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Compliance

UK HFSS placement & promotion restrictions

UK Food (Promotion and Placement) (England) Regulations 2021 — HFSS Restrictions · HFSS regulations · Nutrient Profile Model · NPM 2004/2005 · 9pm watershed · volume price promotion

In short

Term — UK HFSS placement and promotion restrictions: uK HFSS framework — 2004/2005 Nutrient Profile Model classifies food (score 4+) and drinks (score 1+) as 'less healthy', placement restrictions at store entrances/aisle ends/checkouts since October 2022 in qualifying retailers (50+ employees, 185.8m²), volume-price promotion restrictions (BOGOF/3-for-2) from October 2025, 9pm TV watershed and paid online advertising restrictions from October 2025 (SME exemption <250 employees), 13 in-scope product categories.

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.

Regulatory anchors
  • Food (Promotion and Placement) (England) Regulations 2021
  • Health and Care Act 2022
  • DHSC Nutrient Profile Model 2004/2005
Where this term comes up
Food ProcessingBakery & ConfectioneryIngredients & Dry MixesConsumer Products
How V5 handles it
Score your compliance gap — then download the validation pack.
A guided self-assessment walks you against the regulator clauses that apply to your industry. The validation pack — IQ/OQ scripts, traceability matrix, risk assessment, intended-use statement — generates from the same evidence so you can hand it to an auditor on day one.
Labels — designed, approved, checked and printed in one place.
Many plants run a separate label tool beside their production records, so label versions drift and reprints go unrecorded. In V5 the label designer, approval, printing and the recipe's label details sit with the production record: the barcode scheme set on a recipe is checked when the operator packs, and the approved artwork revision is printed on the batch record. Printer connections are configured per workspace.
Document control — one version in force, every change signed and explained.
Draft the next revision while the current one stays in use, approve it under your sign-off route, and track training on it — with the history kept.
Related terms
Natasha's Law (PPDS allergen labelling)
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