IN Brief:
- Sixty-nine per cent of respondents said greater regulatory certainty would support further healthier product innovation.
- Large businesses reported reformulation costs of up to £5 million per project, with one packaging change reaching £500,000.
- FDF wants health-related regulation to remain stable for five to ten years and is seeking a pause to proposed Nutrient Profiling Model changes.
The Food and Drink Federation is calling for five to ten years of stability in health-related regulation after research conducted with Argon & Co found that changing policy benchmarks are affecting investment decisions around healthier food and drink. Sixty-nine per cent of respondents said greater regulatory certainty would support further healthier product innovation, while every manufacturer interviewed highlighted a mismatch between short policy cycles and the multi-year planning required to develop, validate, and commercialise reformulated products.
Large businesses participating in the research put the cost of an individual reformulation project at up to £5 million once ingredients, testing, skilled staff, marketing, and production downtime were included, with one company reporting packaging and artwork write-offs of up to £500,000 following a recipe change. Ten businesses were able to quantify their reformulation costs for 2025, giving the study a limited but concrete view of how quickly technical development can spread into manufacturing, packaging, and commercial budgets.
Recipe development represents only one stage of that expenditure because reducing salt, sugar, fat, calories, or another nutritional characteristic can alter the way a product behaves during processing as well as how it tastes. Ingredient functionality, viscosity, moisture control, bake profile, emulsion stability, texture, fill weight, thermal processing, and shelf life can all shift when a formulation changes, requiring pilot work and factory trials before a revised recipe can be transferred into routine production.
Packaging may then need to follow the product change, particularly where nutritional declarations, ingredients, claims, preparation instructions, or portion information are affected, which turns a formulation project into an artwork, inventory, and production planning exercise. Existing packaging stocks can become obsolete before they have been consumed, while new printed material has to be approved and delivered in time for the reformulated product to move through manufacturing without creating a gap in supply.
The commercial return remains uncertain even after those costs have been absorbed. Sixty-nine per cent of respondents reported having a healthier product fail to reach launch or subsequently be removed by retailers, while 63% had experienced sales below expectations, leaving businesses exposed to development costs that may not be recovered through sustained volume once the product reaches the market.
Those failure rates sit alongside substantial development activity rather than an absence of reformulation, with 63% of businesses completing at least six healthier product innovation projects each year, 81% having reformulated products, and half reporting that regulation had increased their innovation activity. FDF says products made by its members now contain 18% less salt, 19% less sugar, and 17% fewer calories than in 2021, figures that it is using to support its case that companies have already committed substantial technical resources to nutritional change.
The immediate policy dispute centres on the Nutrient Profiling Model used to underpin advertising and promotion restrictions, with the Government consulting on changes only months after the latest rules came into force. FDF wants that process paused and is seeking a longer period during which manufacturers can invest against a stable benchmark, an industry position that will ultimately be weighed against the Government’s public health objectives and any evidence supporting a revised model.
Technical teams do not gain certainty simply because a rule remains unchanged, since retailer specifications, ingredient prices, consumer preferences, and scientific guidance can continue to move, but regulatory stability removes one source of redesign from a process already carrying considerable commercial risk. A product developed against one nutritional threshold can require another round of formulation and validation if the benchmark moves before the original investment has had time to generate a return.
Smaller suppliers face the same sequence with less room to absorb failure, particularly where specialist development work, laboratory testing, or production trials have to be bought externally. James Watson, partner and head of UK manufacturing at Argon & Co, warned that the combination of reformulation cost and recent operating pressures could discourage suppliers from continuing to invest, while FDF is also seeking broader consumer education and more consistent measurement of healthier food sales.
Mandatory reporting of healthier product sales forms another part of the federation’s policy position, with five manufacturers already committed to reporting from next year and FDF arguing that a common measure across the food system would make it easier to judge whether reformulation activity is changing purchasing behaviour. Better sales evidence would not eliminate the technical cost of changing products, although it could give policymakers and manufacturers a clearer basis for assessing which interventions are producing measurable shifts in the market.
The debate therefore reaches further into production than an advertising classification might suggest, since nutritional benchmarks can ultimately affect ingredients, processing conditions, line trials, packaging inventories, quality assurance, retailer approval, and capital allocation. FDF is asking government to give those investments a longer regulatory life; whether that position is adopted will depend on the wider policy process, but the cost data shows why repeated changes can reach the factory well before a reformulated product appears on shelf.
