Engineering compliance: ingredient innovation driving the future of non-HFSS products

As the UK prepares to implement one of the world’s strictest regulatory regimes targeting foods high in fat, salt and sugar (HFSS), food manufacturers face a twin challenge: maintain product appeal whilst ensuring regulatory compliance.

Effective 5 January 2026, the HFSS guidelines will restrict product placements, volume promotions and advertising across digital and broadcast media for non-compliant foods. Far from simply imposing limitations, this framework is acting as a powerful catalyst for innovation, particularly in the realm of ingredient technology.

Brands across baked goods, snacks, confectionery and ready meals are using advances in food science to reformulate or develop entirely new product lines that meet the HFSS nutrient profiling model (NPM) thresholds. The science of sugar reduction, fat substitution and fibre enrichment is undergoing a renaissance, not only to meet compliance metrics but also to sustain brand trust, sensory expectations and nutritional transparency.

The policy shift behind the HFSS reformulation wave

The overall policy scenario and public health data strengthen the need and scale of HFSS reformulation efforts. From January 2026, new UK regulations will impose a 9pm watershed for HFSS product advertisements on television. Additionally, there will be a full ban on paid online advertising, with an aim to reduce children’s exposure to high-fat, salt and sugar foods. In retail, volume-based promotions such as “buy one get one free” will also be prohibited under these rules. These interventions are expected to remove as many as 7.2 billion calories from children’s diets annually. They are also set to prevent 20,000 cases of childhood obesity and yield estimated savings of £50 million for the NHS and £40 million in social care.

Along with these regulations, government reports show that average intakes of saturated fat, salt and sugar remain above recommended limits, while fibre, fruit and vegetable intake lags notably. The occurrence of obesity in school-aged children is particularly striking. As of the 2023–2024 school year, 9.6 percent of children aged 4 to 5 and 22.1 percent of those aged 10 to 11 were living with obesity. Furthermore, in the most deprived areas, the obesity rate for older children reached 29.2 percent, more than double that of their peers in more affluent areas.

In parallel, the Soft Drinks Industry Levy (SDIL), which successfully reduced sugar levels in beverages by 46 percent since its introduction, will be adjusted for inflation from April 2025 to maintain its reformulation incentive. These developments underline that HFSS compliance is not just a technical benchmark, but a public health imperative rooted in clear policy direction and measurable outcomes.

Sweetening the challenge: sugar alternatives and flavour systems

Reducing sugar content in foods is one of the most difficult aspects of HFSS reformulation, not just because of its sweetness, but also due to its multifunctionality. Sugar contributes to texture, mouthfeel, browning, moisture retention and shelf life. Its reduction or replacement must be carefully engineered with both taste and function in mind. Manufacturers are now moving toward synergistic systems involving low-calorie bulk sweeteners, natural high-intensity sweeteners and flavour modulators.

Erythritol and other polyols such as xylitol and maltitol are usually deployed as foundational bulking agents. Erythritol in particular is favoured for its crystalline texture and non-hygroscopic behaviour, imitating sucrose more closely than other sugar alcohols. However, polyols alone do not deliver the intensity of sweetness required in confectionery and bakery items. Therefore, they are usually paired with stevia leaf extracts, allulose or monk fruit derivatives. These high-intensity sweeteners give sweetness with zero or negligible calories but come with formulation issues like bitter aftertaste or metallic notes. This has created a booming market for sweetness enhancers and taste modulators, compounds that suppress bitterness, enhance mouthfeel or extend sweetness duration. Natural compounds like thaumatin or glycosylated steviol glycosides are coming in commercial toolkits specifically for this purpose.

One of the most notable examples is Urban Legend, which uses a proprietary matrix of fibres and natural sweeteners alongside steam aeration to create a doughnut that is both soft and indulgent yet fully compliant with HFSS scoring. More recently, Nestlé introduced Yorkie Crème Desserts (2024), reformulated to meet HFSS requirements while maintaining indulgence. In a similar manner, Little Moons introduced their Refreshos sorbet line in 2024, HFSS-compliant, under 60 calories and free from artificial additives.

Replacing fat with structure and satiety

Replacing fat needs an even more multidisciplinary approach due to its sensory and metabolic importance. Fat not only contributes to flavour richness and mouthfeel but also affects the release of aromatic compounds, satiety signalling and product moisture retention. The hardship lies in maintaining creaminess and lubrication without the caloric burden or the contribution to HFSS fat scores.

Soluble dietary fibres like inulin, beta-glucan and dextrins are now progressively used to replicate the bulk and creaminess that fat delivers. These fibres also give nutritional benefits like improved digestive health and enhanced satiety. This makes them attractive dual-function ingredients. In dairy reformulations, for example, inulin can replace up to 50 percent of fat and, at the same time, still maintain a spoonable texture.

Protein-based fat mimetics are another fast-emerging space. Chickpea protein isolates, egg white protein and pea-derived emulsifiers are used in emulsified spreads, bakery fillings and plant-based dairy to simulate the structural viscosity and emulsification properties of fat. These also positively contribute to the protein density of the formulation, an attribute increasingly favoured by consumers.

For high-temperature applications or savoury foods such as pizzas, microencapsulation has enabled the use of smaller quantities of oils without letting go of the perceived flavour. These encapsulated oils break under shear or heat, releasing concentrated flavour with minimal caloric input. Goodfella’s, for example, reformulated its pizza line. It became 100 percent HFSS-compliant by mid-2023, using high-fibre crusts and optimised fat systems.

Functional fibres and resistant starches: the unsung heroes

Usually operating behind the scenes, functional fibres and resistant starches are some of the most powerful tools available for HFSS reformulation. These ingredients assist in fibre enrichment, caloric reduction and digestive health, all while offering key functional roles such as water-binding, bulking, and texture enhancement.

Resistant starches sourced from maize, cassava and even green bananas are becoming more popular in snacks, cereals and bread. Since they are not absorbed in the small intestine, they give fewer digestible calories and improve glycaemic response. Their inclusion can meaningfully reduce the energy density of a product without sacrificing volume or mouthfeel. When used with insoluble fibres like wheat bran or oat hulls, resistant starches can also modulate satiety and glycaemic load.

Inulin and oligofructose, two key fructans sourced primarily from chicory root, are mainly used for both their functional and health benefits. These ingredients improve texture, act as prebiotics, and help with fat and sugar reduction. They are particularly valuable in confectionery, dairy and cereal bar formats. As reformulation moves beyond usual compliance toward nutritional enhancement, such dual-function fibres are expected to play an even more significant role.

Brands like Eat Real have capitalised on this trend. They put lentil flour, sunflower oil and pea fibre into their HFSS-compliant snack lines. Walkers, under PepsiCo, introduced reformulated Monster Munch and Wotsits in 2024 using chickpea flour and offering under 100 calories per bag, demonstrating how mainstream brands are also leveraging functional ingredients to align with HFSS goals.

Commercial response and market uptake

The shift toward HFSS compliance is no longer niche or experimental; it is well underway and increasingly visible on supermarket shelves. The past 18 months have seen a flood of new launches and reformulations driven by regulation as well as by market opportunity.

Mr. Kipling’s non-HFSS Lunchbox Slices, introduced in 2025, target the children’s snack market under much scrutiny. Deli Kitchen, for the first time, introduced protein-rich flatbreads and pancakes in 2024, combining compliance with functionality. Doritos, one of the UK’s biggest snack brands, launched HFSS-compliant versions of its core flavours in late 2024.

Retailers are equally involved in this transformation. Some have restructured shelf placements to prioritise compliant products, while others have issued supplier mandates to convert core SKUs ahead of the January 2026 ad ban. Private label products are usually the first to reflect reformulation trends, serving as test beds for new ingredients and formats.

As HFSS regulations continue to be enforced and refined, the brands that have invested early in compliance-focused R&D and ingredient innovation are already carving out market share. Their ability to meet both policy requirements and consumer expectations positions them as leaders in a fundamentally changed retail scenario.

As HFSS regulations tighten, what began as a compliance challenge has grown into a meaningful driver of food innovation. Brands across categories are no longer just reacting to policy. They are actively investing in ingredient systems and formulation strategies that align with both regulatory thresholds and shifting consumer expectations. The progress seen in 2024 and 2025, from reformulated indulgent snacks to fibre-rich ready meals, shows a maturing market that knows the commercial value of health-forward innovation.

With the January 2026 restrictions approaching, the momentum is set to accelerate. Retailers, manufacturers and policymakers are increasingly aligned in their goals, creating a rare synergy that supports both public health outcomes and business growth. In the approaching time, the focus will shift from short-term compliance to long-term nutritional impact. The success will be measured not just in grams of sugar reduced, but in the ability to deliver healthier, appealing products at scale. The HFSS transition may have begun with policy, but its future will be supported by science, strategy and a more responsible food system.

Meet the author 

Shivani Nainwal is a Senior Research Analyst, Food & Nutrition at ChemBizR, a boutique business research and consulting partner of global chemical companies, collaborating on interesting aspects of the food, nutrition and beverage industry, along with their other business wings. ChemBizR works towards addressing companies’ critical business challenges and strategic growth initiatives to help them transform their enterprise for sustainable growth in a highly competitive and rapidly evolving environment.