New labelling requirements covering the calorie content of food and drink served out-of-home are due to be introduced from April 2022.
Patient meals and in-house provided food and drinks on hospital sites will be exempt, but meals provided by contract caterers and franchise operations won’t - if those companies have more than 250 employees. Whether hospitals with a subco providing retail catering services will be classed as an in-house or contracted service is unclear and is likely to depend on the wording of any contracts between the Trust and the subco.
Even if hospitals are initially exempt from this new labelling requirement, knowing that the UK has an obesity problem, and given the position of the NHS as the guardian of the nation's health, it is likely that some hospitals will feel they ought to be taking a lead on this initiative too.
Healthcare leads by example, so this exemption seems strange. Brian Robb, National Chair of the Hospital Caterers Association shares his personal view with HEFMA, which is that healthcare organisations should take a lead on this, but there needs to be consensus around the policy, what it looks like to comply, how much it will cost and best practice established.
The guidance issued so far around the implementation of these new rules does not provide full clarity over operational practicalities for compliance. For instance, how the detail should be presented on the label to ensure it is meaningful and impactful. Other issues include how the calorie content is calculated and by whom, and whether the average person understands how many calories they should be consuming anyway.
Brian believes for any policy on calorie content labelling to be truly effective in reducing obesity levels it needs to be supported by a widespread consumer education programme, providing information about daily calorie intake recommendations for different people. Ideally, this would start in schools.
As always, the devil is in the detail - and the detail, at the moment, is missing. Even though hospitals are initially exempt, it is likely that they will have to at least start to consider the implications of these regulations for their sites, not least because as calorie labelling becomes the norm on the high street, consumers will expect to see it everywhere. If it is not provided in the hospital dining areas it will be notable by its absence.
The government has stated the requirements will be reviewed within five years of them coming into force.