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Sustain Brexit Consultation responses

Impact of trade deals on child health, Health and Social Care Committee, 2018

Photo credit: Pexels

Photo credit: Pexels

Written evidence from Sustain
How could new UK trade deals affect child health?

1) Sustain background

Sustain is the UK alliance for better food and farming and a registered charity. We represent around 100 not-for-profit national organisations and work with hundreds more at local level – local authorities, public health groups and community organisations. The Sustain alliance advocates food and agriculture policies and practices that enhance the health and welfare of people and animals, improve the working and living environment, enrich society and culture and promote equity.


2) Sustain and international trade

Sustain is in favour of trade and wants to see the UK agree new trade deals that promote a beneficial race to the top in food standards.


3) Current UK regulations on trade in food

At the moment, UK food standards, composition and labelling are governed mainly by European regulations. If we choose to leave any form of a customs union with the EU (a ‘hard Brexit’) and opt instead for regulatory divergence and wide-ranging new trade deals with other nations, then we will need to adopt rules from the Codex Alimentarius: internationally recognised standards, codes of practice and guidelines on food devised by 159 countries working together, referenced by the World Trade Organisation (WTO). If we entered a trade deal with the EU and other countries, we would need to be able to show that our food meets both WTO and EU rules.


4) New UK trade deals

During 2018, the UK has been consulting on possible future trade deals. Sustain has been campaigning alongside colleagues in the trade justice movement for full trade transparency and would like to see full assessments on the potential impact on child health of future trade deals, with particular reference to implications for food standards if the UK agrees a trade deal with the United States.


5) What could happen if the UK agrees a trade deal with the US?

“We are concerned by the evidence of US hostility in trade talks towards countries that want to set their own domestic agenda on reducing sugar intake – particularly the push to keep traffic light labelling voluntary. We can’t allow trade talks to undermine efforts to tackle childhood obesity. Children’s health outcomes are much worse in the US than in many other comparable countries– and we don’t want to import those along with the sugar.”
Professor Russell Viner, President of the Royal College of Paediatrics and Child Health


6) Sustain’s concerns about the impact of a US trade deal on child health

Sustain believes that tackling diet-related illness and protecting children’s health are among our biggest national priorities. We believe that trade deals should support and not undermine achievement of the UK’s health priorities. We are concerned that a US trade deal could fuel the rise in diet-related illness, increase food poisoning, curb our efforts to reduce advertising of junk food to children and increase costs to the NHS of treating diet related illness.


7) A US trade deal could fuel the rise in children’s diet-related illness such as obesity and diabetes

We are concerned that a future trade deal with the US could undermine UK efforts to reduce consumption of unhealthy food and sugary drinks, and import American levels of diet-related diseases alongside their products.

A study from the Harvard School of Public Health shows spikes in obesity in countries like India and China associated with trade liberalisation. Other studies show that obesity rates rose in both Mexico and Canada after the adoption of the North American Free Trade Agreement (NAFTA) in 1993. This was associated by the researchers with increased availability and promotion of cheap food of low nutritional quality, high in fats, sugars and other refined carbohydrates and with cheap processed meat.

A study on the impact of a US trade deal on health in Central America found that the trade deal was associated with “with rising rates of obesity and chronic diseases such as cardiovascular disease and cancer”. Previous analyses of trade data have shown that the foods most affected by liberalisation are the high-value, high-margin products, such as soft drinks and snacks. In Mexico, in the years after the North American Free Trade Agreement (NAFTA), consumption of sugary drinks increased by 37 per cent. In Peru, sales of juice, sports and energy drinks surged over the 10 years since their 2006 free trade agreement with the US. The rates of adults classified as overweight in Peru stood at 47% in 1997, 50% by 2003, 57% in 2016.

There are much higher rates of diet-related illnesses in the US. One in four adults in the UK is obese versus one in three in the US. Self-reported rates of being overweight (including obesity) in US teenagers is more than double (31%) that of the UK (14%); and around 125,000 under-18s in the US are suffering from Type 2 diabetes (an avoidable condition mainly caused by unhealthy diets), versus approximately 2,000 in the UK. We note that the US population is only five times greater than that of the UK. We estimate that rates of teenage Type 2 diabetes in the UK could potentially soar to 25,000 if our children end up eating what US children are now eating.


8) A US trade deal could undermine or prevent UK efforts to reduce sugar in children’s diets

In the UK, tooth decay is the leading cause for hospitalisation among 5 to 9 year old children, with 26,000 children being hospitalised each year due to tooth decay. According to the Action on Sugar campaign, backed by doctors and dentists, there are seven cohort studies showing evidence of the relationship between dental decay in children and sugar-sweetened beverages.

In 2016, Cancer Research UK issued a report showing that adults and young children currently consume twice the maximum recommended amount of added sugar. It found that 11 to 18-year-olds eat and drink three times the recommended limit, with sugary drinks being their main source of added sugar.

The UK has started to turn the tide on excessive sugar consumption, for example by introducing a sugary drinks tax and championing colour-coded front-of-pack nutrition labelling. Anything that would undermine such measures and seek to increase the sale of sugary products would be a significant step backwards and could affect children’s health.

However, industry lobbyists have been highly effective in the US, blocking attempts to change the pricing or promotion of sugary products. In June 2018, California passed a bill to ban any food or drink taxes for 12 years. Arizona and Michigan have passed similar laws. The state-wide lobbying is being led by the well-resourced American Beverage Association, which includes Coca Cola and PepsiCo.

There is also plenty of evidence of US aggression in trade negotiations towards countries that try and set their own rules or pricing strategies to reduce sugary drinks consumption. For example, in their National Trade Estimate Report the US government argues that a sugary drinks tax introduced by Gulf Cooperation Council countries (Saudi Arabia, Kuwait, the United Arab Emirates, Qatar, Bahrain, and Oman, where diet-related illnesses are on the rise) disadvantages US products and was therefore a barrier to trade. The US also took a dim view of South African, Sri Lankan and Thai plans.


9) A US trade deal could increase the marketing of sugary energy drinks to children

In the second chapter of its Obesity Plan, published in June 2018 the Government pledged to consult on banning the sale of energy drinks to children. It stated that energy drinks had been linked to adverse health outcomes for children and that energy drinks are often high in sugar as well as caffeine, and are therefore a contributor to both obesity and dental problems in children. The government pointed out that UK adolescents drink on average 50% more energy drinks than their EU peers.

Public health academics are similarly concerned about the high level of consumption of energy drinks in the United States and point out that the industry has grown dramatically. Market observers say the US energy drink market was valued at $7.6bn in 2017 and confidentally assert that will rise in the next five years. They also point out that “a major proportion of US households with children consumes more energy drinks as compared to those without children”.

Given the US hostility towards countries with sugar taxes, we can expect them to take a dim view of our attempt to ban sales of energy drinks to young people as this might reduce their market access.


10) A US trade deal could promote cheap sugary products based on high fructose corn syrup

Information from the United States Government shows that the US is exporting ever more ‘corn-based products’, including high fructose corn syrup. High-fructose corn syrup (HFCS) is a sugar made from corn starch that has been processed to convert some of its glucose into fructose. In the US, high-fructose corn syrup is increasingly replacing sugar (sucrose) in the food industry.

There is unresolved scientific debate over whether consuming large amounts of high-fructose corn syrup presents any greater health risk than consuming sugar or other sweeteners. Some reviewers have found that HFCS is “not meaningfully different” in composition to other sweeteners. In contrast, others have found that, “Diabetes prevalence was 20% higher in countries with higher availability of HFCS compared to countries with low availability.” Whatever the outcome of such research, the solid fact remains that high-fructose corn syrup is an added sugar, the overconsumption of which is a major health problem.

There has been some commentary that the increase in obesity recorded in Canada after the North American Free Trade Agreement (NAFTA) trade deal was signed could be attributed at least in part to increased consumption of high fructose corn syrup. NAFTA eliminated all tariffs on high-fructose corn syrup imports from the United States and consumption went up.


11) A US trade deal could greatly increase costs to the NHS of treating diet-related disease

The NHS spends at least £5.1 billion a year dealing with ill health caused by overweight and obesity in England alone. Researchers estimate the cost to UK society every year runs to the tens of billions, which includes the substantial costs of treating Type 2 diabetes. Cancer Research UK estimates that the predicted rise in obesity-related conditions could cost an additional £2.51bn in health and social care costs by 2035.

Treating diabetes in the UK costs the NHS around £13.7bn, with Type 2 costing £8.8bn a year. The US spends around $176bn treating diabetes. If the UK imported American levels of diabetes, resulting from increased availability and promotion of cheap unhealthy food and sugary drinks, the cost of NHS treatment for Type 2 diabetes could soar by tens of billions of pounds. This is why impact assessments are needed.


12) A US trade deal could prevent the UK from requiring food labelling that presents nutrition information in a way that is helpful, colour-coded and easy to interpret

The UK has made great strides over recent decades to improve food labelling. More needs to be done, but UK supermarket shelves now carry consistent front-of-pack colour-coded traffic-light nutrition information.

However, if the UK Government wanted to make this mandatory in the future, they might be stopped from doing so by the terms of a US trade deal, or at least be delayed in lengthy and expensive legal battles.



In June 2016, Chile introduced a new law to establish a front-of-pack warning label system for certain pre-packaged food and drinks that exceed specified thresholds for salt, sugar, calories and saturated fat. They went on to put advertising restrictions in place and were referred by the US to the World Trade Organisation (WTO).

Similarly, Peru introduced front-of-pack warning labels and more restrictions on marketing and sales around schools and were also referred to the WTO by the US who claimed they were failing to provide consumers with information about how these high fat, salt and sugar products “consumed in moderation” can be part of a healthy diet.

The US are also taking umbrage with Ecuador and forced the Indonesian government to pause its requirement for nutritional labelling.

The UK Government’s 2018 update to the national Obesity Plan highlights a survey from Diabetes UK that found that, “Almost nine in ten people agree that the traffic light labelling system helps people make informed decisions about the food they buy.” UK public health organisations such as the Royal College of Paediatrics and Child Health, Diabetes UK, the Local Government Association and the Children’s Food Campaign are all arguing that colour-coded front-of-pack traffic light labelling should be mandatory.

However, the United States argues that labelling initiatives such as front of pack traffic light labelling must remain voluntary.


13) A US trade deal could re-introduce artificial colourings that trigger hyperactivity in toddlers

In the US, it is permissible to use certain artificial colourings that have been phased out of foods available in the UK, largely to scientific research showing their association with triggering hyperactive behaviour in toddlers. Voluntary action by UK supermarkets and manufacturers means their use is now quite rare and the UK supported an EU requirement to put warning labels on products that carried them. If the UK agrees a trade deal with the US, such restrictions these labels could be subject to a legal challenge, described as a ‘barrier to trade’.


14) A US trade deal could increase rates of food poisoning, particularly from meat and eggs

We examined the food safety record of the United States and found that the US reports higher rates of illness from foodborne illness than in the UK. Annually, 14.7% (48 million) of the US population suffer from a foodborne illness, versus 1.5% (1 million) in the UK. This is nearly ten times the percentage of population. Children under 5 are in a higher risk category for food poisoning.

If by importing increased levels of meat from the US the UK ended up with similar patterns of foodborne illness, we estimate that UK deaths from food poisoning could increase and the cost to the NHS and UK economy could be around £1bn per year, with particular concerns for the welfare of young children.

More information and analysis on this particular point is available here


15) A US trade deal could undermine global efforts to reduce profligate use of antibiotics

Sustain is a founding member of the Alliance to Save Our Antibiotics, working with Compassion in World Farming and the Soil Association and backed by medical organisations, public health institutions, farming groups and many others. The systematic overuse of antibiotics in human and animal medicine is creating superbugs that can no longer be treated by life-saving antibiotics. With over one quarter of babies born by C-section in the UK, and many more experiencing childhood health problems that require effective antibiotics, this is clearly an issue highly relevant to children’s health.

Research by the Alliance to Save Our Antibiotics found that the use of antibiotics in US farming is five times higher than in UK production. Full details can be found here.

Sustain believes that trade deals must contribute to the great global effort to conserve antibiotics.


16) A US trade deal could promote formula milk for babies, undermining breastfeeding and health

Sustain is concerned that recent behaviour of the United States is indicative of them acting in the interests of infant formula milk manufacturers rather than the health of mothers and babies. The US has tried to block attempts to promote breastfeeding at international health meetings and threatened sponsor countries with punishing trade terms and the withdrawal of military aid. They have also behaved aggressively in trade talks with countries that try to set their own laws limiting the unnecessary and inappropriate marketing of formula milk to new parents.

Sustain member Patti Rundall of Baby Milk Action was present at the WHO meeting, representing the UK. She reported: “What happened was tantamount to blackmail, with the US holding the world hostage and trying to overturn nearly 40 years of consensus on the best way to protect infant and young child health.”

The United States has referred El Salvador to the World Trade Organisation because El Salvador wanted to restrict marketing and advertising, and to introduce labelling requirements for breast milk substitutes (formula milk). Malaysia, Indonesia and Thailand have also fallen foul of the US Government for trying to restrict the marketing of breastmilk substitutes.

We believe it is vitally important for infant and maternal health to maintain the EU directive standards on infant formula, follow on formula and baby foods as a minimum to protect vulnerable children.


17) Further information on Sustain’s approach to trade

Sustain believes that trade can bring many benefits. However, we want to be sure that such trade deals are agreed only if we can guarantee that people in the UK can enjoy a supply of food that is safe, affordable and good for our health, animal welfare, food producers at home and abroad, and the environment – including protecting precious natural resources and reducing the emissions that cause climate change.

We also think there is a strong case for ensuring human health outcomes from the new Agriculture Bill and believe this would be undermined by a trade deal and race to the bottom on food standards. The health public goods part-resulting from farm policy could include a reduction in antibiotics resistance, greater consumption of healthy diets though more availability of healthy foods like fruit and vegetables, and a contribution to reducing obesogenic environments (by transitioning farmers out of sugar beet production).  A more detailed explanation can be found here.


Further information on our views on trade is available from our website.

October 2018

Brexit: We stand at a cross-roads. When the UK leaves the European Union, will our leaders uphold good standards for our food, farming, fishing and trade deals? And will they agree a sensible deal with the EU? We need to make sure that they do!

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