HFSS is back in focus

What the 10 Year Health Plan Impact Statement signals for food businesses

The Government’s Impact statement on the 10 Year Health Plan for England was published last week (12.01.26), providing further clarity on how broad health policy intends to strengthen action on obesity and diet-related ill health.

While much of the ‘from sickness to prevention’ chapter will feel familiar to food businesses, the document confirms renewed momentum behind five key policy areas:

·        Tightening advertising and promotion legislation

·        Mandatory reporting and healthy food sales targets

·        Strengthening the Healthy Start scheme

·        Introducing new standards for mandatory alcohol labelling

·        Exploring “points-based” financial incentives to encourage healthier choices

This article focuses on the first two areas, where the Department of Health & Social Care (DHSC) has confirmed its intention to run public consultations in the first half of 2026, and where implications for food businesses are likely to be most immediate. (See slide 4 for DHSC roadmap up to Spring 2026).

1. Tightening advertising and promotion standards

A shift to the 2018 Nutrient Profiling Model

The most significant shift for industry is the Government’s intention to replace the current 2004/05 Nutrient Profiling Model (NPM) with the more stringent 2018 NPM as the basis for advertising and promotion policy.

This is not a minor technical update. Applying the 2018 NPM would fundamentally change which products are classified as HFSS, reopening policy areas that many businesses may have considered settled.

Although the draft 2018 NPM was consulted on in 2018, the consultation response has never been published. The Government has now confirmed its intention to:

• Publish the response and the finalised 2018 NPM

• Consult in spring 2026 on how the model should be applied to existing advertising and promotion restrictions

• Move quickly towards implementation following consultation

The Impact Statement suggests this update could increase estimated calorie reduction from existing policies by up to 30%, reducing adult obesity cases by 940,000 and childhood obesity by 170,000.

Why this matters for industry

The 2018 NPM is designed to better reflect current dietary guidance. Compared with the 2004/05 model, key changes include:

• Stricter thresholds, particularly for sugar and salt

• A shift from total sugars to free sugars

• Greater weighting for fibre

• A larger proportion of products classified as HFSS

Our previous article explores analysis suggesting Beverages are expected to be most affected, with more moderate impacts in categories such as breakfast cereals, yoghurts and frozen foods.

Although applying the 2018 NPM would expand the products in scope of existing HFSS advertising and promotion restrictions, rather than introducing entirely new measures for businesses, the implications extend beyond compliance linking to long term health strategies:

• Many data systems, reformulation priorities and portfolios are built around the 2004/05 NPM

• HFSS/Non HFSS status & NPM product scores may change

• Existing commercial, marketing and innovation strategies may need to be reassessed

Data and implementation challenges: free sugars

A key practical issue is the increased reliance on free sugars. There isn’t a standard analytical method to distinguish free sugars from total sugars, and they are not currently captured across most supply chains. This raises questions around:

• Data availability and consistency

• Calculation methodologies

• Governance and assurance processes to support classification decisions

To support progress, IGD is convening an expert roundtable next month to accelerate alignment on a consistent, evidence-based and auditable approach to free sugars calculation.

Key next steps to watch:

• Publication of the final 2018 NPM

• Consultation expected in spring on applying the model to existing legislation

• Further clarity around free sugars calculation

• Possible alignment with mandatory healthy food sales reporting and targets

 2. Mandatory reporting and healthy food sales targets

Alongside changes to HFSS classification, the Government has reaffirmed its intention to move from voluntary to mandatory reporting for large food businesses.

The proposals include:

• Healthy food sales reporting: All large companies in the food sector will be required to introduce mandatory reporting on the healthiness of their food sales.

• Mandatory targets: Large grocery retailers will face mandatory targets to increase the share of healthy food in their total sales.

• Industry support and flexibility: The government intends to design these targets in partnership with the industry to ‘keep implementation costs low’, noting that many large retailers like Tesco and Sainsbury's already have internal targets and reporting systems.

What’s new in the Impact statement?

The Government has signalled that future reporting may:

• Place greater emphasis on local or regional data, rather than national averages

• Explicitly consider health inequalities between communities, avoiding a one-size-fits-all approach

This reflects long-standing concerns, championed by the Chief Medical Officer Sir Chris Whitty, about the limitations of national averages in addressing diet-related health inequalities.

The Impact Statement also references indicative costs, based on similar proposals:

• Around £45 million in one-off transition costs for retailers

• Ongoing bi-annual costs of approximately £3.3 million for periodic product assessments

The Government notes that these figures are subject to change, depending on scheme design, consultation feedback and further policy appraisal.

Key next steps to watch:

• Minutes from ongoing DHSC- Industry engagement

• Public consultation expected in first part of the year

Conclusion: why HFSS remains a live issue

The Impact Statement makes clear that HFSS policy is evolving rather than winding down. The potential adoption of the 2018 Nutrient Profiling Model, combined with mandatory reporting and sales targets, would significantly reshape how food businesses classify products, manage data and demonstrate progress on health.

While key details remain subject to consultation, the direction of travel is increasingly clear: greater scope, stronger accountability and deeper use of data. For industry, early engagement, particularly on technical issues such as free sugars calculation and reporting design, will be critical to shaping workable, proportionate outcomes.

IGD will continue to support members by providing evidence-based interpretation, facilitating technical discussion and creating space for collaboration as these policies develop.