Understanding High Fat, Salt and Sugar (HFSS) UK Government Regulations

High in Fat, Salt and Sugar (HFSS) foods and drinks have been a growing concern in public health worldwide. HFSS foods are often referred to as “junk” or “unhealthy” foods. Their excessive consumption is associated with an increased risk of obesity, heart disease, type 2 diabetes, and certain cancers. These foods are typically high in calories, low in nutrients, and can lead to poor diet quality. HFSS regulations have been implemented to try and combat this worrying trend.

The issue of HFSS consumption has gained increasing attention in recent years, with health experts, governments, and the public becoming more aware of its negative impact on health. For instance, the World Health Organization (WHO) has recognised the threat that HFSS foods pose to public health and as consumption of HFSS foods has increased dramatically over the last few decades, is now considered an important public health challenge.  

The primary purpose of The Food (Promotion and Placement) (England) Regulations 2021 is to:  

a) reduce the availability of products that are high in fat, salt and sugar (HFSS) such as that one can buy through “volume promotions”, typically seen in the form of incentive offers like ‘buy one get one free’. This part of the regulation comes into force in October 2025. 

b) to restrict the placement of HFSS product categories in high footfall areas of an affected store, like checkouts, end-of-aisle units, store entrances, and designated queueing areas. This part of the regulation came into force in October 2022.

You can read the full implementation guidance on ‘Restricting promotions of products high in fat, sugar or salt by location and by volume price’ to find out more about which businesses are affected, what foods are in scope and the enforcement process.  

The increasing concern about the health impact of HFSS consumption has prompted governments and health organisations to take action. Several countries have implemented regulations and policies to limit the promotion, advertising, and sale of HFSS products, particularly to children.  

Around the globe, others such as the US and Europe, are taking similar measures directly targeting HFSS foods with their own legislation. 

• In the United States, the Food and Drug Administration (FDA) regulates food labeling and requires food manufacturers to list the amount of added sugars on the Nutrition Facts panel. The FDA also restricts the use of certain health and nutrient content claims on food packaging that may mislead consumers about the nutritional value of HFSS foods. However, there are no federal regulations on HFSS, although some states and cities have introduced their own policies. For example, Philadelphia has implemented a tax on sugary drinks, and California has introduced warning labels on sugary drinks. Additional guidelines are still under debate and are all aimed at encouraging consumers to lower their intake of red meats, sugar sweetened food and drinks, and refined grains. Furthermore, the Centers for Disease Control and Prevention (CDC) has launched the National Salt Reduction Initiative, which aims to reduce the amount of salt in processed foods. The CDC has also developed the Sodium Reduction in Communities Program, which works with local governments and health organizations to reduce sodium intake in communities.
  
• Chile has introduced a law that requires warning labels on foods and drinks high in added sugars, salt, and saturated fat.
• France has banned the use of cartoon characters and celebrities in promoting HFSS products to children.
• In Australia, the government has developed the Health Star Rating system, which rates the nutritional value of packaged foods and drinks on a scale from 0.5 to 5 stars, with 5 stars representing the healthiest choice. This system helps consumers make informed choices about the foods they buy which has been effective in helping consumers make informed choices about the foods they buy, but it is still a voluntary system, and not all food and drink products carry the rating.
• European Union (EU) and WHO recognised is Nutri-Score, otherwise known as the 5-Colour Nutrition label (5-CNL), which is a five-colour nutrition label and rating system designed to represent the overall nutritional value of food products by using a rating letter from A (healthiest) to E (unhealthiest), with corresponding colours from green to red. First selected by the French Government in 2017, has since been adopted by other EU countries, the EC and World Health Organization (WHO). 
• The WHO have also launched campaigns to raise awareness about the risks of consuming HFSS products and to promote healthier diets. For example, the WHO has recommended the implementation of taxes on sugary drinks and the reduction of salt, sugar, and saturated fat in processed foods as well as recommending a ban on digital marketing for HFSS products, albeit this ban has been pushed out to 2025. 

Consumers find it difficult to cut down on HFSS foods and drinks. Fast food and stretched budgets both point to unhealthy consumption habits. However, shopper sentiment does appear to be changing. There are plenty of healthier alternatives available that are proving popular, and the choice continues to grow. They exist alongside their unhealthy siblings on the shelf. An increasing trend for paying closer attention to food labels which means consumers have started to seek out the products that are lower in sugar, salt and saturated fat be they vegan dairy alternatives, or unprocessed / natural foods. It therefore makes sense to respond to this move through reformulation, and what is becoming increasingly clear is that it’s the food manufacturers which are in control here; they are the one’s able to enact change right from the top down. 

 Let’s summarise the key points: 

• Consumers are choosing whole, unprocessed foods: Whole foods such as fruits, vegetables, whole grains, lean proteins, and low-fat dairy products are naturally low in added sugars, salt, and unhealthy fats. Incorporating these foods into your diet can provide the necessary nutrients and fibre without the negative effects of HFSS. 
• Consumers are seeking out natural sweeteners as an alternative to using table sugar, with honey and maple syrup sales showing year on year growth . However it’s important to remember that these sweeteners contain just as much sugar, and contribute towards total sugar intake, and should be consumed as part of a balanced and healthy diet. 
• Speciality sweeteners such as sugar alcohols like Maltitol or Erythritol are becoming more popular, some of which have negligible calorific value, and often with a very low GI although in some cases can be as controversial as artificial sweeteners that have derived from un-natural processing.    
• Consumers are continuing to choose foods that are ‘low in’ or ‘sugar free, and this means artificial sweeteners like aspartame have an important role to play. However, they are increasingly likely to respond to foods containing natural sweetener alternatives such as Stevia or Oat Syrup. 
• People are cooking more at home. It is easier to control the ingredients and portions of home cooked food. It’s also a great way to experiment with new flavours and ingredients that can help reduce one’s reliance on HFSS products. 

There are also successful examples of reformulated products that have maintained their taste while reducing HFSS content. For instance, Nestle reduced the sugar content in its KitKat chocolate bars by 10% without compromising on taste or texture. They achieved this with a combination of reformulation, and ingredient engineering to hollow out the crystals – Nestle have said that each particle is then able to dissolve more quickly on the tongue, so less sugar is needed to achieve the same taste. Similarly, Coca-Cola reduced the sugar content in its Sprite and Fanta brands by 30% without affecting taste through the use of sweeteners, such as stevia. 

To balance health and taste in their reformulation efforts, food manufacturers should first focus on understanding the sensory profile of their products. This involves analysing the product’s taste, texture, and appearance and identifying the key components that contribute to its sensory experience. Once the key sensory components are identified, manufacturers can experiment with alternative ingredients and flavours to find a suitable replacement for the HFSS ingredients. They need to test and develop alternative ingredients that can maintain the taste, texture, and quality of the product while reducing its HFSS content. This requires significant investment in research and development. Work together with your supply chain partners, ingredients suppliers and formulation experts to work on recipes that deliver against this criteria, and you stand the best chance of staying ahead of a rapidly changing consumer landscape. Consumer testing and feedback are also crucial during the reformulation process. Companies need to understand how consumers perceive and respond to changes in the product’s taste and texture. They can use this feedback to make further adjustments to the reformulated product and ensure that it meets consumer expectations. 

What next?

It is crucial to understand the harmful effects of HFSS on health and take necessary steps to adapt to an evolving consumer landscape. Consequently, HFSS regulations have had a significant impact on the food industry, putting pressure on manufacturers to reduce the HFSS content in their products to support public health. If you’ve not taken time to consider the implications of HFSS upon your own products, then now is the time to respond. 

Reformulation is an obvious strategy, to meet HFSS regulations however it’s not a process to be taken lightly. Reformulation can pose challenges for manufacturers. Changes in taste, texture, and shelf life are often significant and have a huge impact upon how the product is consumed. To overcome these challenges, manufacturers must take a consumer-centric approach and use consumer testing and feedback to ensure the reformulated products are both healthy and enjoyable. Ultimately, the success of reformulation will depend on striking a balance between health and taste, while being mindful of consumer preferences. By embracing reformulation, manufacturers can not only comply with regulations but also meet the growing demand for healthier products, ultimately improving public health. 

Manufacturers must also work with consumers to encourage better habits through the products they sell. Consumers can make small changes in their diet and lifestyle to reduce intake of HFSS by taking actionable steps such as reading food labels carefully, reducing portion sizes, and increasing physical activity.