This mid-point evaluation of Australia’s first wave of reformulation targets under the Healthy Food Partnership found very few achievements have been made. Many leading food companies are not engaging with the program, as evidenced by the minimal progress towards meeting the targets, especially for saturated fat. Since the program’s success relies on food companies reformulating their products, the lack of progress raises serious concerns about the potential of Australia’s reformulation program to achieve meaningful change in the healthiness of the food supply.

Since this evaluation occurred at the mid-point of the first wave of the Healthy Food Partnership reformulation program, the full effect of the targets needs to be reassessed at the end of the implementation period. Nonetheless, the current trajectory of the program is concerning - especially for saturated fat. We observed wide variation in the progress made across the targeted food categories, which suggests food companies are selectively complying with the targets, rather than aiming to reduce sodium and saturated fat levels across all products targeted by the Healthy Food Partnership. This selective compliance highlights a fundamental limitation of relying on voluntary action by the food industry, which is also apparent in the case of other important food policies. For instance, nutrition labeling and declaration of key nutrients have been long recommended by CODEX Alimentarius International Food Standards [15]. However, most food companies only comply once mandatory regulation is enacted [16]. Collectively, our results and those of other voluntary measures attempted in Australia [17,18,19] suggest that relying on industry commitments will not deliver intended public health outcomes and may instead function as whitewashing exercises for food companies.

While it is positive to see some progress made by the food industry, with seven out of the ten top manufacturers improving their compliance with the sodium targets, especially in some major food categories, our findings indicate that the current rate of progress towards the voluntary targets is unlikely to bring about meaningful reductions in the sodium and saturated fat content of the food supply, even if the effect doubles by the end of the program. While the lack of progress made by food companies is a significant factor, the flawed design of the reformulation program also plays a role. A substantial limitation of the program’s design is the small number of food categories targeted (e.g., the WHO global sodium benchmarks cover almost three times as many food categories) [20]. A second limitation is the weak target levels. When it was designed, the Healthy Food Partnership intended to set reformulation levels at the 33rd percentile for sodium and saturated fat of available foods in the targeted categories to ensure feasibility. However, the present study, in line with previous research [13, 21], has shown that far more than one-third of products already met the targets at baseline, suggesting that the targets were more achievable than intended. Our findings suggest that in addition to regulatory measures, there may be a need to redesign the targeted food categories and adjust target levels to ensure they are more ambitious and broader in scope to achieve greater shifts to population diets across Australia.

The Australian Bureau of Statistics (ABS) recently published an evaluation of progress towards meeting the sodium reformulation targets in Australia [22]. Their estimates were based on nutrition composition data from ~1110 packaged food products from Australian companies who voluntarily provided this data along with barcode sales data supplied by major supermarket chains for each of these products [22, 23]. The ABS estimated that progress made towards meeting sodium reformulation targets to date could lead to about 8.3 mg reductions in daily sodium intake, which would represent a ~ 0.4% reduction in daily average sodium intake for Australian adults [22]. Based on the known relationship between sodium intake and blood pressure (and therefore NCD risk), this change will have minimal impact on population health outcomes. This suggests that if the Healthy Food Partnership is to achieve meaningful reductions in disease burden, more stringent and comprehensive targets will be needed [12], such as those covered as part of the WHO global benchmarks [20], as well as incentives for compliance or mandatory regulation to ensure greater compliance with the targets.

The analysis across matched and unmatched products was a novel aspect of this evaluation. We were motivated to conduct this analysis because matched products are those that stay available in the marketplace, and thus tend to be ‘top-sellers’ in any given product category. Reformulation for such products is arguably even more important as they are more commonly consumed. It could be hypothesized that food companies may be reluctant to reformulate top-selling products to avoid changing the taste of the products, which could adversely impact sales. Our findings support this hypothesis, as we found more progress for unmatched products than matched. The limited progress made across matched foods suggests food companies are making minimal effort to reformulate their existing product lines.

Our analysis benefits from the large nutrition databases available from FoodSwitch. The data was collected systematically from products available for sale in large retail stores that collectively account for most of the food products commonly purchased by Australian consumers. Relying on such nationally representative data allows a more accurate and less biased assessment of the progress towards meeting reformulation targets than focusing on subsets of available products or those selectively provided by food manufacturers, such as in the case of the aforementioned ABS evaluation. Another strength was our analysis that explored differences between matched and unmatched products. This allowed us to investigate how much of the progress towards the targets was driven by reformulation versus the formulation of new products and discontinuation of old products lines. A limitation of the study is that we did not explore the impact of the targets on sodium and saturated fat purchases or intakes. Such analyses are needed to explore the impact of the reformulation program on population diets, and should be conducted at the end of the four-year implementation period. This study also only explored the impact of the Wave 1 targets; further research is needed to explore the progress made by the Wave 2 targets that include sodium targets for additional food categories and targets for sugar [24, 25]. Further, future analysis could explore whether there is a difference in locally produced versus imported foods to inform whether overseas based manufacturers are even less likely to comply with the targets.

In conclusion, our analysis of the progress made by the Healthy Food Partnership mid-way through the implementation of the first set of reformulation targets has demonstrated that food companies have made limited progress towards meeting the targets, especially for saturated fat. The fact that many food manufacturers did not reformulate their products highlights the fundamental flaw of the voluntary system. If this trend continues, the reformulation program will not achieve meaningful changes to Australian diets and the health of the population, thereby failing to achieve its stated intentions.