Guide · Nutrient profiling
HFSS explained — the nutrient profiling score, step by step
“HFSS” — high in fat, sugar or salt — is not a label and not a colour. It is a score, worked out from seven numbers per 100 g, that decides whether a product may sit at the checkout, be sold three for two or be advertised. Here is the score, the products it applies to and the businesses it covers.
Where the rules are
- Since 1 October 2022, England — placement in store and online: Food (Promotion and Placement) (England) Regulations 2021.
- Since 1 October 2025, England — volume price promotions and free refills: the same regulations, reg. 5 and 6.
- Since 5 January 2026, UK-wide (date according to DHSC) — advertising on TV and online: Communications Act 2003, with the Advertising (Less Healthy Food Definitions and Exemptions) Regulations 2024.
- Since 1 October 2026, Scotland — promotion and placement: Food (Promotion and Placement) (Scotland) Regulations 2025.
None of them puts anything on the pack. They all use the same test of whether a product is “less healthy”: the English regulations define it as a food that “scores 4 or more points”, and a drink that “scores 1 or more points in accordance with the Nutrient Profiling Technical Guidance”. The Scottish regulations use the same thresholds and the same guidance.
The score in three steps
The Nutrient Profiling Technical Guidance (Department of Health, January 2011) applies the 2004–05 nutrient profiling model. It works on 100 g of the product — “irrespective of the amount of product which is consumed” — and “applies equally to all food and drink; there are no exemptions or category-specific criteria”.
Step 1: ‘A’ points, up to 10 each
| P | Energy kJ | Sat. fat g | Sugar g | Sodium mg |
|---|---|---|---|---|
| 0 | ≤ 335 | ≤ 1 | ≤ 4.5 | ≤ 90 |
| 1 | > 335 | > 1 | > 4.5 | > 90 |
| 2 | > 670 | > 2 | > 9 | > 180 |
| 3 | > 1005 | > 3 | > 13.5 | > 270 |
| 4 | > 1340 | > 4 | > 18 | > 360 |
| 5 | > 1675 | > 5 | > 22.5 | > 450 |
| 6 | > 2010 | > 6 | > 27 | > 540 |
| 7 | > 2345 | > 7 | > 31 | > 630 |
| 8 | > 2680 | > 8 | > 36 | > 720 |
| 9 | > 3015 | > 9 | > 40 | > 810 |
| 10 | > 3350 | > 10 | > 45 | > 900 |
Labels show salt, the model wants sodium. The conversion is the one the labelling rules use the other way round, “salt = sodium × 2,5”: divide salt by 2.5 and multiply by 1 000 for milligrams. 1.0 g of salt is 400 mg of sodium.
Step 2: ‘C’ points, up to 5 each
| Points | NSP fibre | AOAC fibre | Protein |
|---|---|---|---|
| 0 | ≤ 0.7 | ≤ 0.9 | ≤ 1.6 |
| 1 | > 0.7 | > 0.9 | > 1.6 |
| 2 | > 1.4 | > 1.9 | > 3.2 |
| 3 | > 2.1 | > 2.8 | > 4.8 |
| 4 | > 2.8 | > 3.7 | > 6.4 |
| 5 | > 3.5 | > 4.7 | > 8.0 |
Fibre and protein in grams per 100 g. Fruit, vegetables and nuts score by their share of the product: more than 40 % gives 1 point, more than 60 % gives 2, more than 80 % gives 5 — there is no 3 or 4. Use NSP fibre “where this is known”, otherwise AOAC. Fruit, vegetables and nuts count only when intact or minimally processed; potatoes do not count, and dried fruit is weighed double.
Step 3: subtract — with one catch
The overall score is A minus C. The catch, in the guidance’s own words:
“If a food or drink scores 11 or more ‘A’ points then it cannot score points for protein unless it also scores 5 points for fruit, vegetables and nuts.”
So for most rich products, protein does not help. Then: food at 4 or more is less healthy; a drink at 1 or more.
Two worked examples
Illustrative values per 100 g:
| Croissant | Wholemeal roll | |
|---|---|---|
| Energy | 1 720 kJ → 5 | 1 000 kJ → 2 |
| Sat. fat | 13 g → 10 | 0.5 g → 0 |
| Sugars | 9.5 g → 2 | 3 g → 0 |
| Sodium | 300 mg (salt 0.75 g) → 3 | 400 mg (salt 1.0 g) → 4 |
| A points | 20 — 11 or more, protein will not count | 6 |
| Fibre (AOAC) | 2.0 g → 2 | 6 g → 5 |
| Protein | 8.0 g → not counted | 10 g → 5 |
| Fruit, veg & nuts | 0 % → 0 | 0 % → 0 |
| Score | 20 − 2 = 18 → less healthy | 6 − 10 = −4 → not less healthy |
The seven inputs are the values of a nutrition declaration plus fibre and the fruit, vegetable and nut share — which is why the work starts with the recipe. Our free nutrition calculator gives the per 100 g values from your ingredients.
Which products are in scope
A score of 4 is not enough on its own. The promotion and placement rules apply to “specified food”: food in a prepacked item that falls in one of the thirteen categories of Schedule 1 and is less healthy. The categories, shortened:
- soft drinks with added sugar;
- savoury snacks such as crisps, popcorn, pretzels;
- breakfast cereals, including granola, muesli and porridge oats;
- confectionery, chocolate and sweets;
- ice cream, lollies and similar frozen products;
- cakes and cupcakes;
- sweet biscuits and bars based on nuts, seeds or cereal;
- morning goods — “croissants, pains au chocolat and similar pastries, crumpets, pancakes, buns, teacakes, scones, waffles, Danish pastries and fruit loaves”;
- desserts and puddings, including pies, tarts, cheesecake and gateaux;
- sweetened yoghurt and fromage frais;
- pizza, except plain bases;
- roast potatoes, chips, wedges and similar potato products;
- ready meals, main-meal products in sauce, and breaded or battered products.
Three of the thirteen are bakery categories; bread is in none of them. And “prepacked” means prepacked food as defined in Article 2(2)(e) of Regulation 1169/2011, which excludes food prepacked for direct sale. Whether cakes packed and sold in the same shop are therefore outside the rules is our reading of the definition, not a statement in the regulations.
Which businesses it covers
In England, the promotion and placement rules apply to a “qualifying business” (regulation 4). It sells prepacked food to consumers, and “on the first day of the financial year … the business had 50 or more employees”. Restaurants, care homes and educational institutions are excluded from the promotion and placement rules (drink refills aside). Scotland uses the same 50-employee threshold.
The placement rule then has two further exclusions of its own (regulation 7(2)):
- “stores with a relevant floor area of less than 185.8m2”;
- “stores which only or mainly sell food from a single category listed in Schedule 1”.
What is restricted: placing specified food within two metres of a checkout or queuing area, at aisle ends on a main route, near the entrance, and in a covered entrance area; and, since 1 October 2025, “volume price promotions” — “3 for the price of 2”, “buy one get one free”, “50% extra free”. Meal deals are not caught by the multibuy definition.
The advertising rules have their own threshold: the 2024 regulations define a “food or drink SME” as a business that “employs fewer than 250 people”. How the restrictions apply to them is set out in the Communications Act 2003 and the DHSC guidance; this article covers the in-store rules.
A newer model, the “NPM 2018”, was published in January 2026. DHSC says it “is not yet applied to policy”: the 2004–05 model above is the one the regulations name.
HFSS is not the same as the traffic light label. A product with no red light at all can still be less healthy: with amber values at the top of each band (saturates 5.0 g, sugars 22.5 g, salt 1.5 g per 100 g) and 1 500 kJ, the ‘A’ points alone come to 18.
Frequently asked questions
What does HFSS mean?
High in fat, sugar or salt. In the regulations the term is “less healthy”: a food that scores 4 points or more, or a drink that scores 1 point or more, on the 2004–05 nutrient profiling model.
Do the HFSS rules apply to small businesses?
The promotion and placement rules in England and Scotland apply only to businesses with 50 or more employees that sell prepacked food. The placement rules also exclude stores with a relevant floor area of less than 185.8 square metres.
Is HFSS a labelling requirement?
No. Nothing has to be printed on the pack. The HFSS rules restrict where less healthy products may be placed in a store, which price promotions may be used, and how they may be advertised.
Are cakes and pastries HFSS?
They are in scope: cakes and cupcakes, morning goods such as croissants and scones, and desserts such as pies and tarts are three of the thirteen product categories. Whether a particular product is “less healthy” depends on its nutrient profiling score.
This article is general information and does not replace legal advice. Quoted from legislation.gov.uk: the Food (Promotion and Placement) (England) Regulations 2021 (S.I. 2021/1368), revised version in force from 1 October 2025; the Food (Promotion and Placement) (Scotland) Regulations 2025 (S.S.I. 2025/303) as made; the Advertising (Less Healthy Food Definitions and Exemptions) Regulations 2024 (S.I. 2024/1266). The scoring tables are from the Department of Health’s Nutrient Profiling Technical Guidance, January 2011. The date of the advertising restrictions is taken from DHSC guidance of 4 June 2025.