Ultra-processed food manufacturers have proposed that product reformulation should be a key strategy to tackle obesity. In determining the impact of reformulation on population dietary behaviours, policy makers are often dependant on data provided by these manufacturers. Where such data are “gifted” to regulators there may be an implicit expectation of reciprocity that adversely influences nutrition policies. We sought to assess Europe’s industry-led reformulation strategy in five countries deploying critical policy studies as an approach. We found that interim results on industry-led food reformulation did not meet their targets. Information asymmetries exist between food industry and policy makers: the latter are not privy to marketing intelligence and must instead rely on data that are voluntarily donated by food industry actors. These data represent a distorted snippet of the marketing intelligence system from whence they came. Because these data indeed bear all the hallmarks of a gift, regulatory and public health authorities operate within a gift economy. The implications of this “data gift economy” are strategic delay and goal-setting when the field is not visible. Ultimately, this could diminish the implementation of public health nutrition policies that are contrary to the commercial interests of ultra-processed food producers.