Food and Drink

More than 330,000 foodservice operators and 73,000 retailers rely on FWD members for the supply of fresh, chilled and frozen food – often delivered daily, and ready to go straight on the menu or the counter.

FWD represents wholesalers in reactive action by government, for example taking the lead in representing the industry on issues such as Free School Meals, Holiday Hunger and wider health and obesity issues. FWD is on the board of the School Food Plan Alliance, which brings together organisations with an interest in school food and attend the regular meetings of the School Food All Party Parliamentary Group.


We are also actively involved in the formulation of food regulation. We work with the Department for the Environment and Rural Affairs to produce guidance on the new Food Information to Consumers regulations, and bring members together to discuss how best to implement the requirements.

In addition, FWD represents members’ views on economic controls on food supply, such as the Soft Drinks Levy, to ensure that unintended consequences of intervention are taken into account, such as the growth of a grey market.

FWD recognises the role that alcohol plays in contributing to anti-social behaviour and health harms, and supports across-the-board measures that consider the supply of alcohol equally, such as minimum unit pricing.

on your plate
On the radar this month:

July 2021


The Government has published its response to the consultation on restricting promotions of products high in fat, sugar and salt. The regulations outlined in the consultation will come into force in October 2022. Despite an overwhelming majority of respondents suggesting symbol group retailers should be excluded, and that floor size restrictions should be based on existing Sunday Trading regulations, the Government rejected these proposals.

Volume Promotions

“Meal deals” and “Dine in for 2” offers are exempt from the volume price promotion restrictions. The De- partment of Health will publish guidance including clarity on the meal deal exemption and multipacks.

Free Refills

Restrictions will also apply to free refills of sugar-sweetened beverages in the out-of-home sector.


Qualifying businesses that are over 185.8m2 (2,000 square feet) are in scope of the location restrictions and will need to ensure HFSS foods are not placed within the restricted areas of the relevant floor area. The fol- lowing parts of stores are exempt from the ‘relevant floor area’:

• Not used for displaying goods or for serving customers in connection with the sale of goods
• Used mainly for the preparation or sale of food intended for immediate consumption, whether on

or off the premises (including, for example, a coffee shop or a canteen)
• Rooms used for consultation with customers in connection with any medical services (such as phar-

macy or opticians’ services) offered in the store
• Occupied by a business (‘a concession’) other than the business primarily responsible for managing

and operating the store, but only where the concession operates its own payment facilities

In Store

The location promotion restrictions will only apply to checkout, designated queuing areas, end of aisle displays, and store entrance displays.

Non-transactional websites are not in scope of this policy as they do not fall under the definition of an ‘online marketplace’ defined in these regulations.

HFSS Products

Restrictions apply to product categories that are the biggest contributors to children’s sugar and calorie intakes and are heavily promoted, and therefore are the categories of most concern for childhood obesity. All products within these categories are in scope of the promotion restrictions.

Assessing Compliance

  • It is expected that retailers will need to assess whether each of the products they stock is within the categories in scope of the restrictions and if yes, they will need to assess whether it is considered HFSS by calculating its NPM score.
  • If the products are deemed in scope then it will be the responsibility of the retailer to ensure that they comply with the restrictions on promotions as set out in the regulations.
  • There may be some instances where retailers may need to ask manufacturers to provide the NPM score or further information for their products given that retailers may not always have all the nutrient information needed to calculate the NPM score for branded products. Manufacturers may therefore choose to provide NPM scores to retailers if they wish to promote a product that is in a product category within scope, but that is not HFSS due to its NPM score.

Government buying standards

The Government has published its response to the consultation on nutrition standards in the Government Buying Standards for Food and Catering Services. The GBSF includes mandatory nutrition standards in- tended to reduce the intake of salt, sugar and saturated fat, and to increase consumption of fruit, vegeta- bles, fish and fibre. They also include voluntary best practice nutrition standards that cover availability and portion size of soft drinks, confectionery, savoury snacks, calorie or allergen labelling and menu analysis. All Government departments in England and their agencies are required to comply with the GBSF, as are prisons, the armed forces and the NHS. Schools must follow the school food standards legislation but may also choose to use the GBSF.

The headline policy changes and updates are:

• Updating the reducing salt mandatory and voluntary nutrition standards to reflect Government’s

2017 salt targets

  • the meal deals mandatory nutrition standard to ensure food and drinks used within meal deals

    meet the healthier options in the GBSF standards eg a portion of fruit will be sold at a lower price

    than a portion of hot or cold dessert

  • Updating the reducing saturated fat mandatory nutrition standard to include pre-packed sandwich-

    es and other pre-packed meals

  • update the increasing fibre voluntary best practice nutrition standard, to ensure main meals con-

    taining beans and/or pulses as a main source of protein are made available at least once a week

  • Best practice nutrition standard requirement for menus

    The Government has set an implementation period of 12 months from date of publication of the technical written guidance, giving businesses more time to achieve the standards although no date for the technical guidance has been given.


New food labelling laws for prepacked for direct sale (PPDS) food come into effect on October 1 2021. The Food Standards Agency is running a webinar for food businesses on the changes on August 4.

FWD is working with Erudus and GS1 on a shared data model to help wholesalers provide accurate up- to-date information to customers. This includes bar code changes following product formula changes. The GS1 barcode management standard can be found here: support/decision/2

Front of Pack Labelling

The Department of Health and Social Care has launched a consultation on Front of Pack nutrition label- ling in the UK, seeking views on the current label, whether it could be improved, and views and evidence on international labels used in France and Chile, to ensure that labelling has maximum impact to inform healthier choices. The UK Government has also commissioned an independent research body to test whether specific Front of Pack labels help consumers identify healthier choices when purchasing food and drink. FWD will respond to the consultation, which runs until October.

Frozen guidance

FWD are among the signatories on new guidance to help businesses manage frozen stock approaching the end of its shelf life to avoid significant amounts of food waste, which has been produced by the BFFF and is also supported by Food Minister Victoria Prentis, and Ben Elliot the Food Surplus and Waste Prevention Champion for Defra.


The Food Standards Agency (FSA) has published updated technical guidance on food allergen labelling and information requirements. The guidance has been updated ahead of enforcement of the Food
Information Regulations 2019 from October 2021 in England and Wales. These regulations will require food businesses to label all pre-packaged foods with a list of ingredients which emphasises allergens. FWD is campaigning for a mandatory allergens database to help caterers provide accurate information to consumers.

FWD takes its responsibilities seriously as more than 330,000 foodservice operators and 73,000 retailers rely on FWD members for the supply of fresh, chilled and frozen food – often delivered daily, and ready to go straight on the menu or the counter. Ensuring people live, eat and drink healthily is therefore crucial.

Given the vital importance of allergen labelling, wholesalers would like to see more done to give allergy sufferers greater confidence in the safety of their food. This could be done by mandating manufacturers to place allergen information in a central repository, which would allow food operators to easily access allergen information.

Currently there are multiple such systems which exist. A centralised database would only require manufactures to provide information once. Another benefit of this system is that it would easily communicate product recalls.

We are calling on the Government to:

  • Introduce a central allergens database for all food product ingredients that wholesalers can access to ensure they can flag any potential allergens to customers
  • We strongly believe the Government should mandate such a database as this system would be fundamental in ensuring the changes to allergen labelling are robust and reliable and provide greater security for consumers
  • Work with the Food Standards Agency and local authorities to use a centralised database to communicate product recalls

July 2020

Obesity strategy

The Government has launched its strategy to combat obesity in the UK. Measures include:

  • A ban on TV and online high fat, sugar and salt  adverts before 9pm – for the whole of the UK 
  • Front of pack labelling –a UK-wide consultation
  • Introducing legislation to require large out-of-home food businesses, including restaurants, cafes and takeaways with more than 250 employees, to add calorie labels to the food they sell in England
  • Ending the promotion of HFSS food by restricting volume promotions such as buy one get one free, and the placement of these foods in prominent locations intended to encourage purchasing, both online and in physical stores in England
  • Consulting on how to introduce a total HFSS advertising restriction online 
  • A consultation before the end of 2020 to introduce calorie labelling on alcohol

On calorie labelling, the responsibility for calculating calorie content lies with the business making the food or drink, and responsibility for displaying calorie information rests with the business through which the food or drink is sold. Calorie labelling will be required on all items a business offers that are prepared for immediate consumption by the final consumer and are not subject to existing pre-packaged labelling requirements.

Exemptions include:

  • Educational institutions for those under the age of 18
  • In-house workplace canteens where the food and drink on sale is solely for the employees of the workplace
  • Health and social care settings where the food is provided solely for patients or residents