Bran flakes are about to become junk food and nobody has told the shopper
Days before the Budget, the Advertising Association told The Telegraph that the government's plan to widen the junk food advertising ban will cost jobs and drive £100m of investment out of the UK.
Stephen Woodford, its chief executive, accused the Department of Health and Social Care of "sneaking out" a change to the nutrient scoring system that decides what counts as junk, three weeks after the original ban took effect. "Shifting the goalposts," he said, "just makes the UK look flaky and a less attractive place to invest."
He is right, and on current form he will lose. The argument is not weak; it is being made to the wrong audience, in a language that audience has long since stopped listening to.
We said as much in January. Within days of the 9pm watershed arriving, SPQR warned in The Grocer that adopting the shelved 2018 Nutrient Profiling Model would render hundreds of millions of pounds of reformulation worthless, reclassify yoghurts, cereals and fruit juices as unhealthy, and put jobs at risk in the factories and innovation teams that had done what ministers asked.
We urged a pause, a proper consultation and regulatory stability. Ten months on, the industry is making the same case with better numbers and the same result. Here is why the economic argument is not landing, and what should sit alongside it.
An argument the Treasury hears and parents don’t
The numbers are not in dispute. Oxford Economics, cited by The Telegraph, expects the new model to catch a further £300m to £400m of advertising spend, taking the cumulative hit from the restrictions to between £750m and £1bn.
Its separate review for the Food and Drink Federation found the government's own impact assessment rested on an evidence base that is "often limited", with "material uncertainties and evidence gaps". The consultation, now closed, offers businesses 12 months to adapt and no transitional protection for products reformulated to pass the model the government set in the first place. The Advertising Association noted that it contained no assessment of the impact on advertising-funded media.
All true, and all beside the point for the people who will decide whether the policy survives, which is to say parents. The health department's reply fits in a sentence: the old model is 20 years out of date and the new one will help raise "the healthiest generation of children ever". Set against that, a £100m figure and a grievance about process sound like an industry protecting its margins. The gap between what the industry can prove and what the public believes is widest precisely where the Advertising Association has chosen to stand.
The case the industry has not made
The strongest objection to the 2018 model is not economic. The model produces results no shopper recognises. Bran flakes, plain yoghurt and a carton of orange juice are about to be scored as less healthy food and barred from television before 9pm on the same footing as a chocolate bar. No campaigner has had to defend that to a parent in front of a supermarket shelf, because the industry has never put the question to one.
So put it to them. Companies that invested to meet the government's standard should say so, product by product: how much sugar and salt came out, when, and what it cost. In January we named PepsiCo's Doritos line in Coventry, Mondelez's Belvita and Premier Foods' Mr Kipling as reformulation a changed model would strand. Those are UK factories and UK jobs doing what the government asked, and the story belongs in the adverts the industry is still allowed to run, not in a letter to the Prime Minister.
Then show the public the breakfast table. A single image of the products a 2018 model calls unhealthy would do more to shift the ground than another round of consultation responses, because it invites the viewer to test the policy against their own common sense. Public belief is what ministers count before a Budget. Industry cost estimates are what they discount.
Alongside that, ask government for things it can actually grant: honour the five-year review the industry was promised, restore the joint DHSC and DCMS consultation that preceded earlier changes, and grandfather products reformulated to pass the 2004 model, so nobody who followed the rules is punished for having followed them. Each is modest, reasonable and hard to refuse in public.
What remains is political, decided in the days before a Budget by a government that wants a growth story and a health legacy at the same time. Mr Woodford's warning that the UK looks flaky is addressed to investors, who already know. The audience that has not been told is the one buying the yoghurt. Until the industry learns to argue to them, it will keep warning, correctly, and keep being ignored.
