Last updated: 10/09/2024
Ban HFSS volume promotions in food retail businesses
End all volume offers for HFSS products which contribute significant sugar and calories to children’s diets and are of most concern for childhood obesity, in the retail sector excluding small and micro businesses
- Moderate impact on obesity
A percentage estimate of how much the policy would reduce national obesity rates
- Relative reduction in obesity prevalence: 0.7%
- Moderate evidence quality
A rating of the strength of evidence, accounting for both reliability and validity of the evidence
- Reliability and validity rating: 3/5
- Very low cost to governments
Cost to UK and devolved governments over 5 years
- Costs to governments over 5 years: £0.5m
- Benefit to governments per year: £0.4bn
What is the policy?
This policy is the preferred policy option reported in the UK Government’s ‘Restricting volume promotions for high fat, sugar, and salt (HFSS) products’ Impact Assessment (IA). Instead of targeting volume promotions across all HFSS products, this policy specifically targets product categories contributing the most sugar and calories to children’s diets. As specified, the policy is estimated to deliver significant health benefits in a way that considers implementation feasibility and lowers cost to business.
Volume promotions refer to the following promotion types:
- multi-buy offers (eg, ‘Get 3 for the price of 2’)
- combination offers (eg, ‘Get 10% off X when you buy Y’)
- bulk discounts (eg, ‘50% extra free’).
Temporary price reductions (eg, ‘10% off today’) would not be included within this policy.
Recent context
Volume promotions account for 40% of food and drink take home expenditure, and HFSS items are promoted more often than healthier items. Moreover, analysis of Kantar Worldpanel UK data shows that multi-buy promotions result in £75 additional spending per year for an average household, which is offset by £61 of non-incremental purchasing. Therefore the total impact of multi-buy promotions is an overall additional expenditure of £14 per household.
The Food (Promotion and Placement) Regulations 2021 aim to address this issue in England by introducing legislation to restrict location and volume-price promotions on HFSS products in medium and large retailers. These restrictions are expected to be enacted by 1 October 2025.
In Wales, the Welsh Government announced that it is planning to restrict all types of HFSS price promotions (volume and temporary cuts) in their legislation that is set to be introduced in 2024 and rolled out across Wales by 2025. The consultation on this policy also included a proposal to ban free refills and larger sizes of soft drinks in the out of home (OOH) sector; but is not part of the first phase of policies to be implemented.
In Scotland, the Scottish Government is consulting on similar regulations. The proposed regulations would include all volume promotions on pre-packed food and drink products (also including unlimited refills of soft drinks) that are HFSS as defined by the 2004-2005 nutrient profiling model (NPM). The proposed approach is consistent with the food categories within scope of the regulations for England and with the Welsh Government’s proposed approach.
Case studies
Ban on multi-buy alcohol promotions, Scotland
The Scottish Government enacted a ban on multi-buy promotions in ‘off-trade stores’ (retailers licenced to sell alcohol) in 2011, becoming the first in the UK to attempt to influence alcohol purchasing through promotion restrictions. By prohibiting popular price promotions like ‘buy-one-get-one-free’, the aim was to curb bulk purchasing and in turn support responsible drinking.
A comparative study found the multi-buy ban had no significant effect on the volume of alcohol purchased in Scotland, at population level or by socioeconomic group. The study found that retailers replaced multi-buy discounts with temporary price reductions, making it possible for consumers to buy alcohol at the same discount, but for a smaller financial outlay. Ultimately, households that regularly utilised multi-buy offers prior to the ban purchased fewer products per shopping trip post-ban, but took more trips, leaving the overall amount purchased unchanged.
Scotland has since introduced minimum unit pricing (MUP), which has been effective in reducing alcohol-related harm.
Considerations for implementation
Ensuring alignment of regulation scope across the nations will ensure consumer confidence and reduce potential confusion for retailers. Most large retailers operate a national pricing policy, and seek to maintain price per product across the nations. Further details on considerations can be found in the UK Government Impact Assessment.
Estimating the population impact
We estimated that this policy would reduce the prevalence of adult UK obesity rates by approximately 0.7%
Estimating the per-person impact
We estimated that this policy would reduce average daily calorie intake by approximately 3 kcal per person
There are no systematic reviews or meta-analyses on these policy interventions, but a UK Government Impact Assessment estimates that this policy would reduce daily calorie intake by 2.6 calories for adults and 2.5 calories for children. For more information about the modelling methodology, please see the UK Government’s Impact Assessment.
This policy is not applicable to micro and small businesses and is applicable only to medium and large businesses in the retail sector. Furthermore, the foods in scope of this policy are those defined as HFSS as per the Schedule 1 of The Food (Promotion and Placement) (England) Regulations 2021.
Estimating the population reach
- In our analytical model, we applied the effect sizes to people living with overweight or obesity. For adults, that is people aged 18 or above with a BMI of 25+.
- Modelling the effects of this policy for children is currently in progress and we plan to publish this once complete.
Changes in the prevalence of people living with obesity
Table 1 shows the percentage reduction of adults and children moving from BMI ≥ 30 or BMI percentile ≥ 85 into a healthier BMI category following introduction of this policy (five-year follow up). Between 0.7–1% of adults living with obesity would move into a healthier BMI category. We are in the process of modelling the impact for children and will update findings upon completion.
| Adults (England and Wales) | Children (England and Wales) | Adults (Scotland) | Children (Scotland) |
| 0.7% | In progress | 1% | In progress |
Cost and benefits
Cost over 5 years
We estimated that this policy would cost the governments approximately £0.5 million over five years
We commissioned HealthLumen to estimate the cost of the policy to both industry and governments over a five-year period. View the full report.
Table 2 below shows a breakdown of costs. The upfront direct costs to the governments are estimated at £0.1 million, with an annual cost of £0.1 million thereafter. The initial costs to the food industry are estimated at about £5 million, with annual costs of £7 million thereafter. We used the UK Government Impact Assessment to establish the costs.
| Group affected | Cost | Horizon | Detail |
| Costs | |||
| Government | £0.1m | One-off | Enforcement costs (initial) |
| Government | £0.4m | Annual (5 years) | Enforcement costs (on-going) |
| Industry (Retail) | £0.2m | One-off | Familiarisation costs |
| Industry (Retail) | £1m | One-off | Product assessment costs (initial; for current products) |
| Industry (Retail) | £1.5m | One-off | Knowledge sharing costs |
| Industry (Retail) | £2m | One-off | IT system costs |
| Industry (Retail) | £1.4m | Annual (5 years) | Ongoing product assessment costs |
| Industry (Retail) | £16.9m | Annual (5 years) | Lost profits |
| Industry (Manufacturers) | £22.3m | Annual (5 years) | Lost profits |
Total annual benefit
We estimated that this policy would have an annual benefit of approximately £0.4 billion
Using analysis conducted by the Tony Blair Institute and Frontier Economics we estimate this policy would result in benefits of approximately £0.4 billion per year. Approximately two-thirds of this saving would benefit individuals (via quality-adjusted life years, and informal social care). The remaining third relates to savings that benefit the state via NHS treatment costs, productivity and formal social care. See our Methods page for more information about the cost breakdowns.
Impact on disease incidence
We commissioned HealthLumen to report disease incidence avoided if the policy were implemented. These estimates do not represent the total health benefits. The specific diseases selected are those where there is good evidence that living with obesity is associated with the development of the disease.
Table 3 presents a summary of incidence avoided.
| Disease | Incidence avoided |
| Type 2 diabetes | Not statistically significant |
| Hypertension | 3,466 |
| Coronary heart disease | Not statistically significant |
| Colorectal cancer | Not statistically significant |
| Gall bladder disease | 3,135 |
| Ovarian cancer | Not statistically significant |
| Stroke | Not statistically significant |
| Liver cancer | Not statistically significant |
| Depression | Not statistically significant |
| Musculoskeletal disease | Not statistically significant |
Behind the averages: impact on inequalities
The UK Government’s Impact Assessment concluded that there is little variance in use of HFSS volume promotions between socioeconomic groups, meaning restrictions are not expected to exacerbate inequalities.
Rating the strength of evidence
We asked experts working in the fields of obesity, food, and health research to rate the strength of the evidence base for each policy, taking into account both reliability (size and consistency) and validity (quality and content) of the evidence. Policies were rated on a Likert scale of 1–5 (none, limited, medium, strong, and very strong evidence base). The Blueprint Expert Advisory Group rated this policy as having a Medium evidence base.
Ban on all HFSS price promotions in food retail businesses
Ban all price promotions (e.g. was/now prices, introductory prices, temporary price reductions) of HFSS foods in the retail sector excluding small and micro businesses