HFSS update - what have we learned so far?

As many of you may know, back in 2020, the UK Government strategy for tackling obesity imposed restrictions on the promotion of certain, high fat, salt and sugar (HFSS) food and drink products.

 

Some of these restrictions are already in place, such as rules on where HFSS products can be sold in store i.e. they can no longer be featured at checkout facilities, queuing areas, aisle ends, store entrances, supermarket website home pages, website pop ups etc.

 

However, the next set of legislation relating to advertising and sponsorship for less healthy food and drink products, which were originally planned for January 2023, have since been delayed to 1st October 2025. This relates to TV advertising between 5.30am and 9.00pm, and paid for advertising online at any time e.g. Google ads.

 

Restrictions on HFSS products by volume price e.g. ‘buy one get one free’ or ‘3 for 2’, have also been delayed and are due to come into force in October 2025. This has been extended to allow the government to continue to review the impact of the restrictions on consumers and businesses due to concerns on rising food prices and costs of living.

 

So where does this leave us and more importantly, what have we learned so far?

First, let’s look at whether the rules have actually made a difference on consumer behaviour.

 

The Grocer reports that analysis from the NIQ suggests HFSS-compliant products have gained share of units sold in every major grocery category – fresh, frozen and impulse, excluding ambient food.

 

This is echoed by data from Kantar stating that sales of non-HFSS pizzas, crisps and snacks have grown. These are hugely popular categories and best in class innovation has meant that consumers are now switching from HFSS lines.

 

Even when faced with a cost of living crisis and a need to reduce overall spend, Kantar has indicated that non-HFSS lines are in growth. Furthermore, non-HFSS products are actually recruiting new shoppers to the category or convincing existing shoppers to up their consumption.

 

The Grocer also suggests that sales of confectionary have been dampened by HFSS regulations, demonstrating that the action to remove these foods from prominent locations in store, have indeed removed the opportunity to impulse buy and have consequently impacted the category.

 

Here’s some more positive things that have happened:

  • Companies have invested in reformulating their products to meet the new HFSS standards.

  • Many exciting, new challenger brands have emerged that are genuinely healthier without compromising on taste and quality.

  • The guidelines have influenced the marketing of HFSS products and shaped promotional strategies within the industry. This has meant brands have begun to adjust their messaging to align with health-conscious consumer preferences.

 

However, with the next set of restrictions not due to take place until 2025, how can we make sure we don’t drop the ball on making the food and beverage environment healthier?

 

  1. Let’s collaborate with industry – sharing insights, best practice and driving collective efforts across cross-functional teams such as marketing, finance, nutrition and regulatory is crucial in order to move the dial.

  2. Celebrate innovation – it’s been incredible to see the surge of healthier food and beverage alternatives. Let’s not lose this momentum and foster creativity to enable a more health and sustainability focused approach to entrepreneurship and product development.

  3. Persevere with reformulation – the data shows that consumers are less open to reformulated HFSS products such as confectionary. However, as time continues and experience grows, reformulation techniques will only improve. Other tactics such as reducing the pack size as oppose to changing the product itself, have proved to have an interesting impact so far.

  4. Be mindful of the exemptions – the regulation doesn’t cover all brand advertising (so long as there are no identifiable HFSS products in the adverts), owned media, audio content such as podcasts, online radio and broadcast radio, or B2B advertising. Whilst I appreciate there is a need for balance and HFSS products should have a place on the table, we need to emphasise education to help consumers make more informed dietary choices.

  5. Praise retailers doing great work – the OHA is due to publish a study on which retailers are sticking closest to the rules so let’s make a concerted effort to reward them, as well as highlight non-compliance.

 

I’m really keen to hear your thoughts on the HFSS changes. How is your organisation adapting to the HFSS legislation and subsequent delays? Have you seen any examples of best practice (or not)? What opportunities and challenges do you foresee in the evolving landscape of the food and beverage industry?

 

Get involved in the conversation on LinkedIn.

References:

1) The Grocer. Available online: https://www.thegrocer.co.uk/health/one-year-on-have-hfss-rules-made-any-difference/683737.article#:~:text=First%20some%20good%20news%3A%20the,%2Fe%203%20June%202023%5D.

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