Lancet urges UPF taxes; UK FMCG faces policy risk
International experts writing in The Lancet have called for front‑of‑pack warnings and higher taxes on ultra‑processed foods (UPFs). The Series, published on 18 November 2025, reviews 104 long‑term studies and links high UPF intake with greater risk of 12 health conditions including type 2 diabetes, cardiovascular disease and depression. For UK consumer staples, that points to rising policy risk over the next 12–18 months, as reported by Reuters and the Guardian.
UPFs, under the Nova classification, are industrial formulations often containing additives such as emulsifiers, preservatives, colourings and sweeteners; examples include soft drinks, biscuits, instant noodles, some packaged breads and ready meals. The British Nutrition Foundation and the government’s Scientific Advisory Committee on Nutrition (SACN) both note that Nova does not always align with UK dietary advice and that most evidence is observational, which complicates rule‑making.
The current UK rulebook is already shifting. Location‑based restrictions on products high in fat, salt and sugar (HFSS) took effect in October 2022, removing HFSS items from checkouts, aisle ends and store entrances. A ban on HFSS volume‑price promotions such as multibuys is due to start on 1 October 2025 in England. Advertising rules are next. The government has delayed the pre‑9pm TV watershed and online junk‑food ad ban to 5 January 2026, while the Food Standards Agency says it is tracking emerging evidence on UPFs and commissioning new research. The World Health Organization began work this year to develop a UPF consumption guideline, signalling a wider international push.
For investors, the closest UK template is the Soft Drinks Industry Levy (SDIL). HMRC confirms the levy’s uprated bands from 1 April 2025-£1.94 per 10 litres for 5–7.9g sugar per 100ml and £2.59 per 10 litres for 8g+, up from the original 18p/24p per litre in 2018. Treasury’s 2024 review cites extensive reformulation, with an average 46% reduction in sugar in in‑scope drinks, while Oxford’s Nuffield Department of Population Health reports sustained falls in sugar purchased without lasting damage to overall soft‑drink volumes.
If ministers respond to The Lancet with UPF‑specific warnings or a new levy, the design choices will be pivotal. A scheme anchored in nutrient thresholds or the existing HFSS framework would be simpler to enforce than one based solely on Nova. Health groups have already urged government to extend the sugar levy approach to items like cakes and biscuits, an idea that would push reformulation and pricing strategy back to the centre of boardroom planning.
Industry groups are preparing their case. The Food and Drink Federation points to Kantar data showing member products now contain about a third less salt and nearly a third less sugar than a decade ago, alongside lower calories-evidence, they argue, that voluntary reformulation is working and deserves policy support and R&D incentives. Global manufacturers, via the International Food and Beverage Alliance, say using “processing” as a policy trigger goes beyond the evidence and could restrict access to affordable, shelf‑stable foods.
The scientific debate will run hot. Statisticians and methodologists caution that the Lancet Series synthesises mainly observational research, which can show association rather than cause and effect; the Science Media Centre highlights concerns about how precisely UPF intake is measured and classified. The Series’ authors counter that the consistency of the associations across dozens of cohorts is enough to justify government action while mechanisms are studied.
Our read for UK equities is straightforward: categories heavy in packaged snacks, confectionery, ready meals, ice cream and sugary drinks face the greatest policy sensitivity. The SDIL experience suggests a likely sequence-reformulation, packaging changes and portfolio mix shifts-rather than a cliff‑edge in demand. Academic and government reviews of the SDIL indicate material sugar reductions with limited long‑term volume damage to drinks makers, though margins can be pressured by recipe work, capex and marketing resets.
Retailers will feel the change at shelf edge. The 2025 ban on HFSS multibuys will force a pivot from deep promotions to price architecture and own‑label tiering, while the 2026 ad rules will reduce above‑the‑line support for certain SKUs. Range rationalisation, aisle planning and digital merchandising will need another round of updates to stay compliant and protect basket size.
Short‑term, watch three dates. First, 1 October 2025 for England’s HFSS multibuy ban. Second, 5 January 2026 for the online and pre‑watershed ad restrictions. Third, tonight’s London launch of The Lancet Series, which will keep UPFs on the policy agenda through 2026 as WHO work continues. Policy risk is moving from discussion to rule‑writing.
Practical takeaway for CFOs and CMOs: model an excise‑style scenario using SDIL‑type bands as a proxy, stress‑test reformulation timelines, and rebase media plans ahead of the January 2026 ad rules. The firms that move early on recipes, pack sizes and claim frameworks usually defend volume better and keep pricing power when the rules change.