HFSS Promotion Restrictions - Impacts on Retailers & Consumers

HFSS Promotion Restrictions - Impacts on Retailers & Consumers

High fat, sugar and salt (HFSS) products are being targeted by the UK government and food companies alike. But what impact will this have on society?

The UK government's Food Standards Agency (FSA) has just released new regulations that restrict the use of HFSS foods for promotional purposes. These new restrictions will have a direct impact on retailers and consumers...

What are HFSS products and promotions?

HFSS refers to products high in fats, sugars or salt, including products such as pies, pastries and cakes, along with savoury snacks, confectionery and desserts. These foods are often promoted in-store through free samples or end-of-aisle displays.

HFSS promotions such as ‘3 for £1’ and ‘Buy One Get One Free’ have been linked to obesity in children due to their accessibility and cheap price. It is claimed that children who see these types of products advertised may be more likely to purchase them later on, therefore being exposed to the health risks associated with consuming too much sugar. These products are linked to an increased risk of obesity, type 2 diabetes and cardiovascular disease.

What are some of the HFSS restrictions on promotions?

In response to the current national health crisis, the Department of Health within the UK government has proposed a ban on the advertising of HFSS foods towards children. The aim is to prevent potential future health problems.

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For example, there have been public health campaigns to limit the consumption of "junk" foods such as HFSS drinks. These beverages are not just high in sugar but also high in calories which can lead to weight gain and other chronic conditions such as diabetes and heart disease. Retailers should be aware that they may face restrictions on their promotion of these products; consumers should know that they will likely see less advertising from retailers promoting these products or discounts/specials in-store.

According to the official report, restrictions will be placed on promotions of HFSS products by location and price in retailers that sell food and drink in-store and online in England: 

"Locations restrictions will apply to store entrances, aisle ends and checkouts and their online equivalents (that is, entry pages, landing pages for other food categories, and shopping basket or 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."

Gone are the days of BOGOFs and FSDUs for sugary treats...

Why is the UK Government restricting HFSS product promotion?

The recent restrictions on HFSS promotions come as a result of the growing concern over obesity rates in the UK. Obesity is one of the biggest health problems this country faces. Two-thirds of adults are overweight, and over one-fifth of children under the age of 5 are overweight, with this rising to one-third by the time they reach 11 years old!

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Regular overconsumption of food and drink high in calories, sugar and fat can lead to weight gain and, over time, obesity, which in turn has a significant impact on health and wellbeing and increases the risk of obesity-related diseases such as type 2 diabetes, cardiovascular disease and some cancers.

Putting this into context, the NHS spent £6.1 billion on overweight and obesity-related ill-health in 2014 to 2015, with overall costs to wider society reaching £27 billion. The predicted cost of obesity by 2050 is £9.7 billion, with wider costs to society estimated to reach £49.9 billion per year.

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It is claimed that just a 1% reduction of overweight adults could save up to £60 million per year in healthcare costs. Thus, it can be argued that it is not only for the good of people's health and wellbeing but also to relieve some of the country's financial pressures too.

Who will be affected by these restrictions?

In terms of stores, large retailers (with 50 or more employees) will be subject to these restrictions, including stores and restaurant chains owned by a parent company.

There will, however, be some exceptions:

  • Micro and small businesses (fewer than 50 employees)
  • Stores smaller than 185.8 square metres (2,000 square feet)
  • Speciality food store that sells one type of product, for example, chocolate specialist or a cookie kiosk.

In terms of items and therefore brands, the list is much longer:

  • Breakfast cereals and morning goods
  • Cakes and biscuits
  • Yoghurts, puddings and ice cream
  • Ready meals
  • Pizzas confectionary
  • Chocolate confectionary
  • Crisps and savoury snacks
  • Beverages that are already subject to 'sugar tax'

So, what are retailer views on HFSS restrictions?

Following the success of the 'sugar tax' on soft drinks introduced in 2018, it was only a matter of time before similar restrictions came into force for food products.

Many retailers have already taken steps to reduce the number of promotions on HFSS products. For those who anticipated the restrictions, they've gone one step further, with some manufacturers already reducing the levels of fats, sugars and salts in their products. Kellogg's are a great example, having started their fight against HFSS back in 2010 by gradually reduced the fat, sugar and salt content of their Coco Pops:

  • 2010 - announcement of 15% reduction in sugar levels
  • 2017 - 14% reduction in sugar content, reaching 9g of sugar per 30g serving
  • 2018 - a further 40% reduction in sugar content, reaching 5.1g of sugar per 30g serving

The nutrient profile on the packaging shows a stark difference between 2017 and today.

However, some brands are worried that by changing their promotional activities they will be passing a greater proportion of their overall profits onto consumers.

Without the incentive of a discount, many shoppers will not buy these foods at all and this could see an increase in competition as consumers try to find cheaper alternatives for themselves. To combat this problem, some companies may choose to raise prices on non-discounted items not covered by the restrictions.

The FSA will be monitoring dietary habits once these restrictions come into effect in a bid to see if any further measures need to be taken to help improve the health of consumers. While it remains unclear what exact impact these new restrictions will have on retail figures, it will be interesting to see whether they result in a healthier population and, ultimately, a healthier economy.

And how about consumers' views?

These types of restrictions are not new. Over a decade ago, the EU banned the promotion of HFSS products around children's TV programmes, such as before the 9pm watershed, as well as restricting their advertising in other media. With this in mind, we should be well-versed in what to expect.

Having said that, you can't please everyone... Jumping back to Coco Pops tale, we saw parents complaining about the taste and demanding the old recipe be reintroduced, despite the clear health implications. So who knows how the nation will respond.

I’d like to think the move will surely be favoured by many. Consumers are slowly becoming more health-conscious, with a large number turning to plant-based diets and more natural, free-from products as opposed to conventional items. Sales of organic food have increased from $390 million annually to $2.3 billion annually over the last 2 decades. 

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This clearly demonstrates consumer desire for healthier alternatives.

How can retailers promote HFSS products without violating the new rules?

It is important to note that manufacturers are not prohibited from promoting their products, but rather the discounts they offer consumers. So, what options do companies have?

  1. Never running a promotion again...
  2. Reflect on the product itself and consider how it could be made healthier
  3. Adapt their marketing strategies by reaching out to a specialist who knows how consumers react when markets go dark!

Some may argue that as multi-national organisations, these brands surely must take responsibility for encouraging healthier lifestyles. Others may argue that all consumers have a choice - just because it's there, doesn't mean you have to buy it. 

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The question is, how far can we blame marketing and psychology for those decisions?

How will consumers be affected by these restrictions on advertising for HFSS foods?

Although promotions appear to be mechanisms to help consumers save money, data shows that they increase consumer spending by encouraging people to buy more than they intended to buy in the first place. Price promotions appeal to people from all demographic groups and increase the amount of food and drink people buy, with 40% of the food and drink people purchased in 2015 being on promotion. Evidence suggests that volume promotions lead us to buy almost 20% more than we otherwise would.

As much as consumers like to think they take advantage of promotions in order to stockpile the extra purchases at a lower price, the reality is that they often just increase their consumption - a clear contributor to our national obesity crisis.

So, despite consumers initially thinking that they are going to have to spend more to get their usual tasty treats, they may just realise that they were overspending (and over-consuming) in the first place. Perhaps in the long-term, we'll see a healthier, wealthier nation...

What does this mean for the future of food marketing in the UK?

These restrictions will undoubtedly put pressure on manufacturers and retailers to find new ways of promoting their products. However, by adhering to the regulations and focusing more efforts on making healthier products not only tastier but also more appealing, they may see a rise in brand loyalty and sales figures as well as an increase in customer satisfaction.

The health benefits alone should be enough to convince these companies that it is worth investing time into finding solutions!

Ultimately all our lives will improve from this change as people become less prone to illness related to unhealthy lifestyles. Let's hope we see a positive shift in consciousness over the coming months and years.

So, how can I help?

During my 20+ years as a behavioural scientist, I have studied shopping and consumption of ‘state-changing’ products in 23 countries. By ‘state-changing’ I mean products that induce mental change in the minds of consumers; predominantly, tobacco, alcohol and confectionery/sweet treats. 

I know how HFSS is likely to play out in terms of brand performance. 

Here are 3 evidence-based predictions (I have many more)

  1. As markets go dark, larger brands brow share while smaller marques wither and die: without the added standout of promotions, secondary sightings, etc, shoppers have to rely more on brand recall. Brands will need to get more creative at generating meaningful shopper attention and engagement. This means better understanding how shoppers shop and identifying much more subtle channels into their minds.
  2. You don’t need hard-hitting promotions to drive sales: many studies have identified that it isn’t the added value of the deal that drives up sales but simply the additional standout generated by supporting POS and messaging. As examples: Alcohol sales up 23%, but no actual promotion present. Cigarette sales up 150%, simply by leveraging a promotional colour cue. Numerous offers (I have analysed more than 50) that involve the added value being worse than the original single product RRP, still drove sales up.
  3. The part of the brain that studies special offers, is often dormant when shoppers buy added value items: the neocortex in the brain is heavily involved in calculating added value, but fMRI studies have proven that it often is not involved in evaluating certain special offers. In other words, it is possible to bypass reason and go straight to emotion, when it comes to optimising the appeal of ‘rewarding’ products.

Final thoughts on HFSS

I am a firm supporter of nudging us all to be a bit healthier, partly because of the reasons given in this article. However, as HFSS looms ever closer, brands and retailers will still market their wares. 

Going forwards, this will be much more about understanding and applying behavioural science. And that’s where I come in.

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About Phillip Adcock

My name is Phillip Adcock: I have more than 30 years of human behavioural research and analysis, and have developed a unique ability to identify what it is that makes people psychologically and physiologically 'tick'.

Would you like to know more about how shoppers and consumers think? Download my FREE guide now. Alternatively, check out, where there are more FREE downloads available there. Or why not simply email me with what's on your mind?

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Phillip Adcock

Phillip Adcock CMRS
Psychology & Behaviour
Change Consultant

Phillips Signature

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