Reformulating food products to be HFSS compliant


14 May 2024


The introduction of legislation in England restricting the marketing of foods high in fat, sugar and salt (HFSS) has prompted many brands to consider reformulating products to take them out of scope. But this comes with its own set of challenges. Find out why and how RSSL’s technical team successfully reformulated a cereal bar to achieve non-HFSS status.  


Calculating HFSS 


Building an understanding of what is and isn’t possible starts with the UK Department of Health’s Nutrient Profile Model (NPM) which is based on the following simple algorithm:


  • Total energy, saturated fat, sugar and sodium = A points
  • Total protein, fibre and/or fruit, vegetables or nuts = C points
  • A points – C points = Total HFSS score

A food product with a score of 4 or more is classed as HFSS, whereas the threshold for beverages is 1 or more. Of course, not all food products are subject to HFSS legislation but as a general rule, if they are highly calorific and processed – such as ice cream, cakes, breakfast cereals, potato-based snacks or ready-meals – the new marketing rules will apply. 


Reformulation strategy


Should you wish to reformulate, the NPM framework essentially gives you two possible routes to explore. The first is to reduce saturated fat, sugar and/or salt (A points) and the second involves increasing fibre and/or fruit, veg or nuts (C points). But there is an important catch.

Don’t assume you can always bring the HFSS score down simply by bumping up the protein - C point - content. The legislation dictates that if the A score comes to 11 or more, you must bring down the saturated fat, salt and sugar content first.

It’s also important to be aware that every reformulation strategy has its pros and cons. Changing the formulation of an existing product will almost certainly alter the eating experience, so balancing nutritional needs with consumer expectations is vital.

What this looks like in practice very much depends on the product in question. Decisions will need to be made based on complex technical and commercial factors ranging from product performance and functionality to clean label and cost. Let’s take a look at some of the issues.

Reducing A points

Lowering overall fat content, for instance, may cut calories but it’s also likely to compromise taste, texture and processibility. You may also need to add emulsifiers to make the fat that remains go further. Substitution on the other hand, such as switching from a solid fat to sunflower oil may seem a logical move but won’t do anything for calorie content because the total fat content remains the same. Plus, there’s an increased risk of oxidation and eventually rancidity.


Reducing salt is just as complex, with off tastes, consumer acceptance and shelf life all potential risks. Without forgetting the challenges of sugar reduction, where a gradual stealth approach has only limited application and some sugar alternatives raise questions around tolerance and labelling that will need to be addressed.

Increasing C points


Boosting positive nutrition is no less challenging. It’s no secret, for instance, that fruit, veg and nuts are expensive and, if you also consider that a product must contain 40% of these ingredients to secure just one C point, this is perhaps not the most efficient way to improve your HFSS score. Protein is also a relatively high cost option and remember, it can’t even be counted in HFSS calculations unless the total A score is less than 11.

When it comes to fibres, the positive nutritional wins are often offset with technical practicalities. Soluble fibre, for example, may be useful in sugar reduction – helping to decrease A points and boost C points - but can be associated with unwanted bloating and wind problems at high dosages. Insoluble fibre, on the other hand, can boost C points but product texture may be impacted.



In practice


What this brief overview tells us, is that there is no one-size-fits-all approach to product reformulation. Reducing or changing any or all of the target nutritional elements to achieve non-HFSS status will alter the eating experience so needs to be carefully managed.


That’s not to say it can’t be done. When RSSL was tasked with reformulating a cereal bar in the context of HFSS legislation, for example, we successfully reduced its original HFSS score of 7 to zero. How did we do it?


By first focusing on reformulation techniques to reduce the total A points to 10. That meant the protein contributed by ingredients such as nuts and oats already present in the formulation could then be counted, which boosted the overall C point score. We then took the most promising concepts to our client stakeholders to select the best option to take forward.


What’s more, with an HFSS score of zero, our client could be confident that the product’s rating with other nutritional labelling schemes around the world would also improve. It may not gain a top ‘A’ NutriScore, for instance, but would almost certainly move up one or two levels.


Ready to start your product reformulation journey?


Download our Guide: Reformulating To Meet Nutritional Targets or contact us via the form below. 

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