Labels are a mainstay of hospitals and health care centres – even the patients are labelled. In order to help these institutions adapt and maintain the proper labelling of food, one must be up to date on the most recent guidelines.
Many healthcare organisations already provide high quality food and drink to their patients, staff and visitors, but the variation across the country is still too great. Not enough healthy options are consistently available, sustainability is poorly embedded and too much food is wasted. The Food Leadership team has recognised that things need to improve; the publication of the standards is an important step in that journey.
The Healthcare Food Standards and Strategy Group was set up by NHS England to consider, and follow on from, the work started by the Hospital Food Panel in 2014. Comprising individuals, NHS organisations, suppliers and specialists, the group considered recent reviews and reports, seeking to align direction and to link the reports’ chairs and advisors, who have responded with their support for these standards. The standards describe the methods by which organisations must ensure the quality and sustainability of their food and drink provision for patients, staff and visitors, and how they should be applied and monitored, as well as recommending future improvement aspirations and actions.
Food and Drink Strategy
All NHS organisations should maintain a food and drink strategy viewed as a living document. It captures how the organisation addresses safe delivery of nutritious and quality food and drink for patients; how healthier food and the right environment for staff and visitors are provided; and embeds sustainable practices in its service, such as buying food more sustainably and wasting less. Outcomes should be detailed and measured, allowing the organisation to demonstrate how it is meeting required standards. This strategy is the blueprint for how the organisation values food and drink as medicine; it will form part of the annual returns required by NHS organisations to evidence compliance with the Food and Drink Standards, and will form part of PAM.
Labelling of food is part of this strategy. Ensuring that food served is safe to eat is a legal obligation. The Food Standards Agency outlines guidance for food businesses to minimise the risk of harm to the consumer. Complying with food safety covers the management of food hygiene and food standards. Several key pieces of legislation underpin this. Giving the consumers the necessary information on food is part of overall strategy.
The Government Buying Standard (GBS) for food and catering services outlines minimum standards for healthier food and drink options across the public sector, to:
- reduce salt, sugar and saturated fat intakes
- increase consumption of fruit, vegetables, fish and fibre
- revise availability and portion size of soft drinks, confectionery and savoury snacks.
The (voluntary) best practice standards go further and include calorie or allergen labelling and menu analysis. Organisations will need to assess their compliance with the nutrition standards – both mandatory and best practice – and set out a programme of implementation.
Mandatory calorie labelling came into force in April 2022, affecting businesses with 250 or more employees that sell food or drink that is not pre-packed and is suitable for immediate consumption. Implementation guidance can be found on the government website. NHS organisations need to look ahead to comply with upcoming changes to food and drink legislation, including Natasha’s Law, which will change the way food and drink are presented and served for retail, staff and visitors.
The government consulted on calorie labelling for food and drink served outside of the home in 2018. Following this the government has introduced legislation to implement mandatory calorie labelling among large food businesses (businesses with 250 or more employees) in the out of home sector. The out of home sector is generally considered to be any outlet where food or drink is prepared in a way that means it is ready for immediate consumption, on or off the premises.
Food and drink that is prepacked is required to display nutritional information, meaning consumers are familiar with seeing calorie content on the majority of items sold in the retail sector, such as supermarkets and convenience stores. In contrast, the out of home sector typically sells non-prepacked food and is therefore not required to display nutritional information. This makes it difficult for consumers to make informed, healthier decisions when purchasing food from such businesses. In addition to helping consumers to make healthier decisions, calorie labelling also aims to encourage businesses to reformulate the food and drink they offer and provide lower calorie options for their customers.
This guidance helps to illustrate how the Regulations mandating calorie labelling in the out of home sector for businesses with 250 or more employees should be implemented. Failure to comply with the Regulations may result in a food business being issued with an improvement notice. While not subject to this regulatory requirement the government encourages smaller food businesses to also voluntarily adopt calorie labelling, as set out in this guidance document. The government will review the implementation of the Regulations for large businesses within 5 years of the Regulations coming into force and will consider extending the requirement to smaller businesses in the future.
Calorie labelling is not required in certain establishments when food is provided ‘in-house’. However, where the food at that establishment is provided by another organisation with 250 or more employees (such as a contract caterer), calorie information must be displayed. This rule applies to the following establishments:
- an educational institution for those over 18 years old
- a military establishment
- criminal justice accommodation
- a hospital or other medical institution
- a care home or other institution providing social care
- a canteen at a workplace providing food to employees
Businesses selling food in scope of the Regulations must:
- display the energy content of the food in kilocalories (kcal)
- reference the size of the portion to which the calorie information relates
- display the statement that ‘adults need around 2000 kcal a day’ (for the purposes of this guidance, this statement will be referred to as the ‘statement of daily calorie needs’)
Calorie information, the reference to portion size, and the statement of daily calorie needs must be displayed clearly and prominently at the ‘point of choice’ for the customer; this is considered as any place where customers choose what food to buy. For businesses where consumers may choose their food in several locations, such as a menu on the premises, a display case on the premises, and an online menu, businesses are required to provide calorie information at each.
When implementing the Regulations, there are 2 principal types of ‘point of choice’ a business should consider, and labelling requirements vary accordingly. They are:
- food chosen from a menu (such as menu boards, electronic menus, online and third-party delivery app menus)
- food chosen from items on display (such as display cases, shelves, and buffets)
In all cases, the information businesses are required to display must be easily visible, clearly legible, and not in any way hidden or obscured by other written or pictorial matter, or any other intervening material. Ensuring the information is easily visible could be achieved by using the same font type or style of lettering, colour, size and background of the description or price of the corresponding food item.
There are people, such as those living with eating disorders, who may find seeing calorie information on menus and labels difficult. Therefore, the Regulations permit a business to provide a menu without the required calorie information where the consumer expressly requests it (at the business’s discretion). To better inform the customer, it is important that calorie information is displayed in a way which makes it clear the portion size to which it is referring. Therefore, the Regulations also require businesses to indicate the size of the portion to which the calorie information relates, or in the case of an item prepared for more than one person, the number of people it is intended to serve. Information referring to portion size should be displayed as per the requirements where food is chosen from a menu or items on display set out in the section above on ‘displaying calorie content’.
Procuring Healthier Ingredients and Food Products
Businesses should check the labels of products they buy, or ask their supplier to assist them, to choose options with higher fibre and less salt, sugar and fats. This healthier catering advice describes simple practical changes that different types of businesses can make when procuring, preparing, cooking, serving and promoting food. This guidance builds on previous work to support local businesses, for example on salt reduction, and reflects current government dietary recommendations for sugars, the Eatwell Guide and 5 A Day advice. By gradually making the simple changes covered in these tips, businesses can help their customers make healthier choices.
