HFSS Regulations: What’s Changed and What Comes Next

On 30 September 2026, a quiet deadline passed. Larger retailers in England can no longer sell less healthy food in packs printed with “buy one get one free” or “3 for 2”. If your labels still carry those flashes, they are now a problem on the shelf.

The HFSS regulations have arrived in stages since 2022, and the next stage looks tougher. At Positive ID Labels, we print food and drink labels for producers across the UK, so we see where these rules bite. This guide goes beyond the rules: how to read your score, where small recipe changes matter, and how to stop label stock becoming the expensive part of the next change.

This is general guidance, not legal advice. Always check the official Government Guidance.

What Are the HFSS Regulations?

HFSS stands for high in fat, salt or sugar. In England, the HFSS regulations are formally the Food (Promotion and Placement) (England) Regulations 2021. They cover prepacked food and drink in 13 categories, including sugary soft drinks, crisps, cakes, chocolate, ice cream and pizza. This is in addition to the UK food labelling regulations.

A product only counts as “less healthy” if it also fails the nutrient profiling model (NPM). Foods scoring 4 or more fail. Drinks fail at just 1.

Who Must Follow HFSS Regulations?

The rules apply to businesses with 50 or more employees selling food to the public, in store or online. Stores under 2,000 sq ft escape the location rules but not the promotion rules.

Manufacturers aren’t directly liable, but retailers push that risk back up the supply chain. If your product scores as HFSS, expect buyers to ask how you know.

The Three Stages So Far

Check Your Product’s Score

Enter the figures from your product specification. The calculator uses the current 2004/05 model, and nothing you type is saved or sent. You can also download this handy Excel HFSS calculator file to help you calculate multiple items in your range with ease.

Reading Your Score: Where the Real Opportunities Are

Pass or fail is only half the answer. The useful question is how far you are from the line, and which nutrient gets you over it fastest.

Points Move in Steps, Not Slopes

The model doesn’t reward gradual improvement. Each nutrient scores in bands, and a point only changes when you cross a fixed threshold. Sugar, for example, scores 2 points anywhere between 9.1g and 13.5g per 100g.

So a 10% sugar cut can achieve nothing, while a 3% cut in the right place changes your status. Find the nutrient sitting just above a band edge: that’s your cheapest win.

The Protein Rule Most Producers Miss

There is a hidden cliff at 11 “A” points. Below 11, protein counts in your favour. At 11 or more, protein is ignored unless your fruit, vegetable and nut content is above 80%.

Here’s a worked example for a high-protein cereal per 100g: 1,600kJ energy, 1.2g saturated fat, 9.5g sugar, 0.93g salt, 5g fibre and 9g protein.

• At 0.93g salt, “A” points total 11. Protein doesn’t count, and the product scores 6: HFSS.
• Cut salt to 0.90g, a reduction of about 3%. “A” points drop to 10, protein now counts, and the product scores 0: not HFSS.
• Trimming sugar from 9.5g to 9.2g does nothing. Taking it to 9.0g has the same effect as the salt change.

Try those figures in the calculator. If your “A” points land on 11 or 12, check this first.

Score Your Lab Values, Not Your Label

Nutrition labels show rounded figures. A label reading 0.9g salt could sit either side of a threshold in the lab data. Always score the analysed values, and keep that data on file, because officers ask businesses how they have confirmed a product isn’t HFSS.

Declare Fibre If You Have It

Fibre is voluntary on UK nutrition labels, so many producers leave it off. Yet fibre can take up to 5 points off your score under the current model, and up to 10 under the proposed one.

Printing fibre on pack doesn’t change your score, but it makes it verifiable. Buyers can check it against the label without chasing you for data.

Smarter Rules: The Shift to NPM 2018

The current model dates from 2004/05. The government wants a smarter, evidence-based version reflecting modern dietary advice. It published the final NPM 2018 in January 2026 and consulted on applying it between March and June 2026. Its response is still awaited.

How NPM 2018 Changes the Scoring

• Free sugars: points start once free sugars pass 0.9g per 100g, instead of counting all sugars equally.
• Fibre: high-fibre products can earn up to 10 points off, up from 5.
• Salt: measured in grams, matching your nutrition panel.

Energy and saturated fat thresholds also tighten, and far fewer drinks will pass.

What Smarter HFSS Regulations Mean for You

The government has proposed a 12-month lead-in, so the updated HFSS regulations could apply from around autumn 2027.

The key lesson from the worked example cuts both ways. A product that scrapes through today by a single band could fail under tighter thresholds. When you reformulate, build in headroom rather than stopping at the line.

Free sugars aren’t shown on UK labels, so start collecting supplier or lab data now.

Five Steps to Prepare for HFSS Regulations

1. Score every product and note how close each one sits to a band edge.
2. Prioritise products scoring 4 to 8. They are the realistic reformulation wins.
3. Collect free sugar and AOAC fibre data for the new model (see below).
4. Check how many weeks of label stock you hold for each product (stock ÷ weekly usage).
5. Plan recipe and artwork changes together, so both launch at once.

Your Label Stock Is a Deadline Too

The on-pack promotion deadline showed where the real cost of a rule change sits. It isn’t the reformulation. It’s the labels already printed.

Hold 40 weeks of labels for a product near the line, add artwork approval and a recipe trial, and a 12-month lead-in looks much tighter.

Shorter, more frequent runs keep that exposure small. As one of the UK’s leading digital label printers, our Screen UV inkjet press prints at 600dpi on papers and polypropylene, and with no printing plates, a label update costs little more than a new file. Supply press-ready artwork and we’ll process it free.

Replace Multibuy Flashes With Messages That Still Work

Losing BOGOF doesn’t mean losing on-pack selling space. Price reductions and meal deals remain allowed. Non-price messages, such as recipe ideas, provenance stories or a QR code, aren’t promotions at all.

If you reformulate, you may be able to make a nutrition claim. “Reduced sugar” requires at least 30% less than similar products, and “reduced salt” at least 25%. That’s a stronger shelf message than a multibuy flash ever was.

Planning a recipe or artwork change? Call 01332 864895 and we’ll talk through run lengths and timing.

Frequently Asked Questions

Does the calculator tell me if HFSS rules apply to my product?

It tells you whether the product scores as “less healthy”. Restrictions only apply if it also falls into one of the 13 regulated categories and is sold by an in-scope business.

Why did a tiny change flip my score?

Points change at fixed thresholds, and protein stops counting at 11 “A” points. Crossing either line can move your score by several points at once.

Can I still print “50% off” on HFSS products?

Yes, in England. Simple price reductions aren’t volume promotions. Multibuys and “extra free” offers are banned for in-scope retailers.

Do the HFSS restrictions change what must appear on food labels?

No. They control promotion and placement, not mandatory label content. Declaring fibre voluntarily can still help buyers verify your score.

I employ fewer than 50 people. Should I worry?

Your own shop is exempt. Retailers stocking your products may be in scope, and they will expect you to know your NPM scores.

How quickly can you reprint labels after a recipe change?

Short digital runs need no plates, so updated designs go straight into production. Tell us your deadline, and we’ll give you an honest answer on timing.

Get Ahead of the Next Change

The next round of HFSS changes isn’t confirmed yet, but the direction is clear. Score your range, find the near misses and keep your label stock lean. Call 01332 864895 or complete our enquiry form for a fixed-price quote, with no surprises later.

Disclaimer

All guides are provided in good faith for information purposes only and do not constitute legal advice. For specific compliance questions about specific labelling laws, contact a specialist or contact your local Trading Standards authority. Read our Regulatory Information Disclaimer

Sources

• Department of Health and Social Care: Restricting promotions of products high in fat, sugar or salt by location and by volume price (implementation guidance and update history)
• The Food (Promotion and Placement) (England) Regulations 2021
• Department of Health: Nutrient profiling technical guidance (2004/05 model)
• Department of Health and Social Care: UK nutrient profiling model 2018 review and consultation outcome
• Department of Health and Social Care: Applying the new NPM to advertising and promotions restrictions (consultation)
• Welsh Government: Restricting the promotion of high fat, salt and sugar foods: volume price promotions guidance
• Scottish Government: Food (Promotion and Placement) (Scotland) Regulations 2025: implementation guidance
• Department of Health and Social Care: Less healthy food or drink: advertising and promotions restrictions (advertising restrictions)
• Regulation (EC) No 1924/2006 on nutrition and health claims, Annex (reduced sugar and salt claim thresholds)
• Regulation (EU) No 1169/2011 on food information to consumers, Article 30 (voluntary fibre declaration)