Hildegarde Naughton (Galway West, Fine Gael)
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The World Health Organisation (WHO) guidance on Commercial Determinants of Health, defines these as“the private sector activities that affect people’s health, directly or indirectly, positively or negatively”. Commercial determinants can impact a wide range of risk factors- such as smoking, alcohol use, air quality, obesity, physical inactivity and health outcomes, including non-communicable disease, cancer, mental and physical health.

Healthy Ireland supports a range of initiatives across Government departments, agencies and civil society to promote“physical and mental health and wellbeing to their full potential, where wellbeing is valued and supported at every level of society and is everyone’s responsibility.” Policies contained in the Healthy Ireland strategic implementation plan (HISIP) include the National Physical Activity Plan, the National Sexual Health Strategy, the National Mental Health Promotion Plan and the National Obesity Policy Action Plan.

The Department of Health has made progress in reducing exposure to tobacco and alcohol, ever since the smoking ban was introduced as a health promotion initiative in 2004. Recently, the Public Health (Tobacco Products and Nicotine Inhaling Products) Act 2023 forms part of a comprehensive suite of reforms- including the prohibition on the sale of tobacco products and nicotine inhaling products to those aged under 18- to reduce smoking and its harmful effects. The Minister for Health is also developing legislation to further regulate tobacco and nicotine inhaling products.

The Public Health (Alcohol) Act was enacted in 2018 with 28 of the 31 provisions now commenced. The Act seeks to address the high volumes and harmful patterns of consumption of alcohol prevalent in Ireland through a suite of measures including minimum unit pricing, the regulation of advertising and sponsorship, the display of products in mixed retail outlets and the regulation of the sale and supply of alcohol.

In the past year, the Minister has signed into law the Public Health (Alcohol) (Labelling) Regulations 2023, provided for under section 12 of the Act and commenced the Broadcast Watershed provision of the Public Health (Alcohol) Act, which will come into effect in 2026 and 2025 respectively.

From an obesity and nutrition perspective, A Healthy Weight for Ireland, the Obesity Policy and Action Plan (OPAP), was launched in September 2016 under the auspices of the Healthy Ireland Framework (Healthy Ireland: A Framework for Improved Health and Wellbeing 2013-2025). It was developed in recognition of the growing need for a coordinated policy response to the increasing problem of obesity in Ireland and the increasing burden placed on individuals and society.

OPAP covers a 10-year period up to 2025 and aims to reverse obesity trends, prevent health complications, and reduce the overall burden for individuals, families, the health system, and the wider society and economy. It recognises that obesity is a complex, multi-faceted problem and needs a multi-pronged solution, with every sector of society playing its part. Childhood obesity is a key priority under OPAP, as is reducing the inequalities seen in obesity rates, where children (and adults) from lower socioeconomic groups have higher levels of obesity. OPAP is well aligned with the World Health Organisation in terms of the breadth of policy measures that have been introduced or are being considered in order to address the obesity epidemic.

Under OPAP, commitment was given to “develop proposals for a levy on sugar-sweetened drinks”, and “review the evidence...for fiscal measures on products that are high in fat, sugar and salt.”

Following a proposal developed by this Department in consultation with stakeholders, the Department of Finance introduced the Sugar-Sweetened Drinks Tax (SSDT) in 2018. The SSDT has now been in operation for more than five years. Initial indications are that the tax has had a positive impact, particularly in terms of encouraging drinks producers to reduce the sugar content in their products.

In August 2023 the Department issued a request for tender for an external evaluation of the SSDT with the outcomes of interest to include anyone, or all, of the following:

- the extent to which the tax was successful in realizing the objectives as stated in the original policy document and set out below:

(1) that individuals reduce consumption of sugar sweetened drinks by reducing the amount consumed or switching to healthier choices.

(2) that industry reformulates products to reduce (not necessarily remove) levels of added sugar in the drinks products.

- other impacts that the tax may have on public health as identified by recent studies, such as evaluations of dental outcomes and also the measurement of the impact on metabolic markers;

- subgroup analysis focusing on the effect on groups such as those overweight/obese, children, lower income individuals/families.

A contract for the evaluation was awarded in September 2023. The evaluation is ongoing, and we expect it to be complete in April 2024. The Department intends to publish it in a timely manner.

The Department of Finance has been consulted as part of the evaluation. This Department will be engaging with the Department of Finance in considering the findings of the evaluation.

Step three of the Obesity Policy and Action Plan – A Healthy Weight for Ireland’ (OPAP, DOH 2016) relates to food reformulation. It aims to ‘secure appropriate support from the commercial sector to play its part in obesity prevention and agree food industry reformulation targets and review progress’.

To achieve this, a Food Reformulation Subgroup of the Obesity Policy Implementation Oversight Group developed a Roadmap for Food Product Reformulation in Ireland (Department of Health, 2021).

To deliver the Roadmap, the Food Reformulation Task Force, a strategic partnership between Healthy Ireland and the Food Safety Authority of Ireland (FSAI), was established in 2021.

The Food Reformulation Task Force is tasked with implementing the Roadmap and monitoring the progress made in modifying the nutrient profile in processed packaged food over a four year programme up to 2025.

When referred to in the context of the Roadmap for Food Product Reformulation in Ireland, food reformulation means improving the nutritional content of commonly consumed processed foods and drinks. This is achieved by reducing energy (calories) and target nutrients (saturated fat, sugar, and salt) to ensure a healthier food supply. Specifically, the Roadmap sets targets for the reduction of energy (calories) and sugar by 20% and salt and saturated fat by 10% between 2015 and 2025. The current programme is voluntary; outcomes of the reformulation programme will be evaluated to guide future policy options.

Reducing the marketing of foods high in fat, salt and sugar is a policy initiative that has been identified in OPAP as it can impact food consumption behaviour. Coimisiún na Meán was established in March 2023 further to the provisions of the Online Safety and Media Regulation Act 2022 (“OSMR Act 2022”).

As the regulator for broadcasting in Ireland, Coimisiún na Meán is to establish a regulatory framework for online safety, update the regulation of television broadcasting and audiovisual on-demand services, and transpose the revised Audiovisual Media Services Directive into Irish law. Officials from the Department of Health have met with officials from An Coimisiún to discuss implementing codes that would restrict the marketing of high fat, sugar and salt foods and beverages to children and will continue to engage with An Coimisiún going forward.

The Department commissioned an evaluation of progress implementation of OPAP by University College Cork (UCC) in 2021 which was published in 2022. The review of OPAP suggests that many policy options that the WHO European Regional Obesity Report 2022 recommends on managing obesity throughout the life course, are in progress of being implemented.

As OPAP is coming to an end in 2025, officials in the Department are in the early stages of planning the successor. At present there are no plans to commission a separate report into the commercial determinants of health, as the Institute of Public Health and other research colleagues, have commenced research in this area. In preparation for the next OPAP, examination of recent research and best practice relating to healthy eating promotion and prevention, management, and treatment of overweight and obesity will be taken into consideration, including studies relating to commercial determinants of health.

Hildegarde Naughton (Galway West, Fine Gael)
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Coimisiún na Meán was established in March 2023 further to the provisions of the Online Safety and Media Regulation Act 2022 (“OSMR Act 2022”) www.irishstatutebook.ie/eli/2022/act/41/enacted/en/html. The OSMR Act 2022 amended the Broadcasting Act 2009, www.bai.ie/en/download/128802/, to establish Coimisiún na Meán and dissolve the Broadcasting Authority of Ireland (“BAI”).

In addition to undertaking the functions of the BAI as the regulator for broadcasting in Ireland, Coimisiún na Meán is to establish a regulatory framework for online safety, update the regulation of television broadcasting and audiovisual on-demand services, and transpose the revised Audiovisual Media Services Directive into Irish law.

The Health and Wellbeing Unit in the Department of Health has met bilaterally with Comisiún na Meán on two occasions. The first meeting took place on June 6^th2023 on Microsoft Teams, where the Head of Healthy Ireland and an official at AP level met with Niamh Hodnett, Online Safety Commissioner in An Coimisiún, as well as 3 other officials. The main topics of discussion at this meeting were centred around the establishment of An Comisiún and the work that was going to be undertaken for the first set of online safety codes.

The second meeting between the Health & Wellbeing Unit and An Coimisiún took place on the 25^thof January 2024 in the Department of Health. In attendance were the Head of Healthy Ireland and officials at AP and AO level, and the Director of Codes & Rules from Coimisiún na Meán. Issues discussed at this meeting were the outcome of the EU Joint Action Best ReMaP, the Nutrient Profile Model, the Work Programme of the Coimisiún, the consultation on the online safety code that was that was out at the time (which the Department of Health submitted a response to) and how progress could be made on addressing unhealthy foods and beverages within the codes. Both the Department and the Coimisiún na Mean agreed to work together and with other relevant stakeholders to progress this agenda.

Officials from Food Unit in the Department of Health have not met with officials from Coimisiún na Meán.