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The British Sandwich & Food to Go Association has issued the following response to draft proposals: 2023 salt reduction targets.

 

13th March 2020

We are surprised that Public Health England is seeking to introduce a further 10% reduction in salt levels in sandwiches when our industry has clearly been struggling to achieve the previous 2017 targets.

Although we managed to get at least 75% of sandwiches within the maximum targets set in 2017, only 54% of products without high salt fillings were at or below the maximums set.   This is largely a reflection of the technical challenges in reducing salt levels and avoiding issues with food safety and shelf-life.

Expecting our industry to achieve a further 10% reduction in salt levels is unrealistic and clearly takes no account of the work done to date.   Indeed, it appears that PHE has simply decided to target a further 10% reduction in salt levels across the board without regard to the specific issues faced by different food sectors.

While our industry managed to get 88% of products with high salt fillings within the 2017 maximums set, many of the ingredients in this category – such as cured meats – rely on salt as part of the curing process.   There are limits on how much salt can be reduced without affecting shelf-life and product safety, which in turn have an impact on food waste.

For these reasons we believe that a further 10% reduction in salt levels will be seen as unachievable which will discourage many in the industry from taking part in this programme.

There are also concerns that further reductions in salt will impact significantly on the taste of products which could be seriously damaging to the businesses taking part in this work as they compete directly with independent sandwich bars and bakeries which are generally not picked up by PHE.   Indeed, almost 50% of this market is made up of bakers and sandwich bars who trade in direct competition to the supermarkets and chains that PHE is focusing upon.

Conclusion

We believe that the setting of an arbitrary 10% reduction is a mistake and takes no account of the work done to date or the obstacles that certain sectors have due to the nature of the ingredients used.   It would be more realistic to consider new targets in relation to the achievements to date and in consideration of the technical and commercial obstacles faced by each sector.

Our Association understands the need to manage salt intake and is very willing to work with PHE to achieve further reductions but we believe this must be done with realistic consideration for the barriers that exist.

We would be happy to meet with you to discuss this and, particularly, the technical constraints that we face in achieving further salt reductions.

Jim Winship
Director
The British Sandwich & Food to Go Association
T: 07850 104034
E: This email address is being protected from spambots. You need JavaScript enabled to view it.