A wave of innovation is hitting the shelves targeting cognitive function. For workers burned out by ‘hustle culture’, the messaging is spot on. But do brands risk facing a legal minefield?

If one snack summed up January, it was the M&S Brain Ball. Ads were plastered all over M&S store fronts. Column inches soon followed. The almond butter and berry ball fast became a topic of hot LinkedIn debate – branded everything from a “fad” to an “encouraging” innovation.

For M&S, it was anything but a fad. “2025 is the year of the brain,” it proclaimed in a press release for the launch of the ball, which contains “essential brain-health nutrients” iron, zinc and vitamin B12. Already, it’s selling higher daily volumes than any M&S sandwich, and is among the top 10 bestselling products across its Food Halls.

As indicated by those sales rates, M&S has picked up on a growing trend for food and drink with mental  benefits. Nexus PR believes this is the year ‘mood food’ will come to the fore, based on consumer research and conversations with fmcg clients. At the same time, a growing number of smaller brands are bringing out ranges that promise to improve mental clarity – from Tribe’s Protein + Focus bars to Tenzing’s winter blend with added vitamin C and D.

Tribe Protein + Focus

TRIBE PROTEIN FOCUS

Billed as the UK’s first protein and focus bar, this Tribe innovation is targeting the growing demand for snacks that deliver energy. Launched in January, the 60g bars (rsp: £1.99) contain 10g of plant protein to “fuel your energy and metabolism”, on top of magnesium, lion’s mane, B vitamins and ginseng.

The HFSS-compliant bars come in three variants: Choc Brownie, Peanut Butter Choc Chip, and Peanut Butter Blondie. Their development came off the back of extensive consumer research, says Tribe co-founder Tom Stancliffe. “We did a big project looking at different need states,” he says. “What came out on top by a long way was energy and focus.”

So what is driving this spate of cognitive innovation? How big can the market get? And will the health claims stand up to legal scrutiny?

As a concept, food and drink that promotes brain function isn’t anything new. After all, consumers have been knocking back coffee and energy drinks for a buzz since grocery aisles first began.

The difference is that espressos and Red Bull aren’t exactly seen as healthy options. This new wave of products aims to deliver cognitive benefits to the wellness crowd. “The origins were in Silicon Valley, where people were pushing the envelope at both ends of the day,” explains Claire Baseley, a registered nutritionist who has a speciality in sports nutrition.

To keep up with hustle culture, workers were looking for “more natural alternatives” to drugs such as prescription stimulant modafinil, she says.

Fiery Mango Lions Mane 330ml drops-min

Tenzing Fiery Mango

Already known for its natural energy claims, Tenzing spotted an opportunity for a winter edition energy drink with real health benefits. So Fiery Mango (rsp: £2.25/330ml) was launched in November.

Containing vitamin D and C, magnesium and lion’s mane, it targets mood and immunity, as well as energy and cognitive function. Originally designed to be a limited edition, it has now been made permanent due to sales success.

Fiery Mango is already the bestselling Tenzing SKU in Tesco, having overtaken Raspberry & Yuzu.

So brands started looking into more palatable cognitive ingredients – ones seen as an active health choice, rather than a guilty secret.

Today’s shelves are evidence of how mainstream these ingredients have become. Where CBD has become synonymous with relaxation, mushrooms are now hot property in the wider cognitive space. A wave of drinks have come to the fore containing the likes of lion’s mane and reishi – see the M&S Yay Mushrooms range, launched in January – to deliver increased focus and clarity.

Tribe also made use of lion’s mane in its Protein + Focus bars, launched at the beginning of the year. For co-founder Tom Stancliffe, they fit with an increased focus on wellness. “Customers are more health-conscious and looking for natural plant-based alternatives to coffee or energy drinks,” he says. “So we were looking at what natural plant-based ingredients can give energy and focus without the jitters.”

But like many products that promise brain benefits, Tribe doesn’t rely on one ingredient alone. The bar also contains vitamins and minerals associated with cognitive function, such as magnesium, to complete its health proposition. Similarly, the M&S Brain Ball packs iron, zinc and vitamin B12. And Aduna Mind Superfood Blend, due to relaunch in a tub format in March, makes use of cacao, lion’s mane, reishi and baobab, among others.

M&S Brain Food range

Say goodbye to low-fat lineups. M&S kicked off the new year with a new approach to wellness in the form of its 13-strong Brain Food range. Each product contains at least two “brain-supporting nutrients” that many UK consumers lack in their diets: omega-3, iron, iodine, folate, zinc and vitamin B12. The lineup includes the hero Brain Ball line (£1.50/40g), touted as “the perfect on-the-go fruity snack”, as well as a snack bar version (£1/40g). Shoppers can also choose from a Blueberry Yoghurt Bowl (£3/200g), a Smoked Salmon, Egg & Edamame Pot (£3.50/110g), and a Tropical Kefir Shot (£1.50 for one 150ml shot, or £4 for a pack of three).

‘Food as medicine’

The proposition caters to a growing consumer trend, says Aduna co-founder and CEO Andrew Hunt. “We’ve seen a growing awareness of ‘food as medicine’, combined with the demand to address specific functional benefits – one of these being cognitive health,” he explains. “People are now looking for natural superfoods that are not just functional but also taste great and are easy to incorporate into their daily routines.”

A similar insight was behind the launch of Tenzing’s Fiery Mango winter edition (p29) in November. Not only is the spicy taste on trend, but it contains vitamins D and C, magnesium and lion’s mane – ingredients that “were all once in nature” – to help with low mood and energy in the winter months.

The health-led approach to mental wellness has already proven a hit with shoppers. The SKU has overtaken its bestselling Raspberry & Yuzu variant in Tesco in less than two months on shelves – an accomplishment “we’ve never had in our eight years at Tenzing”, reports founder Huib van Bockel. “The holistic feeling of just feeling good and energised is a trend that isn’t going away,” he adds.

Consumer research certainly points to a substantial market in overall brain health. Nearly four in 10 (39%) reported changing their food and drink choices to improve their mental wellbeing in a survey of over 2,000 people by Nexus PR at the end of 2024.

Aduna Mind Superfood Blend Tub

Aduna Mind Superfood Blend

One of a range of five functional lines, the Aduna Mind Blend hit Ocado and Holland & Barrett in 2024.

The 250g pouch, which sells at £22 on Ocado, packs “superfoods with proven cognitive benefits” like cacao, lion’s mane, reishi and baobab into a “delicious rich and chocolatey” blend.

Designed to meet growing demand for cognitive benefits, it will relaunch in a tub format in March.

What’s more, 76% agreed food and drink choices affected their mood in a Vypr survey of over 1,900 consumers conducted for The Grocer in January. More energy (26%) was the most in-demand claim after better sleep (30%).

Mintel has found a similar pattern in its research. Although cognitive claims remain niche, “there is ample demand for food and drink supporting energy and mental acuity”, says Kiti Soininen, Mintel category director of UK food & drink research. “Many consumers look to food and drink as a key means to support their energy and focus.”

That’s the good news. But shopper research also reveals a downside. As many as 65% of consumers felt either very or slightly sceptical towards cognitive claims in food and drink in Vypr’s research for The Grocer.

47%
would be willing to pay a premium for cognitive benefits

65%
are sceptical of food and drink products that claim mood benefits

Source: Vypr survey of over 1,900 consumers, January 2025

These products won’t be for everyone, suggests Chris Blythe, owner of The Brand Nursery. “I suspect consumers are going to polarise on this one,” he argues. “There will be people who are on the lookout for foods that can help their proactive wellbeing and… they’ll give it a try. If somebody like M&S talks about it, you tend to trust and believe it. On the other hand, I think there are people who will be very sceptical.”

That’s particularly when it comes to pushing processed foods over more natural options. Many of these cognitive products offer benefits that “you can get from eating more oily fish and green veg”, Blythe points out. “And actually if you look into the best food for your brain, it almost certainly won’t be processed stuff.”

Brands in this market also face a potential legal minefield. As a nutritionist, Baseley is aware of a growing number of products “on the periphery” of what the law allows in terms of claims. Only certain ingredients appear on the GB register of authorised claims, and these tend to be vitamins and minerals.

Vitamins B12 and B6, for example, are approved under the wording “contributes to normal psychological function”, while iron “contributes to normal cognitive function”. In those cases, brands must simply ensure the product supplies a significant intake – “usually 15% of the reference amount” – Baseley says.

Ingredients like lion’s mane and reishi, however, aren’t yet on the register. That means brands must either avoid making claims around the ingredient altogether, or, where research is ongoing, adhere to the rules of an ‘on-hold’ claim. These claims are reserved for foods like reishi, which are under investigation – but they come with strict rules.

“You must preserve the wording exactly, use the same plant parts, concentration and extraction techniques, and you must hold substantiating evidence as a brand,” explains Baseley. “My advice is don’t use on-hold claims, because you will always come unstuck.”

That is proven by the spate of ASA rulings on supplements containing novel foods: in July alone, there were two rulings against mushroom gummies brands.

Am Sunrise Blend

Youth & Earth AM: Sunrise Blend

This morning blend launched in November as an alternative to the “jitters and energy crashes” caused by coffee.

Instead, these 12g sachets contain ginseng, cordyceps, and maca to “provide a smooth, long-lasting energy boost”.

Meanwhile, lion’s mane, ginkgo biloba and bacopa monnieri work to “support cognitive function”. A pack of 14 sachets comes at £24.99 on youthandearth.com.

To stay on the safe side, brands will typically combine novel foods with authorised ingredients such as vitamins, which allows for more freedom in marketing. Even then, though, Baseley sees a grey area in what is allowed. In a LinkedIn post last month, she pointed to the M&S Brain Ball.

“The Brain Ball is high in iron and zinc, both of which contribute to normal cognitive function. This is a far more rigorous approach than many brands who’ll slap an authorised claim on any old recipe and declare it improves focus, merely to jump on the brain biohacking wagon,” she wrote. “We can argue about whether the claims M&S use are overstating. My question is, are these legally approved health claims misleading? Just because you can, doesn’t mean you should?”

The level of debate under that post – one nutritionist said her “health claim radar was triggered” – shows just how contentious the issue is.

Anthony Warner, freelance development chef and author of The Angry Chef, fears these cognitive claims are treading too closely to the type of content made by Instagram and TikTok influencers. “A lot of products are pushing the lines on what you can say from a regulatory standpoint,” he says.

That could have a detrimental effect on the entire industry, Warner argues. “The industry is in a difficult place regarding trust and worse than it has been throughout my lifetime. People are talking about how to get trust back, and the only way to do it is by behaving in a trustworthy way,” he stresses.

“I worry about this general ‘food as medicine’ approach because it sets us up to have false expectations of our food.”

Social media backlash

If those expectations aren’t met, brands will quickly be called out publicly, Blythe points out. “If people start to find the claims are overblown or that other stuff is better for you, social media, I suspect, will become fairly awash with counter claims,” he says.

So brands needs to ensure their claims are as transparent as possible, and backed by as much evidence as possible. M&S has clearly been conscious of getting it right. Not only did it enlist the help of the British Nutrition Foundation, but the retailer has published the vitamin content of its products in relation to the recommended daily intake (its Brain Ball has at least 30% of iron, zinc and vitamin B12, for example).

Brain food chalk illustration

Source: Getty Images

Brands are in search more palatable cognitive ingredients – ones seen as an active health choice

Tenzing, meanwhile, ensured it stuck to authorised claims for its blend of natural caffeine, electrolytes, magnesium and vitamins C and D. It was also careful to “put enough of the ingredient in there” rather than a token amount, stresses van Bockel – with a can of Fiery Mango providing 30% of the vitamin D daily reference intake.

Tribe was similarly conscious of the science. “It’s something we spent a lot of time thinking about. What was the right adaptogen and nutrient level and so on, and what was the evidence base with nutritionists,” says Stancliffe.

This rigorous approach is the only way to win this market in the long term, says Harvey Choat, MD of Nexus PR. “I think there is a general scepticism over is this good for me or is it just being polished? So brands need to be robust about how they do it, they’ve got to have the right levels of research and the right levels of ingredients and traceability in there.”

It’s a crucial point, even if the work can be costly and time-consuming. Because without those measures, these cognitive products may just find themselves on the losing end of a social media furore. And no amount of brain food could help them navigate their way out of that predicament.