The absence of stringent regulatory measures to control front-of-pack labelling and marketing of ultra-processed foods (UPFs) continues to expose millions of children across the country to unhealthy foods, a report by Makerere University’s Economic Policy Research Centre (EPRC) has revealed.
The number of food and beverage brands trading in UPFs that target children has increased in recent years, with each processing company skillfully developing labels and advertising packages that look to convince children to buy their products.
Such child-directed marketing predominantly promotes UPFs that are known to contribute to harmful diets, with proportions of unhealthy food commercials ranging greater than 75 percent of all food advertising.
The EPRC joins experts who have come to a conclusion that marketing of UPFs to children continues to go unregulated despite its significant links and association with non-communicable diseases (NCDs).
“In Uganda, there is a growing apprehension regarding the surge in NCDs among children. This escalating health concern can be attributed to the unchecked consumption of fast foods and unhealthy diets among children, characterised by their high-calorie content but deficient in essential nutrients,” EPRC’s report reads in part.
It adds: “The situation is exacerbated by unchecked food advertisements and marketing and Front of Park (FoP) nutrition labelling targeting children, disseminated through various channels such as radio, billboards, social media, and television.”
The Centre also hastens to point out that the government’s full liberalisation of the economy and move to popularise agro-industrialisation have unwittingly created a breeding ground for errant food processors. This implies that restricting any form of marketing would stall the government’s efforts towards the country’s economic development.
This, though, is not without consequences, with several risks, including early onset of obesity, related health complications, and impaired brain development – a clear and present threat.
“The study’s findings revealed that although there are obstacles to the adoption of the two interventions aimed at creating a healthy food environment in Uganda, it is legally and politically feasible to adopt both marketing restrictions and FoP labelling interventions,” the report states, adding: “Moreover, the research identified pivotal systems and institutions such as the Uganda Communications Commission (UCC), Uganda National Bureau of Standards (UNBS), and the Ministry of Health (MoH), as instrumental players in the formulation and execution of these interventions.”
Danger lurks
The EPRC urges the government to enhance “existing laws and frameworks to encompass the specific objectives of [marketing restrictions] and FoP labelling interventions” in a bid to stop UPFs from taking over the shopping basket for children in Uganda.
Daniel Kamara, a nutritionist at Bwindi Community Hospital, believes the government has to move swiftly to control advertising of UPFs so as to forestall a potential obesity crisis.
Globally, the prevalence of overweight and obesity in children increased more than fourfold from four percent in 1975 to 18 percent in 2016. While the prevalence of the same in Uganda is currently 3.7 percent, there are fears—captured by EPRC’s study—that there could be a spike. Datasets from elsewhere offer support.
As per the Uganda Nutrition Action Plan 2020/2021 to 2024/2025, obesity and excessive energy intake are known major causes of hypertension, mirroring an indirect measure of the population’s nutrition status or secondary consequences of malnutrition. Overweight and obesity, a 2018 study by the Uganda Bureau of Statistics (Ubos) says, have steadily become more common in Uganda over the past 10 years.
Elsewhere, the Demographic Health Surveys between 2011 and 2016 captures an obesity prevalence that oscillated between three and four percent. Ubos further shows that five percent of children under five were overweight or obese in 2016, with overweight being 3.9 percent and obesity being 1.1 percent. The school-going children (ages three to 16) were found to have a high prevalence of obesity (32.3 percent) and overweight (21.7 percent) issues.
What are UPFs?
UPFs are cheap, attractive and convenient. This is largely because they are essentially concoctions made more appetising by industrial additives such as emulsifiers. Such foods pack a lot of calories in them because they are engineered from highly refined ingredients such as flours, cheap vegetable oils, whey proteins and sugars.
Processed in ways that go beyond cooking and fermenting, UPFs came into being at the turn of the 21st Century when Carlos Monteiro, a Brazilian scientist, graded the degree to which foods are processed. This birthed categorisations of least processed foods, processed culinary ingredients, processed foods, and UPFs. The latter involves, as mentioned before, emulsifiers, flavourings, colour, and other additives. UPFs are typically ready-to-eat in nature.
Consumers, Mr Kamara says, buy products without reading the food labels and their contents because government laws and measures are supposed to act as a sieve. Yet with the Ministry of Health and the Ministry of Agriculture, Animal Industry, and Fisheries (Maaif) never on the same page, joint coordination challenges abound.
The absence of a food authority to regulate the food environment, as well as rampant corruption contrive to make a bad situation worse.
EPRC’s report indicates that liberalising the economy to the forces of demand and supply is associated with massive loopholes—the government has opened fully to “Whom It May Concern." This implies that the government cannot restrict or regulate trade beyond a certain limit, the researchers argued.
“In Uganda, corruption precedes regulation because the people entrusted to inspect and enforce regulations are bribed. The state is also captured by corporate businesses, primarily through media houses, because they pay taxes on every advertisement placed or made,” the report states.
It adds: “Taxation of sugar-sweetened beverages conflicts with agro-industrialisation efforts; the government is currently advocating for agro-industrialisation under the third National Development Plan (NDP3), which is encouraged through tax subsidies and tax holidays to investors.”
Glamourising UPFs
The state, the researchers add, has turned a blind eye to corporate companies. And because the government is poor, it looks at taxes as a lifeline, which is a false lifeline.
The country’s TV industry also heavily depends on the beverage industry whose advertising spend helps keep their lights on. This, however, means children are not shielded from advertising that glamourises UPFs.
An acute lack of information regarding UPFs coupled with the high illiteracy prevalence among Ugandans is also said to curtail efforts to tackle unhealthy foods. The public is generally uninformed, with some believing that foods and beverages such as pizza, burgers, processed juices, and carbonated drinks indicate an improved living standard, and so they continue to buy unhealthy foods or substandard products.
Ben Jawoko, a nutritionist in Gulu City, says children are quickly misled and exploited by food marketing based on their neurocognitive and developmental immaturity.
“Marketing such food products does not operate through conscious arguments and persuasion but rather by subconscious routes and implying (exaggerated) emotional benefits from eating or drinking them,” Mr Jawoko says.
To Mr Jawoko, exposure to influential food marketing communications affects children's food behaviours in ways that are injurious to their natural dietary health.
“Today, you can imagine a bottle of soda has the average quantity of processed sugar you consume in a whole week, but you are drinking them in a single sitting. So, what happens when a child or an adult drinks 10 bottles in a week?” he wondered.
Price of inaction
Significant increase in affordability, accessibility, and promotion of UPFs and drinks high in saturated fats, trans-fats, sugars, and salts continues to depict modern Uganda’s food environment.
In Uganda, the most frequently marketed food categories are said to include fast food, sugar-sweetened beverages, and chocolate, among others. Mr Jawoko says the force of such marketing is influenced by the content of the message, especially the creative strategies used, including graphics, visual designs, cartoons, humour, and sports celebrities, among others.
The United Nations Children’s Fund (Unicef) argues that such developments amplify the reach, frequency, and persuasive power of food marketing. Companies purposefully employ marketing strategies that appeal directly to children. They may use striking graphics, employ humour and fun in their messaging, and link their product promotions to gifts, competitions, and entertainment events.
In its June 2024 report titled Taking Action to Protect Children From the Harmful Impact of Food Marketing, Unicef indicates that all children globally remain vulnerable to the persuasive effects of food marketing, with older children routinely left unprotected by existing restrictions. The explosion of digital media, including social media, as a new communication channel and the increasing amount of time children spend online are possibly the biggest developments in the marketing landscape since 2010, it says.
EPRC’s report titled Restriction on Child-directed Marketing and Front-of-Pack Labelling in Uganda: Legal and Political Feasibility to Create a Healthy Food Environment details how a weak policy environment has imperilled Uganda’s food environment. It discloses that a weak regulatory environment continues to propagate non-compliance in the industry since the available policies encourage trade by promoting free trade, deregulation, and elimination of subsidies, price controls, and privatisation of services. This, the report adds, has enabled the growth of unregulated businesses that sell unhealthy foods and beverages to children.
“These players include food companies, beverage companies, and media houses. Because of the expected loss of revenue and taxes from restricted marketing, this has created a problem of non-compliance in the industry; thus, it is difficult to stop the industry from advertising,” the report states.
“Further still, trade agreements signed between governments such as the AfCFTA, EAC, Comesa, and the African Union Abuja agreement, which advocate for low tariffs and free trade between member countries, make it challenging to implement interventions such as restricting marketing and taxation of SSBs,” it adds.
Egregious deficits
According to the EPRC researchers, the country’s 40-year-old Food and Drug Act (1964) prescribes regulatory measures on food labelling and, on one hand, sanctions the Health minister for issuing such regulations imposing requirements to regulate the labelling of food.
While the UNBS Act 2013 established UNBS that develops and enforces food standards to ensure a healthy population, it is said setbacks have recently levitated around its ability to implement the instituted laws, policies, and standards.
The national standards agency is also said to lack the provisions for effective mechanisms to ensure compliance since the current sanctions for non-compliance need to be more adequate as a deterrent; the financial penalty for non-compliance is very low. The conviction is liable to a fine not exceeding Shs2,000 (less than a dollar). Such a penalty makes the Act ineffective because it is too insignificant to make it effective.
While UNBS has a National Standardisation Strategy, 2019–2022, which specifies general rules for labelling and marking containers for essential oils and labelling requirements for pre-packaged products, it lacks the nutrient profiling model to ensure unhealthy foods are not sold on the market in disguise of being nutritious and healthy.
A lot to be desired
Prof Stefan Swartling Peterson, a public health physician and professor of global health at the Swedish Karolinska Institutet, says it is up to the government to protect children and help parents give the best for their children.
Uganda was successful in curbing the tobacco epidemic, but Uganda needs to be strong and regulate the marketing of this kind of foodstuff, he says.
“There are examples from other countries that Uganda can borrow in terms of regulations, legislation, and taxation because foods full of fats and sugars have been proven in other countries not to be good for children, it is essential that we regulate their marketing,” Prof Peterson says.
He, however, warns that such tougher regulations come at severe costs.
“Look at Kenya, our neighbours, who are currently advancing on front-pack labelling of food with a target to save children being stuffed with dangerous food. But now the companies will fight you, and fight such legislation since they have a much bigger budget than the public health budget.”
Uganda has several laws and policies that target to regulate the consumption of unhealthy foods. Take the Uganda Regulations on Marketing of Infant and Young Child Foods. In 1997, the Food and Drugs (Marketing of Infant and Young Child Foods) Regulations took centre-stage. In 2019, there was a proposed amendment of the statutory instrument number 278-1 of 1997, among others.
In May 2023, at the launch of Parliamentary Nutrition Week 2023 in Kampala, the government released the draft regulations for the sale of UPFs on the Ugandan market. This was aimed at guiding the country on the sale and marketing of all unhealthy foodstuffs in Uganda.
In an emailed response, Samalie Namukose, the assistant Commissioner, Nutrition Division of the Health ministry, explains that her ministry has currently embarked on massive awareness campaigns in light of regulations on the marketing of unhealthy foods across the country.
“On the presidential initiative on healthy eating and healthy lifestyle among Ugandans, awareness campaigns are ongoing countrywide […] we are also in the process of finalising the regulation on marketing of unhealthy foods,” Ms Namusoke says.
“The ministry recently developed the regulatory impact assessment to inform the public food procurement and service policy – this is to ensure all the foods that are procured by all institutions (schools, hospitals, prisons, etc.) are healthy and safe for consumption,” she adds.
Monitor has established that several campaigns are ongoing aimed at promoting healthy eating and lifestyle practices in households and communities, raising public awareness about malnutrition and its consequences, as well as advocating for engagement and involvement of public and private sectors, civil society and other stakeholders in promoting healthy diets and lifestyles.
Ms Namukose says poor eating habits characterised by the consumption of sugary and highly processed foods and drinks, large portion size, alcoholism, lack of fruits and green vegetables in the diet, and fried foods among Ugandans, have contributed to a high burden of overnutrition. This refers to the excess nutrient and energy intake over time. Ms Namusoke says the consumption of unhealthy foods is one of the risk factors for NCDs, including cancer, diabetes, and cardiovascular diseases, among others.