Navigating HFSS Reformulation

Navigating HFSS Reformulation

Last summer, whilst most of us were getting to grips with tiers, masks and social distancing, the Government set out its Tackling Obesity Strategy.

One of the first announcements was legislation to enforce calorie labelling of out-of-home foods sold in restaurants, cafés, and takeaways with more than 250 employees.

Amongst the other proposals are:

  • banning the advertising of High Fat, Sugar and Salt (HFSS) products before 9pm and holding a consultation on if, and how, to introduce a total ban on HFSS advertising on-line.
  • legislation to end the promotion of HFSS foods by restricting volume promotions such as ‘3 for 2’ and ‘buy one get one free’.
  • in addition, preventing the placement of these products in prominent in-store locations such as gondola ends, entrance areas and within 2 metres of a check out. Whilst independent stores of under 2000 sq ft are exempt they are still likely to be affected by product and promotions changes.
  • the location restrictions will also apply to on-line shopping on retailer home pages where the customer is browsing other categories of food and views baskets and checkout pages.

A fourth issue looms large and that is to extend Front of Pack Nutritional Labelling (FOPNL) across a wider range of food and drink products. Currently most retailers use the Multiple Traffic Light system but this is not obligatory…yet!

The Government’s moves are all aimed at reducing obesity with a particular focus on childhood obesity. According to Public Health England over 2/3 adults and 1/3 children are overweight. The link between obesity and severe Covid symptoms has shone the spotlight even more brightly on the urgency of the obesity issue. The premise is that by flagging some foods as ‘unhealthy’, or ‘high calorie’, people will be able to make better choices.

Clearly this strategy is highly contentious, with the advertising industry, food manufacturers and some public health bodies questioning the impact of the proposed changes and restrictions on purchase and consumption. In my view there is no such thing as ‘bad’ food or ‘good’ food but there are good and bad diets and unhealthy lifestyles. Therefore, would a wider education-based strategy that focuses on healthy living including eating, exercise, stress management, cooking from scratch and where food comes from, have more impact? It can be true can’t it that if something is forbidden or naughty, it becomes more attractive? Moreover, with increasing evidence that sugar and fat replacers may actually promote obesity, is taking them out of our foods the best thing to do?

This said, it looks certain that many of these proposals will be implemented, leaving food manufacturers the challenge of maintaining the position and appeal of their core brands. What is even more certain is that reformulation is extremely difficult. Microbial stability and maintaining the same sensory experience are major issues. Moreover, reformulation takes time…consumers taste preferences do change but it doesn’t happen overnight.


If you are faced with the problem of trying to recreate the sensory signature of your brand with a changed ingredient palate, our sensory and consumer research tools can support to inform direction and get you on the right track.

Use SensEyeTM to determine your target sensory profile and understand how each of your changes is moving you closer, or further, from where you need to be. Product DimensionsTM will help you benchmark the appeal of your prototypes to your target market. Or if you are starting all over, Product LabsTM will delve into consumer needs, spark and drive the innovation process. Follow up with OptiMap+TM to inform on key drivers of liking in your sector and then reveal the ideal combination of flavours and textures to delight your target group.

We are here to be your partner for HFSS redevelopment. Please feel free to get in touch…