New UK food rules: time to have your say on HFSS
09 June 2026The government's proposed update to the nutrient profiling model could reclassify more products as HFSS. Your response to the consultation matters.
The UK government is consulting on applying an updated nutrient profiling model (NPM 2018) to existing HFSS advertising and placement legislation in England. The changes, announced as part of the government's 10-year health plan, would mean more products are classified as high in fat, salt and sugar (HFSS), with significant implications for how businesses can promote and place those products.
The consultation closes at 11.59pm on Wednesday 17 June 2026.
IGD's health team hosted this webinar to raise awareness of the upcoming deadline and explain what the changes could mean in practice.
Webinar summary
0:00 Welcome and introductions. Hannah Daley, Head of Health at IGD, opens the session and explains it was put together at the request of retailers, after many suppliers indicated they were unaware the consultation was underway. The webinar also features Hannah Skeggs and Dan Clarke, who are AfN Registered Nutritionists with industry experience.
0:14 Why this matters now. The UK government's 10-year health plan includes an ambition to raise the healthiest generation of children ever. One component is updating the NPM, the scoring system that underpins all current HFSS legislation. The government believes that modernising the model could reduce adult obesity cases by 170,000.
4:23 What is the nutrient profiling model? An explainer of the NPM is provided: a points-based scoring system used to assess the nutritional composition of foods and drinks per 100g. It weighs nutrients to limit such as sugar, salt and saturated fat; against those to encourage, including fruit, vegetables, nuts, fibre and protein. The resulting score determines whether a product is classified as HFSS, which in turn acts as a gateway to regulation around placement, promotions and advertising.
5:45 A brief history of HFSS legislation. The legislative timeline was detailed from NPM 2004 and the first children's TV advertising restrictions in 2007, through to the most recent advertising watershed introduced in January 2026. It was assumed by many businesses that the suite of HFSS regulations were complete at this stage. However, the current consultation was launched on 25th March 2026.
10:15 What's changing under NPM 2018? The key differences between the current and proposed models were outlined. The most significant change is the shift from total sugars to free sugars, with a much stricter scoring threshold, dropping from 21% of energy from total sugars to 5% from free sugars. Other updates include the addition of seeds alongside fruit, vegetables and nuts; up to twice as many points available for fibre; and a switch from sodium to salt for easier interpretation and enforcement.
13:09 The free sugars challenge. It was explained why free sugars are particularly difficult to calculate. Unlike salt or fibre, free sugars cannot be measured in a lab, do not appear on nutrition labels and must be estimated using recipe information and ingredient specifications.
Most businesses have no free sugar values on record, there is no central database to draw from, and calculations become increasingly complex across multi-ingredient products and extended supply chains. Inconsistent interpretation between businesses could also result in the same product being classified differently by different retailers, something IGD's free sugars expert roundtable identified as a concern.
17:13 Portfolio impact: which categories are most affected? The reclassification across the 13 product categories in scope were summarised.
Beverages face the greatest impact, with analysis suggesting up to 75% fewer products could pass under NPM 2018, largely due to the free sugars threshold. Breakfast cereals are expected to see around 11% fewer products qualify. Yogurts, dairy and eggs could see approximately 5% fewer products pass. Interestingly, the model may allow 3% more cake products to qualify, due to additional fibre points.
DHSC advise applying the NPM 2018 will bring products that are high in free sugars into scope of the restrictions, such as desserts, yoghurts, breakfast cereals, cereal bars and juice-based drinks.
IGD advises businesses to conduct their own NPM 2018 analysis, as category-level figures may mask a much greater impact at lower category and product level.
20:24 Business costs and the impact assessment. The government's 106-page impact assessment was reviewed, which estimates cumulative transition costs of £16 million for UK retailers and around £1 million for manufacturers. Retailers are projected to face an average net profit loss of £57 million per year, with manufacturers estimated at £12 million per year.
However, the IGD team highlights that these figures are likely to be underestimates. For example, the assessment assumes just one manager needs to understand the changes, spending around 2.2 hours on familiarisation, whereas in practice one retailer estimated that more than 200 colleagues were involved in implementing the current HFSS regulations. The consultation specifically asks whether cost estimates are accurate, and IGD encourages businesses with real-world evidence to submit it.
26:37 Reformulation and innovation implications. Products previously adjusted to comply with NPM 2004 may now fall foul of the stricter 2018 criteria. This raises concerns about moving the goalposts and could discourage further reformulation investment. Some product categories may be unable to achieve non-HFSS status under the new model regardless of reformulation effort.
On the positive side, the changes are likely to accelerate innovation and lead to healthier products being formulated.
28:28 How to respond to the consultation. The structure of the consultation was outlined, which covers all three areas of current HFSS legislation: location, promotions and advertising.
Key questions include whether the changes will positively impact public health, whether a 12-month implementation period is sufficient, and what the main challenges for industry are.
Most answers are limited to 300 words, and businesses are encouraged to submit evidence alongside their responses.
The consultation closes at 11:59pm on Wednesday 17 June 2026.
29:58 Looking ahead: the legislative timeline. A draft timeline of upcoming legislation was presented. If the government confirms the NPM updates in September 2026, updated HFSS legislation could come into effect as early as September 2027.
On mandatory healthier sales reporting, a consultation is expected before the summer parliamentary recess, with reporting potentially beginning from April 2028. Both developments have significant implications for business planning in the near term.
32:58 Inside the Industry: How it really works learning opportunity. IGD is launching a free course from the 15th June to learn more about how the industry works from farm to fork.
34:07 Q&A. The team took questions from attendees covering: how free sugars compliance will be regulated and enforced (likely to sit with retailers initially, with voluntary enforcement on manufacturers); whether the government will release an official free sugars calculator (currently not known, though industry is developing private tools and calling for agreed methodologies); whether existing display exemptions for smaller retailers apply to the new rules (yes, no changes to category scope or exemptions are proposed); and when mandatory healthy sales reporting will arrive and whether NPM 2018 will underpin it (a consultation is expected before summer recess, but which version of the NPM will be used remains unclear).
Next steps
The full government consultation, including how to respond to the consultation can be found here.
IGD encourages consultation submissions to provide government as much detail as possible to make better informed decisions going forward.
Further government resources
Restricting advertising of less healthy food or drink on TV and online: products in scope
For further information or to submit questions, contact the IGD Health team at [email protected]