The Nutrient Profiling Model explained: Stay ahead of HFSS changes

If you've recently heard about the “Nutrient Profiling Model” (NPM) and are wondering what it is and why it matters to your business, you’re not alone. The NPM might not have been on your radar much before, but it plays a major role in determining which products are classified as high in fat, sugar and salt (HFSS) across the UK, and therefore which product face restrictions on advertising, placement, and promotions.

In July 2025, the government reinforced its commitment to modernising the NPM model through its ‘Fit for the Future: 10-year Health plan for England.’ The plan highlights that the 2004 model no longer aligns with current health priorities and estimates that updating it could help reduce adult obesity by nearly 170,000 cases. This means that many products currently compliant with UK HFSS regulations may become non-compliant under an updated model. The biggest impact would likely be in the Drinks Category (fizzy drinks and fruit juices) but many other categories could also be affected. Keep reading for more information on which categories might be affected and what the key changes are for your business.

NPM matters to your business – it’s getting tougher

The Nutrient Profiling Model (NPM) is a scoring system used to assess the nutritional content of food and drink products.

It was first developed by the Food Standards Agency in 2004/5 to help Ofcom (the UK’s communications regulator) restrict TV advertising of less healthy food and drinks to children. Since 2007, it has played a key role in shaping advertising policy.

Today, the NPM is used far more widely than it once was. Its influence has grown, making it relevant to a much wider range of business functions - including commercial, regulatory, marketing, digital, innovation, and supply chain teams. It’s no longer just the domain of nutrition specialists.

Which regulations and guidance does this apply to?

The NPM now underpins:

• TV and online advertising restrictions for HFSS products (since January 2026).

• Retail promotions and placement rules (e.g. multi-buys, aisle ends and checkouts).

• Transport for London’s advertising policies

• It also influences wider discussions around school food standards and government buying guidelines.

What’s driving the push to modernise the NPM?

The current Nutrient Profiling Model (2004 NPM) is over two decades old. Since its introduction, UK dietary guidance has evolved significantly, particularly around sugar reduction and the importance of dietary fibre. While the exact approach to modernising the 2004 NPM hasn’t been confirmed, discussions with government stakeholders suggest the 2018 NPM is the likely successor.

How the 2018 NPM was developed

In response to evolving dietary guidance, Public Health England developed a proposed update in 2018 to nutritional profiling to better reflect modern nutrition science, known as the 2018 NPM. This development involved significant input from leading academics and policymakers, including Alison Tedstone, Russell Viner, Mike Rayner, and Judy Buttriss. The aim was to create a model that aligns more closely with current dietary guidance.

A key driver for this update was the Scientific Advisory Committee on Nutrition (SACN). SACN is an independent committee of experts that advises the government on nutrition and health matters. Their 2015 report, "Carbohydrates and Health," for example, recommended halving the intake of free sugars and increasing fibre intake. The 2018 Nutrtient Profiling Model was designed to incorporate such updated scientific advice. You can find more information about SACN on the government website.

The 2018 NPM was consulted on and received pushback from industry based on feasibility.

How the 2004 NPM works

The 2004 model scores products per 100g:

• ‘A’ points are given for nutrients to limit (calories, saturated fat, total sugars, salt)

• ‘C’ points are awarded for beneficial nutrients (fibre, protein, fruit, vegetables, nuts)

• The final score is calculated by subtracting C points from A points.

• If a product scores 4 or more points (for food) or 1 or more point (for drinks), it is classified as HFSS and may face restrictions.

The model encourages holistic reformulation by allowing less healthy nutrients to be offset by healthier components. For example, increasing the protein, fibre or fruit content of a product can help improve its overall score.

Key differences between the 2004 and 2018 models?

The updated 2018 model uses the same points-based structure but makes several important changes designed to align with current UK dietary guidance. The model can still be used to classify all foods and non-alcoholic drinks and still considers all products by 100g. This has been a criticism of the 2004 NPM as foods typically consumed in small amounts that are dense in energy or salt, fair badly (e.g. peanut butter, cheese, mayonnaise, yeast extract).

Table 1: Key differences between 2004 and 2018 UK Nutrient Profiling Models

What challenges does this present?

If the 2018 model is adopted in England, this could have wide-ranging implications for businesses, particularly concerning:

• Product reclassification: The stricter criteria mean more products could be reclassified as HFSS. This especially impacts categories high in free sugars or fibre. Beverages are expected to be the most affected category, with a study across 45,000 retail products indicating a 75% drop in products meeting the criteria under the 2018 NPM. Breakfast cereals (11% fewer products passing), yoghurts (5% reduction), and frozen foods (6% reduction) would also see moderate impacts. Interestingly, the model could allow around 3% more cake products to qualify, potentially making them eligible for promotion. See Table 2 to understand category impacts.

• The ‘free sugars’ challenge: One of the biggest practical issues with the 2018 Nutrient Profile Model is the switch from total sugars to free sugars. While this better reflects current dietary advice, there is no standardised scientific methodology to calculate free sugar, and it is often based on estimates and subjective interpretations of ingredient lists. As free sugars don’t typically appear on nutrition labels, many businesses don’t currently capture this data, presenting a significant technical challenge.

• Reformulation incentives: The 2004 NPM is a key focus for reformulation by the food industry, with salt, NPM score, and sugar ranked as the top three reformulation priorities in IGD research. However, products previously reformulated to pass the 2004 model may now fail under the stricter 2018 criteria. This raises concerns about "moving the goalposts" and could disincentivise continued investment in reformulation.

• Innovation: Innovation is likely to accelerate, particularly in response to the updated NPM criteria. We may see new product development focused on boosting fibre content to improve scores. Beverages, as one of the most affected categories, could see a wave of reformulation and innovation aimed at meeting the stricter thresholds.

What businesses should do now

The 2004 model remains the legal reference used in England to define HFSS products. However, with the 2018 model under active consideration, it’s a strategic time for food and drink businesses to:

• Familiarise yourself with how the new model works.

• Review your product portfolio to understand which items might be reclassified as HFSS.

• Work with supply chains to ensure data on fibre, FVN (fruit, veg, nuts), and crucially, free sugars, is available.

• Engage with innovation and technical teams or external consultants to assess reformulation options, especially where free sugars may be present.

• Keep up to date with government announcements on HFSS policy, mandatory reporting, and any formal decisions on adopting the new model.

Summary: Key takeaways for food and drink businesses

The Nutrient Profiling Model is a behind-the-scenes tool with major retailer and manufacturer consequences. The potential move from the 2004 model to the proposed 2018 version reflects the UK’s shift toward stricter, evidence-based dietary standards. A modernised model has the potential to support healthier food environments, but it also brings challenges - particularly around measuring free sugars and adapting to stricter thresholds.

For the food and drink industry, the main takeaway is this: if the 2018 model is adopted, more products could fall under HFSS rules, affecting advertising, promotions, and shelf placement. Understanding the model, and planning for its likely arrival, is essential to staying ahead of regulation and supporting healthier food choices.

Table 2: Percentage of products passing 2004 and 2018 UK Nutrient Profiling Models

Adapted from: https://www.researchgate.net/publication/344689584_Restricting_promotions_of_'less_healthy'_foods_and_beverages_by_price_and_location_A_big_data_application_of_UK_Nutrient_Profiling_Models_to_a_retail_product_dataset

References

1. NHS, Fit for the Future: The 10 Year Health Plan for England, 2005.

2. FSA, The Nutrient Profiling Model, 2004.

3. SACN, Carbohydrates and Health Report, 2015.

4. Public Health England, Annex C: Basis of the nutrient/food component and scoring for the UK NPM 2004/5 and the draft 2018 NPM, 2018.

5. Jenneson, Victoria & Greenwood, Darren & Clarke, GP & Hancock, Neil & Cade, Janet & Morris, Michelle. (2020). Restricting promotions of ‘less healthy’ foods and beverages by price and location: A big data application of UK Nutrient Profiling Models to a retail product dataset. Nutrition Bulletin. 45. 10.1111/nbu.12468.

6. Gov.UK, NPM consultation responses K-P, 2018.

7. IGD, Reformulation by the food industry in the context of HFSS, 2023.