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LHGP response to the UK DHSC National Cancer Plan evidence call

LHGP Publications

In May 2025, Local Health and Global Profits (LHGP) responded to the UK Department of Health and Social Care’s call for evidence to inform the development of the government’s national cancer plan for England.

This page provides a summary the response. LHGP has drawn on their understanding of the commercial determinants of health, and the response addresses the key areas of prevention, inequalities and priorities for the national cancer plan.

Prevention and awareness

The call for evidence asked for a list of risk factors to be prioritised, with the three ‘most important’ identified.

It is LHGP’s view that all cancer risk factors should be addressed through dedicated resources to improve prevention within the population. There is strong and consistent evidence to link obesity, physical inactivity, UV radiation and air pollution to various forms of cancer, and none should be prioritised as more important than another.

Similarly, alcohol, tobacco and the commercial determinants of health (CDOH) are risk factors which also have robust evidence for their links to cancer. These are the commercial sector activities that affect people’s health, positively or negatively.

Unhealthy commodity industries

The tobacco, alcohol and ultra-processed food industries are examples of unhealthy commodity industries, which shape health both directly and indirectly as a result of their business practices. These activities can be

  • direct, such as the marketing and sale of unhealthy products;

  • more indirect, like industry lobbying against duty increases, donating to political campaigns, funding research, and generating doubt in relation to product harms.

Non-communicable diseases (NCDs), such as cancer, are often the result of the physical and social environment, which includes the commercial determinants. These diseases are a major driver of health inequalities. Tackling this major driver will help in reducing the incidence of these diseases, and thus health inequalities.

These system-level challenges require system-level solutions to protect people from harm, reduce health inequalities, and foster healthier models of economic growth.

The impact of inequalities

Variation in cancer incidence and outcomes exist based on geographical location and socioeconomic background. When considering areas where the government could have the most impact in reducing inequalities in cancer incidence. tackling the commercial determinants of health should be a priority.

Unhealthy commodities, such as tobacco, alcohol and gambling, drive an increased burden of disease for communities, and health harms from unhealthy products are much higher when risk factors are combined, which is more common in disadvantaged groups.

Evidence and references:

Inequalities in health outcomes among these groups are clearly linked to commercial practices and operators. This represents a fundamental power imbalance with negative health and equity implications. Tackling it should be a priority for the Government in reducing inequalities in health, particularly cancer incidence.

Priorities for the national cancer plan

Interventions that the Government can and should introduce to limit the influence of industry on the population’s diet and facilitate a greater diversity of healthier choices for more people in more places include:

  • restricting marketing of unhealthy foods to children

  • mandatory reformulation of unhealthy foods

  • restricting fast-food outlets near to children’s education settings and playgrounds.

Increasing excise duties

Reducing the affordability of tobacco is recognised to be the most effective way of reducing smoking prevalence. With regard to excised duties on unhealthy products, the evidence suggests the following:

This provides a win-win situation for public health and the economy, as it also addresses the significant costs associated with tobacco-related illness, such as through productivity loss and strain on healthcare systems.

It is important that price interventions are implemented alongside targeted, accessible and well-resourced cessation services, to ensure that those facing greatest harm are supported.

Protecting resources for population approaches

Local authorities need ring-fenced, long-term funding to deliver vital services which support their populations and reduce health inequalities.

A polluter pays levy and excise taxes are an opportunity to raise the money needed to carry out vital public health interventions, as health is not only a human right but is the foundation on which a thriving economy is built.

The government’s focus should be on population-level approaches to prevention – those that tackle the underlying social and systemic causes of ill-health rather than clinical interventions. These are proven to be more effective at improving health outcomes and are more cost effective (Centre for Health Economics, 2019)

There also continues to be broad public support for a bolder approach to public health policymaking (Health Foundation, 2014).

This emphasises the need for the national cancer plan to focus on prevention and the wider determinants of health in order to effect a step-change in our national approach to cancer prevention.