3 major developments for UPF and HFSS in 2025

19 January 2026 | Lewis Wallis, Regulatory and Nutrition Affairs Advisor

As we start 2026, there is a well-needed opportunity to reflect on what was a big year for development and discussion regarding ultra-processed foods (UPFs) and foods high in fat, sugar and/or salt (HFSS).

Here we pick out three of the major 2025 developments for UPF and HFSS, namely regulatory / nutrition policy updates, as well as what they will mean for the food and drink industry in 2026 and beyond.

1) US policy developments

The past year has seen the start of US policy developments relating to UPFs.

Some key events from 2025 include:

The FDA and USDA jointly launched a federal Request for Information on defining UPF (first time US agencies have formally engaged with the concept of UPFs in a regulatory context).
California published legislation that will restrict certain UPFs from school meals.
New York policy indirectly excluded UPFs from meals and snacks served by public institutions (by focussing on what must be included as a minimum; whole, minimally processed foods).

For more on US federal nutrition policy, see our blog ‘Nutrition policy developments: An update on the United States’.

2) Studies exploring the overlap between UPF and HFSS

One of the common discussion themes in the area of UPF and HFSS is the challenge posed by divergence of various classification systems and what this means for policy approaches. Studies exploring this were published / presented in 2025.

Wallis et al. (2025) explored the overlap between UPF and HFSS classifications. The study found that most products from categories in scope of UK HFSS promotion and placement restrictions were considered UPF, yet only around half failed the UK Nutrient Profiling Model (NPM) and would be subject to regulation.

Williams et al. (2025) also found divergence between the two systems when applying classifications to a larger dataset of nearly 90,000 products. Nesta published a large-scale analysis of purchase data that found partial overlap between the two systems – it found that 64% of UPF calories purchased come from HFSS products.

3) HFSS implementation and updating the UK NPM

There were various key activities and dates in 2025 regarding HFSS implementation. See our associated blogs for further information:

An associated development was the 2025 intention to adopt an updated UK NPM (for determining whether a product is HFSS or not) as part of the 10 Year Health Plan for England . If the model developed in 2018 were to be applied, it would involve a focus on free (rather than total) sugars, stricter thresholds for sugars, allow more points for fibre content, change how salt is expressed, and update the calorie thresholds to reflect current recommendations – meaning that, ultimately, fewer products will meet the criteria for being ‘non-HFSS’. One of the main challenges here is regarding free sugars, which cannot be directly analysed, opening up potential data issues with relying on assumptions/estimation that may vary between different food businesses.

Other developments, and expectations for 2026

With the busy year that 2025 was in relation to UPF and HFSS, there were plenty of other developments not discussed here.

For example, 2025 saw the outcomes of various clinical trials relating to UPF health impacts, including into potential mechanisms. There was also much interest in the 2025-launched Lancet UPF series of three papers. In addition, the past year saw developments in technology-driven approaches to classification, such as Mobile Food Profiling Models in the form of mobile apps, as well as advances in machine learning applied to food classification.

In 2026, we can expect conversations on both topics to continue alongside emerging policy developments and evolving awareness of the associated data challenges. The food industry will need to consider feasibility of applying definitions in practice, and whether current data pipelines are sufficient to apply classifications to product portfolios at scale.

For more information on these and more major developments in this space, see ‘UPF and HFSS – the new state of play’ published with New Food Magazine.

How we can help

Need advice on how HFSS restrictions or UPF considerations could impact your business, or help with calculating Nutrient Profiling Model scores for your products? Our Regulatory Affairs team can help with any HFSS and NPM regulatory requirements and ultra-processed food classifications.

Our experienced team of regulatory experts can help you ensure that your products are compliant with the legislative requirements of your target market. We offer a valuable, extensive and authoritative information and advisory service to help clients stay compliant with food regulations in more than 80 countries.

Some of our services in this area include:

Scaling up food classification systems to product portfolio data;
Scoring additives based on regulatory/safety aspects to inform internal business policies;
Horizon scanning on research and regulation in NPMs and UPFs, including stakeholder perceptions and emerging classifications;
Reformulation and product development services.

We also 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 – this half day course provides an overview of HFSS policy; the latest restrictions and applying the UK Nutrient Profiling Model (NPM) to products; and insight into international developments and divergences in front-of-pack nutrition labelling schemes.

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.

Need advice?

Need advice on how HFSS restrictions or UPF considerations could impact your business, or help with calculating Nutrient Profiling Model scores for your products?

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