Healthy Food Partnership Reformulation Program: Wave 3 Category Definitions and Targets

Thank you for the opportunity to provide feedback on the Healthy Food Partnership Reformulation Program: Wave 3 Category Definitions and Targets. On behalf of Cancer Council Australia, we are providing general comments on the current state of the Healthy Food Partnership Reformulation Program.

In 2015, the Australian Government established the Healthy Food Partnership (HFP) to encourage the food industry to support population level dietary improvements through a healthier supply of packaged food products. The initiative seeks to extend previous Food and Health Dialogue reformulation efforts by establishing nutrient targets for reformulation (including sodium, saturated fat and added sugar) across various priority food categories.1
The voluntary nature of the reformulation program relies on the cooperation of the food industry. There is no incentive for industry to participate in voluntary reformulation and relying on the goodwill of companies means that there is limited accountability if the proposed voluntary targets are not achieved. Further, the voluntary nature of the initiative has led to suboptimal industry participation in the program2-4 which has subsequently demonstrated negligible impact on dietary intakes.5,6 For example, research has shown that Australia’s reformulation targets for sodium are weak and addresses fewer food categories with modest goals compared to other international initiatives. 7-10 Research also showed that voluntary engagement with these targets has proven unsuccessful, resulting in minimal reductions to sodium content. 7-10

In 2021, the World Health Organization (WHO) released benchmark targets for sodium across 58 food categories considered to be major contributors to sodium intake globally, with the aim of prompting further policy measures to reduce the sodium content of packaged foods.11 When compared to existing Healthy Food Partnership targets, the WHO benchmarks encompass additional food categories with more stringent targets. Previous studies have proposed that meeting the WHO benchmarks has the potential to avert 3.5 times more deaths per year than those averted with meeting the Healthy Food Partnership targets.7,12 This suggests that even if the Healthy Food Partnership reformulation program were to be made mandatory, it would still likely produce an underwhelming effect in its existing form. Therefore, it is recommended that current targets be reviewed to align with more ambitious targets as observed internationally. 8

The process of identifying and selecting healthier products according to its labelling and marketing predominantly relies on a range of individual factors including consumer awareness, education and time which can increase the burden placed on individuals seeking to improve their diet. Well-designed and implemented policies on product reformulation can serve as an effective measure to optimise dietary behaviours by reducing the resources and agency required to recognise and consume healthier products.4 Strengthened, more extensive and mandatory compositional limits will be required to achieve meaningful public health outcomes with many examples of successful measures on product reformulation available to guide action within the Australian food regulatory system.13,14 Such policies must also extend to labelling, marketing and fiscal measures to ensure efficacy in reducing and preventing diet-related and other non-communicable diseases in Australia. Evidence currently exists on the efficacy and cost-effectiveness of similar policies in Australia.15

The development of a comprehensive monitoring and evaluation action plan is another crucial aspect which has the potential to contribute to the success of the targets. Current weaknesses in the design, implementation and monitoring of the program, as well as Healthy Food Partnership more broadly, can be attributed to the food industry’s close involvement throughout these processes.16 A comprehensive monitoring and evaluation action plan should include publicly available progress reporting which includes compliance among individual companies through annual food supply audits, conducted independently of government and industry. The findings can then be applied to assess the overall performance of the Healthy Food Partnership and determine how the targets can be modified to maximise impacts on health as well as addressing any social and economic effects.16
Please feel free to contact us if you need any further information on our response.

References
1. Australian Government Department of Health and Aged Care. Healthy Food Partnership Communiqué. Canberra: Australian Government; 2015.
2. Jones A, Maganja D, Shahid M, Neal B, Pettigrew S. Voluntary versus mandatory food labels, Australia. Bull World Health Organ. 2024;102(10):691-8.
3. Keaney M, Maganja D, Barrett E, Pettigrew S, Jones A. Selective industry adoption of a voluntary front-of-pack nutrition label results in low and skewed uptake: 10-year results for the Health Star Rating. European Journal of Clinical Nutrition. 2024.
4. World Health Organization. Reformulation of food and beverage products for healthier diets: policy brief. Geneva: World Health Organization; 2022.
5. Australian Bureau of Statistics. Healthy Food Partnership Reformulation Program: Wave 1, two-year progress 2023 [updated 15 February 2023. Available from: https://www.abs.gov.au/articles/healthy-food-partnership-reformulation-program-wave-1-two-year-progress.
6. Australian Bureau of Statistics. Healthy Food Partnership Reformulation Program: Wave 2, two-year progress 2024 [updated 22 May 2024. Available from: https://www.abs.gov.au/articles/healthy-food-partnership-reformulation-program-wave-2-two-year-progress.
7. Trieu, K., Coyle, DH., Afshin, A., et al. The estimated health impact of sodium reduction through food reformulation in Australia: a modeling study. PLoS Med. 2021; 18, e1003806-e
8. Coyle, D., Shahid, M., Dunford, E., et al. Estimating the potential impact of Australia's reformulation programme on households' sodium purchases. BMJ Nutr Prev Health. 2021; 4:49-58
9. Marklund M., Trieu K., Aminde LN., Cobiac L., Coyle DH., Huang L, et al. Estimated health effect, cost, and cost-effectiveness of mandating sodium benchmarks in Australia's packaged foods: a modelling study. The Lancet Public Health. 2024;9(11):e861-e70.
10. Coyle DH., Shahid M., Dunford EK., Louie JCY., Trieu K., Marklund M, et al. Estimating the potential impact of the Australian government’s reformulation targets on household sugar purchases. International Journal of Behavioral Nutrition and Physical Activity. 2021;18(1):138.
11. World Health Organization. WHO global sodium benchmarks for different food categories. World Health Organization; 2021, https://www.who.int/publications/i/item/9789240025097
12. Trieu, K., Coyle, DH., Rosewarne, E., et al. Estimated dietary and health impact of the World Health Organization's global sodium benchmarks on packaged foods in Australia: a modeling study. Hypertension. 2023; 80:541-549
13. World Cancer Research Fund International. NOURISHING and MOVING policy databases. Available from: https://policydatabase.wcrf.org/level_one?page=nourishing-level-one
14. Global Food Research Program. Policy Research [Available from: https://www.globalfoodresearchprogram.org/policy-research/
15. Centre for Research Excellence in Obesity Policy and Food Systems. Assessing Cost-effectiveness of Obesity Prevention Policies in Australia: League Table [Available from: https://www.aceobesitypolicy.com.au/results/league-table/.
16. Coyle, DH., & Rosewarne, E. n.d. Rethinking the Healthy Food Partnership. The George Institute. [Available from: https://www.georgeinstitute.org.au/profiles/rethinking-the-healthy-food-partnership.