For anyone who needs to be reminded, HFSS stands for ‘High Fat, Salt and Sugar, often referring to products such as pies, pastries and cakes, along with savoury snacks, confectionery and desserts.
HFSS Policy Summary
Promotion of HFSS products will be restricted by location and volume price. Location restrictions will apply to store entrances, aisle ends and checkouts plus their online equivalents:
- Entry pages
- Landing pages
- Shopping baskets
- Payment pages
Volume price restrictions will prohibit retailers from offering promotions such as "buy-one-get-one-free" or "3 for 2" offers on HFSS products.
The following categories will be impacted:
- Soft drinks
- Cakes
- Chocolate confectionery
- Sugar confectionery
- Ice cream
- Morning goods (for example pastries)
- Puddings
- Sweet biscuits
- Breakfast cereals
- Yoghurts & milk-based drinks with added sugar
- Juice based drinks with added sugar
- Pizza
- Ready meals
- Meal centres, including breaded and battered products
- Crisps and savoury snacks
- Chips and similar potato products
The restrictions will apply to medium and large retailers (with 50 or more employees), including symbol group stores.
HFSS restrictions in hospitality
Restrictions on HFSS items will also apply to free refills of sugar-sweetened drinks in the out-of-home sector. For example restaurants like Nando’s with their bottomless refills.
Fast-food chains may find themselves particularly hard-hit!
So, why is the Government doing this?
Data shows that children and adults in the UK are not eating balanced diets. We consume too much sugar, saturated fat and salt and too many calories, but not enough fibre, fruit and vegetables.
The retail promotional environment does not align with healthy eating guidelines and makes it harder for families to make healthier choices when shopping.
A recent survey from the Obesity Health Alliance showed that 43% of all food and drink products located in prominent areas, such as store entrances, checkouts, and aisle ends were for sugary foods and drinks.
Less than 1% of food and drink products promoted in high profile locations were fruit or vegetable…
The impact of Promotions
It is clear from the academic evidence that promotions in stores are extensive, and effective at influencing food preferences and purchases. Although promotions might appear to help shoppers save money, the data shows that they increase spending by encouraging shoppers to buy more than they intended to buy in the first place.
Price promotions appeal to shoppers from all demographic groups and increase the amount of food and drink they buy. Promotions on food and drink in the UK reached record levels in 2015 and were the highest in Europe, with 40% of the food and drink people purchased being on promotion.
The latest data shows that shoppers buy almost 20% more as a direct result of promotions.
We also know that promotions directly drive-up brand and product visibility. Numerous studies have shown that the mere presence of promotional material increases product standout and awareness, and also drives sales, even if the mechanics of the promotion are weak or even meaningless. For example, a single shelf edge barker increased sales of a beer brand by more than 11%. However, it’s message was simply: “Thieves will be prosecuted”.
For the purposes of this discussion, let’s say that promotions increase awareness and sales through generating visibility and overall visual impact.
So, what happens when you reduce or remove product visibility? Because this is what is going to happen when the HFSS legislation comes into force.
How might brands and retailers respond?
There are a large number of powerful brands and retailers that are going to be impacted by this new legislation, and we thought it worth exploring recent history to see how they may respond.
Let’s look at what happened with tobacco...
1991
The Children and Young Persons (Protection from Tobacco) came into force. This tightened up existing legislation on the sale of cigarettes to children under 16. The new law made it illegal to sell single cigarettes and also required warning notices, stating that it is illegal to sell tobacco to anyone under the age of 16, to be displayed at all points of sale including vending machines.
2002
A bill to ban tobacco advertising, which began as a Private Member’s bill in the House of Lords, was passed by parliament. In order to comply with the EU tobacco advertising directive, the date for the phasing out of tobacco sponsorship of Formula One motor racing was brought forward from Oct 2006 to July.
2003
The first phase of the Tobacco Advertising and Promotion Act was implemented. This ended tobacco advertising on billboards and in the print media, and banned direct mail, internet advertising and new promotions.
2004
The tobacco advertising point of sale regulations are upheld and enter into force on 21 December. The only permitted brand advertising was one single A 5 sized ad or ad with equivalent overall dimensions. At this point in time, 24.5% of the adult UK population were smokers
2012
New legislation came into effect to protect children from being the target of tobacco promotion and to help people quit smoking. All large shops and supermarkets in England needed to cover up cigarettes and hide tobacco products from public view. By now, 20.5% of the adult UK population were smokers.
2015
The visibility base was extended to cover small shops as well. The UK ban stipulated that the tobacco gantry must be fully covered to obscure the view of tobacco products completely.
The result
Evidence on the impact of display bans suggests that they may help to contribute to a reduction in adolescent smoking rates. A study found that across six European countries which had implemented a display ban, the measure was associated with a 15% decrease in the odds of adolescent regular smoking. Evidence from Australia and New Zealand also found a reduction in adolescent smoking rates:
- Research by the University of Sterling in 2019 concluded that smoking risk in children has fallen since the implementation of a tobacco display ban. Smoking susceptibility among never-smokers decreased from 28% pre-ban to 23% mid-ban, and 18% post-ban.
- Noticing cigarettes at point-of-sale decreased from 81 % pre-ban, to 28% post-ban; and cigarette brand awareness also reduced, with the average number of cigarette brands recalled declining from 0.97 pre-ban to 0.69 post-ban.
Doctor Allison Ford of the University of Sterling commented: “We also found that young ‘never smokers’ support for a display ban was very high,” She continued. “For example, post-ban, 90% of never-smokers aged 11 to 16 years supported the display ban, while 77% indicated that it made cigarettes seem unappealing, and 87% that it made smoking seem unacceptable.”
In conclusion, reductions in visibility by way of both partial and full implementation of a display ban were followed by a reduction in smoking susceptibility among adolescents, which may be driven by decreases in brand awareness.
In some countries that have introduced tobacco advertising and promotion bans, showcasing tobacco products at the point of sale (POS) has become more important for the tobacco companies.
Studies have shown that there are positive associations between POS displays and increased smoking, smoking susceptibility and positive attitudes among youth.
Finally, by 2018, 10.6% of UK adults were smokers (down from 24.5% in 2004).
So, what will happen to HFSS products?
The Government is taking away important aspects of HFSS category visibility, just like it did with tobacco in previous years. And the evidence from history shows that this should be an effective measure to reduce consumption of less healthy food and drink products.
In response, some brands are already reformulating products to be less unhealthy and to improve their Nutrient Profiling score. A nutrient profiling model is already used to define products high in fat, salt or sugar (HFSS), to determine what can or cannot be advertised to children on TV, internet, outdoor spaces and in print media. This same model will be used to underpin future HFSS advertising and promotional restrictions.
For some brands, it simply won’t be possible to reformulate and so they may well look to improve visibility as a means of defending share of sales.
This is where an understanding of human psychology, behavioural science and specifically, knowledge of how humans look, see and attend, might play a part.
Here are just 3 thought-starters that may be more common after the introduction of the latest HFSS legislation:
1. A picture speaks a thousand words
Images of consumers, consuming, are known to effectively drive desire, engagement and sales. Psychologically this can be explained by Mirror Neurons; a class of neuron that modulates our activity both when we execute a specific motor act and when we observe the same or similar act performed by another person.
As neuroscientist Marco Iacoboni, MD, PhD says:
"Mirror Neurons are important for understanding intentions as well as actions."
2. Smell is a powerful lever
The human sense of smell (or olfaction) is our most primitive sense and yet is one of the most powerful senses that cannot be turned off. Aromas can trigger emotional and even physical responses and allow vivid memory recall of people or places. They can help transform your moods and move you from one state of mind to another.
Will some start to target our sense of smell, as we know from research that a single aroma alone, can drive up sales by as much as 40%?
3. Will music be the food of… …impulse?
When people hear music, this represents more than just the action of sound waves upon the eardrum. Rather, when this information reaches the cortex, the brain interprets these sounds.
A study was conducted by Adrian North and colleagues from the University of Leicester. They played traditional French (accordion music) or traditional German (a Bierkeller brass band – oompah music) music in-store and watched the sales of wine from their wine shelves, which contained French and German wine matched for price and flavour.
On French music days 77% of the wine sold was French, on German music days 73% was German – in other words, if you bought wine, you were 3 or 4 times more likely to choose a wine that matched the music than wine that didn’t match the music.
Interestingly, when asked specifically if they thought that the music affected their choice 86% of shoppers said that it didn’t.
The future of HFSS promotions
There are hundreds, if not thousands of other interventions that can and do alter shopping behaviour and purchasing activity. It will be fascinating to see how effective the HFSS legislation is and how brands and retailers respond.
To conclude, those same multitude of behavioural science based interventions can also be used in positive ways. For example, A study was conducted by public health nutrition researcher Christina Vogel of the University of Southampton and colleagues, in tandem with the supermarket chain Iceland Foods Ltd.
The results of the trials revealed that the simple changes to each store's presentation resulted in a decrease in confectionery sales and an increase in fruit and vegetable purchases across the store. The researchers found that fruit and vegetable sales increased by an average of 6,170 portions per week after three months under the new layout and 9,820 after six months, while weekly confectionery sales fell by 1,575 items after six months.
In another example, researchers simply replaced the sweet confectionery treats with healthier fresh fruit and moved the former to a different location. As a direct result, there was a dramatic increase in sales of healthy items and decrease in sales of sweet treats.
Finally, by simply changing the order in which shoppers were presented with their overall lunch options in the Food to Go areas, was proved to cut the sales of sweet treats by as much as 60%
A Final Thought on HFSS
From health and wellness, to sustainability, social responsibility, implementing rules and regulations are powerful ways of changing human behaviour, but arguably, behavioural science can be equally effective if in the right hands.
Hmm, something to think about.
