Butter and knife on yellow background

    There’s no such thing as ‘junk food’ – so how will an advertising ban work?

    19 March 2019

    When the government announced its public consultation on restricting food advertising on Sunday, the press release came with an intriguing quote from Steve Brine, the Public Health Minister, who said: ‘This isn’t about banning everyday staples like butter and olive oil, it’s about reducing children’s exposure to those products that have little nutritional value’. This was reinforced by a bullet point at the top of the page which said: ‘Options will not affect adverts for everyday staples like butter, olive oil or meat’.

    Why so defensive about butter and meat? Perhaps because Transport for London had become a laughing stock two weeks earlier when it pulled a tube advertisement for showing a glimpse of butter and bacon. This was the first clear indication to the public that there was more to the clampdown on ‘junk food’ than met the eye. As I have explained ad nauseum, ‘junk food’ doesn’t exist, but HFSS food (High in Fat, Salt or Sugar) does. Butter is patently high in fat and is included in the government’s salt reduction scheme. Bacon is very high in both salt and saturated fat. Since the advertising rules are based on a rigidly defined version of HFSS, it difficult to give a pass to these products just because you can buy organic versions of them in Waitrose.

    But it is also difficult to sell a policy on the pretext of tackling ‘junk food’ (a term that appears three times in the press release) when the public has just seen how far the definition is stretched in practice. The promise to exclude the likes of butter was a small concession to sanity, but how would the government justify it scientifically?

    The answer came yesterday when the public consultation was opened. The government intends to apply the advertising ban to any product that is both defined as HFSS and is included in Public Health England’s sugar and calorie reduction programme. This gets butter and olive oil off the hook because the former is only included in the salt reduction programme and olive oil is not part of the reformulation programme at all.

    The reformulation programme was originally sold to the public as an attempt to make children’s food healthier, but it was soon extended to all food because – as Pubic Health England’s Alison Tedstone suddenly noticed – ‘Our children don’t eat special children’s food. We buy the same food for our entire family.’ Anything that can be reformulated is considered fair game for the government’s arbitrary targets of a 20 per cent reduction in sugar by 2020 and a 20 per cent reduction in calories by 2024.

    This means that a few HFSS products, such as raisins and walnuts, are exempt because they are as nature made them and reformulation is physically impossible. Raw meat is exempt, but meat products (including bacon) are not. Fruit is exempt but tinned fruit and smoothies are not. In short, a food category is included in the programme if there is any element of processing that could be altered.

    So many foods are included in the sugar and calorie reduction programme that the new exemption makes little difference to the advertising ban’s vast scope. It means that there is an exemption for butter, which is great news for Johnny Rotten, but Public Health England’s documents reveal that the only other HFSS foods that will benefit from the loophole are fat spreads, olive oil, baked beans, stock cubes and cheese. The following categories will still be covered by the ban:

    Breakfast cereals, yoghurts, fromage frais, sweet biscuits, savoury biscuits, cakes, pastries, croissants, pain au chocolat, puddings, ice cream, sweets, chocolate, jam, marmalade, honey, pasta products, rice products, quiche, breadsticks, noodle products, crackers, crispbreads, ‘bread with additions (eg. ciabatta with olives)’, ‘ready meals with carbohydrate accompaniment’, ‘meal centres without carbohydrate accompaniment’, ketchup, mayonnaise, pretzels, flapjack, oatcakes, ricecakes, cereal bars, bacon, kebabs, ham, pepperami, haggis, sausage rolls, pesto, fish fingers, guacamole, salsa, salad dressing, curry sauces, pasta sauces, ‘egg products’ (but not eggs), ‘potato products’ (but not potatoes), pasties, pies, sausages, milk drinks, sorbets, hummus, coleslaw, potato salad, soup, sandwiches and ‘food-to-go’. I could go on.

    A few of these could be viewed as ‘junk food’ and several of them should be considered as treats, but more of them look like the kind of ‘everyday staples’ that Brine claims to be protecting. It is debatable whether many of them ‘have little nutritional value’ or needed to be shielded from children’s delicate eyes. The purported war on ‘junk food’ remains an assault on what most of us simply call ‘food’.