UK HFSS rules flag half of UPFs as unhealthy, versus over 90% under Eatwell-based models

A statistical analysis has found that the UK faces significant inconsistencies in how unhealthy foods are defined and regulated. It reveals that current food regulations in the nation categorize 46–57.6% of processed and ultra-processed items as unhealthy, while new nutrient profiling models developed by the researchers to align with UK dietary guidance classify more than 90% of these products as such. 

According to experts, the current labeling system may misguide consumers on selecting healthy foods, which risks overlooking high in fat, salt, and sugar (HFSS) products. The researchers are from the UK’s University College London (UCL) and the University of Cambridge and the WHO.

They jointly call for a unified classification system, independent of food industry influence, to help consumers make healthier purchasing decisions.

The team carried out a cross-sectional analysis of 262 processed and 1,636 ultra-processed foods (UPFs) that the public consumed from the UK National Diet and Nutrition Survey database for Year 12 (2019–20).

They applied the Nova classification of food processing to distinguish processed foods from UPFs.

When comparing the identified proportions of healthy and unhealthy foods, the team found large differences between the Eatwell-based models and the Food Standards Agency Nutrient Profiling Model (FSA-NPM) and traffic light systems.

Inconsistent classifications

The BMJ Medicine paper includes various official public health definitions used to identify and regulate food and drinks. 

“Current food and drink regulatory tools do not capture products with an excess content of harmful nutrients, but UK dietary guidance does,” comments lead author Sam Dicken, research fellow at UCL Epidemiology and Health Care.

The Eatwell Guide, for instance, outlines government-recommended nutrients, foods, and drinks. The FSA-NPM (currently used in regulation) uses the HFSS definition, while the traffic lights are voluntary green, amber, and red labels on the front of the pack.

The researchers constructed three new nutrient profiles based on the Eatwell Guide for use in the model comparison. NPM1 identified excess saturated fat, free sugar, and sodium; NPM2 identified excess saturated fat, free sugar, sodium, and total fat; and NPM3 included all the components with added energy density.

Dicken says UK food and drink regulatory tools do not capture products with an excess content of harmful nutrients unlike UK dietary guidance.When examining UPFs, the three Eatwell Guide-based models classified 91.5% to 99% of these foods as unhealthy. This figure was 48% for the traffic light labels and 57.6% for FSA-NPM.

Also, 91.6% to 95% of the UK processed foods analyzed were deemed unhealthy, according to the Eatwell Guide-based models. This was 46% for the traffic lights labeling system and 50% for FSA-NPM.

Experts react

The researchers built their models by scaling whole-diet intake goals down to individual products, an approach used by the Pan American Health Organization and WHO.

However, in response to the study, Alberto Fiore, a professor of food chemistry and technology at Abertay University, UK, points out that the “more than 90% unhealthy” figures come from models the authors built themselves.

“These models are new and untested — not previously published, not used in policy, and not validated against health outcomes or any external reference — so the finding that the HFSS and traffic light systems ‘miss’ products is better described as a disagreement with the authors’ new yardstick than as an independent demonstration of failure,” he says.

Also not involved in the study, Dr. Rosiered Brownson-Smith, postdoctoral researcher in nutritional sciences at King’s College London, UK, cautions: “The finding that almost 99% of UPFs were classified as unhealthy under the new model does not mean that 99% of these products have been demonstrated to cause harm.”

Call for a unified system 

Examples of foods classified as unhealthy under the Eatwell-based models, but not under traffic lights or the HFSS definition, include canned pasta in tomato sauce, macaroni and cheese made from a packet mix, and fat-free probiotic yogurts. 

The researchers add that the traffic light labels could flag foods such as nuts or whole fruit as high in sugar or fat, despite the Eatwell Guide advocating their inclusion in a healthy diet.

Co-author Dr. Dolly van Tulleken, visiting researcher from the University of Cambridge, says: “A single, unified system for categorizing food and drink products as unhealthy using existing UK dietary guidance is much needed, both for consumers and for regulation.” 

“This must be developed independently of the food and drink industry’s influence. This would help to close regulatory loopholes and address the inconsistency of front-of-pack ‘traffic light’ labels and FSA-NPM.”

The team points out that, to date, no other study has examined these inconsistencies. They also do not propose a specific policy.

Séamus Higgins, associate professor in food process engineering at the University of Nottingham, UK, who previously worked in the food industry, believes that the study underscores the need to align dietary guidance, labels, and marketing rules.

Tulleken calls for a single, unified system for categorizing food and drink products as unhealthy using existing UK dietary guidance, developed independently from industry.“Unless we can agree on consistent criteria for defining healthier foods, manufacturers will struggle to reformulate products with confidence, regulators will struggle to provide clear guidance, and consumers will struggle to make informed choices.”

“The bigger question is whether the government has the political will to agree to those rules and assess whether they help people across the UK source and afford healthier food.”

Labeling gaps

The inconsistencies in healthy food labels worry the researchers, who say that consumers could purchase food and drinks that are high in saturated fat, salt, and sugar without realizing.

“This study shows that the UK food environment is saturated with products that make it hard for consumers to eat a diet in line with UK government advice,” comments the senior author, professor Chris van Tulleken from UCL’s Infection, Immunity and Transplantation.

“The reason such products are so dominant may be because existing labeling and regulation systems fail to identify them as unhealthy. If these products make up the majority of a person’s diet, as they do in the UK, there is a significant risk of consuming more sugar, salt, and saturated fat than the Eatwell Guide recommends, even if someone fastidiously avoids red traffic lights and HFSS products.”

“This itself would be difficult as traffic lights are voluntary and the HFSS definition is hidden from consumers.”

Nutrient or processing?

A linked editorial in BMJ Medicine by professor Franco Sassi and Dr. Shashika Rathnayaka from Imperial College London, UK, discusses the issue of classification in the context of policy.

Fiore says the “more than 90% unhealthy” figures come from models the authors built, which are untested, unpublished, and not validated against health outcomes.“Policies mostly target products, but their goal is to improve diets overall. A greater dietary share of UPFs is associated not only with poorer nutrient profiles but also with lower consumption of fruits, vegetables, and legumes,” reads their article.

“Policies may trigger substitution between foods, so their effects cannot be inferred from the number of products crossing a classification threshold. Evaluation should therefore consider purchasing and consumption, reformulation and substitution, and, ultimately, overall dietary patterns.”

They continue that what is essential for governments to answer is whether nutrient-based, processing-based, or combined approaches should be used to target food policies.

“Determining when nutrient quality or processing, or both, should guide policy must rely on evidence of the relevance, feasibility, and reproducibility of different policy approaches, and on their effects on reformulation, food choices, substitution, and dietary patterns,” the paper adds.

Meanwhile, Fiore reacts to the study, saying that its data show little difference in processing levels: “Under the authors’ most conservative model, 91.6% of ‘processed’ (Nova group 3) products and 91.5% of ‘ultra-processed’ (Nova group 4) products were flagged as unhealthy — virtually identical.” 

“If the level of processing tracked nutritional quality, those figures would diverge; they do not, because it is nutrient content that varies between products, not processing.”

Under the other models, ultra-processed products were flagged more often than processed ones.

Gunter Kuhnle, professor of nutrition and food science at the University of Reading, UK, agrees: “The results of the study support the assumption that the often observed adverse health effect of so-called ‘ultra-processed foods’ is mainly due to their nutrient composition.” He has previously received research funding from Mars (2010–2020) and sits on the UK Advisory Committee on Novel Foods and Processes.

The study’s researchers point out that their findings identify a representative selection of processed foods for comparison. However, they underscore that these outcomes do not imply that the foods would be subject to regulation. They add that the study did not test minimally processed foods, suggesting these can be explored in further research. 

Kuhnle adds that including minimally processed foods would have provided useful context: “Many foods in these categories would fall into the ‘unhealthy’ category of the models used, e.g. milk, eggs, nuts, and avocados due to their fat or saturated fat content.”

“A key difficulty of all food labeling systems is that many foods are not uniformly ‘healthy’ or ‘unhealthy’ — and this is the reason why a balanced, varied diet is important.”