Nutri-Mark A reformulation in the UAE is a product-redesign problem, not simply a labelling exercise. Nutri-Mark uses a nutrient profiling model that counts energy, sugars, saturated fat and sodium against a product, and fibre, protein, fruit and vegetables for it [1][6]. Sugar helps control water activity, fat supports emulsion stability and mouthfeel, and salt affects flavour, dough behaviour and preservation.
Why Reformulating for a Nutri-Mark ‘A’ Can Collapse Shelf Life, Mouthfeel and Emulsion Stability — and How to Redesign the Formula Without Losing the Product
Dr Shreya Iyer, PhD (Food Science), Director of New Product Development, Food Research Lab
Food formulation, beverage development, ingredient functionality, product stability and reformulation.
Quick Answer
Nutri-Mark A reformulation in the UAE is a product-redesign problem, not simply a labelling exercise. Nutri-Mark uses a nutrient profiling model that counts energy, sugars, saturated fat and sodium against a product, and fibre, protein, fruit and vegetables for it [1][6]. Sugar helps control water activity, fat supports emulsion stability and mouthfeel, and salt affects flavour, dough behaviour and preservation.
Published studies show the consequences:
- In a 2026 pound-cake study, aw rose from 0.816 in the control to 0.871–0.887 in cakes with 20–60% of the sugar replaced by polydextrose [9].
- A 2026 mayonnaise study found that oil concentration changed viscosity, yield stress and viscoelastic behaviour [8].
- In a 2024 bread study, 5% pea fibre raised water absorption by 12% and hardness by about 50% [10].
The response is to identify the function lost, rebuild it with a suitable ingredient and process system, and repeat shelf-life stability testing and sensory evaluation before approving the revised product.
Introduction
The UAE is developing its nutrition framework through several regulatory and industry initiatives.- Abu Dhabi’s Nutri-Mark grades products from A to E under guideline ADG-044-2024 [1].
- Federal excise on sweetened drinks moved to a tiered model on 1 January 2026 [3].
- In January 2026, the Ministry of Health and Prevention (MoHAP) announced plans for maximum salt levels in bread and processed foods [4].
- Al Ain Farms Group committed to cutting added sugars by 10–20% in selected dairy products [4].
Where Nutri-Mark Stands in the UAE
Scheme scope and official documents
Nutri-Mark is Abu Dhabi’s five-grade front-of-pack label, from A to E, for comparing products within the same category [1]. The Abu Dhabi Quality and Conformity Council (QCC) approved the guideline on 1 March 2025 [1].
QCC’s guidance names retailers, suppliers, importers and manufacturers as operators. It publishes the guideline (ADG-044-2024), Conditions for Use (QCC-CoU01-01), label and graphics guidance, and an official calculation tool [1].
Table 1: Implementation timeline: what has been reported
Date | Development | Source |
26 November 2024 | QCC and Abu Dhabi Public Health Centre announced the Nutri-Mark front-of-pack labelling initiative, initially covering five product categories. | |
1 March 2025 | QCC announced approval of the Abu Dhabi guideline for use of the Nutri-Mark label. | The Abu Dhabi Quality and Conformity Council Approves the Nutri-Mark Label Guideline. |
30 May 2025 | QCC and Abu Dhabi Department of Health announced postponement of official implementation from June 2025 to Q4 2025. | Emirates News Agency (WAM). ADQCC, DoH Launch ‘Nutri-Mark’ Initiative in 2025. |
18 February 2026 | Nutri-Mark was reported as integrated into a TAMM app feature allowing consumers to scan product labels and view grades. | Emirates News Agency (WAM). Healthy Living Oversees Implementation of Strategic Initiatives. |
Australian government market-access notices describe a timeline later reported as delayed [2], while 2026 media coverage calls the scheme voluntary with no confirmed mandatory date [4]. Dubai announced no Nutri-Mark requirement as of October 2025 [5]. Confirm the applicable requirements with QCC before planning front-of-pack labelling reformulation or launch dates.
How the Grade Is Calculated
What the model measures
QCC describes Nutri-Mark as a standardised nutrient profiling model set out in ADG-044-2024. Energy, sugars, saturated fat and sodium count against a product; fibre, protein, fruit and vegetables count in its favour [1].
Trade and technical analyses report that the model follows the 2023 revision of Nutri-Score [6]; QCC’s score page does not state this. Published Nutri-Score tables do not replace the Abu Dhabi guideline or calculation tool, and beverages, cheese and fats can have different rules [1].
Formulation functions behind each scoring variable
The table below is a technical guide for food formulation, not a copy of the official calculator.
Table 2. Formulation Changes and Their Impact on Product Quality and Stability
Nutrient or component | Role in the profile | Function in the formula |
Sugars | Counts against | Sweetness, bulk, humectancy, browning, free-water control |
Saturated fat | Counts against | Structure, plasticity, lubrication, flavour delivery |
Sodium | Counts against | Flavour, fermentation control, dough properties, preservation |
Fibre | Counts in favour | Water binding, viscosity, structure, texture |
Protein | Counts in favour | Emulsification, gelation, heat sensitivity |
Why Every Cut Triggers a Cascade
Nutrients versus functions
Food reformulation works on functions, not just nutrients: the model assesses composition, but the product depends on what its ingredients do. Removing an ingredient without replacing its function can improve one parameter while damaging another, which is why sugar and fat reduction challenges rarely stay on the nutrition panel. Successful Nutri-Mark A reformulation treats each cut as the start of a chain of consequences.
Three questions that guide reformulation
- What function did the ingredient provide?
- Which physical, chemical or microbiological property changes when it is reduced?
- Which ingredient, process or preservation system can replace that function?
Sugar Reduction: Water Availability Is the First Domino
Water activity and microbial stability
Sugar contributes sweetness, bulk, browning and water activity (aw) control. Reducing it can raise the water available for microbial growth, depending on the replacer and matrix. Moulds can grow across an aw range of roughly 0.6 to 0.84, and the limit varies by species and conditions [11].
In the 2026 pound-cake study, 20%, 40% and 60% of the sugar was replaced with polydextrose. The aw was 0.816 in the control and 0.871–0.887 in the polydextrose cakes. Moisture rose from 19.97% in the control to 23.51% at 60% replacement. The 20% replacement was most preferred [9].
Higher aw does not by itself prove a shelf-life loss, but the original product’s microbial stability data can no longer be carried over. That is one of the first sugar- and fat-reduction challenges teams meet: evidence built for the old formula does not transfer to the new one.
Figure 1. The sugar cascade: a compositional change can trigger microbial, preservation and validation changes downstream.
Excise tiers for sweetened drinks
From 1 January 2026, UAE excise on sweetened drinks follows total sugar per 100 ml [3]:
- Below 5 g: AED 0 per litre.
- 5 g to below 8 g: AED 0.79 per litre.
- 8 g or more: AED 1.09 per litre.
Federal Tax Authority guidance covers sugar-content determination and conformity documentation [3]. A fruit nectar therefore faces two tests, its excise tier and its Nutri-Mark beverage grade, and improving one does not resolve the other.
Rebuilding the lost function
In food reformulation, rebuilding means selecting bulking agents by water-binding behaviour, matching the sweetener’s time-intensity profile, reviewing the preservative system, and repeating aw, microbiological and shelf-life tests on the revised formula. For clean label reformulation, check every bulking agent, sweetener and preservative against the label claim.
REFORMULATION DIAGNOSTICS
Find the Failure Mode Before You Cut the Ingredient
Our Nutri-Mark A food reformulation services model the grade gap against Nutri-Mark requirements and map the likely cascade before bench trials begin.
Fat Reduction: The Emulsion Loses Its Skeleton
Oil content and emulsion rheology
Fat contributes structure, lubrication, spreadability and flavour release. Reducing oil changes the dispersed-phase volume fraction and can alter viscosity, yield stress, viscoelasticity and emulsion stability. Among the sugar and fat reduction challenges, the fat side is usually structural.
A 2026 Journal of Food Engineering study tested mayonnaise with about 54%, 70% and 77% sunflower oil. Oil concentration shaped viscosity and structure, and the roughly 70% formulation balanced texture, spreadability and thixotropic recovery [8].
The study described flow with a Herschel–Bulkley model, which supports setting targets from yield stress and flow curves, not a single viscosity reading [8]. The missing structure may need fat replacers, emulsion stabilisers for food, tuned emulsifier systems or a process change. Clean label reformulation narrows the choices, because every structuring must fit the ingredient-list claim.
Figure 2. Oil concentration and mayonnaise rheology in the 2026 study [8]; results are recipe-specific.
Oxidative stability of replacement fats
A 2022 Antioxidants study compared low-moisture crackers made with different fat systems, matched for linoleic acid and tocopherol. Crackers with interesterified fat at 13.7% solid fat content had a hexanal lag phase of 33 days, compared with 24 days for fat blends. Solid fat content and fat distribution influenced lipid oxidation [12].
Fat structure, not only saturated-fat grams, can therefore affect oxidative rancidity and shelf life. Every fat swap, including fat replacers, needs an oxidation study that tracks it with measures such as peroxide value and hexanal formation.
Sodium Reduction: Salt Is a Structural and Microbial Control
UAE salt policy context
MoHAP’s January 2026 announcement covers maximum salt levels in bread and processed foods, with limits still to be set [4]. The National Nutrition Strategy 2022–2030 targets a 30% cut in average salt intake by 2030 [4].
The 2026 survey found that 96.2% of surveyed residents aged 18–69 exceeded recommended sodium intake [4].
Technological risks in bread
A 2022 Journal of Food Science and Technology review examined how salt-reduction strategies affect the technological characteristics of wheat bread. It covered mineral salt substitutes, hollow salts and plant-based alternatives and found suitability depends on the matrix and on the sensory and processing performance required [7].
When reformulating bread, judge the result on dough handling, proofing, loaf volume, crumb texture, sensory acceptance and mould-free life. A sodium cut that weakens dough or shortens shelf life is not commercially complete.
Adding Fibre and Protein: Positive Points, Negative Side Effects
Fibre in dough and bread
Food reformulation that adds fibre and protein can improve a nutritional profile, but the technological effects depend on source, level, hydration and processing, so it belongs in food formulation work from the start.
In a 2024 Foods study, pea, cocoa and apple fibres were tested in wheat dough and bread. Replacing 5% of flour with pea fibre raised water absorption by 12%, density by up to 25% and hardness by about 50%. The effect depended on fibre type and level [10]. Fibre addition is therefore a texture modification that needs farinographic, rheological and finished-product testing, not a simple nutritional swap.
Protein stability in UHT beverages
A 2024 Food and Bioproducts Processing study examined pretreated whey proteins in UHT high-protein dairy beverages. Pretreatment denatured about 97.8–99.4% of the whey protein, and after UHT, the beverages showed similar particle size and equal or lower sedimentation than the comparison formulation [13].
This does not show that the same pretreatment suits every UHT beverage. Pilot-test heat stability, particle size, sedimentation and storage behaviour, and check how emulsifier systems and emulsion stabilisers for food interact with the protein.
Table 3. Functional Impacts of Ingredient Reformulation and Required Validation Parameters
Lever | Documented formulation concern | Function to rebuild | Validate with |
Sugar | aw 0.816 in control vs 0.871–0.887 with polydextrose [9] | Preservation, bulk, sweetness | aw, microbiology, shelf life |
Fat | Oil level changed viscosity and yield stress [8]; fat system changed oxidation [12] | Rheology, oxidative stability | Flow curves, yield stress, oxidative rancidity markers |
Salt | Reduction can affect taste, dough performance and preservation [7] | Process control, taste, preservation | Proof profile, sensory, shelf life |
Fibre/protein | Fibre raised bread hardness by about 50% [10]; UHT stability depended on pretreatment [13] | Hydration, structure, heat stability | Texture analysis, particle size, sedimentation |
Where UAE Categories Differ
Federal and emirate-level requirements
The UAE is not a single enforcement environment. QCC publishes Nutri-Mark guidance for Abu Dhabi [1]. Dubai Municipality’s Food Code provides the food-control framework in Dubai [5]. MoHAP has announced plans for federal salt limits [4] and sweetened-drink excise sits under the federal tax framework [3]. Food product manufacturers should therefore plan front-of-pack labelling reformulation market by market. Nutri-Mark A reformulation is only one of several UAE requirements a formulation must meet.
GCC-specific product categories
- Flavoured laban: Drinking yoghurt and flavoured milk need acidity, viscosity, syneresis and sensory stability controlled in chilled storage, and any texture changes must hold there. A 2023 study evaluated laban with 0.5% carboxymethyl cellulose, one of the emulsion stabilisers for food, over 7, 14 and 21 days of refrigerated storage; quality parameters declined with storage time [14]. This supports storage testing but is not direct evidence for a specific sugar-reduced laban.
- Fruit nectars: These may face the federal excise tiers and the Nutri-Mark beverage category together [3]. Evaluate sugar, acidity, flavour balance and preservation as a set; a clean label reformulation of a nectar also needs sweeteners and preservatives checked against the claim.
- Arabic sweets and date confectionery: We found no published Nutri-Mark grading data for these products; confirm the category and scoring requirements with QCC before changing syrup, date paste, fat or moisture levels.
Operators are responsible for the accuracy of their nutrition data and label use. Adding fibre to restore body, or changing oil to restore creaminess, alters the nutritional profile, so reassess after each significant food reformulation step.
The FRL Approach: Diagnose the Failure Mode, Rebuild the Function
Five-step method
Food Research Lab’s Nutri-Mark A food reformulation services follow five steps, diagnosing the dominant failure mode first and then rebuilding the lost function:
1 | Function audit Map what each target ingredient does, using baseline aw, pH, rheology and sensory data. |
2 | Score-gap modelling Identify the minimum change needed for the target grade using the applicable QCC calculation method. |
3 | Cascade mapping Predict the dominant failure mode: microbial, structural, oxidative or sensory. |
4 | Function rebuild Redesign preservation hurdles, emulsion stabilisers for food, texture modification, flavour and processing around the function that was reduced. |
5 | Revalidation Run shelf-life stability testing, microbiological checks and sensory evaluation, then reassess the grade. |
Evidence over supplier claims
Each step rests on measured product properties and the applicable regulatory calculation, not on ingredient claims alone. That is the standard behind our Nutri-Mark A food reformulation services, from food formulation and food product development to final grade sign-off.
Al Ain Farms Group: Added-Sugar Reduction in Flavoured Milk, Yoghurt and Laban
Brief: On 1 June 2026, Al Ain Farms Group announced a commitment to reduce added sugars by 10–20% across selected products, including flavoured milk, yoghurt and laban, with updated products planned for September 2026 [4].
Pathway: A cut of this scale in cultured dairy drinks can change sweetness balance, body and acid perception. Chilled-storage acidification may continue after filling, so track viscosity, syneresis, pH drift and sensory acceptance across shelf life [14].
- 10–20% added-sugar reduction announced
- Selected dairy products
- Updated products due September 2026
- No product-specific stability or Nutri-Mark results cited
This is a documented industry initiative, not evidence that the reformulated products have reached a particular grade or shelf-life outcome.
END-TO-END SUPPORT
Take Your Reformulated Product from Grade Target to Validated Shelf Life
From grade-gap modelling and cascade mapping to stability studies and sensory validation, our Nutri-Mark A food reformulation services help food product manufacturers protect product performance during nutrition-led food product development.
Conclusion
A Nutri-Mark ‘A’ comes from nutritional composition, but successful Nutri-Mark A reformulation must also keep the functions that make the product viable. Sugar, fat, salt, fibre and protein shape free water, rheology, texture, preservation and sensory acceptance, so front-of-pack labelling reformulation belongs with R&D as well as regulatory affairs.
Begin with the applicable QCC requirements and the product’s baseline performance, assess each reduction against the whole food formulation, especially the sugar and fat reduction challenges that change structure and stability, then run pilot trials and shelf-life stability testing.
Food Research Lab supports brands across the UAE and GCC with food product development and Nutri-Mark A food reformulation services, including formulation optimisation, clean label reformulation, pilot manufacturing and shelf-life validation for food product manufacturers.
Frequently Asked Questions
Nutri-Mark is Abu Dhabi’s A–E front-of-pack label, based on a nutrient profiling model that counts energy, sugars, saturated fat and sodium against a product and fibre, protein, fruit and vegetables in its favour. Use the official QCC calculation tool to grade a product.
Market-access notices and 2026 media reports describe the timeline differently. Confirm current implementation and registration requirements directly with QCC before making compliance decisions.
Sugar controls free water as well as sweetness and bulk. In a 2026 pound-cake study, aw rose from 0.816 in the control to 0.871–0.887 with polydextrose. The reformulated product needs its own microbiological checks and shelf-life stability testing.
A cut may improve one scoring parameter, but it can also affect structure, preservation, mouthfeel or processing, so Nutri-Mark A reformulation must be tested. Published studies show changes in cake aw, mayonnaise rheology, cracker oxidative rancidity and bread texture.
Federal excise on sweetened drinks has been tiered since 1 January 2026, and MoHAP has announced plans for salt limits. Check the latest federal and emirate-level requirements before changing a formula.
Reference
- Abu Dhabi Quality and Conformity Council (QCC). Nutri-Mark: Overview, scoring and official documents.
- Australian Department of Agriculture, Fisheries and Forestry (DAFF). Market Access Advice – UAE food labelling and WTO notification.
- MAA 2025-12 – New labelling requirements for dairy, cheese and beverages, 6 June 2025
- MAA 2025-15 – Abu Dhabi delays new labelling requirements, 16 July 2025
- UAE sweetened-drink excise framework – Cabinet Decision No. 197 of 2025 and tiered volumetric model.
- KPMG UAE – Significant Changes to UAE Excise Tax Rates for Sweetened Drinks
- Federal Tax Authority – Calculating Excise Tax
- Gulf News – UAE Sets New Sugar-Based Tax Tiers for Sweetened Drinks
- UAE public-sector and news reporting – Nutrition policy, salt reduction and Al Ain Farms Group.
- Abu Dhabi Media Office – Al Ain Farms Group Commits to Reduction of Added Sugars Across Portfolios, 1 June 2026
- Gulf News – UAE to Introduce New Salt Regulations as 96% of Residents Exceed Daily Sodium Levels, 7 January 2026
- UAE Government Portal – health and nutrition policy information.
- Abu Dhabi Quality and Conformity Council (QCC). Nutri-Mark: Official Documents and Tools. Access official QCC documentation
- Nutri-Score 2023 algorithm revision – supporting background literature.
- Sarda, B., Kesse-Guyot, E., Deschamps, V., Ducrot, P., Galan, P., Hercberg, S., Deschasaux-Tanguy, M., Srour, B., Fezeu, L. K., Touvier, M., & Julia, C. (2024). Consistency of the Initial and Updated Version of the Nutri-Score with Food-Based Dietary Guidelines: A French Perspective. The Journal of nutrition, 154(3), 1027–1038. https://doi.org/10.1016/j.tjnut.2024.01.029
- 2024 Nutri-Score Update Research – Nature Food
- Pashaei M, Zare L, Khalili Sadrabad E, et al. (2022). The impacts of salt reduction strategies on technological characteristics of wheat bread: A review. Journal of Food Science and Technology. 59(11):4141–4151, https://doi.org/10.1007/s13197-021-05263-6
- Kubra K, Nambyaruveettil S, Suliman M, et al. (2026). AI-driven modelling and experimental analysis of oil concentration impact on mayonnaise rheology for innovative food design. Journal of Food Engineering, https://doi.org/10.1016/j.jfoodeng.2025.112814
- Nguyen TQ, Russell L, Idowu AT. (2026). Polydextrose as a sugar replacement in pound cake production: Impact on water activity, colour, texture, and consumer acceptability. International Journal of Food Science & Technology. 61(2):vvag124, https://doi.org/10.1093/ijfood/vvag124
- Verbeke C, Debonne E, Versele S, Van Bockstaele F, Eeckhout M. (2024). Technological Evaluation of Fiber Effects in Wheat-Based Dough and Bread. 13(16):2582, https://doi.org/10.3390/foods13162582
- Vermelho AB, Moreira JV, Neves Junior A, et al. (2024). Microbial Preservation and Contamination Control in the Baking Industry. Fermentation. 10(5):231, https://doi.org/10.3390/fermentation10050231
- Vu TP, Gumus-Bonacina CE, Corradini MG, et al. (2022). Role of Solid Fat Content in Oxidative Stability of Low-Moisture Cracker Systems. Antioxidants. 11(11):2139, https://doi.org/10.3390/antiox11112139
- de Souza AB, et al. (2024). Prior denaturation and aggregation of whey proteins: Is this a useful strategy for increasing the content of these proteins in UHT high-protein dairy beverages? Food and Bioproducts Processing, https://doi.org/10.1016/j.fbp.2023.12.008
- Junaid M, et al. (2022/2023). Physical, chemical, microbial, and sensory evaluation and fatty acid profiling of value-added drinking yogurt (laban) under various storage conditions. Journal of Dairy Science, https://doi.org/10.3168/jds.2022-22358
💬 Contact Our Compliance Experts
Get a free packaging compliance review within 24 hours.
Let’s create something Innovative and Delicious together
Food Research Lab strives for excellence in new Food, Beverage and Nutraceutical Product Research and Development by offering cutting edge scientific analysis and expertise.
