We welcome the Government’s consultation on applying the updated Nutrient Profiling Model (NPM) to existing restrictions on the advertising and promotion of less healthy food and drink – an important next step in improving the UK’s food environment.
We have produced a short two-page briefing, including our likely recommendations on how Government could go further, examples of the model in practice, and a brief ‘free sugars/NPM explainer’ – access this here.
The consultation portal and questions can be accessed here.
The Government’s Press Release, featuring Quotes from Public Health and Prevention Minister, Sharon Hodgson, and Chief Medical Officer for England Prof. Sire Chris Whitty, can be accessed here.
A Nutrient Profiling Model is a scoring system used to distinguish healthier from less healthy foods based on their nutritional content. The UK’s current 2004/05 model underpins policies regulating the marketing of a limited number of categories of food and drinks high in fat, salt and sugar (HFSS)*, particularly to children, before 9pm on TV, 24/7 on paid-for online media across the UK, and multibuys and location promotions in large retailers in England.
The updated model reflects recent scientific advice on free sugars and fibre, and better captures how food is processed today**. This will help close longstanding loopholes that currently allow some products containing free sugars***, such as those made from juices, purées or added sugars, to be promoted more widely than intended, despite contributing to excess sugar intakes.
Applying the updated model to existing rules is a practical and necessary step to ensure that restrictions on advertising and promotions work as intended: reducing children’s exposure to less healthy products while creating a level-playing field for businesses to make and sell genuinely healthier food.
This consultation is part of a broader package of measures, as committed to in the NHS 10 Year Plan, to improve the food environment, including the proposed ‘Healthier Food Standard’ and restrictions on the sale of high-caffeine energy drinks to children. Taken together, these policies can help improve child health and support the ambition of raising the healthiest generation of children ever.
Katharine Jenner, Executive Director of the Obesity Health Alliance, said:
“Current regulations do not fully protect children from exposure to unhealthy food and drink marketing, whether on TV, online or at the checkout, which is why updating how foods are classified is a necessary and sensible next step. Some products can look healthier on paper than they are in reality; a stronger model ensures advertising rules actually reduce children’s exposure to less healthy options.“If we are serious about improving children’s health, making the food on sale genuinely healthier is the first step to real change.”
British Dental Association Chair Eddie Crouch said:
“Sugar is fuelling an epidemic of tooth decay, which remains the number one reason for hospital admissions among young children.
“The Government needs to take the gloves off with industry, so they can no longer get away with peddling junk food as healthy options.
“Parents can only make informed choices if Ministers clear the decks of the half truths and downright deceit that passes for marketing in 21st century Britain.”
Bite Back CEO, D’Arcy Williams said:
“We welcome the government’s consultation on applying the updated Nutrient Profiling Model to advertising and promotions. Ensuring that our definition of ‘less healthy’ food reflects the latest science is a vital step in creating a food environment that better supports children’s health.
“It is encouraging to see the government taking a firm, evidence-led approach in the face of continued pressure from parts of the food industry. Policies like this will make it harder for these companies to hide their harmful products behind outdated definitions, and therefore harder for them to sneakily advertise such junk to children. Putting the health of young people first is exactly how to shift the balance and deliver on their ambition to create the healthiest generation ever.
“We look forward to working with the government and partners to ensure these proposals translate into meaningful, consistent action that protects children from the overwhelming influence of junk food marketing.”
Liz Stockley, British Dietetic Association:
“The BDA strongly welcomes the consultation on the updated Nutrient Profile Model (2018). We see this as an important step in aligning food policy with the realities of modern diets and current evidence.
The model has a significant influence on the food environment, particularly through advertising and promotions. Getting this right matters. A well‑designed and well‑implemented model can help support healthier dietary patterns across the population and reduce exposure to less healthy food marketing, especially for children.
We look forward to working with the OHA, government, and stakeholders to ensure the consultation benefits from dietetic expertise and results in a model that is fair, evidence‑based and effective in supporting public health.”
Sonia Pombo, Head of Research and Impact, Action on Salt & Sugar
“This is a hugely important step forward for children’s health. The new model is much more robust and finally reflects the evidence on free sugars, salt and excess calories, offering a stronger foundation to protect children from unhealthy food environments. But for this to make a real difference, the updated NPM must be applied consistently across all areas of food policy, not just advertising and promotions, but also labelling and nutrition claims. This is a crucial opportunity to close loopholes, ensure healthier and more affordable food options are available to all, and drive reformulation across products that shape our diets every day. This is exactly the kind of action we need to see if we are serious about preventing childhood obesity and preventing diet-related disease.”
Dr Hannah Brinsden, Head of Policy and Advocacy, The Food Foundation
“Shielding our children from the advertising and promotion of unhealthy food is critical, and today’s consultation marks an important step in getting the updated nutrient profile model into policy. Updating the way we define foods that can and cannot be advertised in line with the latest evidence and dietary recommendations isn’t revolutionary, but smart, common sense and good practice for policy.
We’ve waited a long time for this update, and once enforced it will help to ensure that our food policies are working as they should to protect children’s health. Setting out a timeline for implementation will be critical, ensuring that businesses are clear on what is expected of them, and by when. We’ve got the evidence, we’ve got the model, we know what we need to do – let’s crack on!”
Fran Bernhardt, Commercial Determinants Co-ordinator at Sustain says:
“The Nutrient Profiling Model has been crucial for progress on children’s health. By allowing us to differentiate between healthier and less healthy foods and drinks, it’s been the cornerstone of several successful policies. One of its key strengths is its simplicity – it’s easy for businesses and policymakers to use and understand, and that must be preserved as the model is updated.
“Opening this consultation is a welcome step, as unanswered questions remain around how to implement these changes. We urge the government to work closely with experts to ensure the necessary data and guidance are in place, so the updated NPM can continue – and strengthen – its role in safeguarding children’s health.”
NOTES
*What’s in the Scope of the Marketing Regulations?
- Categories in scope include sugary soft drinks, confectionery, cakes, breakfast cereals, savoury snacks, ready meals, sweet biscuits, morning goods, and desserts.
- Categories not in scope include (but not limited to) commercial baby food, sweet spreads, flavoured noodles, pastry products, fruit juices and smoothies.
- Products only fall inside scope if they fail to meet the government’s nutrient profiling model thresholds and are high in fat, sugar, and/or salt (HFSS).
- For the advertising restrictions, the advert must also identify a product consumers can buy, not brand advertising.
**2004/05 NPM vs 2018 NPM: What’s changed?
- Free sugars replace total sugars, aligning with Scientific Advisory Committee on Nutrition (SACN) and WHO recommendations.
- Sugar and energy-density thresholds are lowered, reducing opportunities for high-sugar/high-energy foods to pass.
- Model uses salt instead of sodium
- Seeds have been added to the fruit/vegetables/nuts score due to their having a similar nutritional profile to nuts.
- Fibre and protein scoring is revised, to align with adult recommended nutrient intakes. Foods high in fibre may now accrue more positive points (max of 10) but free sugar content may still result in the product being classified as Less Healthy.
***What are free sugars?
The updated model incorporates stronger treatment of free sugars, following recommendations from the Scientific Advisory Committee on Nutrition (SACN).
Free sugars include:
- sugars added during manufacturing
- sugars in honey and syrups
- sugars released when fruit or vegetables are processed (for example in juices or purées)
They do not include sugars naturally contained within intact or minimally processed fruits, vegetables or unsweetened milk/dairy products. This distinction is important because free sugars are more rapidly absorbed and are strongly linked to excess calorie intake, tooth decay, increased risk of type 2 diabetes and weight gain. It does not include artificial sweeteners.
Previously, some products containing whole fruit or vegetables could be penalised by total sugar calculation, even when those sugars were naturally present within the food. The updated model may reward products that contain whole foods, such as fruit, vegetables and fibre-rich ingredients. This helps ensure that foods which are heavily processed and contain free sugars are less likely to be classified as “healthier”.
For more information, see our news story and series of blog posts on the New Nutrient Model