As new technical guidance clarifies how free sugars would be calculated under the 2018 UK Nutrient Profiling Model, food manufacturers face fresh complexity. Lewis Wallis of Campden BRI explains what the changes mean and how businesses can continue to create products consumers love while staying on the right side of regulation.
The food industry has always needed to balance two fundamental drivers – engaging consumers with tasty products that meet their expectations, while navigating an evolving regulatory landscape that continues to be shaped by public health priorities.
The recent publication of detailed technical guidance on the 2018 UK Nutrient Profiling Model (NPM), and the underlying calculation of free sugars, represents the latest chapter in that balancing act. This follows confirmation from the Government of its intention to replace the current 2004/05 NPM with the stricter 2018 version as part of the 10 Year Health Plan for England. However, policy discussions remain ongoing, and any implementation would be subject to public consultation expected later this year.
For senior leaders, technical managers and commercial teams, this is more than an update to the thresholds of the current model. It has operational and supply-chain implications, and understanding what has changed and why it matters is now essential.
From total sugars to free sugars
The UK Nutrient Profiling Model underpins the classification of products as high in fat, salt or sugar – often shortened to HFSS. That classification affects where products can be placed in store and how they can be promoted and advertised.
The current model uses total sugars as part of its scoring system, which is data currently passed throughout the supply chain. The updated approach replaces total sugars with free sugars. This is a significant shift.
Free sugars include sugars added to foods by manufacturers, cooks or consumers, as well as sugars naturally present in ingredients such as honey, syrups, fruit juices and purees. They do not, however, include sugars that are naturally present inside the cellular structure of whole fruits and vegetables, cereals and nuts, or lactose in milk and dairy products.
The distinction was made to ensure the UK NPM reflects current dietary recommendations. It aligns the model more closely with public health thinking, recognising that free sugars are more readily available in the diet and are more closely linked to excess calorie intake and dental decay. By targeting free sugars specifically, the model aims to capture this development.
For manufacturers, however, the change introduces new layers of complexity.
A technical definition with practical consequences
Unlike total sugars, which can be measured analytically in a laboratory, free sugars cannot be directly tested. They must be calculated from detailed formulation and ingredient-level nutrition data.
That calculation depends on understanding each ingredient in a recipe, how it has been processed and how it contributes to the final product. For example, sugars in fruit juice concentrate are treated differently from sugars in whole fruit pieces. Purees, pastes and extracts all require careful consideration. Therefore, two products with identical total sugar values may have very different free sugar classifications depending on processing.
The new guidance sets out a structured approach for calculating free sugars. It explains how to assess ingredients as contributing to free sugars, before calculating the total free sugar content. For a significant proportion of manufacturers and retailers, implementation of the new model to current HFSS restrictions would mean revisiting existing formulations and the data behind them.
The supply chain dimension
For many commonly used ingredients, free sugar calculation requires greater detail than product specifications typically provide.
Many finished products contain ingredients made up of several components, such as fruit preparations, chocolate pieces or flavoured coatings, which include both free and non-free sugars. Accurately modelling free sugars therefore requires either supplier-declared free sugar values or sufficient breakdown of ingredient composition and nutrition data to calculate the value internally. In some cases, this may involve clarifying data several tiers upstream in the supply chain.
Specifications historically designed around total sugar declarations may not contain the detail required for this level of modelling. As a result, businesses may need to revisit supplier engagement, documentation practices and internal calculation systems.
Free sugar calculation is, in effect, a data access challenge as much as a nutritional one.
HFSS in the wider regulatory landscape
The updated guidance sits within a wider regulatory landscape that continues to evolve. Retail restrictions on the placement and promotion of HFSS products are already in force. At the same time, debate continues around ultra-processed foods (UPFs) and how they should be defined and regulated.
While HFSS and UPFs are distinct concepts, they show significant overlap and both point to higher scrutiny of formulation and ingredient choices.
Against this backdrop, the fresh clarity on the 2018 UK NPM will be a welcome development in some respects, but it also brings the new challenges mentioned here.
Practical next steps
Senior managers and executives should ensure that regulatory awareness is embedded across functions. Technical, NPD, regulatory and commercial teams need a shared understanding of how free sugars are defined and calculated. Regulatory change can feel like a barrier to business development, but it can also act as a catalyst for improved data systems.
The first priority for manufacturers is gaining a clear and consistent understanding of how free sugars are defined and calculated under the updated model. This includes reviewing recipe data, ingredient specifications and internal calculation methods. It is therefore important to engage early with suppliers. If implemented, ingredient specifications may need to be more detailed, especially where fruit preparations, concentrates or syrups are involved. Reliable free sugars calculations require precise underlying data.
Clear documentation is essential, not only for compliance but also for discussions with retail customers.
The next step is strategic review. Scenario modelling can help identify where products may move closer to, or beyond, HFSS thresholds under the revised approach. Early insight allows businesses to make strategic decisions rather than reactive adjustments.
Advice and support are available to help producers navigate these challenges by interpreting the technical guidance, reviewing formulations and stress-testing nutrient profiling outcomes. Used well, that expertise can reduce uncertainty and accelerate confident decision-making. The shift to free sugars may add complexity, but for businesses that respond early and strategically, understanding the practical challenges of implementation, and the potential impact on HFSS classification across product portfolios, will be essential as policy continues to evolve.
Campden BRI is a leading provider of scientific, technical and regulatory support to the food industry, with more than 2,500 member companies in 80 countries. Lewis Wallis is a regulatory and nutrition affairs advisor in the Global Regulatory Affairs team at Campden BRI and is a member of the IFST Food Regulatory Special Interest Group.
