The importance of ‘Welsh businesses increasing the scale of reformulation and developing healthier alternatives’ is highlighted in the Government’s Healthy Weight, Healthy Wales strategy (p. 11). In addition, several measures that could indirectly incentivise reformulation, such as bans on price and placement promotions of less-healthy foods, are currently under consultation by the Welsh Government. The Healthy Weight Healthy Wales strategy even states that ‘Welsh taxation powers on discretionary foods high in fat, salt and sugar to be considered if the pace of reformulation does not meet expectations’ (p. 11). However, the successful evaluation of these measures all rests on having access to data on food reformulation which, at present, does not exist.
A major challenge contributing to the lack of data on the composition of food is that while producers of pre-packaged foods are typically required to list the ingredients and provide nutritional information on their labels, they are not required to register this information with any centralised database; doing so could add huge value by allowing the tracking of reformulations. Moreover, it has been suggested that when policymakers rely on such information to be provided voluntarily by food manufacturers, this can create a transactional relationship, where policymakers can feel obliged to return the favour, which may lead to less impactful food policies.
“In determining the impact of reformulation on population dietary behaviors, policy makers often depend on data provided by these manufacturers. Where such data are “gifted” to regulators, there may be an implicit expectation of reciprocity that adversely influences nutrition policies.”