HFSS Nutrient Profiling in Scotland

What nutrient profiling is and what it does

Nutrient profiling is a statutory classification tool built into the Scottish HFSS regulatory framework. The Food (Promotion and Placement) (Scotland) Regulations 2025 use it to determine whether a product in an in-scope category qualifies as relevant food for the purposes of the promotion and placement restrictions. The mechanism provides a consistent basis for classification across a wide range of products and categories.

This page explains the role of nutrient profiling within the wider framework. It does not reproduce the profiling calculation, provide a scoring tool, or classify specific products. The profiling mechanism is defined by reference within the Regulations and operates as described in the statutory framework.

Profiling as the second stage of classification

As explained in the HFSS food classification page, the classification process works in two stages. The first stage is product category: the food must fall within a category that the Regulations bring into scope. The second stage is nutrient profiling: the product must meet the profiling criteria applicable to that category.

Nutrient profiling is therefore not a standalone classification system — it operates within the context of the category structure established by the Regulations. A product in an excluded category is not subject to nutrient profiling for the purposes of the framework, regardless of its nutritional composition.

What the profiling mechanism assesses

The nutrient profiling model assesses defined nutritional components of a product against criteria set out in the statutory framework. The model was developed as a policy tool to allow systematic categorisation of food products by nutritional characteristics relevant to the public health objectives behind the Regulations.

The detailed operation of the profiling model — including the components assessed, the criteria applied, and the scoring structure — is established by reference within the statutory framework. This page describes the general role and purpose of the mechanism rather than its technical operation. The HFSS Regulations publication provides commentary on how classification, including profiling, operates within the framework.

What profiling determines — and what it does not

The nutrient profiling mechanism determines whether a product in an in-scope category meets the threshold to be treated as relevant food. It does not make a finding about nutritional quality in a broader scientific or medical sense. A product above the profiling threshold is relevant food for the purposes of the Regulations. A product below the threshold in an in-scope category is not relevant food, even if it might informally be considered less healthy than alternatives.

This distinction matters because classification under the Regulations is a legal question determined by the statutory framework, not an informal assessment of whether a product is good or bad for health. The question of which products are commonly associated with HFSS classification is addressed in the HFSS food list explainer.

Nutrient profiling and product reformulation

Because the profiling mechanism operates by reference to nutritional composition, reformulation of a product may affect its classification under the Regulations. Whether reformulation changes the classification of a product depends on whether the reformulated version meets the profiling criteria. The Regulations govern the method of classification. This page does not assess reformulation decisions for specific products.

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