The BDA has responded to the consultation on application of the 2018 Nutrient Profiling Model (NPM), an important step in strengthening action on diet-related ill health, and a key recommendation outline in the NHS 10 year plan. Our response highlights support for the updated model and outlines key considerations for implementation.
The proposed application of the updated NPM is a significant opportunity to improve population health. Evidence in our responses highlights that applying the 2018 model to policy could prevent over 110,000 cases of childhood obesity and nearly 520,000 cases in adults, alongside wider health improvements including reductions in conditions such as type 2 diabetes and hypertension.
The dietetic workforce will recognise the need behind these proposals. Despite longstanding recommendations to reduce free sugar intake, only a small proportion of children currently meet these guidelines, while obesity and diet-related ill health continue to rise. Updating the NPM is therefore seen as essential to align policy with current scientific evidence, modern dietary guidance, and the realities of today’s food environment.
Key points from our response
1. Support for applying the new NPM
The consultation response supports applying the updated model to advertising and promotions, recognising it as a necessary step to achieve the government’s ambition of improving child health and tackling obesity, as outlined in the NHS 10 year plan.
Early evidence from existing placement regulations already suggests progress, with reductions in sales of less healthy products. Strengthening these policies through the updated NPM is expected to further increase impact.
2. Gaps remain in current product categories
The updated NPM is expected to better capture foods contributing to excess calorie and free sugar intake in children, while also providing an opportunity to expand the scope of products and calls for the government to regularly review the NPM in line with dietary guidance.
While supportive overall, our response identifies important gaps in the scope of products captured. Foods such as pies, pastries, processed meats, and other commonly consumed items high in nutrients of concern are not always included, despite their likely contribution to poor dietary outcomes.
Addressing these gaps will be essential to ensure the policy delivers its full public health potential.
3. Need for clarity on free sugars calculation
One of the most significant challenges identified is the need for clearer, standardised approaches to calculating free sugars within the NPM.
Current limitations in data availability, such as missing ingredient-level information and gaps in food composition databases, make it difficult to apply the model consistently and transparently.
Improving technical guidance and data transparency will therefore be critical to ensure the model is robust, defensible and workable in practice.
4. Implementation and enforcement considerations
The response supports a 12-month implementation period, noting that there has been long-standing awareness of potential changes.
However, effective implementation will depend on:
- clear and consistent guidance
- adequate resourcing for local enforcement teams
- practical tools to support compliance
The role of dietitians
The dietetic workforce, particularly those working in industry and public health, are recognised as critical to the success of the new NPM. They bring expertise in nutrient profiling, interpretation of guidance, and product reformulation, helping translate policy into real-world practice.
Our response advocated for stronger collaboration between policymakers and the dietetic workforce will be key to ensuring the updated NPM is applied consistently, transparently and in a way that reflects real-world food systems. The dietetic workforce can help bridge the gap between technical policy requirements and practical implementation, supporting accurate nutrient profiling, advising on meaningful reformulation, and helping organisations understand how changes should translate into healthier food environments for all.
Looking ahead
Overall, the consultation represents a pivotal moment in the UK’s approach to food policy. By updating the NPM and applying it across existing policy, such as advertising restrictions and promotions, there is a clear opportunity to reduce exposure to less healthy products, improve dietary patterns, and support long-term health outcomes.
Acknowledgements
We would like to extend our sincere thanks to colleagues at the Obesity Health Alliance (OHA) for convening the working group, to which the BDA contributed, their leadership and collaboration throughout this work.
We also recognise the invaluable contribution of members of the BDA Public Health Specialist Group and wider academic colleagues, whose expertise and evidence have been instrumental in shaping a strong, evidence-based response to this consultation.
With special thanks to Dr Sally Moore RD, University of Leeds School of Food Science and Nutrition (Committee member and former Chair of the Public Health Specialist Group) and Liv Chessell, University of Leeds School of Food Science and Nutrition (Msc Nutrition research student) for providing strong evidence to support the BDA’s response.
