Less Healthy Food (HFSS) Promotion and Placement Readiness
Know which products count as specified food, where they cannot be placed and which promotions stopped on 1 October 2025.
In Short
- 50+ staff and Schedule 1 food.
- Food scoring 4+ is less healthy.
- Multibuys restricted since Oct 2025.
The Food Processing Operations Guide
Safe changeovers. Right labels. Every lot traceable.
- The rules and the plan
- Supplier to filled tray
- Allergen changeovers and pack checks
We ask for your name and email so we can handle this request. The full guide then opens on this site, ready to translate, print or save. Privacy policy. Practical orientation, not legal advice; your quality unit decides which rules apply.
UltimateFree guide
The Food Processing Operations Guide
Safe changeovers. Right labels. Every lot traceable.
The Food (Promotion and Placement) (England) Regulations 2021 restrict where qualifying businesses place less healthy prepacked food in store and online and, since 1 October 2025, volume price promotions such as multibuys. This guide covers scope, each restriction and the product data manufacturers supply to retailers. It covers England only. Orientation, not legal advice. Sources checked 4 Oct 2026.
Which businesses and foods
Regulation 4 makes a business qualifying if it offers prepacked food to consumers and had 50 or more employees on the first day of the financial year, unless it falls in an excluded category listed there. Under regulation 3, specified food is food in a prepacked item that falls in a Schedule 1 category, is less healthy and is not charity food.
More on which businesses and foods
A food is less healthy if it scores 4 or more points under the Nutrient Profiling Technical Guidance, and a drink if it scores 1 or more. If any food in an item is Schedule 1 food, the whole item is treated as Schedule 1 food.
In-Store Placement
Regulation 7 stops a qualifying person placing specified food within two metres of a checkout or designated queuing area unless it is inside an aisle, at an aisle end next to a main customer route or on a separate structure within 50 cm of such an aisle end, within the prohibited distance of a public entrance to the main shopping area, or in a covered external area such as a foyer. The prohibited distance is the smaller of 15 metres or 0.03 times the relevant floor area.
Placement limits (reg 7)
| Location | Specified food |
|---|---|
| Within 2 m of checkout or queue | Not allowed, unless inside an aisle |
| Aisle end on main route | Not allowed |
| Near store entrance | Not within 15 m or 0.03 × floor area, whichever is smaller |
| Store under 185.8 m² | Placement limits do not apply |
- Within 2 m of checkout or queue
- Specified food
- Not allowed, unless inside an aisle
- Aisle end on main route
- Specified food
- Not allowed
- Near store entrance
- Specified food
- Not within 15 m or 0.03 × floor area, whichever is smaller
- Store under 185.8 m²
- Specified food
- Placement limits do not apply
More on in-Store Placement
Stores under 185.8 square metres and single-category specialists are exempt.
Online Restrictions
Regulation 8 stops specified food being offered on an online marketplace's home page, on pages opened without the consumer's intention such as pop-ups, and while a consumer is browsing or searching for other products, unless the exceptions in the regulation apply. While a consumer browses Schedule 1 food, specified food from the same Schedule 1 category may still be shown.
More on online Restrictions
Online marketplace here means any website or app used to offer the qualifying business's products to consumers.
Volume Price Promotions
Regulation 5 has applied since 1 October 2025. A qualifying person must not offer specified food as part of a volume price promotion, in store or online.
More on volume Price Promotions
That includes multibuys such as '3 for 2' or 'buy 6 and save 25%' and offers saying an item or part of it is free, such as 'buy one get one free' or '50% extra free'. Packaging already carrying such a promotion could be sold for 12 months from 1 October 2025. Regulation 6 separately restricts free refills of certain less healthy drinks that are not prepacked.
What manufacturers supply
The duties fall on qualifying retailers, but they depend on manufacturer data. For each product and recipe version, keep the Schedule 1 category your team assigned, the nutrition data and the nutrient profiling score calculated with the current technical guidance, who checked it and when.
Worked Example: Item BK-88 Customer Data Pack
More on what manufacturers supply
Rescore when a recipe changes and tell customers. Review pack artwork for promotional flashes on specified food. These are decisions people make and record; the scoring method itself is in the government's technical guidance, not reproduced here.
Questions
Do these rules apply to small shops?
Placement limits do not apply to stores under 185.8 square metres or single-category specialists (regulation 7(2)), and only businesses with 50 or more employees qualify (regulation 4).
When did the multibuy restriction start?
Regulation 5 came into force on 1 October 2025 (regulation 1(1A)).
How is 'less healthy' decided?
By the Nutrient Profiling Technical Guidance: 4 or more points for food, 1 or more for drinks (regulation 3(4)).
Does this cover Wales or Scotland?
These Regulations apply in relation to England. Other nations' rules were not checked for this guide.
Practical orientation, not legal advice. Rules differ by jurisdiction; your quality and compliance team decides what applies.
Keep reading
Bisphenols and Phthalates in Plastics: EU 2024/3190, FDA Abandoned Uses and CPSC Limits
UK Cosmetics Regulation and SCPN: Responsible Person, PIF and Notification (Great Britain)
UK Packaging EPR and Plastic Packaging Tax: Readiness Guide
Food Supplements (England) Regulations 2003 Readiness
UK Medical Device Regulatory Readiness Guide (GB and NI)
UK Clinical Trials Amendment Regulations 2025: Sponsor Guide