As the clock counts down to 1st October 2022, many food and beverage brands are racing to reformulate their products outside HFSS restrictions. But reducing the salt, fat and sugar content of the UK’s favourite foods is easier said than done.

How can brands update their products without compromising on flavour, texture, perishability and cost? And will the introduction of HFSS stimulate or strangle new product development in the long term? There are many questions the new guidelines are yet to answer.

How will brands reformulate current products to meet HFSS guidelines?

Any foods that score highly on the government’s Nutrient Profiling Model (NPM) will face promotional restrictions from October. However, making products HFSS-compliant can be a complex process.

Read more on which products will be affected by HFSS?

Food and beverage brands reformulating their range for HFSS have several questions to answer in a relatively short space of time, including:

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

While all HFSS changes will involve recipe amendments, certain categories – such as 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 their 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. Brands may be able to offset product perishability with changes to processing and packaging, but this can increase production costs and potentially impact their sustainability credentials.

• Are fat, salt and sugar alternatives any healthier?

The entire HFSS programme has been 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, food and drink brands want to choose natural alternatives to salt, sugar and saturated fat, but the cost of these ingredients pushes some towards cheaper artificial flavourings and sweeteners.

• Should every product be HFSS compliant?

Food and drink brands also need to consider whether they want to reformulate their entire range to meet HFSS requirements or whether they only change a proportion of their products, giving consumers more choice over the type of food they want.

Some brands have already 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?

Beyond immediate reformulation challenges, food and beverage companies need to consider how HFSS guidelines will impact future product development.

Established brands have an advantage, as a loyal customer base will seek their products out – even if they’re not displayed on a homepage or at the aisle end. Indeed, many consumers will continue to choose snacks based on personal preference. Recent Lumina Intelligence research claims just 12% say HFSS will stop them from buying high fat, salt and sugar items.

However, a gatekeeper stands between food brands and open-minded customers: supermarket buyers. HFSS’s impact on retail promotions could have a defining influence on NPD – particularly for challenger brands. Is it worth putting time, money and resources into a product that supermarkets can’t promote in high profile positions?

How will brands approach NPD after HFSS?

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.

At the other end of the scale, 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. And there are already trailblazers in this camp.

Low sugar, low-calorie ice cream brand Oppo Brothers sold 10 million scoops in summer 2021, exceeding both Alpro and Oatly in retail sales value. And Urban Legend – which Hooley Brown named one of our food brands to watch in 2022 – is making waves with its range of steamed doughnuts.

Established brands that don’t reformulate their entire product range will have to concede premium online and in-store marketing positions from October. And this could pave the way for challenger food and beverage brands to secure promotional spots that were previously beyond their reach.  

HFSS legislation is also having a positive impact on the development of salt and sugar alternatives. For example, Washington State University scientists have created a microwave assisted thermal sterilization (MATS) technique that will enable companies to protect the flavour and texture of processed foods while reducing sodium content.

Will HFSS stimulate or stagnate product development?

Continuous innovation is critical to success in the food and drink industry; consumer tastes and preferences are constantly evolving. And the introduction of HFSS legislation is pushing many brands to reformulate their products on a tighter time scale than they may have moved organically.

Only time will tell how HFSS will impact broader product development. But for challenger brands prepared to rethink the ingredients and processes involved in creating traditional treats, there’s a lot of high-profile shelf space that will need filling…

Get your business HFSS ready with Hooley Brown’s product compliance services: book a free briefing call with our Co-Founder to discuss your challenges.

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