Response to draft proposals: 2023 salt reduction targets

The Pizza, Pasta & Italian Food Association has issued the following response to draft proposals: 2023 salt reduction targets.

13th March 2020

We fully support the UK Government’s efforts to tackle obesity and improve the health of the nation and are keen to work in partnership with Public Health England to achieve its goals.  

One concern we have with the new targets is that those who worked hardest to successfully achieve the 2017 targets are being unfairly penalised as the new targets appear to make no distinction between those who succeeded and those who failed.  

There is also a substantial margin of difference between the targets set between the in-home and out-of-home sectors.   In the case of pizzas, average salt content reported against 2017 targets was 1.03g/100g for retail/manufactured products vs 1.25g/100g for out of home products.   Yet these are increasingly competitive markets.

Furthermore, only 53% of out of home products were at or below the maximum target compared to 88% of own label retail pizzas and 72% of branded retail products.   This highlights that there is a considerable disparity between the different sectors – even between branded and own label products.

We believe that 2023 targets need to take account of the work that has been done to date and focused on bringing all sectors up to 2017 levels before new targets are set.

In the case of packaged branded products, much of which comes from outside the UK, more attention needs to be given to targeting these products to ensure that they do no undermine our home industry, putting UK investment and jobs at risk while also reducing consumer choice.

More work also needs to be done to support and help the out of home sector meet its targets. We appreciate that this is a difficult task to achieve due to the complex nature of this market.   However, it may be best addressed by focusing on the key ingredient sectors supplying this market.   Just as in manufacturing, success in reducing salt levels largely revolves around the toppings used as salt is not generally added to pizzas.

Do you agree with the draft proposed 2023 salt targets?   Do you consider the targets to be broadly achievable?   Do you have an alternative proposal?

We believe that the proposed 2023 targets will lead to an increasing disparity between market sectors and create a grossly unfair competitive playing field.

Salt is a major factor in taste and needs to be reduced gradually if consumers are to agree to go on the salt reduction journey.   The greater the disparity between market sectors in this respect, the more risk there is that consumers will choose the tastier/saltier products at the expense of those who have sought to comply with targets.

Setting an arbitrary 10% reduction in salt gives no recognition to the work that has been done to date or to the technical issues involved with individual products.   Indeed, we are concerned that such an arbitrary reduction shows a serious lack of understanding of both the commercial and technical considerations involved.

We would strongly recommend that any new targets are set in consultation with the different sectors and not just applied across the board.     A further 10% reduction in salt in pizzas, for example, could have implications in terms of food safety, shelf-life and food waste.  

These factors must be taken into account before new targets are set.   Hence, we urge PHE to be realistic in recognising the wider implications - taking these factors into account - by setting individual targets in consultation with the different industry sectors.

Are there any technical or other challenges associated with achieving the draft proposed 2023 salt targets?

Salt is a key component in preserving ingredients such as cured meats. There is a fine balance between reducing salt in these products, their shelf life and, ultimately, their safety.

Salt is also an essential ingredient in the fermentation process when making pizza bases and there are limitations on how much this can be reduced before the product becomes unworkable.

We believe the proposed 2023 targets will be unachievable because of these technical barriers.

Do you agree with the draft proposals for the new Table 1 sub-categories and targets for foods not previously covered by salt reduction targets?

No comment.

Do you agree with the proposals to incorporate additional products in certain sub-categories? Are there any further additional products which you think should be included?

No comment

Do you use or are you considering using potassium-based or other sodium replacers to reduce the sodium content of your products?   Are there any technical or other challenges associated with their use?

We have no concerns with the use of these replacers provided that there is sufficient evidence to support their use and it is legally acceptable for our members to do so.   However, we understand there are still concerns in the medical sector about the potential damage they can cause in relation to kidney disease.

Jim Winship
Director
The Pizza Pasta & Italian Food Association
Association House
18c Moor Street
Chepstow NP16 5DB
Tel: 07850 104034
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