The first phase of restrictions on HFSS in the UK has been in place for almost two years.
The UK government has imposed restrictions on the in-store marketing of products high in fat, salt and sugar (HFSS). The UK government has banned secondary promotion locations such as store entrances, end-of-aisle displays and checkouts.
The description of the movie was 'The most significant in-store changes in decadesIn the country.
In just over a year, British manufacturers and brands, and all European exporters of products to the UK, will face a new wave of disruption as the second round of regulations is due to come into force.
What should companies affected by the new regulations expect?
How to Navigate a Volume Pricing Ban
From October 2025, all HFSS sold in UK products will be subject to an additional ban on volume-based price promotions. Multiple purchases, as well as any other offers stating that additional volumes are free or discounted, will be banned. You may see a sign saying “50 extra %s for free” or “buy 300g to save 10 %s”.
The UK's advertising regulator, the Advertising Standards Authority, will ban any HFSS-related SKUs from being advertised on pre-watershed or digital TV in the same month.
The new restrictions will apply to foods that score four or more on the UK's nutrient profile model. The model awards points for energy, sodium, sugar and saturated fat content. It also gives points to fibre, fruit and vegetables and nuts.
All medium and large UK retail stores with at least 50 employees that sell pre-packed food in-store and online will have to comply. This includes franchises and Symbols Group stores. Out-of-home is not affected, with the exception of those offering free refills on sugary drinks.
Mixed messages
Following the British elections in July, the left-wing Labour Party won a landslide victory, replacing the Conservative government that had been in power for 14 years. The change raises new questions about its possible impact on the marketing of HFSS.
Before the election, Labour’s shadow health secretary, Wes Streeting, said a BOGOF (buy one, get one free) ban was not an option. In September last year, he said he wanted to “work productively” with food companies to find out what they could do proactively. Keir Starmer, then leader of his party and now prime minister, has promised to press ahead with plans to ban junk food ads before the watershed, as well as cracking down on social media ads.
Ian Wright, former chief executive of the UK trade group Food and Drink Federation and currently an industry advocate at Lockton Consulting, has every reason to believe that HFSS and highly processed foods will come under fire from Labour.
He says the next few years will be fraught with risk for automakers. It has been clear for years that a new administration would target both ultra-processed foods and HFCS.
He adds that "the cost of living and fear of backlash from key constituencies have delayed the implementation of comprehensive restrictions on advertising, promotions or in-store placement of HFSS products." Labour's top priority is saving the NHS, or National Health Service. Food policy will therefore be heavily influenced by obesity reduction targets over the next five years.
Manufacturers must reconsider their economic model in the face of the probable contraction of margins.
Addressing potential challenges
Luke Withers of Lockton, a leading UK food and drink company, says that in the rush to avoid restrictions and reformulate over the coming month, food manufacturers in the UK and Europe should brace themselves for a number of likely issues.
He says: “It is important to keep in mind that the change will affect the entire industry and multiple regions. If regulatory pressures are applied, the race to find enough new ingredients or alternatives could lead the industry to resource shortages and even more supply line challenges.
Manufacturers looking to use sweeteners to reduce the amount of sugar in their products will face a flood of concerns and questions. Managing risks and perceptions will be key. Additional risks related to handling, processing and storage must also be considered, as well as the implications for consumer health.
As pressure increases and businesses need to evolve more quickly, companies should also consider the strategic and operational risks that these product and business model changes could pose. A first step should be to review current risk registers to see how changes could either create new risks or alter existing ones. Risks and opportunities should be considered within the broader perspective of consumer behavior and regulation in international markets.
Wright sees an opportunity to work with UK industry to address a common challenge. He says the direction has been known for years and industry must be prepared to take the first steps. The next question is: “Can manufacturers come together and create a coherent, collective and compelling narrative to combat the coming wave of draconian action on ultra-processed foods?”
This would be a serious blow to the mass production model of this industry. So far, neither large companies nor representative bodies have advocated for the food industry. "The risk is that the case will be decided by default."
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