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Leaked Strategy vs Published Strategy: A Side by Side Analysis

By Dr Chris Yap, FixOurFood Research Fellow. City University, London.

This blog was first published by the Food Research Collaboration (

FixOurFood policy researcher, Christopher Yap compared the leaked and the published versions of the Food Strategy White Paper. Here he looks at five key differences and what they tell us about policy-making.

The long-awaited Government Food Strategy White Paper was published on Monday (13 June 2022). But it is not a White Paper. And it is “not a strategy”. Many experts and commentators have been quick to criticise the document for failing to translate into policy the majority of the cohesive, ambitious, and ultimately necessary recommendations set out in Henry Dimbleby’s (2021) Independent Review for the National Food Strategy.

The lack of new, coherent, and progressive proposals is a missed opportunity for the national government to show leadership in addressing a wide range of societal challenges. For policy-watchers, the process by which the document became public sheds interesting light on how public policy is formed – in this case, apparently negotiated sentence by sentence, down to publication.

On Saturday (11 June), the Guardian newspaper leaked a draft of the Strategy (version 19). We will likely never hear the full story of how the published Strategy was produced; how particular decisions were made and words carefully chosen. But comparing the leaked and published versions of the Strategy offers a rare glimpse into the ways that policy documents are produced, with potentially wide-reaching implications.

We compared the documents side by side. They are easily comparable, suggesting that the leaked document was a relatively late draft. However, there are a number of important differences. Beyond the significantly redrafted Foreword, here are five we think are important:

The first is the removal of a sentence that stated the government accepts much of Dimbleby’s analysis and recommendations (paragraph 4):

This Government Food Strategy responds to the findings and recommendations of the independent review; we accept much of the analysis and do not repeat it here. We also accept the majority of recommendations.

This is significant because Dimbleby’s review was based on a thorough and devastating diagnosis of the challenges related to our food system, which justified the scale of interventions he proposed to address them. Without recognising that, “the food we eat – and the way we produce it – is doing terrible damage to our planet and to our health” (Dimbleby, 2021, p10), there is a reduced imperative for significant government intervention.

The second is the downplaying of animal welfare in relation to trade in the stated objectives of the Strategy. In the leaked version, one of three headline objectives was to deliver:

Trade that provides export opportunities and consumer choice through imports, without compromising our standards for animal welfare or doing environmental or social harm.

This was replaced in the published version with the less inspiring objective to deliver:

Trade that provides export opportunities and consumer choice through imports, without compromising our regulatory standards for food, whether produced domestically or imported.

Animal welfare does feature prominently in the published Strategy: section 3.4 remains dedicated to animal welfare standards. However, the language is watered-down and the commitment less clear. For example, animal welfare becomes one of a number of factors that will be taken into consideration, rather than a principle of new Free Trade Agreements (FTAs). The leaked version stated that:

We will seek animal welfare linked liberalisation in our FTAs, allowing us to offer more generous liberalisation for products certified as meeting certain key animal welfare criteria specified in the agreement.

This was replaced in the published version with:

Decisions on the liberalisation of products through FTAs will consider factors such as climate change, animal welfare and the environment alongside the broader economic and strategic benefits of our trading relationships.

The third is the removal of £10 million from the money allocated to UK Research Councils (UKRI) for food systems research. The reduction of investment in research from £130 million to £120 million is not hugely significant in itself. However, this does draw attention to the lack of new investment set out in the strategy, as well as to how far short the published Strategy falls against the £1 billion of investment in innovation needed to transform the food system recommended by Dimbleby, of which £500 million was to be distributed through a UKRI ‘Challenge Fund’ over five years.

The fourth is the addition of an entirely new section on the seafood indsutry as a source of employment (paragraph 1.3.7), focusing on Grimsby and the Humber Region. This is a welcome addition and reflects important work by Sustain and others that has drawn attention to the environmental and economic benefits of regenerating fishing communities in the UK. The question this raises, however, is why the Strategy is so geographically specific and not aimed at current and former fishing communities around the UK coastline?

The fifth is the rewriting of particularly controversial paragraphs on healthy food choices and obesity (2.1.8 and 2.1.9). The differences are subtle, but revealing. The leaked version of the Strategy stated:

Since obesity is a complex cultural challenge, there is a shared responsibility to identify the solution, which lies in making healthier choices easier. There is an important role for individual responsibility and choice which can result in increased demand for healthier foods. Industry also has a role to play, with its responsibility for promoting and supplying healthier foods… There is also a crucial role for government to make targeted regulatory interventions to support change.

While the leaked Strategy emphasised the shared responsibility of individuals, industry, and the government in creating healthy food environments and supporting healthy food choices, the published Strategy subtly shifts the emphasis towards government and industry, not only by changing the order of presentation but by highlighting the importance of “better information” in supporting individual food choices. As the published Strategy states:

There is a shared responsibility to identify the solution to obesity; industry has a role to play through its responsibility for promoting and supplying healthier foods, government has a role in making targeted regulatory interventions to support change, and individual consumers, empowered with better information about healthier choices, can stimulate demand for healthier foods.

Regardless of the emphasis, the argument for shared responsibility is likely to be controversial; there is significant evidence for the role that food environments play in shaping individual food choices as well as the limited role that individual agency plays in addressing obesity.

The rewriting of these paragraphs also draws attention to the recent decisions of the government to delay well-evidenced policies with broad cross-party support that were designed specifically to improve food environments and contribute to public health outcomes. In May 2022, the Department of Health and Social Care announced that the policy to ban ‘buy one get one free’ offers on high fat, salt and sugar (HFSS) foods, which was signed into law in December 2021, would be delayed by at least 12 months to give the government time to assess the implications of the policy for the current cost-of-living crisis. The plan to restrict the advertisement of HFSS foods before 21.00 – limiting children’s exposure – has been delayed until at least January 2024.

It is important not to overstate the conclusions that can be drawn from these changes; from the conversations that were had and the decisions made sometime between version 19 (leaked) and the final published versions of the Strategy. Policy-making involves multiple departments and policy documents are routinely revised right up until publication. What this does provide, however, is some indication of the most recent areas of contestation and discussion, as well as a too-rare insight into the policy-making process.

Beyond the specific examples here, and the numerous other changes between the documents (such as the addition in paragraph 1.2.6 to “regulate… where necessary”, and the removal of the suggestion to eat more wild venison from paragraph 1.3.5), the leaked and published strategies are not vastly different. Both fail to live up to the promise of a once-in-a-generation opportunity to transform the food system; both eschew the majority of Dimbleby’s recommendations.

So what now? The published strategy contains some specific signposts to forthcoming White Papers and reports, such as the Health Disparities White Paper and the House of Lords Special Inquiry Committee into land use in England. These take on a renewed significance for their role in addressing the crucial issues omitted from the published National Food Strategy.

This national disappointment also reaffirms the importance and value of local food strategies and leadership from the local level. Local and regional food strategies, policies, and initiatives are now the frontiers for food systems transformation, with an even more significant role to play in transforming the food system to meet social, economic and environmental challenges. Get involved in your local food strategy, because this is now where change must happen.