The introduction of HFSS legislation has left many UK food and beverage brands asking the same question: should we reformulate our products to avoid promotional restrictions?

Some brands have chosen to stick with their current recipe and take the hit. Others have chosen to pursue healthier product formulations - but reducing the salt, fat and sugar content of foods is easier said than done. How can you update products without compromising on flavour, texture, perishability and cost?

4 questions to ask before you reformulate your products

Any food or drink that score highly on the government’s Nutrient Profiling Model (NPM) faces promotional restrictions under HFSS rules. However, reformulating that product to fall under the HFSS threshold can be a complex process.

If you're considering reformulating your products due to HFSS restrictions, there are several questions you need to ask: 

• How will changing the recipe affect the taste and/or structure of a product?

While all HFSS changes involve recipe amendments, certain categories – like baked goods and ice cream – face more significant challenges with reformulation. This is because sugar and/or fat plays an integral role in the structure and consistency of products.

Flavour matters, too. Only 20% of international consumers say they prefer the taste of low or no-sugar products, while a Public Health Nutrition study found that products labelled as reduced or low salt were perceived as less tasty – and, in some cases, encouraged people to add more salt.

• How will recipe changes impact product shelf life?

Reducing the salt and saturated fat content of foods doesn’t just affect their taste and consistency; it can impact their shelf life too. Your brand may be able to offset product perishability with changes to processing and packaging, but this can increase production costs and potentially impact your sustainability credentials.

• Are fat, salt and sugar alternatives any healthier?

The entire HFSS programme is designed to help people make healthier choices, and for many brands, this is an opportunity to make new product claims. However, any “healthy” messaging needs to stand up under scrutiny – and some alternative ingredients aren’t always better for people.

For example, a San Antonio Heart Study found that people who drink large quantities of diet soft drinks are more likely to become overweight or obese than those who don’t drink sugar-free soda. And a separate study published in the Journal of Family Medicine and Primary Care found that type 2 diabetics who frequently consume artificial sweeteners have higher insulin resistance levels than those who don’t.

• How will ingredient changes impact the cost of production?

We’ve already touched on the financial impact of changing packaging and production processes, but recipe reformulations can also affect the product cost per unit. Ideally, you want to choose natural alternatives to salt, sugar and saturated fat to match the HFSS ethos, but the cost of these ingredients are often higher than artificial flavourings and sweeteners.

HFSS is increasing the business case for food and drink brands to invest in innovative new ingredients and processes that give traditionally fatty, sugary and salty foods a facelift. There are already trailblazers in this camp: low sugar, low-calorie ice cream brand Oppo Brothers made $12.9m revenue in 2023.

Does your product need to be HFSS compliant? 

The big question is whether your brand wants to reformulate the entire range to meet HFSS requirements, or should you only change a proportion of your products. Reformulating some but not all products gives consumers more choice over the type of food or drink they want.

Some brands are undeterred by promotional restrictions, instead viewing HFSS as an opportunity to grow market share while ‘sticking to their guns’. For example, Border Biscuits’ Managing Director, Paul Parkins, believes consumers will choose to buy a premium biscuit if they decide to purchase something non-HFSS.

Other brands have opted for a ‘half and half’ approach. For example, Goodfellas has added three new pizza SKUs to its range, all of which are HFSS-compliant, and 50% of its existing range is already non-HFSS. Meanwhile, Walkers has announced that half its crisp products will be non-HFSS by 2025.

What does HFSS mean for long-term product innovation?

Established brands have an advantage, as a loyal customer base will seek your products out – even if they’re not displayed at the checkout or aisle end. Lumina Intelligence research claims just 12% say HFSS will stop them from buying high fat, salt and sugar items. But conceding premium online and in-store promotional positions is a painful compromise.

However, if you're a new food and drink brand with products that fall within the scope of HFSS, supermarket buyers may act as a gatekeeper to new sales opportunities. HFSS may have a defining influence on retailers' buying strategies - is it worth putting time, money and resources into a product that supermarkets can’t promote in high profile positions? Those same buyers may be looking for non-HFSS products to fill their primary promotional spaces.

Will HFSS stimulate or stagnate product development?

Continuous innovation is critical to success in the food and drink industry. The introduction of HFSS legislation has pushed many brands to reformulate their products on a tighter time scale than usual, increasing the pace of product development.

HFSS legislation is also pushing tech companies to explore healthier production techniques. For example, Washington State University scientists have created a microwave assisted thermal sterilization (MATS) technique that enables companies to protect the flavour and texture of processed foods while reducing sodium content.

Only time will tell how HFSS will impact long-term product development. But currently, there’s a lot of high-profile shelf space that needs filling…

Discuss your product innovation strategy with a food indistry expert: book a free discovery call with our Director, Clare Daley.

This blog post was written in May 2022 and updated in September 2024. Facts were correct at the time of writing.