Will your products need reformulating to meet new HFSS guidelines?

Clare Daley
April 10, 2022
5 min read
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Will your products need reformulating to meet new HFSS guidelines?

The food and beverage sector is preparing for its biggest shake-up in years with the roll-out of promotional restrictions on products high in saturated fat, salt and sugar (HFSS) this October.

Following our introduction to what HFSS is and how it will impact food & beverage brands, we’re now diving deeper into the new legislation. Keep reading to learn how HFSS regulations will impact product categories – and which products may require reformulation to improve their nutrient scores.

Is HFSS targeting “junk food” products?

As the purpose of the HFSS campaign is to encourage healthier choices, unsurprisingly, these new rules target many convenience foods that consumers turn to for a quick meal or celebratory treat.

From October 1st 2022, limitations will be placed on the online and in-store promotion of:

  • Pizza – chilled and frozen, all toppings and sizes
  • Potato products – such as chips, croquettes, hash browns, novelty potato products (like smiley faces), waffles and wedges
  • Ready meals – marketed as ready for cooking/reheating with no preparation, but excluding retail meal kits that require some cooking, e.g. make your own fajitas or enchiladas
  • Breaded/battered products – including chicken kievs, chicken nuggets, fishcakes, fish fingers, scampi and vegetarian/vegan equivalents

There are some surprising inclusions on this list, too: for example, filled/stuffed fresh pasta like tortellini and ravioli will be subject to HFSS restrictions.  

Which chocolate and confectionary products are affected by HFSS?  

Another category that will be hit hard by HFSS is chocolate and confectionery. The latest government update states that all products “predominantly found in the confectionery aisle” will fall under HFSS legislation, including free-from products.

Among the items that will be subject to promotional restriction are: dark, milk and white chocolate (in bar and box format), cooking chocolate, chocolate-covered products like fruit, nuts and pretzels, plus bags and tubes of sweets. The legislation also covers jellied fruit sweets, marshmallows, popcorn and chewing gum.

Which snacks feature in HFSS legislation?

Many savoury products will be affected by incoming HFSS legislation, including snacks made from grains, pulses, potatoes or other vegetables – like tortilla chips, corn puffs and seaweed-based snacks – pork rind-based products, and fried or seasoned chickpeas.

Bagged snacks are under scrutiny too. The legislation calls out:

  • Bombay mix
  • Chocolate covered nuts
  • Crackers
  • Crisps
  • Papadums
  • Pitta chips
  • Popcorn
  • Pretzels
  • Prawn crackers
  • Rice cakes

Restrictions will apply to all packet sizes and formats, including multipacks, grab bags and resealable packets.

Sweet snacks don’t escape, either.  All cake and cake mixes are HFSS products, including brownies, flapjacks, doughnuts and frozen cakes. HFSS restrictions also apply to pastry products – like bagels, croissants, crumpets, Danish pastries, hot cross buns, pancakes, pains au chocolat, teacakes, scones and waffles – and desserts such as cheesecake, gateaux and rice pudding.

All sweet biscuits are subject to HFSS legislation, including those marketed as cereal bars or breakfast biscuits. In addition, ice cream, ice lollies, frozen yoghurt and sorbets feature in HFSS guidelines (including vegan and lactose-free ice cream products), along with ice cream cones.

Are drinks included in HFSS restrictions?

It’s not just food brands facing reformulation challenges as a result of HFSS. Beverages are also coming under scrutiny.

Although many soft drink companies are ahead of the game due to 2018’s industry levy, HFSS affects a broader range of products.

For example, HFSS restrictions apply to any prepared drink containing added sugar – including fizzy drinks, milk-based drinks, juices, smoothies and cordials. Plant-based milk alternatives, fermented yoghurt drinks (such as kefir and probiotics), energy drinks and kombucha also feature.

And drinks sold as powders, pods and syrups are also subject to the new legislation. Products affected in this category include powdered milkshakes, hot chocolate and malt drinks.  

Are any “healthy” foods included in HFSS regulations?

It’s not surprising to see products like chocolate, crisps and pizza on the list of foods in HFSS regulations, but some categories may surprise brands and consumers. For example, the new legislation covers:

  • Breakfast cereals – granola, muesli, porridge oats and ready-to-eat cereals
  • Protein bars – if they possess the features of or ingredients found in a confectionery bar
  • Protein powders – if they contain added sugar
  • Yoghurts – including Greek yoghurt, fromage frais, low fat/fat-free yoghurts, drinkable yoghurts and probiotics, if they are sweetened with sugar, sweeteners or fruit ingredients

Are there any surprising omissions from HFSS restrictions?

On the flip side, many products are currently exempt from HFSS restrictions – including some that people may perceive as unhealthy. These include:

  • Alcoholic drinks/alcohol substitute drinks with more than 1.2% ABV
  • Cream
  • Dessert toppings
  • Dried fruit (including fruit chips/crisps)
  • Drinks sweetened with natural fruit/vegetable juice
  • Garlic bread
  • Jams and marmalades
  • Meat jerky
  • Nuts that are raw, flavoured, roasted or coated (excluding chocolate covered nuts)  
  • Plain, unfilled meringue nests
  • Plain pizza bases
  • Party food
  • Potato salad
  • Pre-packed sandwiches
  • Processed meat, e.g. burgers, chorizo, ham and sausages (unless they form part of a product that falls into a regulated category, e.g. a sausage and mash ready meal)
  • Savoury pastry products, e.g. sausage rolls, pasties and quiche
  • Sushi
  • Total diet replacement drinks
  • Unsweetened smoothies and milk-based drinks

Non-prepacked items are also exempt, which means supermarkets could still put pick ‘n’ mix or loose bakery items such as cakes and doughnuts in restricted promotional areas. However, HFSS guidelines state that this “would not be considered best practice”.

How are HFSS calculations made?

It’s important to note that while the new restrictions cover a broad range of food and drink categories, they will ONLY impact products deemed to be high in saturated fat, salt or sugar. And whether a product falls under HFSS guidelines is determined by a scoring system called the nutrient profiling model (NPM).

Products are analysed and awarded points based on their nutrient content per 100g of food or drink. Calculations are made based on the product’s final form – so made to manufacturer instructions in the case of fruit cordials, powdered drinks and cake mixes.

Each product is given an ‘A’ score for total energy, saturated fat, sugar and sodium, and a ‘C’ score for fibre, protein, fruit, vegetable and nut content. Score C is subtracted from score A to provide the product’s final nutrient score.

If a food product scores 4 points or more and a drink scores 1 point or more, it will be ruled high in saturated fat, salt or sugar. And brands may choose to reformulate key products to lower their NPM score – rather than risk declining sales as a result of reduced promotional opportunities.

Here’s more information on how to calculate your NPM score to check the current status of your products.

Hooley Brown can help your brand reformulate products to avoid HFSS restrictions. Our experts will ensure your goods are compliant with UK food law and international market legislation.

Get in touch to prepare your products for HFSS.

This blog post was written in April 2022. Facts were correct at the time of writing.

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