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A short and ‘sweet’ (with no added sugar) guide to HFSS

Our whistle stop tour of HFSS and what we know about the regulations so far.


Sam Brotherton



If you’ve opened this article looking for legal advice on the impending HFSS regulations, I’m afraid you’ve come to the wrong place

We’re definitely not sensible enough to be legal advisors. Plus, with a possible 10 months still to go until this legislation is due to be finalised (if all goes to plan), a lot will likely change.

With that said, what we can do is help you to understand the information the Government have released so far, and some of the ways brands can start to prepare.…

First things first, what does HFSS mean?

HFSS refers to a food or drink item that is High in Fat, Salt and Sugar, and is worked out using the Nutrient Profiling Model. The model uses a points system to work out the balance of ‘good’ and ‘bad’ nutrients in food and drink. The resulting Nutrient Profiling Score determines whether the food or drink is a HFSS or not.

So, what’s changing?

As a country, 28% of the population are deemed to be obese, and the UK was ranked the 36th most obese nation in the world. So, to try and tackle this, the Government are introducing controls on the promotion of high fat, sugar and salt foods and drinks. The legislation is set to come into effect in late 2022/early 2023, meaning tighter restrictions are on the horizon for brands.

We have identified four main areas of restriction as:


Limiting the areas within stores (both on and offline) where HFSS products can be present e.g., store entrances or aisle ends

Price Promotion

Banning the use of promotions that imply you are getting free product for your money e.g., buy one get one free

Broadcast Advertising

Implementation of a 9pm watershed, restricting the time at which HFSS products can be advertised on TV

Online Advertising

Restriction of paid for online advertising of HFSS products

What can we do?

Whilst the finer details are still being finalised, we can still look ahead and use our time wisely to plan. But don’t worry FMCG folk, it’s not all doom and gloom, there’s still lots we can do! Here are five ways your brand can adapt…

Embrace the change

When advertising restrictions came into play around gambling, bookmakers embraced the move and became proactive by self-regulating and adopting the “When the Fun Stops, Stop” tagline. Likewise, alcohol brands are often seen using safe the “Drinkaware” logo. The same approach could be taken by HFSS brands, setting up a proactive movement to encouraging healthy eating.

Develop existing products

If products are close to being in the green when it comes to HFSS, some reformulation tweaks may be the solution, to shift that nutrient profiling score. Not only will this mean less advertising restrictions, but it will also demonstrate how the brand is committed to public health. For example, earlier this year Haribo invested £22 million in its UK manufacturing operations, to strengthen the reformulation of products and cut sugar within the portfolio. Plus, Kellogg’s has promised to cut sugar in its children’s cereals by 10% and salt by 20% by the end of 2022.

Enter new markets

The alcohol market is heavily restricted when it comes to advertising, but some brands have seamlessly created brand awareness by entering other markets, such as Guinness who now sell everything from apparel and glassware to chocolate and preserves. HFSS brands could also boost their awareness through expanding into non-food related markets.

Be forward thinking

With just short of a year before restrictions are enforced, there is still plenty of time to get prepared. One key area to focus on in the next 10 months is to build brand awareness, through creating brand salience and getting to know your audience. This will reduce the need for product-specific advertising in the future and help you to generate sales through other means.

Own your owned content

At the moment, we think that owned channels will be exempt from HFSS restrictions. So, it may be worth putting extra energy into developing your website, social channels and email marketing to ensure you have an engaged and loyal audience ahead of the restrictions hitting.

There you have it, our whistle stop tour of HFSS and what we know about the regulations so far. If your brand is going to be impacted, take this time to plan ahead as best as possible, and if you need a helping hand navigating it all, you know where to find us.


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