The government’s NPM reforms risk undermining progress

The government is currently consulting on changing the Nutrient Profiling Model (NPM) – the technical measure that decides if a food or drink product is determined to be ‘healthier’ or ‘less healthy’ and so subject to promotion and advertising restrictions. 

In recent years the high fat, sugar, salt (HFSS) regulations have changed supermarket layouts, restricted the types of food on promotion and banned outright certain food products being advertised online or before 9pm on TV. 

Early evidence suggests change is happening. A government report found that the proportion of HFSS sales fell year-on-year between 2021 and 2023. 

We know significant progress has been made by food manufacturers in developing healthier products. Our research has found that FDF members now contribute nearly a fifth less salt (18%), sugar (19%) and calories (17%) than they did five years ago. This builds on decades of progress, showing that when industry is given a clear goal, it will move to meet it. 

So, if regulation seems to be working, will stricter rules bring more benefits? We don’t think so. 

Rewriting the rules 

We believe the proposed changes will at best slow down – and at worst start to reverse – some of the positive changes we are seeing. Investment is already being paused because companies no longer know what they’re aiming for and because the new model is so strict in many categories there will be no ‘healthier’ options.  

For decades, government has encouraged companies to change recipes and introduce new healthier options. This is because, while people don’t often switch from buying biscuits to apples, they might switch to a lower sugar biscuit or a higher fibre oat bar.  

Yet under the revised NPM, many of these easy swaps couldn’t be advertised or promoted to shoppers. If they don’t sell, they’re likely to disappear from shelves, removing healthier options from consumers and undermining businesses’ investment, which runs to hundreds of millions of pounds. 

The proposed NPM is also impractical. It introduces criteria for ‘free sugars’ that cannot be analysed for with any consistency. This is particularly challenging for products containing dairy, fruit or vegetables. For example, how long a tomato is cooked for, or how lumpy a fruit puree is, impacts how much of the sugars would become ‘free’.  

Expecting businesses to manually calculate recipe scores to overcome the technical challenges of free sugar is unrealistic, even before you consider industry is already contending with major packaging reforms, potential realignment to EU food law and a global energy crisis. 

Taking stock 

The government’s impact assessment doesn’t model the availability of healthier products, nor the technical feasibility of producing them. It does not consider the impacts on diets if people no longer have healthier options to choose from.   

Rather than changing course so soon, we want government to build on existing momentum. Last year, we shared the sector’s support for mandatory reporting of healthier food sales in The Grocer. Now, we want government to deliver on its pledge. This would be a world-leading approach, incentivising businesses to keep investing in healthier product development and allowing us to evaluate the impact of existing regulations before chopping and changing. 

Stability matters. Like government, we agree there’s further to go to support healthier diets and tackle obesity. But moving the goalposts now will present a barrier to investment, innovation and reformulation, which are central to achieving the government’s health priorities. We’ve made real progress in shifting the food environment. Now is the time to support that work, not put it in jeopardy. 

Kate Halliwell is chief scientific officer at the Food and Drink Federation