From delayed implementation to the suggestion of repeals, the regulations surrounding food and drink products that are high in fat, sugar and salt seem to be far from finalised. Here, we examine the regulations that are now in force, and what the Labour Government plans to change further down the line.

Obesity has been, and continues to be, one of the most pressing health issues in England, with rates in both adults and children rising, particularly in the most deprived areas.
 
According to the House of Commons Library’s most recent obesity statistics, 28% of adults in England were obese in 2022, with a further 36% overweight. Around one in eight children between the ages of two and 10 are also considered to be obese, according to the NHS.

In addition to increasing the risk of developing long-term health issues, such as type 2 diabetes, coronary heart disease, and some types of cancer, obesity costs the NHS in England around £6.5bn a year to treat. 

With these costs expected to rise to £10bn a year by 2050, various governments have, over the years, introduced legislation and regulation to support people in eating healthily and exercising more regularly.

In the past five years, these efforts have included greater regulation on the way in which less healthy foods, such as crisps, sweets, chocolate, and sugary drinks, are promoted and sold to the public.

What regulations has the UK Government introduced?

The Food (Promotion and Placement) (England) Regulations 2021 (‘the Regulations’) were first introduced by the former Conservative Government to prevent unhealthy foods from being prominently featured in store or online.

Speaking at the time, former Public Health minister Jo Churchill said: “We know families want the healthy choice to be the easy choice, and restricting promotions on unhealthy foods will help them achieve this.

“We want to support everyone to eat healthier foods more regularly and this starts with helping supermarkets and manufacturers promote healthier food choices lower or free from HFSS [high fat, sugar or salt], to support families to make healthier choices.”

In the first instance, the Regulations restricted where food and drink products that are high in fat, sugar or salt (‘HFSS products’) could be placed in stores. 

Since October 2022, convenience retailers with more than 50 employees and a relevant internal floor area of 2,000 square feet have not been permitted to display HFSS products in, or within certain distances of, checkouts, designated queuing areas, end-of-aisle units and store entrances (albeit with some exceptions).

This October, a ban on volume promotions such as ‘3 for £10’ or ‘Buy one Get one Free’ for HFSS foods has also been introduced, again affecting any convenience retailer with more than 50 employees.

What is a HFSS product?

A HFSS product is decided via a two-step process. According to guidance from the Department of Health & Social Care, a product will be deemed “less healthy” if it:

  1. falls within one of 13 categories specified in Schedule One of the Regulations. This includes items such as cakes and cupcakes, ice cream, pizza, chocolates and sweets, and prepared soft drinks with added sugar; and
  2. scores 4 or above for food, or 1 or above for drink when applying the 2004 to 2005 Nutrient Profiling Model (NPM) using the 2011 technical guidance.

Only pre-packaged food (i.e. food that is not freshly prepared and intended for immediate consumption) falls within the scope of the Regulations.

What rules are due in 2026?

In addition to the ban on volume promotions, advertising restrictions were also due to be introduced this October. 

These amend the Communications Act 2003 to implement UK-wide restrictions on advertising HFSS products on television, as well as Ofcom-regulated on-demand services, between 5.30am and 9pm. They also expand on the ban for advertising HFSS products directly to audiences under the age of 16, which has been in place since 2007.

These Regulations will also prohibit certain methods of online promotion for HFSS products, including:

  • any paid-for advertising;
  • placing a HFSS product on a retailer’s home, checkout, or suggestion web pages;
  • featuring a HFSS product in a ‘pop-up’.

Although the Regulations’ implementation has been delayed until 5 January 2026, many major retailers intend to adhere to the original deadline.

Are these Regulations going to change?

It is possible that some elements of the Regulations will be changed or repealed.

In July 2025, the Labour Government published its 10-Year Health Plan for England, in which it stated its intention to “repeal legislation restricting volume price promotions and aisle placement” in favour of “smarter regulation, focused on outcomes”.

Changes mentioned in the Government’s plan include:

  • Introducing mandatory healthy food sales reporting for all large companies in the food sector;
  • Introducing mandatory targets on the average ‘healthiness’ of sales; and
  • Changing the current and “plainly out of date” Nutrient Profiling Model.

It is not yet clear how or when these changes will be introduced. As such, retailers should continue to comply with the current regulations, including those that may be repealed at a later date.

What should retailers do?

Retailers that fall within the scope of these regulations should already have re-evaluated store designs and product placements, as well as any forthcoming volume promotions or advertising campaigns that would have been applicable to HFSS products.

For those that haven’t, the clock is ticking, with the volume promotion ban now effective as of 1 October 2025 and the advertising ban informally self-imposed by several large retailers ahead of its formal implementation next January.

Depending on the local authority, retailers that fail to comply could also face fines of up to £2,500, as well as the associated costs of complying with any Improvement Notice requirements, such as revising store layout or cancelling advertising campaigns.

Given the complexity of the Regulations, as well as the likelihood of further changes on the horizon, retailers should seek specialist legal advice to ensure that they are compliant in all aspects of the Regulations, both on the shop floor and online.

In doing so, retailers can also play a significant part in improving the nation’s health, reducing the rate of obesity, and minimising the burden on the NHS.

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