‘New’ nutrient profile model implementation – 12 month countdown

The Nutrient Profile Model (NPM) consultation was published 25 March 2026 and proposes businesses have just 12 months to apply the ‘new’ NPM (2018 model) for their advertising and promotion of products. Applying the new NPM to advertising and promotions restrictions - GOV.UK

What will this mean for your business?

Background

The currently applicable NPM was developed by the Food Standards Agency (FSA) in 2004-2005 (therefore over 20 years old) and applies a nutritional calculation to judge what foods may be considered High in Fat, Salt or Sugar (HFSS) and subject to a range of advertising, marketing and promotion restrictions.  

This consultation proposes the application of the 2018 model to advertising and promotion restrictions and timescales for implementation.

Impact

The importance of the NPM as a tool for restricting advertising, marketing and promotion of HFSS foods has grown massively from a tool to ensure against advertising directed at children to restrictions on placement and volume promotions in retailers, to a sweeping ban this year across all social media and TV before a 9pm watershed, for paid for advertising of Less Healthy Food, applying a two stage test of HFSS and a list of 13 broad food categories.

The Impact statement: 10 Year Health Plan for England (published January 2026) proposed the application of the ‘new’ NPM, a 2018 version, that was previously reviewed/consulted on but not implemented for advertising compliance purposes at that time.  

The stricter criteria of this new NPM is likely to mean more products would be reclassified as HFSS. This is likely to especially impact categories high in free sugars or fibre, such as beverages, breakfast cereals, cereal bars, yoghurts, desserts and frozen foods.

The government is proposing 12 months as an appropriate amount of time for all relevant businesses and enforcement authorities to adapt to the new NPM to the advertising and promotions restrictions:

• the Advertising (Less Healthy Food Definitions and Exemptions) Regulations 2024
• the Food (Promotion and Placement) (England) Regulations 2021

2018 NPM Version

Under the NPM foods scoring 4 or more points and drinks scoring 1 or more points are classified as HFSS. The 2004/5 DoH nutrient profiling model currently applicable to advertising and promotion restrictions is available here and includes detailed technical guidance on how the profiling works.

The 2018 NPM consultation received 42 responses from companies, trade bodies, NGOs and four individuals. A summary of responses was published Consultation on the UK Nutrient Profiling Model 2018 review.

The 2018 NPM still considers all products by 100g. This has been a criticism of the 2004 NPM as foods typically consumed in small amounts that are dense in energy or salt, fair badly (e.g. peanut butter, cheese, mayonnaise, yeast extract).

Key differences between NPMs

Sugars:  

The move from ‘total’ sugars to ‘free’ sugars. Free sugars means all sugars added to food plus those naturally present in honey, syrups and fruit juices.  The NPM recommends free sugars should make up no more than 5% of energy intake.

The informal definition of free sugars is: all added sugars in any form; all sugars naturally present in fruit and vegetable juices, purees and pastes and similar products in which the structure has been broken down; all sugars in drinks (except for dairy-based milks); and lactose and galactose added as ingredients. This definition was used to calculate intakes in the National Diet and Nutrition Survey

Free sugars are mostly defined as:

• all added sugars in any form
• sugars in honey, syrups and nectars
• all sugars naturally present in fruit and vegetable juices, purées, powders and pastes, extruded fruit and vegetable products, and similar products in which the structure has been broken down
• all sugars in drinks (except for unsweetened dairy-based drinks)
• lactose and galactose added as ingredients (this also includes hydrolysed lactose and the sugars (lactose) in whey powder)
• all sugars in drinks except for lactose naturally present in cows’ milk and other dairy products - this includes the sugars naturally present in fruit and vegetable juices, concentrates, smoothies and dairy-alternatives
• all sugars in lactose free dairy products where the lactose has been partially removed through filtration and the remainder broken down to glucose and galactose using lactase

The definitions of free sugars do not include:

• sugars (lactose and galactose) naturally present in cows’ milk and other dairy products including dried milk powder
• all sugars naturally present in fresh, frozen, dried, stewed and canned fruit and vegetables (other than purées, powders, pastes, juices, smoothies and extruded products)
• all sugars naturally present in puréed and powdered starchy carbohydrates, including tubers (such as potatoes, sweet potatoes, yams, cassava and plantain)
• all sugars naturally present in cereal grains including rice, pasta and flour and all sugars naturally present in nuts and seeds (other than cereal-based or nut-based drinks)
• maltodextrins, oligofructose and sugar substitutes such as polyols (for example, sorbitol)

The move to free sugars is likely to be problematic for food businesses due to a lack of a standardised scientific methodology to calculate this and that it is often based on estimates and subjective interpretations of ingredient lists. As free sugars don’t typically appear on nutrition labels, many businesses don’t currently capture this data.  
The new NPM is likely to limit advertising of fruit juice and juice-based drinks, due to their high free sugar content.  

It is also likely to affect many cereals and yoghurts (which may have been previously reformulated to score within the current NPM).

Fibre:

The revised NPM 2018 version would ‘award’ additional points for a given content of fibre with a proportional change in recommendation in fibre from 24g to 30g.

Saturated fat and Energy:

The new NPM is also slightly stricter on points for saturated fat and energy, meaning more savoury snacks will be classified as ‘less healthy’.

Summary:

A helpful IGD summary of main differences is provided below:

The Nutrient Profiling Model explained: Stay ahead of HFSS changes

Recommendations

• Respond to the consultation on timescales ahead of 17 June 2026 to request where additional time may be required for industry.
• Consider the 2018 NPM and the key changes.
• Review your product portfolio See if your products are likely to be affected.
• Consider the areas of change in relation to your products and where there may be opportunities or challenges.
• Ask Mills & Reeve to advise on potential restrictions and classifications

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