490	380	55	40	15
1041: Manufacture of oils and fats	70	55	5	5	0
1042: Manufacture of margarine and similar edible fats	5	5	0	0	0
1051: Operation of dairies and cheese making	365	235	75	45	10
1052: Manufacture of ice cream	325	240	75	10	0
1061: Manufacture of grain mill products	160	100	25	25	10
1062: Manufacture of starches and starch products	10	5	0	0	0
1071: Manufacture of bread; manufacture of fresh pastry goods and cakes	2,570	1,750	630	145	45
1072: Manufacture of rusks and biscuits; manufacture of preserved pastry goods and cakes	290	175	80	25	10
1073: Manufacture of macaroni, noodles, couscous and similar farinaceous products	25	15	5	0	0
1081: Manufacture of sugar	5	0	0	0	0
1082: Manufacture of cocoa, chocolate and sugar confectionery	420	290	90	30	10
1083: Processing of tea and coffee	100	60	25	10	5
1084: Manufacture of condiments and seasonings	240	180	35	20	10
1085: Manufacture of prepared meals and dishes	260	170	40	35	15
1086: Manufacture of homogenised food preparations and dietetic food	190	165	20	5	0
1089: Manufacture of other food products n.e.c.	955	715	160	55	25
5610: Restaurants and mobile food service activities	90,975	72,190	17,220	1,235	335
5621: Event catering activities	12,055	10,575	1,270	165	40
5629: Other food service activities	2,540	2,160	290	40	50
5630: Beverage serving activities	37,630	26,005	11,115	450	60
Column total	151,105	116,300	31,585	2,510	710

1. See Impact assessment of government buying standards specifications food and food services, 2011. ↩

2. Estimates for UK in 2014 to 2015 are based on: Scarborough, P. (2011) The economic burden of ill health due to diet, physical inactivity, smoking, alcohol and obesity in the UK: an update to 2006-07 NHS costs. Journal of Public Health. May 2011, 1-9. Uplifted to take into account inflation. No adjustment has been made for slight changes in overweight and obesity rates over this period. We assume England costs account for around 85% of UK costs. ↩ ↩²

3. Rayner M, Scarborough P (2005). The burden of food related ill health in the UK. Journal of Epidemiology & Community Health. 2005 Dec 1;59(12):1054-7. ↩ ↩²

4. Guh et al. (2009). The incidence of co-morbidities related to obesity and overweight: A systematic review and meta-analysis, BMC Public Health. ↩ ↩²

5. Health Survey for England 2019, NHS Digital, 2019. ↩

6. Tackling Obesities: Future Choices – Project report, Government Office for Science, 2007. ↩

7. Pineda E, Sanchez-Romero LM, Brown M, Jaccard A, Jewell J, Galea G, Webber L, Breda J (2018). Forecasting Future Trends in Obesity across Europe: The Value of Improving Surveillance. Obesity facts. 2018;11(5):360-71. ↩

8. Calorie reduction: The scope and ambition for action, Public Health England, 2018. ↩ ↩² ↩³

9. Sugar reduction: the evidence for action, Public Health England, 2015. ↩ ↩² ↩³

10. Health Survey for England 2017, NHS Digital, 2017. ↩ ↩²

11. Public sector employment, UK September 2019, Office for National Statistics. ↩ ↩²

12. Offender management statistics quarterly, April to June 2019, Ministry of Justice, 2019. ↩

13. Quarterly service personnel statistics: 2019, Ministry of Defence, 2019. ↩

14. CQUIN Indicator Specification Information on CQUIN 2017 to 2018 to 2018 to 2019, NHS, 2018. ↩

15. Carbohydrates and Health, Scientific Advisory Committee on Nutrition, 2015. ↩

16. The second biggest preventable cause of cancer: being overweight, Cancer Research UK, 2016. ↩

17. This would be for all categories of ‘meal deals’ such as ‘breakfast meal deals’, ‘hot food meal deals’, ‘sandwich meal deals’, ‘hot drink and snacks, for example, confectionary, savoury snack or items under the reducing sugar category’. Meal deals should not include sugar-sweetened beverages. Healthier breakfast cereals should be included in the ‘breakfast meal deals’. ↩

18. EU Food Information for Consumers Regulation 1169/2011. ↩

19. UK’s Food Information Regulations 1855/2014. ↩