HFSS changes: What to prepare for

High fat, salt and sugar (HFSS) food and drink regulations continue to reshape the UK food and drink landscape. This autumn and into 2026, new restrictions come into force that will affect how products are promoted, marketed, and reported across the UK.

Details of additional HFSS legislation this autumn and January

The government’s phased approach to HFSS restrictions means businesses in England are facing two major milestones.

Autumn 2025: Multibuy restrictions

New rules will limit or ban volume promotions (e.g. “buy one, get one free”) on HFSS products in England with the objective of improving the food environment, leading to healthier consumer choices. Multibuy restrictions were postponed from October 2022, when the placement restrictions were implemented. The government cited cost of living pressures as the driving factor. Some retailers have already implemented not using multi-buy promotions before the legislation.

January 2026: Advertising restrictions

Restrictions on advertising HFSS products between 5:30am and 9pm on TV and a total ban online are scheduled to come into force across the UK. This includes digital marketing, paid online ads and paid influencer marketing (including via gifts) which are significant channels for many brands.

In 2007, advertising restrictions prevented marketing on children's broadcast tv, in 2017 restrictions broadened to online and out of home media where under 16s make up more than 25% of the audience and prohibited targeted advertising across children's media. These new restrictions could be seen as an expansion of previous legislation.

For businesses the new legislation means promotion strategies have already been reviewed and so we are likely to see a major shift in advertising strategies from 1 October as large businesses voluntarily agreed to apply the ban from this date. This is a big change in the ‘golden quarter’ of advertising this year. The good news for industry is that it’s been confirmed that branding falls out of scope as long as there are no depictions or references to a HFSS product.

How this varies across England and the devolved nations

HFSS regulations are being implemented at different times across the UK, with England leading the way. While Scotland and Wales initially proposed stricter rules, both are now aligning more closely with England to create consistency for businesses. Northern Ireland has yet to introduce specific legislation but has indicated in its 2024 Obesity Strategy that it will do so in the future.

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

Mandatory reporting before end of parliament

As detailed in the 10 Year Health Plan for England, mandatory reporting of healthy sales is expected before the end of the current parliament (2029).

The government is considering requirements for companies to disclose sales data related to HFSS and non-HFSS products. The NHS 10 year plan also suggests potential targets for sales of Healthy sales after this Government.

At this stage, the details remain unconfirmed. However, the clear signal is that greater transparency will be expected, and this will require companies to have robust data systems in place – which will pose some challenges for the industry.

To add additional complications, there have been discussions of updating the 2004 NPM model. If this was to involve transitioning to the 2018 NPM model the industry would have to look at reformulating again due to the stricter criteria and scoring free sugars over total sugars.

IGD resources

Evaluation of the HFSS placement legislation IGD report

The University of Leeds, IGD and four major retailers worked in collaboration to share data to enable an independent analysis by the University of Leeds to understand the impact of the HFSS legislation.

The research estimates a 0.63% point reduction in sales of in-scope HFSS products as a proportion of total sales by weight, followed the introduction of the legislation. This equates to two million fewer in-scope HFSS products sold per day after the new legislation took effect. It found that before the legislation was implemented, 20 out of every 100 items sold were in-scope HFSS products. Following legislation this number dropped to 19.

Summary of what’s changing

Multibuy and advertising restrictions in England from autumn 2025 and January 2026 respectively.
Devolved nations diverging: Scotland had consulted on broader restrictions but is likely to align with England by Autumn 2026, Wales is implementing its own promotion rules by March 2026 and Northern Ireland yet to legislate.
Mandatory reporting expected before end of parliament, with a likely focus on Mandatory Healthy sales data reporting and transparency.

What this means for business

Plan for regional variations: A one-size-fits-all approach to promotions may not work across the UK.
Review advertising strategies: What has been permitted before, is no longer permitted. It’s a new marketing landscape that will require navigating.
Prepare data systems: Mandatory reporting will require new levels of transparency and tracking for sales & nutrition data.
Engage with reformulation: Restrictions highlight the long-term need to grow the healthier side of portfolios.