The UK food and beverage industry experienced its biggest shake-up in years when the government started introducing promotional restrictions on products high in saturated fat, salt and sugar (HFSS) - and the net will tighten when further HFSS rules come into force in October 2025.
Following our introduction to what HFSS is and how does it impact food & beverage brands, let's dive deeper into which product categories fall under HFSS restrictions.
HFSS targets “junk food” products
The purpose of the HFSS campaign is to encourage consumers to make healthier choices. Unsurprisingly, this means targeting many convenience foods that consumers turn to for a quick meal or celebratory treat.
Many popular comfort foods fall under HFSS restrictions, including:
- Pizza – chilled and frozen, all toppings and sizes (except plain pizza bases)
- 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 are subject to HFSS restrictions.
Chocolate and confectionary products also affected by HFSS
Another category hit hard by HFSS is chocolate and confectionery.
Among the items 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.
Snacks suffer under HFSS legislation
Snacks are another heavy-hit category as a result of HFSS legislation. Pre-packaged savoury snacks made from grains, pulses, potatoes or other vegetables – like tortilla chips, corn puffs and seaweed-based snacks – must all be given an HFSS score. Pork rind-based products and fried or seasoned chickpeas fall under HFSS rules too.
Other bagged savoury snacks also come under scrutiny too, including:
- Bombay mix
- Crackers
- Crisps
- Papadums
- Pitta chips
- Popcorn
- Pretzels
- Prawn crackers
- Rice cakes
Restrictions 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. Desserts such as cheesecake, gateaux and rice pudding are HFSS products too.
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.
Drinks are included in HFSS restrictions
It’s not just food brands affected by HFSS. Beverages also come under scrutiny.
Although many soft drinks reformulated when 2018’s industry levy on sugar came into force, 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.
Drinks sold as powders, pods and syrups are also subject to the HFSS legislation. Products affected in this category include powdered milkshakes, hot chocolate and malt drinks.
“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. 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
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
- 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-pre-packaged 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”.
Do your products fall under HFSS rules?
While HFSS restrictions cover a broad range of food and drink categories, they ONLY impact products deemed to be high in saturated fat, salt or sugar. Whether a product falls under HFSS rules 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. 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 you calculate your HFSS score and develop a strategy for reformulating products to avoid HFSS restrictions. Get in touch to find out more.
This blog post was written in April 2022 and updated in September 2024. Facts were correct at the time of writing.
