Last updated: 10/09/2024
Ban HFSS volume promotions in out of home (OOH) businesses
Ban all volume promotions on HFSS products for large out of home businesses such as restaurants, coffee shops, fast food outlets (medium, small and micro businesses are excluded)
- Low impact on obesity
A percentage estimate of how much the policy would reduce national obesity rates
- Relative reduction in obesity prevalence: 0.1%
- 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
- Cost to governments over 5 years: £0.5m
- Benefit to governments per year: £0.1bn
What is the policy?
This policy relates to restrictions on volume promotions for food and drinks that are classified as high in fat, salt, or sugar (HFSS) for large OOH businesses (businesses with 250 or more employees). It would apply to non-retail food businesses, but not those classified as medium, small or micro businesses (businesses with less than 250 employees).
Volume promotions can refer to the following, but do not include temporary price reductions:
- bulk discounts, where a customer receives a larger portion for the same price (eg, free drink refills).
- multi-buy offers, eg, ‘get 3 for the price of 2’
- combination offers, where a customer gets a discount on one product based on purchasing another product
Recent context
In the UK Government’s initial consultation in 2019 on price promotion restrictions, it intended to include the OOH sector alongside retailers. However, The Food (Promotion and Placement) (England) Regulations 2021 exempted OOH businesses from restrictions on volume promotions, and there have been minimal further attempts to extend restrictions to this sector (though it should be noted that free refills of high-sugar drinks are not exempted in the OOH sector).
In Wales, the Government announced the Healthy Food Environment consultation which included planned proposals set to be introduced in 2024 and rolled out across Wales by 2025. The consultation included a proposal for volume promotion restrictions for OOH food businesses, specifically restrictions on large portion sizes of sugary drinks and free refills of sugary drinks, a form of volume promotion restriction.
The Scottish Government is currently consulting on introducing regulations to restrict promotions of HFSS foods in both OOH and retail businesses. They propose that price (including volume) and location restrictions (both instore and online) will apply to a qualifying business including OOH, such as takeaway, home delivery services, restaurants, cafes, coffee shops, bakeries, sandwich shops and workplace canteens (including online sales). The proposed regulations stipulate a business would be subject to these conditions if it has 250 or more employees.
Case studies
Irresponsible alcohol promotions bans, UK
Excess alcohol consumption has, and continues to be, a pressing public health concern in the UK with nations implementing policies to tackle this. For example, the Alcohol etc. (Scotland) Act 2010 introduced regulations banning volume and price promotions (eg, multi-buy promotions like ‘three for two’) on alcohol in the off-trade sector in Scotland. The aim was to reduce incentives for purchasing more alcohol than intended, thereby lowering overall consumption.
Evaluations of the policy found that restricting volume promotion was effective at reducing some alcohol sales, with evidence showing a 2.6% decrease in total off-trade alcohol sales in Scotland, driven largely by 4% reduced wine sales and 8.5% lower ready-to-drink sales.
Whilst there was evidence of some effect with this policy, further evaluation suggested that retailers were shifting to other discounting strategies like straight price reductions, which remained legal – thus diminishing the Act’s overall impact. Indeed, evidence suggests that no significant changes occurred for beer, spirits or cider where these straight price reductions increased in prevalence.
This case study highlights the importance of well-designed volume promotion restrictions. It is evident that multi-buy bans can achieve reductions in the consumption of products to which the restriction applies, eg, wine sales in Scotland. However, its limited impact underscores the need for comprehensive and complementary policy cover, with restrictions on other price-related promotion mechanisms.
Considerations for implementation
Refining this policy for implementation would require considering:
- ensuring that OOH products are in scope of the HFSS classification
- the scope of HFSS products covered by the restrictions
- the types of volume promotions that would be exempted from restrictions based on the different characteristics of the OOH versus retail sector
- identifying any examples of OOH businesses that would be exempt from restrictions, for example, small independent stores
- 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. Variance in regulated promotion types across the nations may create challenges for retailers.
Estimating the population impact
We estimated that this policy would reduce the prevalence of adult UK obesity rates by approximately 0.1%
Estimating the per-person impact
We estimated that this policy would reduce average daily calorie intake by approximately 0.5 kcal per person
There are no systematic reviews or meta-analyses on this policy intervention. Instead, we have used UK Government Impact Assessment estimates, in addition to estimates for population diet calorie contributions from the retail and OOH sector. From the impact estimates, a policy affecting in-home purchases of adults (contributing around 1,700 calories) reduces daily calories intake by 2.6 calories. We assume that if a similar policy is implemented in the OOH sector (contributing ~ 296 calories), focused on large businesses, then it would lead to a proportional decrease of ~0.5 calories from a person’s daily energy intake. We do not account for compensation here as it is accounted for in the modelling of the impact assessment.
This policy is not applicable to micro, small and medium businesses and is applicable only to large businesses in the OOH sector. Furthermore, the foods in scope of this policy are those defined as HFSS as per 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+.
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).
| Adults (England and Wales) | Children (England and Wales) | Adults (Scotland) | Children (Scotland) |
| 0.1% | 0.6% | 0.2% | 1% |
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 approximately £2 million per year totalling to approximately £10 million over five years. We used the UK Government Impact Assessment to establish the costs.
Table 2. Summary of costs
| Group affected | Cost | Horizon | Detail |
| Costs | |||
| Government | £0.1m | One-off | Enforcement costs (initial) |
| Government | £0.4m | Annual (5 years) | Enforcement costs (ongoing) |
| 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 assessments |
| Industry (OOH/ Retail) | £3.4m | Annual (5 years) | Lost profits |
| Industry (Manufacturers) | £4.5m | Annual (5 years) | Lost profits |
Total annual benefit
We estimated that this policy would have an annual benefit of approximately £0.1 billion
Using analysis conducted by the Tony Blair Institute and Frontier Economics we estimate this policy would result in benefits of approximately £0.1 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 (rounded to the nearest 100).
| Disease | Incidence avoided |
| Type 2 diabetes | Not statistically significant |
| Hypertension | 2,100 |
| Coronary heart disease | Not statistically significant |
| Colorectal cancer | Not statistically significant |
| Gall bladder disease | Not statistically significant |
| 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
There is limited literature directly addressing the effects of this specific policy on inequalities. Nonetheless, we can look to wider literature to infer what impacts this policy could have on different population groups. For example, evidence suggests that people from higher-income households eat out more regularly than those from lower-income households, meaning that they may be impacted more frequently by the intervention. Other research has also shown similar policies, such as bans on price promotions in retail settings, have greater impacts on lower-income households.
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