Less sugar, more pressure: Scotland’s HFSS rules force a food industry rethink

Key takeaways:

• Scotland’s HFSS regulations come into force on 1 October 2026, restricting promotions and prime shelf placement for products high in fat, sugar or salt across larger retail stores.
• Reformulation is becoming a long-term commercial strategy as manufacturers balance HFSS compliance with taste, texture, affordability and changing consumer expectations.
• FDF Scotland has launched a new grant fund worth up to £5,000 to help SME food and drink manufacturers cover reformulation costs including trial ingredients, nutritional analysis, consultant support and laboratory testing.

Reformulation is hardly new to the food industry. Manufacturers have been quietly changing recipes for years, sometimes to hit retailer nutrition targets, sometimes because ingredient prices changed, and sometimes because consumer tastes moved on.

Salt reduction programmes have been running for more than a decade; then sugar targets followed. Fibre enrichment, protein claims and calorie reduction soon became part of mainstream product development, too.

What’s different now is the pressure attached to the process.

From 1 October 2026, Scotland’s HFSS restrictions will mean products classified as high in fat, sugar or salt could lose access to some of the most commercially valuable promotional space in supermarkets.

The stakes are significant. Before England introduced its HFSS placement restrictions in 2022, Kantar estimated affected products represented roughly £18bn in annual UK food and drink sales – around 16% of the market at the time. Since then, retailers and manufacturers have already seen major changes to store layouts, promotional planning and category strategy.

There are already signs the policy is changing shopping behaviour. Research published in 2025 by the University of Leeds examining sales data from 480 supermarket stores across England found HFSS placement restrictions introduced in October 2022 were linked to around two million fewer in-scope HFSS products being sold per day. The study analysed 11.6 billion product sales across Tesco, Sainsbury’s, Asda and Morrisons over a 30-month period.

A separate survey of 1,968 shoppers in England, published in 2023 in BMC Medicine by researchers from the University of Southampton, found 71.4% viewed the legislation as ‘a good first step’ towards healthier eating. However, almost 90% said the affordability of healthier food was equally or more important than restricting HFSS promotions.

From 1 October 2026, products deemed high in fat, sugar or salt (HFSS) will face restrictions on where and how they can be promoted in larger stores throughout Scotland. Checkout displays, aisle-end promotions, multibuy deals and certain seasonal promotions will disappear for in-scope products that fail the UK Nutrient Profile Model.

According to Joanne Burns, Reformulation for Health manager at FDF Scotland, the organisation is increasingly hearing from businesses trying to understand what the rules will mean in practice.

“Scotland’s food and drink manufacturers want to know more about the implementation and impact of the upcoming HFSS regulations for Scotland,” she said. “With less than six months to go until the 1st of October 2026 implementation date, it is essential that Scotland’s retail supply chain is ready for the impact of the HFSS regulations.”

As a result, reformulation is no longer sitting solely with technical and nutrition teams.

Manufacturers are also trying to do this at a time when ingredient costs remain unpredictable and consumer expectations are shifting. Shoppers still want indulgence and value, but they are also paying closer attention to labels, protein content, fibre and ingredient familiarity. That leaves product developers trying to satisfy multiple demands at once.

Against that backdrop, businesses are trying to work out how far recipes can evolve without losing the qualities consumers expect from familiar products.

When healthier means harder

The science behind reformulation is more complicated than it can appear from the outside.

Sugar, for example, affects everything from browning and texture to shelf life. Salt plays a role in flavour and preservation. Fat contributes texture and eating quality. Remove or reduce one element too aggressively and the final product can behave very differently during production or taste noticeably different once it reaches shelves.

That complexity explains why some reformulation projects take years rather than months.

FDF Scotland’s Reformulation for Health programme has spent the past several years supporting companies working on sugar reduction, salt reduction, fibre enrichment and calorie reduction projects.

The organisation recently launched a new grant fund worth up to £5,000 for Scottish SME food and drink manufacturers preparing for the October 2026 regulations. The funding can be used for trial ingredients, consultant support, nutritional software, laboratory analysis and other reformulation-related costs. Applications close on 31 May 2026.

Burns said the aim is to help smaller businesses navigate what can often become an expensive and technically demanding process. “We want to make sure that our much loved Scottish brands have the opportunity to prepare for these restrictions, understand how the legislation will affect them and be supported to adjust recipes to become compliant and avoid the restrictions if applicable,” she said.

“In short – we want to keep Scotland in the spotlight.”

Some of its most successful case studies show just how delicate the balancing act can become.

Growers Garden, a farmers’ collective based in Cupar, Fife, reformulated its broccoli crisps by cutting salt levels by more than 40%, while also reducing potato content to improve the product’s HFSS and VAT positioning. The business said reformulation was driven as much by commercial opportunity as public health.

“Our broccoli crisps have always been healthy,” it noted in an FDF Scotland case study. “But we recently looked at the market opportunities and direction and decided to reformulate.”

The company worked to lower salt levels in stages after finding larger substitutions affected flavour and texture. “We found that’s the point where you don’t impair the taste or texture of the end product,” it said after trialling calcium chloride in small increments.

The result helped the product gain approval for use in Scottish schools and the NHS, with the company noting that HFSS compliance had become one of the first questions retailers and wholesalers now ask.

“Being able to get it in front of children and into the NHS is important to us,” the company added.

Meanwhile, family-owned Tower Bakery, based in Abernethy, Perthshire, worked on fibre-enriched morning rolls after Stirling Council requested products with improved nutritional profiles for schools. “The reformulation process is not new to the business, who have been reformulating for years in order to meet retailers’ specification requirements,” said owner Angela McKinnony.

The bakery more than doubled fibre levels in the rolls from 2.1g per 100g to 4.3g per 100g while maintaining the appearance of a traditional white morning roll.

“It was important to Tower Bakery that the roll carried a similar appearance to their white morning roll, making it an easy transition for procurement and customers alike.”

McKinnon also highlighted how specialist support became essential during the process. “We wouldn’t have been able to use it if we hadn’t been told exactly where to source it from by our consultant,” she said, referring to a specialist powdered fibre ingredient eventually used in the formulation.

Elsewhere, Scottish meat producer Simon Howie explored salt and calorie reduction across products including haggis and black pudding – categories where consumers are often particularly resistant to recipe changes.

Other Scottish companies linked to reformulation work through FDF Scotland include Macsween of Edinburgh, Brownings the Bakers, Rowan Glen and Saltire Patisserie.

Burns said companies are increasingly looking for practical guidance rather than broad policy discussion, particularly around how products are scored under the Nutrient Profile Model and which categories fall within scope of the regulations.

The challenge for SMEs is that reformulation rarely involves one neat recipe change. A sugar reduction project might require new ingredients, fresh supplier agreements, reformulated packaging information, shelf-life testing, sensory panels, retailer approval and factory trials – all before a single updated product reaches shelves.

And even then, success isn’t guaranteed – a familiar headache for product developers.

Consumers say they want healthier products, but they also expect them to taste the same as they always have. In categories linked to comfort, routine or nostalgia, even relatively small changes can attract criticism from shoppers who immediately notice differences in flavour or texture. That balancing act sits at the centre of the current HFSS debate.

Public health groups argue reformulation is essential to improving diets at scale. Food Standards Scotland has repeatedly pointed to reformulation as one of the most effective ways to improve the nutritional quality of everyday foods without relying solely on individual behaviour change.

Manufacturers don’t necessarily disagree. The problem is that consumers still expect healthier products to taste exactly the same as before.

A commercial risk and a commercial opportunity

At the same time, few in the industry see reformulation purely as a regulatory burden. In fact, some manufacturers believe the next phase of reformulation could create opportunities for product innovation rather than simply regulatory compliance.

Some manufacturers are using reformulation projects to reposition products altogether. Instead of only talking about what has been reduced, brands are increasingly promoting what has been added back in – fibre, seeds, protein, wholegrains or functional ingredients linked to satiety and digestive health.

That approach can help products feel more premium rather than simply ‘less bad’.

It also mirrors broader consumer behaviour. Today’s shoppers aren’t only looking at calories. They’re examining protein content, satiety, ingredient familiarity and perceived naturalness. A product marketed as high in fibre or made with recognisable ingredients may resonate more strongly than one simply carrying a reduced-sugar claim.

That could support premium positioning as well as improved nutrition credentials. Manufacturers that successfully navigate reformulation may gain stronger health credentials, improved retailer relationships, and access to promotional freedoms unavailable to competitors that remain classified as HFSS.

Still, pressure on the industry is unlikely to ease.

Critics of voluntary reformulation programmes argue progress across some categories has been too slow, particularly compared with the impact of the UK Soft Drinks Industry Levy. Public health advocates continue to push for tighter intervention and broader restrictions.

For many manufacturers, reformulation is now becoming part of long-term product strategy rather than a temporary response to one set of regulations. It’s becoming a permanent part of modern product development.

And as Scotland edges closer to October, manufacturers across multiple food categories are confronting the same uncomfortable question: how far can you change a product before consumers decide it is no longer the product they loved in the first place?

Studies:

Alice R. Kininmonth, Victoria L. Jenneson, et al. Customer awareness and perceptions of the high in fat, sugar, and salt (HFSS) placement legislation and impacts on self-reported food purchasing. Food Policy, Volume 135, 2025, 102941, ISSN 0306-9192, https://doi.org/10.1016/j.foodpol.2025.102941.

Muir S, Dhuria P, Roe E, Lawrence W, Baird J, Vogel C. UK government’s new placement legislation is a ‘good first step’: a rapid qualitative analysis of consumer, business, enforcement and health stakeholder perspectives. BMC Med. 2023 Jan 26;21(1):33. doi: 10.1186/s12916-023-02726-9. PMID: 36703194; PMCID: PMC9878939.