Last updated: 10/09/2024
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
- Very high impact on obesity
A percentage estimate of how much the policy would reduce national obesity rates
- Relative reduction in obesity prevalence: 29%
- Very high evidence quality
A rating of the strength of evidence, accounting for both reliability and validity of the evidence
- Reliability and validity rating: 5/5
- 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: £18bn
What is the policy?
This policy relates to a ban on all price promotions for food and drinks that are classified as high in fat, sugar, or salt (HFSS) and labelled as discretionary.
Price promotions include both volume offers (such as multi-buys (eg, ‘buy-one-get-one-free’), combinations (eg, a discount if you buy a fizzy drink with a pizza, bulk discounts, etc.), and temporary price reductions (such as reference pricing cuts like ‘Was/Now’ prices, and comparisons to other retailer prices).
Discretionary items are a subset of HFSS products that contribute to high intake of calories, fats, and sugars and displace nutrient-rich foods. Based on an analysis from Food Standards Scotland, they include confectionery, sweet biscuits, savoury snacks, cakes, pastries, puddings and sugar-containing soft drinks.
Recent context
In the UK Government’s initial consultation on HFSS promotion restrictions in 2019, a decision was made to focus on volume promotions alone (rather than volume and temporary price promotions). As such, only volume promotions were included in The Food (Promotion and Placement) (England) Regulations 2021.
In Wales, the Welsh Government announced that it is planning to restrict all types of HFSS price promotions (volume and temporary cuts) in legislation that is set to be introduced in 2024 and rolled out across Wales by 2025.
The Scottish Government’s recent consultation states that their preferred position is to consider restricting all types of HFSS promotions on discretionary foods. They propose that price and location restrictions (both instore and online) will apply to qualifying businesses including retail: supermarkets, convenience stores, discounters and bargain stores (including online sales).
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 ‘4 for the price of 3’, the aim was to curb bulk purchasing and in turn encourage 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. The evaluation concluded that multi-buy bans would have been more impactful if further similar bans were introduced in tandem (ie, price reductions).
Scotland has since introduced minimum unit pricing (MUP) in 2011, which has been effective in reducing alcohol-related harm.
Considerations for implementation
- Refining this policy for implementation would require considering the scope of discretionary products covered by the restrictions, and the types of price promotions to be included in the regulations.
- Welsh and Scottish governments are considering restricting temporary price reductions in future legislation. Temporary price reductions are a natural replacement of multi-buy promotions, offering a similar discount for a smaller outlay.
- 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 29%
Estimating the per-person impact
We estimated that this policy would reduce average daily calorie intake by approximately 88 kcal per person
There are no systematic reviews or meta-analyses on these policy interventions, but a Scottish Government Impact Assessment estimates that this policy would reduce daily calorie intake by 87.6 kcals for adults. The evidence in the impact assessment is based on a randomised trial and therefore we have assumed no compensation effect as this would have been accounted for in the trial.
The businesses in scope of this policy are those outlined in the Scottish Government impact assessment and the products in scope are also listed there. The products in scope align with 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 26%-29% 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) |
| 29% | In progress | 26% | 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.
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 (initial) |
| 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 (Retail) | £38.8m | Annual (5 years) | Lost profits |
| Industry (Manufacturers) | £50.9m | Annual (5 years) | Lost profits |
Total annual benefit
We estimated that this policy would have an annual benefit of approximately £18 billion
Using analysis conducted by the Tony Blair Institute and Frontier Economics we estimate this policy would result in benefits of approximately £18 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 | 90,700 |
| Hypertension | 47,800 |
| Coronary heart disease | 25,600 |
| Colorectal cancer | 6,700 |
| Gall bladder disease | 107,000 |
| Ovarian cancer | Not statistically significant |
| Stroke | 13,700 |
| Liver cancer | 900 |
| Depression | 900 |
| Musculoskeletal disease | 37,400 |
Behind the averages: impact on inequalities
Socioeconomic status: The Scottish Government’s Impact Assessment concluded that there is little variance in use of HFSS price 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 Strong evidence base.
Data collection on healthiness of product portfolios
Mandate data collection of sales and nutritional information for large businesses (in a data reporting framework such as the FDTP)