Consultation launches defining the future of HFSS policy

On 25 March 2026, the UK government launched a public consultation on applying the new Nutrient Profiling Model (NPM)  to existing advertising and promotions restrictions in England.

Running for 12 weeks, this marks a pivotal moment for future food and drink policy.

The consultation will close at 11.59pm BST on 17 June 2026.

This consultation explores updating the secondary legislation underpinning:

• Restricting location promotions of HFSS products (in force since 1 October 2022)

• Restricting volume price promotions of HFSS products (in force since 1 October 2025)

• Further advertising restrictions (in force since 5 January 2026).

A future consultation on healthier food targets and reporting is expected to follow.

New model and timings proposed

The consultation proposes tightening the nutrient profiling model that sits behind existing HFSS legislation, with the aim of strengthening action on childhood obesity.

The NPM determines how “less healthy” food and drink are defined across regulation. Current restrictions are based on the 2004/05 model, which no longer reflects modern dietary guidance, particularly on free sugars and fibre.

The 2018 update addresses this gap and applying it to existing restrictions would bring a wider range of products into scope, particularly those high in free sugars.

To understand the practical challenges associated with the consistent calculation of free sugars and potential solutions required to calculate 2018 NPM scores, IGD convened a Free Sugars Expert Roundtable.

An implementation period of 12 months for industry has been proposed.

What the impact assessment tells us

The consultation was published alongside a 106- page consultation-stage impact assessment, providing the clearest indication yet of the scale of change under consideration.

 Three policy options are assessed: 

• Do nothing

• Apply NPM 2018 to existing advertising and promotions restrictions (DHSC’s preferred option and focus of the assessment).

• Apply NPM 2018 alongside amendments to the product categories in scope. (‘Sweet Spreads’ and ‘Savoury Pastries’ would be the only additions).

If the estimated calorie reductions are realised, the policy could:

• Reduce childhood obesity by over 110,000 cases

• Reduce adult obesity by almost 520,000 cases

According to this assessment, over a 25-year period, applying NPM 2018 to advertising and promotions restrictions is estimated to deliver £36.93 billion in total health and economic benefits, including:

• £1.26 billion in NHS savings

• £1.13 billion in social care savings

• £26.9 billion in health benefits to the population

• £7.62 billion in wider economic output

Importantly, these benefits are expected to be additional to those delivered by existing HFSS regulations.

At present, a formal post-implementation review of current regulations has not yet been undertaken. This means independent evidence remains limited. The DIO Food research, a collaboration between the University of Leeds, IGD and four major retailers, provides some of the only insights using real-world retail data at scale.

This analysis identified a 0.63 percentage point reduction in in-store sales of in-scope ‘less healthy’ products by weight. This is notably lower than the 3.5 percentage point reduction estimated in the government’s 2020 impact assessment, highlighting the importance of continued evaluation, and evidence based impact assessments.

Commercial implications for industry

The impact assessment highlights several immediate and longer-term implications for businesses.

Applying NPM 2018 is expected to:

• Increase the number of products classified as HFSS, particularly in categories high in free sugars

• Drive portfolio shifts and reformulation activity

• Change advertising spend and promotional strategies

• Introduce transition and ongoing costs, including product assessment, IT system updates and store planning

Previous modelling indicates fewer products will pass NPM 2018 overall, with a particularly significant impact on drinks and other categories explored here.

This is not just a regulatory update, it represents a broader commercial reset in how products are developed, positioned and sold.

Businesses can respond

With significant investment already made to comply with current HFSS rules, the pace and design of transition will be critical. It’s important that any future action is therefore coordinated and based on evidence from industry and government.

The consultation places a strong emphasis on evidence-based responses. Most questions have a 300-word limit and request specific data and examples.

Key areas include:

• Applying the new NPM to existing restrictions

• Understanding the impact on industry

  • Main challenges and operational issues

• Timescale for applying NPM

  • Including timelines for applying future updates. This could suggest NPM 2018 is not an end goal, laying ground for a NPM that is continuously updated to reflect dietary guidance.

• Enforcement considerations

• Transition and ongoing costs

  • Including advertising impacts

• Impacts on groups with protected characteristics

Businesses can also upload supporting evidence (up to three files).

If the NPM is reviewed and updated again in the future to reflect new dietary recommendations, what would be a proportionate timeframe for applying any future updates which supports alignment with the investment cycles of industry?

The direction of travel is clear

Taken together, the consultation and impact assessment reinforce a clear policy trajectory:

• Stronger alignment with nutrition science

• More stringent, potentially evolving, definitions of “less healthy”

• Greater use of regulation to shape purchasing environments

As part of the NHS 10-year plan, this forms part of a broader shift towards system-level interventions to improve population health.

IGD perspective

For industry, this is a critical window to engage & provide evidence.

The consultation, and the impact assessment underpinning it, will shape the next phase of HFSS regulation, with implications for product portfolios, commercial strategy and long-term investment decisions.

At IGD, we will continue to consider the consultation and impact assessment in detail, and work towards solutions for industry calculating free sugars consistently at scale.  

We encourage businesses both in England where this is being actively considered, and Devolved Nations where this may later impact, to respond to this consultation, helping to inform the final policy design, impact assessment and timelines.

Ultimately, this is not just a technical consultation. It is a defining moment for how health is operationalised in future across the UK food system.