Regulating health and nutrition claims in the UK using a nutrient profile model: an explorative modelled health impact assessment

Background: Health-related claims (HRCs) are statements found on food packets that convey the nutritional quality of a food (nutrition claims) and/or its impact on a health outcome (health claims).The EU stated that HRCs should be regulated such that they can only appear on foods that meet a specified nutrient profile (NP). A NP model has been proposed, but not agreed by the European Commission.Methods: To model the impact of HRCs on health impacts in the UK, we built a front-end model to a pre-established non-communicable-disease (NCD) scenario model, the Preventable Risk Integrated ModEl (PRIME) by combining data from a meta-analysis examining the impact of HRCs on dietary choices and a survey of pre-packaged foods examining the prevalence of HRCs and the nutritional quality of foods that carry them. These data are used to model the impact of regulating HRCs on the nutritional quality of the diet and PRIME is used to model the health outcomes associated with these changes. Two scenarios are modelled: regulating HRCs with a NP model (the FSANZ NPSC and a draft EU model) so that only foods that pass the model are eligible to carry HRCs, and reformulating HRC-carrying foods that fail the model.Results: Regulating the use of HRCs with a NP model (the FSANZ NPSC) would have unclear impacts on population health and could potentially lead to less healthy diets. This is because HRCs are currently more likely to be found on products with a better nutritional profile and restricting their use could shift consumers to less healthy diets. Two hundred fifty-eight additional deaths (95% Uncertainty Intervals [UI] -6509, 8706) were predicted if foods did not change in their nutrient composition. If all foods that currently carry HRCs were reformulated to meet the NP model criteria then there would be a positive impact of using the model: (4374 deaths averted (95%UI -2569, 14,009)). The largest contributor to the uncertainty is the underpowered estimates of nutritional quality of foods with and without claims.Conclusions: Regulating HRCs could result in negative health impacts, however the wide uncertainty intervals from this analysis demonstrate that a larger health impact assessment is necessary