Updating the Nutrient Profiling Model isn’t moving the goalposts – it’s making the game fair, writes our Executive Director, Katharine Jenner…
Since the government announced it would publish the updated Nutrient Profiling Model (NPM) as part of its 10 Year Health Plan in July 2025, industry criticism has followed a familiar line. Some argue the changes are unfair, that companies only improved their products to keep advertising them, and that updating the model now renders that investment “wasted”.
And there was us thinking that taking out salt, saturated fat and sugar was about making products healthier for customers.
But this misses the real issue. Updating the Nutrient Profiling Model is not about moving the goalposts – it’s about updating a rulebook that has become increasingly easy to game, and that no longer reflects modern dietary guidance or the food people actually put on their plates.
What is the Nutrient Profiling Model?
The Nutrient Profiling Model was developed by the Food Standards Agency in 2004–2005 to help Ofcom distinguish between healthier and less healthy foods for the purposes of children’s TV advertising. It works by balancing nutrients to limit, such as saturated fat, sugars and salt, against beneficial components including fibre, fruit, vegetables, nuts and protein. Foods and drinks scoring above a set threshold are classified as “less healthy”.
Over time, the NPM has become central to a range of policies, including restrictions on advertising and promotions of less healthy food and drink. However, it has not kept pace with the evidence. Dietary guidance has evolved significantly, particularly following recommendations from the independent Scientific Advisory Committee on Nutrition (SACN) on free sugars* and fibre [1]. A revised NPM was consulted on in 2018 to reflect this evidence, but was never published.
Now, as part of the NHS 10 Year Health Plan, the government is moving forward with publishing the updated model, issuing technical guidance and consulting on its application in policy in future.
Healthier vs less healthy – and common sense
Let’s be clear: porridge, yoghurt, cereals and even protein bars can and should be nutritious. But over time, we’ve seen entire categories split. Some products remain genuinely healthy, while others have been transformed into highly processed, high-sugar, high-salt or high-fat versions of their former selves.
These products sit at the heart of the ultra-processed food debate for good reason. They continue to benefit from a powerful “health halo”, despite no longer delivering the health benefits consumers reasonably expect.
Consider just a few examples:
- Rolled oats → pre-packaged porridges soaked in golden syrup
- Wheat biscuits → chocolate-coated breakfast cereals
- Natural yoghurt → sugary yoghurts sold with chocolate balls on the side
- Nut bars → protein bars packed with highly processed ingredients
Under the existing Nutrient Profiling Model, many of these products can still pass as “healthier” – and be advertised and promoted to children accordingly.
The updated NPM recognises this difference. It doesn’t demonise whole categories. It distinguishes between products that genuinely support health and those that have been pushed far from their natural form. There is even an ‘allowance’ for naturally occurring lactose in dairy products like yoghurt, so their natural sweetness won’t be affected.
Chocolate and sweets are rarely going to be healthy – though they can be healthier. Porridge, yoghurt and cereals, however, should be healthy by default. When they aren’t, that should matter.
Coco Pops in Parliament
This issue was brought into sharp focus during recent Health and Social Care Select Committee evidence sessions. Professor Chris van Tulleken produced a box of Coco Pops and explained that, under the existing NPM, it is classified as “healthier” – despite a 30g serving providing more than a quarter of the recommended maximum daily intake of free sugars for a child aged four to six [2].
At a later session, when the Food and Drink Federation was asked whether it would recommend Coco Pops as an everyday cereal for children, the response was – hesitatingly but accurately – that it was “a healthy product as defined by the nutrient profile model” [3].
MPs were unconvinced. And rightly so. Most parents would struggle to see a chocolate-coated cereal as a healthy daily breakfast for children. That is simply common sense.
Coco Pops pass the old model.
They are likely to fail the new one.
Porridge-gate
Porridge has also been hotly debated in the context of advertising and promotion restrictions. Because it sits within the broader breakfast cereal category, it is sometimes cited by the lobbyists as evidence that the rules are too blunt.
Porridge is widely – and rightly – seen as a healthy food. But what happens when oats are ground down, heavily processed, sweetened, and sold pre-packaged with golden syrup flavouring?
Under the existing model, even porridges like this can still pass as “healthier”, despite bearing little resemblance to the simple oat-based food most people understand porridge to be.
Under the updated NPM:
- plain oats pass easily;
- porridges high in fibre and low in free sugars pass;
- pre-packaged porridges loaded with sugar would be likely to fail.
That’s not a blunt policy. That’s common sense.
Gaming the system
Perhaps the clearest illustration of why the model needed updating came when Joe Wicks demonstrated how easy it was to “game” the existing NPM in his Channel 4 programme Joe Wicks: Licensed to Kill.
By adding protein powder to an ultra-processed bar, it was possible to create a product that looked virtuous on the label – and passed the model – despite being far from genuinely healthy.
The so-called “killer bar” would pass the old model.
It is likely that it will fail the new one.
This isn’t about singling out individuals or brands. It’s about acknowledging that when a regulatory system can be gamed so easily, it no longer serves its purpose.
Reformulation isn’t a flaw – it’s how the policy works
Despite growing consumer demand for healthier food, some critics argue that companies only reformulated products in order to advertise and promote them. But that is not an indictment of the policy – it’s evidence that it worked.
Advertising and promotion restrictions were designed to change commercial incentives. Reformulation in response to those incentives is exactly how public health policy delivers impact. What policy never promised was that once a product scraped over a threshold, it would enjoy permanent privileges – even as evidence, dietary guidance and products evolved.
Updating the model delivers real health benefits
The case for updating the NPM is not theoretical. Government analysis suggests that applying the updated model to existing advertising and promotion restrictions, in time, could increase calorie reductions by up to 30% compared to the current model. That equates to preventing around 170,000 cases of childhood obesity and 940,000 cases of adult obesity [4].
Children currently consume around 50% more free sugars and 40% less fibre than recommended [5]. Tooth decay remains the leading cause of hospital admissions among young children [6]. And children in more deprived areas continue to be exposed to more advertising for unhealthy food [7].
Maintaining an outdated model would mean knowingly leaving significant health gains on the table.
Clarity and common sense
The updated Nutrient Profiling Model doesn’t ban products. Companies can still make and sell whatever they choose. What it does is stop heavily processed, high-sugar foods from being placed centre-stage simply because they’ve been engineered to pass an outdated test.
It brings policy back into line with dietary guidance, closes loopholes, and gives the public a clearer, more honest signal about what “healthier” really means.
Updating the NPM isn’t radical.
It’s overdue – and essential if food policy is to reflect both the evidence and common sense.
Naturally occurring sugars are found in whole fruit, vegetables, and milk-based products. These are not considered harmful for health, as they are released more slowly into the bloodstream, and come packaged with fibre and/or micronutrients – though they still provide calories.
Added sugars are those introduced during food preparation or processing – such as table sugar (sucrose), glucose, honey, syrups, and nectars.
Free sugars include all added sugars plus those sugars naturally present in fruit juices, smoothies, and purées, where processing has broken down the cellular structure (e.g. releasing fructose from the fruit cell wall). These sugars are all rapidly absorbed, provide little or no nutritional benefit, and contribute ’empty calories’ that can spike blood sugar and insulin levels. The SACN recommendation and health evidence is based on free sugars, to capture both added sugars and those released during processing.
Total sugars (what’s used in the old model and what is on the food label) is all of the above
References
- Scientific Advisory Committee on Nutrition (2015) Carbohydrates and health. https://assets.publishing.service.gov.uk/media/5a7f7cc3ed915d74e622ac2a/SACN_Carbohydrates_and_Health.pdf [Accessed: 23rd January 2026]
- Health and Social Care Select Committee (2025) Health and Social Care Committee Oral evidence: Food and weight management, HC 1181. https://committees.parliament.uk/oralevidence/16688/pdf/ [Accessed: 23rd January 2026]
- Health and Social Care Select Committee (2025) Health and Social Care Committee Oral evidence: Food and weight management, HC 1181. https://committees.parliament.uk/oralevidence/16846/pdf/
- NHS (2026) Impact statement: The 10 Year Health Plan for England. https://assets.publishing.service.gov.uk/media/69651a7699fbdc498faecd1f/impact-statement-10-year-health-plan.pdf [Accessed: 23rd January 2026]
- Office for Health Improvement and Disparities (2025) National Diet and Nutrition Survey 2019 to 2023: report. https://www.gov.uk/government/statistics/national-diet-and-nutrition-survey-2019-to-2023/national-diet-and-nutrition-survey-2019-to-2023-report [Accessed: 23rd January 2026]
- Office for Health Improvement and Disparities (2026) Short statistical commentary for hospital tooth extractions in 0 to 19 year olds 2024. Available at: https://www.gov.uk/government/statistics/hospital-tooth-extractions-in-0-to-19-year-olds-2024/short-statistical-commentary-for-hospital-tooth-extractions-in-0-to-19-year-olds-2024
- Bite Back (2025) Fuel us don’t fool us. https://news.liverpool.ac.uk/2025/04/09/study-reveals-scale-of-junk-food-advertising-in-uks-most-deprived-areas/ [Accessed: 23rd January 2026]