HFSS placement legislation: Assessing the impact and what comes next for the food industry

10 October 2025 | Lewis Wallis, Regulatory and Nutrition Affairs Advisor

The UK Government’s Food (Promotion and Placement) Regulations 2021, implemented in October 2022, introduced restrictions on the placement of foods classified as high in fat, sugar and/or salt (HFSS) within specific restricted areas of supermarkets in-store and online. These regulations target key locations such as store entrances, aisle ends and checkouts, which are known to influence purchasing behaviour and promote impulse buying.

The DIO Food team at The University of Leeds have now released three independent studies evaluating the legislation’s in-store impact on 1) in-scope HFSS sales 2) retailer implementation 3) customer perceptions. They have also released a report with IGD on the key findings, which are covered below.

1. Sales data analysis

To assess the effect on in-scope HFSS product sales, researchers analysed daily store-level sales data linked to product information. The data covered up to 18 months pre- and 12 months post-legislation across 480 stores from three major English retailers. To assess the equality of impact, store-level sales were linked to the Priority Places for Food Index (PPFI) that identifies neighbourhoods most vulnerable to increases in the cost of living and which have a lack of accessibility to cheap, healthy and sustainable sources of food. Using this tool, the researchers were able to identify how stores in different types of neighbourhoods have been affected by the legislation. As such, this was the first independent evaluation of England’s HFSS legislation using UK supermarket sales data.

Key findings:

• The legislation reduced sales of in-scope HFSS products as a proportion of total sales.
• When scaled nationally, this equates to around 2 million fewer in-scope HFSS items sold per day.
• Importantly, the impact did not exacerbate inequalities and, where HFSS sales went down, this happened equally in areas across the PPFI spectrum.

2. Retailer interviews and surveys

Researchers surveyed and interviewed representatives from four major UK supermarkets, the British Retail Consortium and trading standards enforcement bodies, with insights consolidated through three workshops to develop eight policy recommendations.

Key findings:

• Retailers broadly supported the aims of the legislation.
• Challenges arose around interpretation, delayed guidance, limited government communication, and lack of access to reliable product nutrition data.
• Retailers used varied promotional strategies to comply, with enforcement found to be limited.

3. Customer surveys

Researchers carried out a survey of 1968 shoppers in England, illustrating how the legislation was perceived by customers.

Key findings:

• 92.5% of shoppers still purchased products from HFSS-dominated categories at least once per week.
• Households with children and those experiencing food insecurity purchased HFSS products more frequently and were more influenced by promotions.
• 71.4% of shoppers saw the legislation as a good first step.
• However, 90% felt affordability of healthier foods was equally or more important than restricting HFSS products.

Policy recommendations

Among the eight recommendations outlined in the policy brief , several focus directly on implementation and product-level food industry data. These include:

• Strengthening legislation to further restrict the promotion of less healthy foods and minimise unintended consequences.
• Coupling HFSS restrictions with positive promotion of healthier alternatives, ensuring affordability and visibility of better options.
• Developing an open, regularly updated food composition database with mandatory provision of ingredient and nutrition data by suppliers to enable HFSS classification.
• Improving enforcement capacity through better tools, training and funding, supported by dedicated guidance and accessible resources.

Next steps for the food industry

IGD supported the research through their Social Impact programmes, convening partner meetings, and as a dissemination partner, translating findings from the research for industry.

Their evaluation of the HFSS placement legislation report outlined five recommendations for industry, which we are well positioned to support with.

Here are the five recommendations and how we can support with each:

• 1. Healthier environments: Optimise store layouts and product placement to promote healthier options –
  • We review product placement, promotion and advertising strategies, identifying what is in scope of legislation and developing action plans for compliance and impact.

• 2. Keep reformulating: Build on progress already made in product reformulation –
  • We provide technical and regulatory support for reformulation and innovation, helping businesses reduce Nutrient Profiling Model (HFSS) scores while maintaining product quality and consumer appeal.

• 3. Utilise data: Making improvements to access and quality of data to guide healthier and more sustainable choices, in collaboration with government and academia to establish clearer, standardised data definitions & methods –
  • We offer product and portfolio evaluations, supporting data collection, review and quality to ensure alignment with industry best practices and emerging nutrient profiling reporting data requirements.

• 4. Collaborate proactively: Share best practices and align on health-focused business strategies –
  • Our Member Interest Groups offer forums for industry to address shared challenges and opportunities, including what works and what doesn’t.

• 5. Embrace technology: Use personalisation, digital advertising and AI to drive healthier choices –
  • We support by advising manufacturers, retailers and technology platforms to ensure digital tools and advertising strategies are aligned with regulatory requirements and industry best practice.

Taken together, the research and recommendations highlight that HFSS placement legislation has had an effect to shift sales of products in scope of the policy. Both retailers and shoppers recognise the value of the legislation, but challenges remain around affordability, access to data and practical implementation.

At Campden BRI, our nutrition and regulatory services are designed to help businesses translate these recommendations into action, turning policy challenges into opportunities for growth and innovation.

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