Bulletin: HFSS - what could NPM 2018 change?

NPM 2018: 72% of products assessed could be HFSS  

New University of Oxford research provides an indication of the potential impact if NPM 2018 is applied to existing HFSS restrictions. Across more than 15,000 products in 13 in-scope categories at Tesco, Sainsbury’s, Asda, Ocado and M&S, 72% were classified as HFSS under NPM 2018, up from 58% under the current model, with soft drinks, breakfast cereals and yoghurts among the most affected.

The government’s consultation has closed, but its response and final decisions are still awaited.  

Read our analysis of what the findings could mean for food and grocery businesses, including the implications for free sugars and different categories. 

Preparing for the Milburn review 

The final report of the Milburn review into young people and work is expected next week. IGD will provide a full analysis of its key recommendations and what they could mean for the food and drink industry. 

Alan Milburn has acknowledged that proposed reforms to sickness and disability benefits could mean less financial support for some under-25s at the start of their claims, alongside expanded personalised employment support. These are reported proposals ahead of the final review, not confirmed changes to benefit entitlements. 

Ahead of publication, explore our existing research and practical guidance on the sector’s workforce challenge. Our Quiet Crisis report examines the structural pressures affecting labour supply, skills and productivity, while our analysis of the interim Milburn report considers the implications of rising youth inactivity for food businesses.  

Businesses can also explore how stronger links between education and employment, meaningful work experience and employer volunteering can help build a more resilient future talent pipeline.

Explore IGD’s workforce insight and find out how to get involved in Feeding Britain’s Future. 

UK economy maintains momentum

The UK economy grew by 0.7% in Q3, continuing a stronger-than-expected performance during 2026 despite a challenging global backdrop. The latest data reinforces signs that the economy has proved more resilient than anticipated this year, building on growth of 0.6% in Q1 and 0.5% in Q2.  

This provides a firmer platform heading towards 2027, although continued geopolitical uncertainty and pressure on businesses and households mean stronger recent growth does not necessarily signal sustained momentum.  

IGD opinion 

The stronger growth picture is encouraging for food and consumer goods businesses. Greater economic resilience should provide some support to consumer demand, but businesses should remain cautious about assuming this translates into a sustained improvement in household spending as we move into 2027. 

There are two major issues to note. First, there is some evidence (e.g. Bank of England studies) that shoppers are drawing down savings and saving less to maintain current spending levels, which cannot be sustained indefinitely. 

 Second, a large part of UK GDP growth in 2026 appears to be connected to investment in advanced technology, such as AI and cloud computing. This is obviously positive, but it is increasingly clear that these technologies create both environmental and social burdens. 

Geopolitics: cheaper crude offers hope, not a cost reset 

Lower oil prices offer hope of easing cost pressures, but not a cost reset. Brent briefly fell below US$90 a barrel on 10 November before settling at US$91.49. 

President Trump said the Iran conflict could end “fairly soon”, lifting hopes of de-escalation and recovering oil flows. But negotiations remain uncertain, with risks to shipping and energy infrastructure unresolved. 

Russia, Ukraine and the US also held talks in Abu Dhabi on 10 November, with a second session scheduled for 11 November. Zelenskyy described the talks as constructive; Rubio called them productive but said much work remained. For food businesses, diplomatic optimism is not yet evidence of sustained supply or cost relief. 

IGD opinion 

For food businesses, cheaper crude and diplomatic progress are not yet a reason to assume lower distribution costs or more reliable supplies. Businesses should monitor delivered fuel prices and supply reliability rather than assume a matching reduction in distribution costs. The Ukraine talks merit watching, but they do not yet justify treating conflict-related supply risks as resolved. 

Emergency buying masks a subdued grocery market 

Take-home grocery sales rose 2.2% year on year in the four weeks to 1 November 2026, against like-for-like price inflation of 2.6%, according to Worldpanel. This suggests subdued demand ahead of Christmas, although the figures do not directly measure sales volumes. 

Following government advice issued on 22 October, sales of hand sanitiser, tinned and jarred food, and bottled water increased over the next ten days. Worldpanel describes more households buying recommended essentials, rather than panic buying or larger typical purchases. 

IGD opinion 

IGD's ShopperVista research, conducted just after the Budget, suggests that about one-third of shoppers' plan to stock up on essentials, as a response to government advice, which aligns with the Worldpanel data. 

Household emergency supplies can provide a short buffer during disruption, but they do not remove the need for a resilient food supply chain. 

For food businesses, the immediate challenge is to distinguish a temporary uplift in essentials from sustained demand growth. Stock availability and replenishment matter, but emergency purchases alone are not evidence of stronger household spending power. 

Supply chain resilience remains the longer-term priority: household preparedness and the ability of producers, manufacturers and retailers to recover from disruption are complementary, not substitutes. 

The implication for Christmas planning is caution: a rise in spending on selected essentials does not, by itself, signal a stronger festive trading outlook. 

Are current rules missing many ultra-processed foods? 

UK food regulation may be identifying only around half of processed and ultra-processed foods as unhealthy. New research published in BMJ Medicine found the current FSA Nutrient Profiling Model classified around 58% of ultra-processed foods as unhealthy.  

Alternative models based more closely on UK dietary guidance captured over 90%. The findings highlight how different definitions of “less healthy” food could significantly change the number of products affected by regulation.  

UK–EU food trade: lower friction, but preparation is essential 

A proposed UK–EU sanitary and phytosanitary (SPS) agreement could reduce checks, certification costs and delays for food businesses, including on movements from Great Britain to Northern Ireland. The summit in Brussels on 20 November 2026, which Prime Minister Andy Burnham is expected to attend, is an opportunity to advance the agreement, not the point at which businesses should assume new trading arrangements begin. 

The summit is expected to cover wider bilateral cooperation, including defence, energy, climate, migration and law enforcement. For food and drink businesses, the practical priority is the scope and implementation of the proposed SPS agreement. 

Reports of a 200-page draft agreement suggest progress, but a draft is not an agreement in force. Businesses should continue to follow current requirements until official changes take effect. 

IGD opinion

Lower border friction would be welcome, particularly for perishable goods. However, Defra guidance makes clear that changes could affect businesses across the agrifood sector, including those that do not trade directly with the EU. Reviewing product standards, labelling and sourcing exposure now is more useful than waiting for the summit outcome. 

Implementation timing remains uncertain. Defra’s published intention is mid-2027, subject to negotiations, while some recent media reporting suggests 2028. Businesses should use official updates rather than treat either date as a firm operational deadline. 

The regulatory trade-off is dynamic alignment: keeping relevant UK rules in step with EU rules in the areas covered by the agreement, subject to negotiated exceptions. This is not EU control of all UK regulation. The business question is how reduced trade friction balances against compliance changes and any effects on sourcing from outside the EU. See Defra’s preparation guidance and reporting on the possible implementation delay. 

COP31: climate adaptation cannot wait 

 As COP31 gets under way in Turkey, the message for food and drink businesses is clear: cutting emissions must go hand in hand with preparing for climate shocks. 

The United Nations Environment Programme (UNEP) warns that warming above 1.5°C is unavoidable. Its lowest-overshoot scenario limits peak warming to 1.7–1.8°C around mid-century, with about a 50% chance of returning to or below 1.5°C by 2100. 

That pathway requires global greenhouse gas emissions to fall 18% by 2030, 45% by 2035 and 69% by 2040 from 2025 levels, alongside increasing CO₂ removal. It is a scenario, not a forecast. 

IGD opinion 

A projected slight fall in oil emissions is welcome, but not proof of a lasting transition. The Global Carbon Budget projects only a slight reduction in oil emissions in 2026, partly reflecting the Iran conflict’s energy shock, while total CO₂ emissions, including land-use change, are projected to rise. 

For food and drink businesses, the priority is to adapt and strengthen supply-chain resilience while accelerating the pace and increasing the scale of emissions reductions. Planning should increase preparedness for climate shocks, not just a gradual shift to a warmer “normal”. 

Explore IGD’s resilience resources for materials on climate adaptation and mitigation. The IGD Food supply chain sustainability framework also supports businesses with supply chain sustainability, including emissions reduction. 

Food resilience needs joined-up energy, trade and investment policy 

A long-term food resilience strategy would put manufacturing capacity, energy costs and investment at the centre of food security policy. That is the central proposal in Food Resilience In A Changing World, produced by London Economics and commissioned by Associated British Foods (ABF), published on 10 November 2026 and launched at a parliamentary event. 

The report calls for a National Strategy for Food Resilience to 2050, backed by coordinated policies on energy, trade, science and investment. Its proposals include tackling industrial energy costs, supporting innovation and automation, and assessing how tax, planning, skills and regulation affect domestic production. These are recommendations, not announced government policy. See ABF’s publication announcement. 

IGD opinion 

The key issue is whether policy supports businesses to invest in resilience while keeping food affordable. A strategy will be more useful if it translates into clear priorities, measurable outcomes and coordinated delivery, rather than adding another layer of ambition without implementation. 

Public-service reform matters for policy delivery 

 Public-service productivity remains a constraint on what government can deliver within tight budgets. In her LSE lecture on 10 November, Cabinet Secretary Dame Antonia Romeo set out the case for a more productive, AI-enabled Civil Service. For food businesses, what matters is the delivery of policy and services, rather than the internal organisation of Whitehall. 

IGD opinion 

ONS provisional estimates put total public-service productivity in 2025 at 2.9% below its 2019 level. These figures provide broader context, rather than a direct measure of Whitehall efficiency or the delivery of policy and services affecting food businesses. The statistics are in development and subject to revision. 

The food-sector test is whether reform improves the timeliness and consistency of regulation and policy delivery, including through Defra. The speech is a useful signal of intent, but it is not yet evidence of improved outcomes for food businesses.