Calculating free sugars for the 2018 UK Nutrient Profiling Model
2 February 2026 | Lewis Wallis, Regulatory and Nutrition Affairs Advisor
Are you prepared for potential changes to HFSS restrictions?
We are aware of ongoing policy discussions on updating the UK Nutrient Profiling Model (UK NPM), for determining whether a product is categorised as high in fat, sugar and/or salt (HFSS), as part of the 10 Year Health Plan for England.
The UK NPM underpins the calculation of HFSS scores and determines which products, within in-scope categories, are subject to restrictions on placement, promotion and advertising in the UK. While the 2004/05 model currently used was formally reviewed and consulted on in 2018, technical guidance for the 2018 model was not published until January 2026.
Policy discussions remain ongoing and any changes to the current HFSS restrictions would be subject to further consultation prior to implementation.
Changes in the proposed new model: The free sugar challenge
The 2018 NPM proposes a number of updates to the original 2004/5 model to better reflect more recent UK dietary recommendations. These include changes to thresholds for energy, fibre, sugar and salt.
One of the most significant proposed changes is the move away from total sugars (currently declared on nutrition labels as a mandatory requirement) towards thresholds based on free sugars.
Total sugar is defined in UK/EU legislation on food labelling as ‘all monosaccharides and disaccharides present in food, but excludes polyols’.
Alternatively, ‘free sugars’ is defined in the technical guidance as including any sugars added to foods or drinks, as well as sugars released when the structure of fruit or vegetables is broken down (such as in juices, smoothies and purées), and most sugars in drinks except those naturally found in milk. They do not include sugars naturally present in whole fruit and vegetables, starchy foods, nuts, seeds, or lactose naturally occurring in dairy products.
As free sugars are not required to be declared on labels, their calculation relies on detailed ingredient and formulation data held by manufacturers to identify and quantify free-sugar-contributing ingredients and their contribution per 100 g. This creates practical challenges when assessing product portfolios against the 2018 model, particularly where data are incomplete or inconsistent.
How we can help
We are already working closely with clients to help them navigate the practicalities of calculating free sugars and to understand the potential implications of the 2018 NPM for their product portfolios, should the model be taken forward as part of current HFSS restrictions.
This includes evaluating the number of products that would be impacted and how current HFSS scores would change, alongside key data considerations and areas of uncertainty.
If this is an area you are currently considering, get in touch to discuss how we can support you.
Our Regulatory Affairs team can help with any HFSS and NPM regulatory requirements, as well as ultra-processed food classifications. Plus, we have a training course specifically on nutrient profiling models; Nutrient profiling models: high fat sugar salt (HFSS) restrictions, front-of-pack nutrition labelling (FOPNL) and nutrition claims.
Our HFSS support is part of a valuable, extensive and authoritative information and advisory service to help clients stay compliant with food regulations in more than 80 countries. Whatever the legislative requirements of your target market, our experienced team of regulatory experts will ensure your products are compliant.
About Lewis Wallis
Lewis is a Regulatory and Nutrition Affairs Advisor in the Global Regulatory Affairs team at Campden BRI and has previous industry experience from working for a large multi-national company. He has contributed to and written material for a variety of outputs including research publications, technical reports, food law updates, blog articles, white papers, book chapters, eBooks and guidance documents. Lewis presents on Campden BRI courses and at a range of industry and academic events on the topics of High Fat Sugar Salt (HFSS) legislation, ultra-processed foods, and front-of-pack nutrition labelling.
He is a member of the IFST Food Regulatory Special Interest Group that work to host thought-provoking discussion workshops which feature experts presenting on the latest regulatory hot topics.
Alongside his current role, Lewis is a Postgraduate Researcher at University of Leeds and draws upon his regulatory expertise to conduct research at the intersection of food legislation and consumer behaviour, particularly focusing on measures designed to promote healthier and more sustainable food choices within digital food environments (e.g. online retail, meal delivery apps, social media). He has conducted research on the implementation of HFSS restrictions within online retail and his work involves the application of nutrient profiling models and processed food classification systems to products promoted and sold in digital settings.
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