HFSS promotions ban marks policy shift in England

What's changed?

As of 1 October 2025, volume promotions have been restricted on high fat, salt and sugar (HFSS) products in England, which follows the placement limitations that were introduced in October 2022. On the same day, the DHSC released its updated impact assessment for this legislation, estimating that the resulting reduction in calorie consumption among overweight and obese people could deliver £2.39 billion in health benefits over the next 25 years. 

Media coverage of the legislation has been largely positive; a minority of outlets have used the term “nanny state” to describe the government using mandatory measures, while most framed the new restrictions as an important step towards improving the nation’s health.  
 
This latter statement is supported by work conducted by IGD and the University of Leeds that found the previously introduced placement restrictions resulted in an estimated 2 million fewer in-scope HFSS products sold per day and 56% of shoppers didn’t notice any changes in store. 

What does this mean for the food industry? 

For the food industry, the introduction of the volume promotion legislation represents another significant milestone in a long-term shift in how products can be marketed and sold in retail settings. It also underscores the continuing momentum of health policy in England – with Scotland and Wales to follow – one that increasingly prioritises structural interventions over awareness campaigns.  

It’s important to note that several retailers, including Sainsbury’s since 2016 and Tesco since 2022, voluntarily implemented these changes before 1 October 2025. According to Andrea Martinez-Inchausti from the British Retail Consortium, the “vast majority” of members were already compliant by the time the restrictions took effect so the public has likely seen fewer changes than the government expected since 1 October. 

"There will not be a big change for them."

"Food retailers are supporting their customers to make healthier choices through better calorie labelling, reformulation of products, and portion control." 

Across the UK, the approach to HFSS legislation varies, as shown in the table below. England remains furthest ahead, with both placement and promotion restrictions now in place, while Scotland and Wales are at different stages of policy development and consultation.  

Nation	Placement	Volume price promotion	Notable differences to England	Advertising (UK wide)
England	October 2022	October 2025		January 2026
Scotland	Winter 2026 TBC	Winter 2026 TBC	Initially considered broader and stricter rules; restricting HFSS meal deal components, expanded location rules and wider category scope   However, they have recently already revised earlier proposals to be more in line with England/Wales	January 2026
Wales	March 2026	March 2026	Bans free refills of sugary drinks	January 2026
Northern Ireland	N/A	N/A	May develop own regulations in future	January 2026

What’s next? 

The introduction of further advertising restriction are scheduled to take effect across the UK on 5 January 2026, following a delay from the original Autumn 2025 start date. These restrictions will prohibit the advertising of HFSS products on television between 5:30am and 9pm, and a total ban online. This includes digital marketing, paid online ads and paid influencer marketing (including via gifts) which are significant channels for many brands.   

A number of large businesses have already opted to comply early, removing HFSS advertising from their campaigns from 1 October. The impact of which has come under scrutiny due to the minor changes made to advertising; while HFSS product advertising is restricted, brand-level advertising remains out of scope, allowing companies to market through more general brand-building activities.  This trend is likely to continue as companies move their advertising spend more towards brand building. 

What this means - a collective shift in HFSS policy 

The implementation of the HFSS volume promotion restrictions represents another step forward in the UK’s ambition to create a healthier food environment. The combination of placement, promotion, and soon advertising restrictions, reflects a long-term policy shift: one that relies on collective effort from government, industry, and consumers alike. 

With the government progressing with its preventative focused NHS 10 Year Plan, and the introduction of mandatory reporting, policy framework is evolving, the continued proactive action from the food industry will be key to ensuring that healthier diets become the easy, accessible choice for everyone.