22 Jun 2026 HFSS Is Broken by Design — And the Nutrient Profiling Model Still Can’t Fix It
For nearly two decades, the UK’s Nutrient Profiling Model (NPM) has been treated as the scientific backbone of High Fat, Salt and Sugar (HFSS) regulation. Yet both the original 2004/5 model and the updated 2018 version share the same fundamental flaw: they were built on an incomplete understanding of carbohydrates, and they continue to misclassify one of the most widely used processed-food ingredients in the modern diet, – maltodextrins.
The result is a regulatory framework that looks rigorous on paper but fails in practice.
The Maltodextrin Problem: A Blind Spot That Undermines the Entire System
Maltodextrins are starch-derived carbohydrates used extensively in processed foods for bulking, texture, and to improve mouthfeel. They are everywhere: in breakfast cereals, “no-added-sugar” drinks, infant foods, sports supplements, sauces, and even products marketed as “healthy”.
Fundamental misclassification and an error:
- Resistant maltodextrin is classified as fibre and therefore earns positive points in the NPM.
- Digestible maltodextrins, which behave metabolically like sugar, are excluded from the model entirely.
This is not a minor technicality. It is a structural defect.
Digestible maltodextrins have a glycaemic index close to glucose (95-100%). They raise blood sugar rapidly. They contribute to energy density. They are used as sugar replacers precisely because they deliver similar functional effects. Yet under both NPM 2004/5 and NPM 2018, they are treated as if they barely exist. A model that claims to regulate “sugar” but ignores a sugar-like ingredient used in thousands of products is not fit for purpose. It never was.
A few examples illustrate how absurd the current situation has become.
- Breakfast Cereals That Game the System
A cereal can reduce sucrose, add resistant maltodextrin to boost its “fibre” score, and still rely on digestible maltodextrins and sweeteners for sweetness and texture. The NPM rewards it. The consumer gets a product that behaves like a sugar-sweetened cereal in all but name.
- Children’s Snacks That Look Healthy on Paper
Many toddler snacks marketed as “no added sugar” use maltodextrins as a primary carbohydrate source. Parents assume they’re making a better choice. The NPM effectively endorses this illusion.
These are not edge cases. They are mainstream products on UK shelves today.
Why the 2018 Update Didn’t Fix the Problem
The 2018 revision of the NPM was intended to modernise the model and align it with updated dietary guidance. But it left the maltodextrin loophole untouched. The scientific understanding of carbohydrate quality has advanced dramatically since 2004. We now know that:
- Glycaemic response matters
- Ultra-processed carbohydrate structures matter
- The distinction between “sugar” and “not sugar” is nutritionally meaningless when the metabolic effect is the same
This is not science-based regulation. It is regulatory inertia.
A Model That Cannot Deliver the Policy Outcomes It Promises
HFSS policy aims to reduce childhood obesity, improve dietary quality, and shift the food environment toward healthier options. But a nutrient profiling system that ignores a major class of sugar-like carbohydrates cannot deliver those outcomes.
If the model can be gamed, it will be taken advantage of, particularly when the ingredient in question is cheap. If the model rewards reformulation tricks rather than genuine nutritional improvement, industry will follow the incentives. And if the model misleads consumers, it undermines public trust.
The UK deserves better than a framework that allows products high in rapidly digestible carbohydrates to masquerade as “healthier choices”.
What Needs to Happen Next
To restore credibility, the government must:
- Acknowledge that the current and 2018 NPM are outdated and scientifically incomplete.
- Reclassify digestible maltodextrins as sugars for regulatory purposes.
- Ensure that fibre scoring reflects physiologically meaningful fibre, not ingredients that are detrimental to health.
- Commission an independent scientific review of carbohydrate classification within HFSS regulation.
This is not about punishing industry. It is about aligning regulation with modern nutrition science and protecting consumers, especially children, from misleading health claims and ultra-processed formulations. The UK’s HFSS framework was built on a nutrient profiling model that never fully understood the ingredients it was meant to regulate. The maltodextrin loophole is not a technical footnote; it is a fundamental design flaw that distorts the entire system.
If we want HFSS regulation to work, we must stop pretending that the 2004/5 and 2018 models are adequate. They are not. And until we fix the carbohydrate classification at their core, the UK will continue to regulate today’s food environment with yesterday’s science.
