Clean label sugar reduction: what actually works in the UK

A chilled dessert brand cut sugar by 30% to pull its NPM score down. The technical answer was a sucralose and erythritol blend. The buyer brief said clean label, so the team used date paste and apple juice concentrate instead.

Six weeks later the score hadn't moved, the "no added sugars" claim was gone, and water activity had crept up enough to cost them 9 days of shelf life.

That product now has a longer ingredient list, a worse score, and a shorter life. It also still looks clean on the back of pack, which was the only part of the brief it met.

This trade-off is about to land on a whole category at once. Milk-based drinks lose their Soft Drinks Industry Levy exemption on 1 January 2028, and the new threshold sits at 4.5g of sugar per 100ml. Flavoured milks and milkshakes are exactly the products where clean label positioning and sweetener use pull hardest against each other.

If you're formulating in that category, you have roughly 17 months. Worth knowing what each route actually costs you before you pick one.

Clean label has no legal definition

Clean label is a commercial term. No UK or EU food law defines it, sets criteria for it, or restricts its use. There is no threshold you clear and no register you appear on.

What it means in practice is set by retailer buying specifications, brand standards, and consumer expectation. That's why two buyers can reject two different ingredient lists and give you the same one-word reason.

Across most UK retailer specs, clean label tends to mean some combination of: a short ingredient list, ingredients a shopper would recognise as food, no E numbers, and no artificial sweeteners, colours, or flavourings.

None of that is a safety judgement. Every additive permitted under Regulation (EC) No 1333/2008 has been through a safety assessment, and E numbers exist precisely so that additives are declared consistently. Clean label is a positioning decision, and it costs you specific things.

The four routes out of sugar, and what each one costs

The bottom row is where most clean label briefs end up, and it's the row that solves the least.

Fruit sugars are still free sugars

Swapping sucrose for apple juice concentrate changes your ingredient list. It doesn't change your sugar.

Under the NPM 2018 update, scoring runs on free sugars, and sugars from fruit juice concentrate and fruit pastes are free sugars. So the score barely moves, and in some formulations it gets worse, because you've added water and had to compensate elsewhere.

You also lose a claim. Under Regulation (EC) No 1924/2006, "no added sugars" requires that the product contains no added mono- or disaccharides or any other food used for its sweetening properties. Juice concentrate is caught by that second clause. So is date paste, honey, and malt extract.

If you want to know where your product currently sits, the 13 HFSS categories and the 2026 thresholds are the place to start.

The declaration teams find out about late

This is the part that catches people, because it isn't in the ingredient list.

Annex III of Regulation (EU) No 1169/2011 requires additional statements that sit with the name of the food, not buried in the declaration:

• Any product containing an authorised sweetener carries "with sweetener(s)"
• Products containing both added sugar and a sweetener carry "with sugar(s) and sweetener(s)"
• Products containing aspartame carry "contains a source of phenylalanine"
• Products with more than 10% added polyols carry "excessive consumption may produce laxative effects"

That last one is the one that surprises reformulation teams. Erythritol and maltitol are useful because they bulk as well as sweeten, so inclusion levels are high by design. Cross 10% added polyols in a chilled dessert or a bar and you're putting a laxative warning on your front of pack.

You can have a perfectly tidy ingredient list and still lose the clean label argument in the buyer meeting because of a line you didn't know you'd triggered.

Sugar was doing more than sweetening

The other reason clean label sugar reduction fails is that sucrose was never only a sweetener. It lowers water activity, drives Maillard browning and crust colour, provides bulk and structure, and depresses freezing point in frozen formats.

Pull 30% of it out and you've quietly changed your preservation system. The usual fix is a preservative or a higher-acid system, which is another clean label problem, or a shorter shelf life, which is a commercial one.

We've written up what sugar is actually doing in a formulation and what each function needs replacing with. Worth reading before you commit to a replacement strategy, because the sweetness swap is usually the easy part.

Where teams actually land

Two patterns work reasonably well in UK retail right now.

The first is fibre-forward. Use chicory root fibre or another soluble fibre for bulk, accept a smaller total sugar reduction, and take the fibre credit in your NPM score rather than chasing the sugar reduction alone. This keeps the ingredient list recognisable. The constraints are real though, especially in drinks, where solubility and viscosity push back fast. We covered why fibre is hard to formulate and harder to claim in detail.

The second is steviol glycosides at low inclusion with a fruit or dairy base carrying the rest. You take the "with sweetener" declaration on the chin, but steviol glycosides read better to most consumers than sucralose, and low inclusion keeps the bitter and liquorice notes manageable. Some buyers treat stevia as clean label compatible. Some don't. Ask before you formulate, not after.

What rarely works is a straight sucrose-to-fruit-concentrate swap presented as a health improvement. Buyers have seen it, the score shows it, and you've spent a development cycle to move backwards.

What to do on your next brief

Get four things settled before anyone touches a bench formulation.

1. Ask the buyer what clean label means in their spec. Get it in writing. Ask specifically about steviol glycosides, polyols, and natural flavourings, because that's where specs differ most.
2. Model the NPM score for each route before you formulate. The date paste version and the sucralose version give very different scores, and you'll want to know that in week 1, not week 12.
3. Check your Annex III triggers early. Run the sweetener and polyol inclusion levels against the 10% polyol threshold and the "with sweetener" requirement.
4. Work out what sugar was doing beyond sweetness. Water activity, browning, bulk, freezing point. Replace the function, then worry about the sweetness.

Frequently asked questions

What does clean label mean in UK food law?

Nothing. Clean label has no legal definition in UK or EU food law. There's no defined criteria, no threshold, and no restriction on using the term. It's a commercial standard set by retailer buying specifications and brand positioning, which is why it varies between buyers.

Are E numbers allowed in clean label products?

Legally, yes. E numbers are the standardised identifiers for additives permitted under Regulation (EC) No 1333/2008, and all of them have passed a safety assessment. Most UK retailer clean label specs discourage or exclude them, but that's a commercial requirement rather than a legal one.

Does stevia count as clean label?

It depends on the buyer. Steviol glycosides are an authorised sweetener with the additive number E960, so a product using them must carry "with sweetener(s)" alongside the product name under Annex III of Regulation (EU) No 1169/2011. Some UK retailers accept steviol glycosides within a clean label spec because of the plant origin. Others exclude all authorised sweeteners.

Do fruit sugars count as added sugar?

For nutrition claims, yes. Regulation (EC) No 1924/2006 blocks a "no added sugars" claim where the product contains added mono- or disaccharides or any other food used for its sweetening properties, which covers fruit juice concentrate, date paste, honey, and malt extract. Sugars from these sources also count as free sugars for NPM scoring.

Do I have to declare sweeteners on the front of pack?

You have to declare them with the name of the food. Annex III of Regulation (EU) No 1169/2011 requires "with sweetener(s)" for products containing an authorised sweetener, and "with sugar(s) and sweetener(s)" where both are present. Products with more than 10% added polyols also need the statement "excessive consumption may produce laxative effects".

Does clean label reformulation improve my HFSS score?

Only if it reduces free sugars, saturated fat, salt, or energy, or increases fibre, protein, or fruit, vegetable, nut and legume content. Swapping sucrose for a fruit-derived sweetener changes the ingredient list without changing the free sugar content, so the NPM score usually stays flat.

The short version

Clean label is a positioning choice with a technical bill attached. The bill is usually paid in shelf life, in claim eligibility, or in a smaller sugar reduction than the brief asked for. Decide which one you're paying before you start, and model the score for each option first.

If you want to see what each substitution does to your NPM score before you run a trial, that's what we built Nibblr for. Try it here.