As GLP-1 use changes how some consumers eat, New Food examines how nutrition science can translate into viable products, with Osborne Clarke’s Charlie Hennig unpacking the claims and regulatory challenges.
Growing GLP-1 use is creating an unusual brief for food developers: designing products for consumers who may want to eat less, while ensuring adequate nutrition.
Shrinking the portion is the easy part. Making that smaller meal deliver enough protein, fibre, vitamins and minerals, while still tasting good and earning its place in the shopping basket, is considerably harder.
That challenge is moving rapidly from theoretical to commercial. A nationally representative YouGov survey commissioned by The Food Foundation found that nearly seven percent of UK adults were using or had used GLP-1 medicines, while a further eight percent had considered or were considering them.
The effect on eating behaviour can be substantial. In a 60-week double-blind randomised controlled trial, semaglutide 2.4mg produced a roughly 270kcal greater reduction in ad-libitum test-meal energy intake than placebo at week 60, even though differences in subjective appetite were no longer significant.
For product developers, that creates a deceptively difficult task of putting more nutritional value into less food.
Shrinking the portion is the easy part. Making that smaller meal deliver enough protein, fibre, vitamins and minerals, while still tasting good and earning its place in the shopping basket, is considerably harder.”
More protein is only part of the answer
Protein has predictably become one of the first places developers look.
There are good reasons for that. A 2025 joint advisory from four US nutrition and obesity organisations identified nutritional quality, adequate protein and preservation of muscle and bone as being priorities accompanying GLP-1 therapy for obesity.
Yet the evidence cautions against reducing the GLP-1 nutrition challenge to a mere protein target.
A 2026 systematic review and meta-analysis covering 20 randomised controlled trials involving 15,782 participants found that lean mass represented 35.2 percent of weight lost with semaglutide, 26.8 percent with liraglutide and 25.4 percent with tirzepatide. Intensive lifestyle interventions produced a comparable figure of 26.2 percent, while lifestyle interventions incorporating resistance training had the lowest proportion, at 17.5 percent.
The findings thus caution against presenting lean-mass loss as a problem unique to GLP-1 medicines or protein enrichment as a complete solution.
The picture becomes more complicated when micronutrients are considered. A 2026 narrative review identified evidence of micronutrient deficiencies and inadequate intakes among GLP-1 receptor agonist users, including concerns around vitamin D, iron and calcium. However, as only six studies met its inclusion criteria, the evidence was predominantly observational and causality could not be established.
The opportunity is therefore broader than creating a miniature high-protein ready meal. Smaller portions concentrate the development challenge. Every gram has to work harder nutritionally, while taste, texture, tolerance, convenience and value must still compete with conventional products.
Working out what belongs in the product is only half of that challenge. Once developers have translated the emerging science into a formulation, they must then consider what they can actually say about it.
When the science outruns the claim
This is where the pace of nutritional research can diverge from the pace of regulation.
Research into satiety, appetite, nutrient sensing and metabolic responses may point towards new formulations and ingredients. Yet in Great Britain, health claims used in commercial communications must be authorised and included in the GB Nutrition and Health Claims Register.
Claims referring to slimming or weight control, reduced hunger or increased satiety fall within the health-claims framework, while claims referencing the rate or amount of weight loss are prohibited.
For Charlie Hennig, Associate at international law firm Osborne Clarke, that makes the register an important checkpoint early in development.
“Where we’re looking at things such as satiety and weight, there aren’t many authorised claims on there,” she explains. “So when you go into the Nutrition and Health Claims Register, [you must] look to see exactly what’s authorised which will determine what you can and can’t claim, because it may be that what you’re trying to claim may not be an authorised health claim and therefore cannot be made.”
That creates an important distinction between what informs a formulation and what can support a consumer-facing claim. A food could be developed around a smaller eating occasion or formulated to contain more protein or fibre, without necessarily having a regulatory basis to claim effects on appetite, satiety, weight loss or GLP-1 itself.
Nor is that tension confined to GLP-1. M&S has, for example, recently called for changes to authorised fibre health claims, arguing that terminology including “faecal bulk” and “intestinal transit” can make recognised benefits difficult to communicate meaningfully to shoppers.
What do common nutrition claims require?
Under the GB nutrition and health claims framework:
- Source of protein: at least 12 percent of the food’s energy value must be provided by protein
- High protein: at least 20 percent of the food’s energy value must be provided by protein
- Source of fibre: at least 3g per 100g or 1.5g per 100kcal must be provided by fibre
- High fibre: at least 6g per 100g or 3g per 100kcal must be provided by fibre.
Meeting the threshold is only the starting point. Hennig stresses that businesses also need evidence to substantiate their claims.
“If you’re making claims… you have to be meeting the thresholds within those claims. And you need to have the evidence to back that up,” she says.
Even staying within the claims framework does not make positioning straightforward. What a product communicates can extend beyond the precise wording printed on the pack.
In May, the Advertising Standards Authority (ASA) considered the name GuLP-1. The regulator found that it implied the supplement could affect GLP-1 production and therefore constituted a specific health claim. Its advertising also included claims around cravings and weight loss and comparisons with injections.
The case is particularly interesting because GuLP-1 contained glucomannan, for which an authorised weight-loss health claim exists. That authorisation did not provide a basis for the broader GLP-1, appetite and weight-loss claims used in the advertising, while the ASA also found that the conditions for using the authorised claim had not been met.
For Hennig, the case demonstrates why apparently creative approaches to naming must still be assessed through the regulatory framework. She describes GuLP-1 as “a classic example of a creative way of using a name that strays into risk regualtory waters”, adding that businesses considering innovative ways of advertising GLP-1-related products should consider both the terminology and how consumers may perceive it.
The absence of a defined regulatory meaning for “GLP-1 friendly” is therefore only part of the positioning challenge. The GuLP-1 ruling shows how naming and overall presentation can also shape the regulatory position, even without an explicit claim.
That leaves developers with a more fundamental commercial decision. How closely must GLP-1 be tied to the product in the first place?
Is GLP-1 itself the market, or is its growth accelerating a broader opportunity for smaller, nutrient-dense foods?”
Does GLP-1 need to be on the pack?
Recent UK launches suggest there is more than one answer.
Morrisons’ Applied Nutrition Small & Balanced meals have been described as “GLP-1 friendly”, putting the emerging consumer group close to the centre of the proposition.
M&S’s Nutrient Dense range takes a broader approach. Its 20 products focus on nutrient density and reduced appetites, including those associated with weight-loss medicines, without making GLP-1 the identity of the range.
Neither establishes which strategy consumers will ultimately prefer. What they do expose is a more interesting strategic question. Is GLP-1 itself the market, or is its growth accelerating a broader opportunity for smaller, nutrient-dense foods?
Hennig sees scope to address the underlying need without making medicinal associations central to the marketing. She points towards smaller portions and authorised protein and fibre claims as possible approaches, while warning that greater emphasis on the medical side increases regulatory risk.
“I think for food businesses, there’s definitely ways in which they can explore other avenues, within a compliant way of communicating that their products are suitable for GLP-1 consumers; that they’re doing so in a more compliant way rather than going into the risky area of looking like they’re advertising prescription-only medicines, which is prohibited.”
There is also a commercial reason not to design too literally around today’s GLP-1 user. The medicines themselves are changing.
The UK Medicines and Healthcare products Regulatory Agency (MHRA) approved the UK’s first GLP-1 receptor agonist tablet for weight loss and weight management in June this year. In August, it authorised orforglipron for weight management and type 2 diabetes, making the UK the first country in Europe to approve the oral GLP-1 treatment.
As treatment formats evolve, products built around more enduring needs such as smaller portions, nutrient density and convenient nutrition may retain relevance beyond a particular medicine or mode of administration.
But whichever positioning route a business chooses, there is a point at which changing direction becomes considerably more expensive. That makes the timing of regulatory input almost as important as the advice itself.
The most expensive time to ask legal
By the time a recipe has been signed off, a name chosen and thousands of packs printed, a regulatory problem has stopped being theoretical.
Hennig argues that regulatory and claims strategy should therefore enter product development at the beginning, rather than once the proposition is ready to launch.
“If you’ve got the product development team developing a product and it’s going to be calling out GLP-1, and from there they start producing the packaging, spending money developing the name and recipes, then at the last minute they bring legal in and say, ‘This is our new product. We’re about to launch it next week. Is that okay?’ it is likely legal are going to say, ‘Well, no, actually the regulatory area in this space is really hot and using the word GLP-1 may be deemed a health claim and advertising of prescription-only medicines is prohibited, making it very important to have those conversations at the start of product development.’”
Whether a GLP-1 reference constitutes a health or medicinal claim will depend on its context and the overall impression of the communication. The practical problem of discovering this at a late stage is the lack of remedial options.
An advert might need new creative, an unsupported nutrition claim could require reformulation and a problematic product name can affect packaging, artwork, marketing assets and retailer conversations simultaneously.
That risk sits against a wider GLP-1 advertising environment already receiving intense scrutiny. In decisions published on 2 October, the MHRA said nine weight-loss treatment-service providers had amended their advertising following regulatory action, including over indirect references to weight-loss injections or GLP-1 medication likely to lead consumers to request prescription-only medicines.
Those cases concern medicinal treatment services rather than foods; this distinction matters. It nevertheless illustrates the scrutiny surrounding public-facing promotion of GLP-1 prescription medicines.
For Hennig, that brings the argument back to when regulatory questions are asked during development.
“Once you’ve produced a product and you’re producing the packaging and you’re getting ready to launch it, if you haven’t considered the regulatory constraints around it, that launch is going to be delayed and it could cost the business a lot of money,” she says. “So it’s really ensuring that you’ve got early planning and you’re looking at the regulatory framework as a whole when you’re developing that product, especially when it comes to more novel areas such as products for GLP-1 users”
Five questions to ask before GLP-1 food product signoff
- What consumer need is the product addressing?
Define the nutritional or eating occasion before deciding how closely GLP-1 needs to feature in the proposition. - Can the formulation support the intended claims?
Check compositional thresholds while recipes can still be altered. - What does the complete proposition communicate?
Review the product name, pack design, imagery, portion format and advertising together. - What does the evidence actually support?
Separate emerging nutritional research, evidence used to inform formulation and claims authorised for consumer communication. - How much flexibility remains?
Consider regulatory developments and intended markets before committing to names, packaging and claims that could be expensive to change.
Taken together, these questions suggest that the lasting impact of GLP-1 on food innovation may extend far beyond products carrying the term on pack.
Smaller appetites put greater pressure on each eating occasion to deliver. Emerging science creates new formulation possibilities, but existing claims rules constrain how those benefits can be communicated. Meanwhile, rapidly evolving medicines make propositions built too tightly around today’s treatment experience vulnerable to becoming outdated.
The strongest development process therefore considers three questions before formulation is locked: What does the evidence show? What can the product meaningfully deliver? And what can the business credibly communicate?
Answering them together gives businesses a better chance of developing products with relevance beyond the current GLP-1 moment.
UPCOMING WEBINAR | Developing foods for the GLP-1 era: reformulation, claims and market readiness | 15 October 15:00 BST

As GLP-1 medicines reshape eating habits, food developers face new questions around nutrition, formulation, claims and product positioning.
Join our webinar on 15 October 2026 at 3pm BST, where Professor Gary Frost, Chair in Nutrition and Dietetics at Imperial College London; Dager Florez, Chief Commercial & Operations Officer at Alianza Team; and Pete Martin, Regulatory Specialist at Clavis Food and Trading Law Support will explore how changing appetites are influencing food development, what the emerging science means for formulation, and how businesses can navigate claims and regulatory requirements.











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