UK HFSS placement & promotion restrictions

Food (Promotion and Placement) (England) Regulations 2021 — HFSS Regulations restrict where and how foods classified as High in Fat, Salt or Sugar can be displayed and promoted. Classification engine — Nutrient Profile Model 2004/2005 calculates 'A' points (energy kJ, saturated fat g, total sugar g, sodium mg per 100g/100ml) offset by 'C' points (fruit/veg/nut content %, fibre, protein). Foods scoring ≥4 and drinks scoring ≥1 are 'less healthy'. Thirteen in-scope product categories — soft drinks with added sugar, cakes, chocolate confectionery, sugar confectionery, ice cream, morning goods, puddings, sweet biscuits, breakfast cereals, yogurts, milk-based drinks with added sugar, pizza, ready meals, crisps/savoury snacks. Qualifying retailer threshold — 50+ employees and 185.8m² qualifying floor area. Placement restrictions in force October 2022 — no HFSS at store entrances (within 2m), aisle ends/gondola ends, checkouts (within 6 retail metres including queueing area), and equivalent online locations (homepage, category landing, checkout/basket, favourites). Volume-price promotion restrictions from October 2025 — BOGOF, 3-for-2, multi-buy at single price, free with HFSS purchase, free refills on HFSS soft drinks. Single-product discounts and component-priced meal deals remain permitted. Advertising restrictions from October 2025 (Health and Care Act 2022) — 9pm TV watershed and paid online advertising restrictions (sponsored social, paid search, paid display, paid influencer, paid newsletter). SME exemption <250 employees from advertising restrictions only — placement and promotion restrictions apply at retailer level regardless of brand size. NPM 2018 update under DHSC review not yet adopted. Reformulation programmes against NPM (sugar/sodium reduction, fibre/F+V/N increase) drive category-level nutritional improvement.