Use of the WHO Nutrient Profile Model for Food Marketing Regulation in Germany: Feasibility and Public Health Implications.

Introduction: Exposure to marketing for foods high in sugar, salt, and fat is considered a key risk factor for childhood obesity. To support efforts to limit such marketing, the World Health Organization Regional Office for Europe has developed a nutrient profile model (WHO NPM). Germany's Federal Ministry of Food and Agriculture plans to use this model in proposed new food marketing legislation, but it has not yet been tested in Germany. The present study therefore assesses the feasibility and implications of implementing the WHO NPM in Germany.

Methods: We applied the WHO NPM to a random sample of 660 food and beverage products across 22 product categories on the German market drawn from Open Food Facts, a publicly available product database. We calculated the share of products permitted for marketing to children based on the WHO NPM, both under current market conditions and for several hypothetical reformulation scenarios. We also assessed effects of adaptations to and practical challenges in applying the WHO NPM.

Results: The median share of products permitted for marketing to children across the model's 22 product categories was 20% (interquartile range (IQR) 3-59%) and increased to 38% (IQR 11-73%) with model adaptations for fruit juice and milk proposed by the German government. With targeted reformulation (assuming a 30% reduction in fat, sugar, sodium, and/or energy), the share of products permitted for marketing to children increased substantially (defined as a relative increase by at least 50%) in several product categories (including bread, processed meat, yogurt and cream, ready-made and convenience foods, and savoury plant-based foods) but changed less in the remaining categories. Practical challenges included the ascertainment of the trans-fatty acid content of products, among others.

Conclusion: The application of the WHO NPM in Germany was found to be feasible. Its use in the proposed legislation on food marketing in Germany seems likely to serve its intended public health objective of limiting marketing in a targeted manner specifically for less healthy products. It seems plausible that it may incentivise reformulation in some product categories. Practical challenges could be addressed with appropriate adaptations and procedural provisions.