The government's HFSS legislation is set to reshape how high fat, salt and sugar products are promoted. From TV ads to in-store displays, retail brands in the food & drink space will need to rethink their marketing strategies to stay compliant and competitive.
HFSS stands for high fat, salt, and sugar, and is expected to roll out a strict promotion ban on these types of products. But what does this really mean for you, and how should you start preparing?
Let’s break it down in simple terms so you can see how it might affect your business and what you can do about it.
What Is HFSS?
HFSS stands for High Fat, Salt, and Sugar, and it refers to food and drink products that are considered unhealthy based on the Nutrient Profiling Model developed by Public Health England. Think of sugary snacks, fast food, fizzy drinks, and ready meals. These are the kinds of products that the UK government wants to target with new rules to tackle rising obesity levels.
HFSS legislation imposes strict regulations on the promotion of HFSS foods, especially to children, to reduce over-consumption, combat obesity and encourage healthier eating habits. HFSS restricts advertising and placement of less healthy products and is set to significantly impact manufacturers, retailers, and marketers.
The restrictions will apply to medium and large retailers (with over 50 or more employees) offering pre-packed food for sale in store and online, including franchises (fast food chains) and symbol group stores (Spar, Londis, Nisa Local).
The legislation applies to 13 categories of HFSS food and beverages, including soft drinks with added sugar, confectionery, cakes, breakfast cereals, savoury snacks, ready meals, sweet biscuits and bars, morning goods (pastries), desserts, puddings and dairy desserts, sweetened yoghurts and fromage frais, pizza (except plain pizza bases), chips and similar potato products, milk drinks with added sugar and juices with added sugar and refill drinks.
Certain exemptions exist, such as products marketed exclusively to adults or in very small businesses.
When will HFSS Come Into Effect?
The HFSS (High Fat, Salt, or Sugar) volume promotion restrictions in England are scheduled to come into effect on 1st October 2025, impacting how retailers can promote HFSS products, including bans on volume priced promotions such as "buy one get one free" and multi-buy deals.
The government has delayed the implementation of advertising restrictions until 5th January 2026. These restrictions, initially planned to take effect on 1st October 2025, will now be legally enforced on that later date. The delay gives businesses some extra time to adjust and clarify the scope of the restrictions, particularly around brand advertising. The delay is also a crucial opportunity to start preparing your marketing strategies now to avoid scrambling as the new date draws nearer.
What Will the HFSS Advertising Ban Cover?
This legislation covers a broad range of advertising channels, from online advertising to TV advertising, in-store placements and promotion restrictions such as location promotions and volume price promotions.
Here’s where the advertising restrictions will apply:
- Online Advertising: Paid online ads for HFSS products will also be restricted across social media, apps, and websites. It will be implemented, encompassing non-Ofcom regulated ODPS (Netflix, iPlayer, etc) and internet protocol television (IPTV) services (Smart TVs, Roku, Apple TV apps).
- TV Advertising: 9pm watershed: Advertisements for less healthy food and drink products will be prohibited on TV, including Ofcom-regulated on-demand programme services (ODPS), between 5:30 am and 9:00 pm
- In-store Placement: HFSS foods will face restrictions on prominent displays and need to be placed differently in stores, meaning they won’t be front and centre, aisle ends, entrances or at checkout points. The regulations explain that specified food must not be offered for sale as part of a volume price promotion. This includes a promotion in which non-specified food items or non-food items are also included.
- OOH (Out of Home) Advertising: The Advertising Standards Authority (ASA) and Committee of Advertising Practice (CAP) guidance suggests that HFSS advertising should not be displayed where more than 25% of the audience is under 16 years old. This is generally interpreted as a 100-meter radius around school boundaries.
- Print Media: Print ads for HFSS products are prohibited from appearing in media targeted at under-16s or in media where under-16s make up more than 25% of the audience. While the regulations do not explicitly mention newspapers/magazines, they do cover online content, which could include newspapers/magazines available digitally. Direct mail: marketers are required to take all reasonable steps to exclude under-16s from marketing lists or targeting criteria if data is used to create an audience. Brand-only ads may still be permitted, provided they do not feature identifiable HFSS products, do not appeal to children, and appear only in publications aimed at general or adult audiences.
This is a big shift, and businesses, if not already, will need to start thinking about how they’ll market their products in new, compliant ways.
Why Is This Legislation Being Introduced?
There’s growing concern over the rise in obesity and other health problems in the UK. The aim of the high-fat, salt, and sugar advertising ban is to curb these trends by making unhealthy foods less appealing, particularly to children and young people, who are most influenced by advertising.
With so many brands reliant on advertising for product visibility, this new legislation will certainly shake up the way companies think about their marketing strategies.
How Will Businesses Respond to HFSS Legislation?
You’re probably already thinking about how this could affect your business. The reality is that many businesses will have to rethink their entire approach to marketing these products. Here are a few ways we expect the market to respond:
- Reformulating Products: Some companies might choose to reformulate their products to reduce fat, salt, or sugar content so they can avoid the restrictions.
- Redesigning Packaging: With stricter rules around product placement, brands will likely need to redesign packaging to make it more compliant.
- Shifting Marketing Strategies: Brands will have to get creative and focus on promoting healthier options or use different channels and approaches for their HFSS products.
- Reworking Store Layouts: Retailers will need to adjust their in-store displays to comply with the new placement rules, which could impact everything from how products are stocked to where they’re positioned in stores.
How Can Your Business Adapt?
These changes to the HFSS regulations are going to affect many businesses, especially those in food and drink. However, this doesn’t have to be seen as a setback. Instead, it’s an opportunity to pivot and get ahead before the deadline. By adjusting your strategies now, you can ensure that your business is fully prepared for the new rules.
Here are some practical steps to consider as you plan your response:
Educate Your Team and Stakeholders
The more informed your team is, the better they can handle the changes. Consider creating internal resources or hosting team workshops to ensure everyone understands the HFSS legislation. By keeping everyone aligned, you’ll be able to respond quickly when the time comes and ensure a smooth transition.
Audit and Update Your Digital Content
With the restrictions on advertising HFSS products, it’s a good time to review your website, social media, ads and other online content. Check that everything complies with the upcoming rules, and update any campaigns or materials that might be affected. Being proactive here will help you avoid any last-minute scramble to update content as the legislation takes effect.
Revisit Your Packaging Design
Packaging will play a key role under the new regulations. Take time to review your product packaging and see if any changes need to be made to comply with the in-store placement rules. If necessary, work with your design team to create fresh, engaging packaging that aligns with the regulations while still attracting your target audience.
Reassess Your Marketing and Branding Strategy
The HFSS advertising ban might require a shift in how you position and promote your products. Now’s the time to take a close look at your overall marketing and branding strategies. Consider whether your current approach still aligns with the new rules, and explore ways to emphasize healthier options, or find creative ways to reach your audience without violating the new advertising restrictions.
Explore New Marketing Channels
Traditional advertising channels for HFSS products may no longer be an option, but there are plenty of creative and compliant alternatives. Look into new, effective ways to connect with your audience think influencer marketing, content collaborations, or experiential campaigns that work within the new guidelines. Staying flexible and open to new approaches will help you navigate this shift successfully.
Examples of Brands Amending Products to be HFSS Compliant
Walkers
Walkers reduces salt contents of core crisps range using "innovative R&D processes" following years of development. Walkers recipes across its core range have seen the salt content cut by 47%.
Coca-Cola
Coca-Cola is promoting its zero-sugar variants, such as Coca-Cola Zero Sugar and Diet Coke, which are exempt from the HFSS regulations. They are offering smaller cans (150ml-250ml) allowing Coca-Cola to appeal to consumers seeking portion control and lower sugar intake. Coca-Cola ran compliance-friendly campaigns promoting lifestyle and brand over product.
Cadbury
Cadbury launched snacking made right campaign implementing a 100-calorie cap for portion-controlled packs of various Cadbury products, including Fudge, Curly Wurly and Chomp. Cadbury has also launched non-HFSS product variants, like 30% less sugar Dairy Milk. Shifted marketing efforts to non-restricted products and focused on in-store branding not covered by HFSS laws.
Kellogg's
Kellogg's removed 10% of the sugar and at least 20% of the salt from their kids' cereal range, making them non-HFSS compliant. Kellogg's also introduced new products that meet HFSS guidelines, such as the oat-based crunchy cereal "Oaties," which is made from a blend of oats and cereal flours.
Kellogg's has also engaged in legal actions to address ambiguities in HFSS regulations, highlighting the complexities and potential financial impacts of the new rules.
Tesco
In 2019, Tesco voluntarily removed HFSS products from checkout areas, even before it became mandatory. Tesco have reformulated thousands of its own-brand products, removing over 71 billion calories to date. They have created Better Baskets' zones in stores, highlighting healthier and more sustainable products. Tesco also set up Stronger Starts program, a £5 million grant initiative aimed at providing school children with access to healthy food and fitness activities.
McDonald's
McDonald’s has implemented a range of strategies to promote balanced eating, simplify ingredients and market responsibly. Key initiatives include displaying calorie information at point of purchase since 2011, launching nutrition-focused tools and menu bundles under 400 and 600 kcals. They’ve introduced plant-based options like the McPlant and Veggie Dippers, promoted healthier choices such as grilled over crispy chicken, and reordered drinks on kiosks to encourage lower-sugar options. With over half of new menu items now non-HFSS, McDonald’s aims for at least 50% of products to meet their nutritional criteria by 2026, supported by research, expert councils and refreshed menus with clear nutritional labelling.
HFSS: Ongoing Uncertainty and Industry Lobbying
With active lobbying from industry stakeholders and ongoing speculation about further delays, while no official government confirmation has been made, some sources suggest restrictions on volume price promotions, such as “buy one, get one free” offers, will still be enforced from 1st October this year. Others report that Labour may repeal the multibuy ban altogether, responding to retailer and manufacturer concerns, as well as cost-of-living pressures, arguing these deals help keep unit costs down for families. In parallel, the government has announced plans to make “healthy food reporting” mandatory for supermarkets, setting targets for large retailers to improve the healthiness of the average shopping basket.
The Government's Ten-Point 'Good Food Cycle' Plan
In July 2025, the Government unveiled its ten-point “Good Food Cycle,” designed to make healthier, affordable, and sustainable food the norm. The initiative focuses on creating a food environment that supports healthier, more environmentally friendly choices; ensuring everyone has access to safe, affordable, and appealing options; and enabling the food sector to grow sustainably through innovation, improved productivity, and transparent, fair supply chains. Together, these goals aim to create a joined-up system where public health, environmental sustainability, and industry growth work hand in hand.
Preparing for the Future
It’s clear that the HFSS legislation will have a significant impact on many sectors, particularly those in food and drink.
At STM AGENCY, we bring a wealth of experience working with businesses across these sectors, helping them navigate regulatory changes and stay ahead of evolving market trends. With our expert teams specialising in strategy, creative and brand development, we can guide you through this transition and help you adapt to the new regulations.
By working with our team, you can ensure that your business remains compliant, relevant and successful in an ever-changing market.
Stay tuned for more content on HFSS, as we continue to explore how this new legislation will reshape advertising and marketing across the UK. As the landscape continues to shift, we’ll help you stay agile and ready to meet the demands of an ever-changing market.
HFSS Explained: What You Need to Know to Stay Compliant
Whether you’re new to HFSS legislation or have been following it closely, understanding the full impact of the advertising ban is essential.
As it approaches, it’s crucial to stay informed and be proactive in your response. With the right preparation, this can be a chance to rethink your strategy, stay ahead of the competition, and maintain strong connections with your customers.
Need help navigating HFSS? Contact us today to learn more about how we can help you stay compliant.
Disclaimer: The information provided in this article is for general informational purposes only and does not constitute legal advice. While we have taken care to ensure the content is accurate and up to date as of 13th August 2025, regulations and guidance may change. For the most current and authoritative information, please refer to official government resources at gov.uk and seek advice from a qualified legal professional.
