Reformulation: the trials, tribulations… and the UPF debate

As far as health champions go, you don’t get much bigger – or more influential – than the UK’s biggest supermarket. So when Tesco group CEO Ken Murphy called for large food businesses to face mandatory health reporting at the end of May, it was a seismic moment.

A raft of supermarkets and manufacturers currently report on the healthfulness of their sales on a voluntary basis – including Tesco – but using a variety of metrics. “To truly support public health, we need consistent, transparent reporting across the industry,” Murphy argued. “We urge the UK government to take this important step forward to make healthier food sales reporting mandatory.”

If the government takes heed, it’s likely to speed up reformulation efforts – which so far have tended to cluster around particular categories. Soft drinks has been one hub of activity, as has savoury snacks.

However, other categories are trickier to reformulate. There is also the question of what constitutes a healthy product. Reformulation to comply with HFSS rules, for example, ignores the growing concern around ultra-processed foods (UPFs).

So, where does the industry stand on reformulation? What are the key challenges? What impact has the UPF debate had, and how should policy follow?

The 2018 Soft Drinks Industry Levy (SDIL) is touted as the biggest reformulation success story. Between 2015 and 2020, sugar levels in soft drinks fell by 34.3%.

By contrast, the government’s voluntary sugar reduction programme, which targeted a raft of categories including cereals, biscuits and chocolate, has been far less successful. It drove a modest 3.5% reduction between 2016 and 2021, despite a target of 20%.

“This demonstrates that mandatory targets or fiscal measures are absolutely necessary,” says Rozzie Batchelar, senior nutritionist at Jamie Oliver Group.

It’s a similar story on salt. Things started well with a 2006 programme from the Food Standards Agency (FSA), which led to a 20% reduction in the average amount consumed in England. But when the coalition government abandoned the programme in 2011, salt intake rose from 7.58g a day in 2014 to 8.39g a day in 2018 and has “stalled” since, according to a 2023 study published in the Journal of Hypertension.

Nonetheless, development chef and writer Anthony Warner, who has worked on reformulation for Bisto, Homepride and Loyd Grossman, highlights a number of brands that “have been very willing to pursue reformulation strategies, often at great cost to themselves”.

Nomad Foods is a case in point. Brands such as Birds Eye, Aunt Bessie’s and Goodfella’s now generate circa 94% of combined sales from non-HFSS products following reformulation efforts. All of  Goodfella’s pizzas have been non-HFSS since the end of 2023, for example.

That was no mean feat, according to Lauren Woodley, head of nutrition & sensory sciences at Nomad Foods. “We had to make sure each individual element of the pizza was non-HFSS, from the bases to the sauces to the toppings,” she says. “We didn’t want to compromise on taste, so we conducted sensory testing during the development process to ensure our new recipe hit the mark.”

Another big investment came from Pepsico in October. That month, it unveiled a new recipe for its £287.2m Doritos brand that reduced salt and fat by up to 18% and 14% respectively. “To support the move, we invested £13m into our Coventry factory, paving the way for continual range development,” reveals Fernando Kahane, chief marketing officer at PepsiCo.

The company is keen to stress it’s not just about reformulation, though – rather, developing “exciting innovation” with health in mind. Doritos Flamin’ Hot, Walkers Max Flamin’ Hot and the brand’s limited-edition Walkers Flamin’ Hot – all non-HFSS – are a case in point.

It’s a sign of the high level of activity in the crisp sector. Other categories, such as confectionery, are far trickier to reformulate. Yet there are efforts at play. Nestlé UK&I has reduced the sugar content in its confectionery by 10% since 2015, says Tatiana Lillingston-Price, nutritionist at the fmcg giant.

Meanwhile, more than 85% of Nestlé’s cereal sales come from non-HFSS products, including its biggest brands Shredded Wheat, Cheerios and Shreddies – following reformulations for the latter two.

“It’s really encouraging to see market leaders leading the way and reducing the sugar, salt and fat content of their products, especially if it’s their flagship and most popular products rather than lower-selling SKUs,” says Dr Hannah Brinsden, head of policy and advocacy at The Food Foundation.

“There’s a wide variation in salt and sugar content of snacks such as cakes, biscuits and crisps. This demonstrates that further reformulation is possible, as many products fall just below the targets.”

Pain points

It may be possible, but that doesn’t mean it’s simple.  Warner says the key problem with reformulation is that, quite simply, “this is all mind-bendingly complicated”.

Especially when it comes to sugar reduction. “For example, if I’m making a biscuit and take some sugar out, then fat by percentage goes up, so I’ll actually be increasing the number of calories in that product. And I don’t think people quite understand that,” he says.

Salt reduction can be slightly easier. Reducing salt by 10% in one go can be imperceptible in taste terms, depending on the product, says Nomad’s Woodley. “Looking at the ‘available’ salt in the product (i.e. the salt that will actually touch tastebuds) can also be a useful approach, and it’s helped us to achieve maximum taste impact from minimum salt,” she says.

Because ultimately, consumers won’t buy a product that doesn’t taste good. Yoplait bore that in mind when launching reduced-sugar Petits Filous and Frubes in January. “We take a gradual approach to reformulation to ensure we don’t lose any shoppers along the way,” says Antoine Hours, general manager of Yoplait UK. “The recipe reformulation on our brands took months to achieve with a cross-functional team spanning R&D, innovation and marketing.”

In many cases, the core issue lies in what you’re putting into the product to replace what you’re taking out. A sweet taste can be achieved with ingredients other than sugar, but these come with their own issues.

When taking out sugar from biscuits, “you have to think of something lower in calories than sugar to replace it with, and there’s not much apart from fibre”, Warner says. “But then pretty soon you’d need laxative warnings on the pack because you put so much fibre in. Which isn’t ideal in a biscuit.”

In items like lower-sugar ketchup, you can use artificial sweeteners. Still, “a lot of people don’t like artificial sweeteners,” he points out. “There are natural flavour solutions you can use, but the problem is a lot of people will say [they] come within the UPF classification.”

The Food Foundation’s Brinsden believes part of the work involves changing taste preferences, rather than mimicking flavours through additives. “We need to wean ourselves off preferences for such highly sweet and salty flavours,” she says. This lessens the need for sweeteners and other additives as part of reformulation.”

UPF or NPM?

But for Warner, the issue around replacing sugar with sweeteners speaks to a wider problem. “It’s the same with lots of the things for removing fat, like using interesting starch systems or fibre systems. Even though within the nutrient profiling model it is healthier, people will now say it’s not healthy because it’s a UPF.

“There’s a fine balancing act appearing. A lot of reformulation is moving towards cleaner labels, which is an entirely different set of challenges.”

The UPF debate has certainly muddied the waters – especially when it holds so much sway with consumers. In February 2024, a poll for The Grocer suggested a million people a month were avoiding UPFs. Since then, discussion and awareness has, if anything, intensified.

That’s not necessarily making products healthier, argues Warner. For him, the UPF debate “tells us something about trust in the food supply and trust in ingredients”. But he describes the UPF definition – usually determined under the Nova system – as “a very poor classification system to determine the healthfulness of a food”.

“A lot of people who haven’t done the work on fat, salt and sugar are now adopting the UPF thing because they can see a loophole. There are plenty of perfectly healthy things that fall foul of that classification system,” he says.

Warner acknowledges concerns over the Nutrient Profiling Model (NPM), which determines whether a food is classed as HFSS. The model assigns points for unhealthy ‘A’ nutrients such as saturated fat, sugars or sodium,  and points for healthier ‘C’ nutrients like fruit & veg, fibre, or protein. It then subtracts C from A to give a final nutrient profile score (the lower the better).

“It’s not perfect. No system really is. But it’s probably still the best way we have of determining the healthfulness of food,” he argues.

Warner isn’t the only one to voice concerns about a focus on UPFs. In April, a report by ‘nudge’ body Nesta suggested the introduction of targets against UPFs would risk “undermining” the war on obesity, by placing it in unnecessary “competition” with HFSS. It pointed out 64% of UPF calories came from food already classified as HFSS under the NPM.

“The NPM is the dominant metric for assessing the ‘healthiness’ of food in policy. It’s both well established in law and already familiar to retailers, manufacturers and policymakers,” says John Barber, deputy director of the healthy life team at Nesta. “As a result, there are substantial barriers to a UPF-focused shift, which could only be justified if harmful products were being overlooked. Our analysis suggests this is not the case.

“This isn’t to reject concerns surrounding UPF, or a call to inaction,” he stresses. “As research evolves, policymakers should consider refining the NPM to reflect new evidence.”

For now, many big suppliers want to focus on the known quantity that is the NPM. Like Nomad Foods. “We’re led by nutrition science,” says Woodley. “However, we face the challenge of an external narrative that looks to position products as unhealthy, irrespective of their positive nutritional composition. There is also the challenge that, by there being no agreed specific definition of UPF and different opinions on how much health risk specific ingredients pose, nutritional reformulation is being impacted.”

However, Professor Barry Smith of the Centre for the Study of the Senses at the University of London is sceptical of these claims.

“The least healthy products are not going to be reformulated because you’re never going to get them over the threshold, so why bother?”

Anthony Warner

Arguing against the robustness or completeness of the science around UPFs serves industry aims, Smith argues. “This allows them to continue using UPF ingredients, which are cheap, have longer shelf life and replace more expensive, natural food ingredients. The food industry doesn’t want to give them up.”

The main problem is that UPF ingredients often used in reformulation, such as bulking agent maltodextrin, “can stimulate overeating”, he argues.

Smith sees issues with the HFSS system, in that “it speaks to the contents of a food product but doesn’t have anything to say about eating behaviour. If foods have reduced fat, salt and sugar, but are designed (with the help of ultra-processing) to encourage us to continue eating them, we may still consume more fat, salt and sugar than we should.

M&S one-ingredient corn flakes cause ruckus

One of this year’s most high-profile instances of reformulation came in March, when M&S unveiled its clean-label ‘Only… ingredients’ range. The retailer said every product contained six or fewer ingredients.

The most talked-about product was a box of corn flakes made up of just one ingredient: corn. The range was described at the time as “very clever NPD” by Emma Gardner, director of PR agency Aubergine.

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M&S was clearly taking aim at UPF-aware consumers with the language used. “We develop our foods using processes as close to the kitchen as possible and with ingredients you’d typically find on cupboard shelves,” a spokesperson told The Grocer.

“This approach contributes to the high quality customers expect from M&S. Our ‘Only… ingredients’ range has been lovingly created for customers who are looking for products with fewer ingredients.”

However, it was not long before M&S’s bold move was in the critical crosshairs. Many questioned whether it really was a positive for health, given the flakes weren’t – like many rival products – fortified with vitamins and minerals.

When the retailer bolstered the range with three chocolate bars in April, the snipers returned. The main contention was that the Dark Chocolate & Coconut Date Bar was said to have ‘only five ingredients’ on front of pack – despite naming nine in the full ingredients list.

For M&S, the range offers consumers the opportunity to buy products made from common household ingredients. Dark chocolate is one of them, and therefore listed as a single ingredient. So is this an understandable approach, or is M&S pulling the wool over consumers’ eyes?

Development chef Anthony Warner believes M&S is “slightly gaming the system” with its claims. However, he praises the range for showing the power of retailers to push reformulation.

And M&S clearly hasn’t been deterred. This week, it bolstered the range further with the launch of two new loaves.

Future of policy

However it is done, one thing all commentators agree on is the need to reformulate. After all, the UK remains in the grip of an obesity crisis: around two-thirds of adults are estimated to be overweight or obese [Office for Health Improvement and Disparities]. The debate is how government policy should encourage action.

For Nomad, it’s about pressing ahead in the current direction of travel. “We believe the government should continue to base health policy on the NPM and fully support incoming HFSS placement, promotion and advertising restrictions,” says Woodley. “We’ll continue to reformulate to reduce sugar and salt, maximise positive nutrients and ingredients, and ensure responsible and realistic portion sizes.”

Read more: Kid’s snacking - helping balance nutrition and fun

Nestlé similarly talks about portion sizes. Children’s portions will be 110 kcal or less by 2026, says Lillingston-Price, while the company has “strengthened” its responsible marketing of indulgent products.

“Beyond reformulation, we also believe there is a role to guide consumers towards responsible consumption,” she adds.

The Food Foundation’s Brinsden believes government should be forcing companies to act responsibly. The difference in the success of the SDIL versus the voluntary reformulation programme “demonstrates the need for incentives and mandatory initiatives”, she says. “The use of a fiscal incentive, such as a tax on salt and sugar, is a critical step.”

Warner, though, calls for more radical thinking than simply taxing selected products. Almost all of the industry’s work has focused on getting products below the HFSS threshold, he says, meaning reformulation has always ducked just below that line. A similar issue could arise with a sugar or salt tax at a certain level.

“There’s a fundamental flaw with that sort of system, in that it’s still a black-and-white ‘this is healthy, this is not healthy’ system,” he says. “And actually, the least healthy products – which are probably the biggest drivers of issues – are not going to be reformulated because you’re never going to get them over the threshold, so why bother?”

He suggests a ‘sales-weighted average’ system as a better alternative. That would still be based on the government’s NPM, but rather than singling out individual products as ‘good’ or ‘bad’,  the scores would be weighted against sales volume.

“Although this sounds complicated, it’s actually quite simple to calculate from existing data, and it would incentivise retailers and brands to improve the overall mix of products they sell and reward the reformulation of some of the least healthy items, not just those close to the cut-off. I personally think that’s where reformulation can have the most impact,” Warner says.

Retailers “have a lot of the power to drive this” as well as “a lot of the understanding of how to direct people towards these sorts of products”, he adds.

Warner holds up M&S’s work on its clean-label range (see box, p38) as an example of what can be achieved when the will exists. “I don’t agree with it, but… a lot of manufacturers would have said: ‘Oh no, we can’t do that.’ It shows retailers do have the power to push that sort of reformulation.

“I think enough people have done really positive work to prove that significant moves are possible.”

And with a backer like Tesco’s Ken Murphy, significant moves are likely to be in the pipeline.