The UK Government’s January Impact Statement on the 10 Year Health Plan for England has pushed HFSS back to the top of the commercial agenda. It signals policy changes that will directly impact retailers and suppliers, and implementation will happen quickly.

A major shift: the 2018 Nutrient Profiling Model becomes the new HFSS baseline

The Government has confirmed its intention to replace the 2004/05 Nutrient Profiling Model with the more stringent 2018 update. On 27 January, it published a finalised version and supporting documents. Read more details.

Responding to this will be a complex task for the industry, involving significant time and resources.

More products will be classified as “less healthy”  

Key changes to the 2018 NPM include tougher sugar and salt thresholds, a move from total sugars to free sugars, increased credit to fibre and seeds being included in the fruit, vegetables, nuts and seeds component.

There is a significantly greater impact on drinks than on foods. Post-consultation modelling shows a six percentage point reduction in foods scoring as non-HFSS, a 21 percentage point reduction for drinks, and an overall reduction of eight percentage points across foods and drinks.

Shift in focus to free sugars

A significant practical challenge is the replacement of total sugars with free sugars. This aligns with current dietary guidance and reinforces a long-signalled shift in policy direction. However, its new and central role within NPM scoring will require agreed calculation methods and data governance to enable companies to move forward with their preparations.

Changing the measurements that underpin HFSS policies has come under criticism from some parts of the industry. Businesses highlight the investment and timelines required to reformulate. There’s also a risk that companies may feel discouraged from making products healthier if those changes wouldn’t help achieve better NPM scoring. Where healthier innovations have already been launched to be non-HFSS based on the 2004 model, there may be a risk of reclassifications that put them at risk of delisting.

The difficulty of enforcement, one of the challenges around implementation of HFSS legislation in store in October 2022, will also not be made any easier, as free sugars, fibre and FVNS content aren’t included as mandatory on-pack nutrition labelling.

Five ways to start planning for change

1. Revisit your NPM scores

If the 2018 NPM is put into legislation, it will significantly impact what products could be promoted in stores. Sit down with your nutritionists or technical teams to understand how your portfolio is likely to be impacted ahead of the public consultation.

2. Re-assess reformulation and NPD pipelines

With changes coming down the line quickly, are there projects that require pausing until more concrete details emerge? Consider what “future-proofing” innovation and reformulation really looks like under the more restrictive model?

3. Scenario plan for shifting shelf space

Promotional, front of store, and till adjacent space will once again be re-assessed, providing new opportunities and challenges, depending on which categories and products will be impacted.

4. Prepare for further changes in the long term

With a greater focus on defining mandatory reporting for healthier sales expected in the short term, businesses will need to continue to prepare and be able to adapt to an increasingly complex policy landscape.

5. Keep on top of the latest announcements

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