UK HFSS legislation: How to approach reformulation effectively

Reformulating HFSS products ahead of planned UK legislation is technically challenging, but analytical testing can help brands confidently navigate the process. Carole Bingley, technical specialist at Reading Scientific Services Ltd (RSSL), explains.​

New legislation restricting price promotions, advertising and the in-store location of certain HFSS foods is expected to come into force in the UK in 2022. Part of the Government’s wider Childhood Obesity Strategy, it aims to “help improve people’s diets and reduce children’s sugar intake.” 

As a result, many of the categories that fall within scope are those that make a significant contribution to children’s overall calorie intake, including cakes, biscuits, breakfast cereals, morning goods and confectionary. Although there are notable exceptions, such as sausage rolls.

In practical terms, the new policy means that many brands will need to reformulate if they want to ensure regulatory compliance and avoid any curbs on marketing activity. Yet with fat, salt and sugar providing vital sensory and functional characteristics, this strategy requires careful management.

Afterall, achieving non-HFSS status will be a short-lived success if consumers don’t buy the revamped product - no matter how much promotional activity is put in place to support it.

This is why analytical testing is such a valuable tool. By making it an integral part of the development process, brands can understand and evaluate the impact of reformulation changes on key aspects of product performance. Meaning they are in a much stronger position to move forward.

And when it comes to reworking an existing formulation to achieve non-HFSS status, there are a number of important issues to address.

Farewell fats​

Altering the fat content of a product will directly impact the overall eating experience. Fats play a fundamental role in product structure, which means that using a different type of fat is highly likely to create changes in mouthfeel, flavour release and taste. Something which may also have implications for the processability of the product during manufacturing.

In baked goods, for example, switching from a hard fat to a more liquid alternative will reduce saturated fat content, but make it much harder to aerate the dough; creating potential problems with the volume and texture of the finished product.

Fat migration may also be problematic, particularly for products with layers or toppings such as cakes and biscuits. So too can shelf life, which may be shortened due to the beneficial role that saturated fats play in oxidative stability and rancidity.   

So long salt​

Reducing salt content will affect two important product parameters; preservation and taste.

Although changing packaging or processing may help to compensate for some of the salt’s preservative effects, the addition of other preservative ingredients may be needed in order to fully match the original. Yet, with little currently available in terms of clean label options, this is likely to require a certain level of compromise for some brands.

One of the most effective strategies for tackling the change to taste profile, however, is to gradually reduce salt content by stealth over time. This slow and steady approach has been successfully adopted by a number of brands following high profile health campaigns. That said, there will be a baseline below which consumers will start to reject a product. 

Sweet good bye ​

The multi-faceted role of sugar makes this element of non-HFSS reformulation complex and challenging. 

Sugar not only provides sweetness and bulk, it also acts as a preservative, stabiliser, thickener and fermentation substrate in a range of different products. And let’s not forget its ability to create the distinctive flavour and colour that is brought about by caramelisation and the Maillard reaction.

This makes sugar unique. So, although there are a number of well-known alternatives (natural and artificial), none can replace sugar on a like-for-like basis. Which means that understanding the strengths, weaknesses and limitations of each option in different applications is essential.

The value of analytical tools​

So how can analytical testing help to resolve these reformulation concerns?

Reformulation in the context of HFSS is often seen as an opportunity to review a product’s nutritional content as a whole. So even if the main focus is sugar reduction, it may also make sense to look at lowering salt and fat content at the same time. 

Whatever approach is taken, the taste and texture of the reformulated concept will be critical both to consumer acceptance and the commercial success of the initiative.

To evaluate these aspects, RSSL’s multidisciplinary team of technical experts uses these main data sources:

• Sensory assessment: An objective, descriptive assessment of the sensorial qualities provided by our team of trained product evaluators.  This is often linked to consumer understanding, in terms of liking or disliking the reformulated concepts. 
• Physical analysis: Key physical product characteristics, such as rheology, density and texture, measured and mapped through instrumental methods; where the existing product is used as a benchmark for reformulated concepts.

Each element provides measurable data and objective insights that can then be used to shape the direction of the reformulation process.

Used in combination, this approach enables us to answer key questions about a reformulated product’s performance. Such as why a biscuit has a less satisfying snap, or a yogurt’s texture is lacking the required indulgent mouthfeel. 

Optimising opportunities​

For manufacturers, this level of detailed understanding can only help to ensure the reformulation project stays on track to build on the expertise of the food developers. 

And of course, not every product will be suitable for reformulation. In which case, the best solution may be to go down a non-HFSS innovation route, rather than try to tweak an existing product to fit the criteria.

Either way, having the analytical data to support the chosen strategy means that brands can make an informed decision - and ultimately create products consumers will enjoy.

To find out more about RSSL and how we can support your product reformulation goals please click here​​ or contact us on +44 (0)118 918 4076 or email radhvevrf@effy.pbz​