Last updated: 10/09/2024
Restrict delivery platform HFSS ‘location’ promotions
Restrict 'location' promotions on digital food/drink delivery platforms of food and drinks high in fat, salt, and sugar (HFSS)
- Low impact on obesity
A percentage estimate of how much the policy would reduce national obesity rates
- Relative reduction in obesity prevalence: 0.1%
- High evidence quality
A rating of the strength of evidence, accounting for both reliability and validity of the evidence
- Reliability and validity rating: 4/5
- Very low cost to governments
Cost to UK and devolved governments over 5 years
- Cost to governments over 5 years: £0.05m
- Benefit to governments per year: £0.1bn
What is the policy?
This policy recommendation would restrict the location promotions of HFSS food and beverage products on online delivery platforms, by restricting their appearance in prominent locations.
This would be applied to any online marketplace, where a customer can make a food and beverage delivery purchase. This would apply to the websites of medium and large organisations in the out of home (OOH) food sector. This would also apply to the most commonly used third-party delivery applications. Locations these restrictions would apply to include:
- the homepage of a food retail website
- when a consumer is searching or browsing for products
- on a page not opened intentionally by the consumer, such as a pop-up page or a brand burst
- on a ‘favourite products’ page.
Online product positioning has an impact on how likely a customer is to buy them. Location-based promotions incentivise increased purchasing of products or spur impulse buys that customers might not have initially intended. This policy aims to encourage retailers to promote healthier food options online, making it easier for individuals to choose these healthier products.
Recent context
In October 2022, the UK Government introduced restrictions to location promotions of HFSS products for medium and large retailers. This move is grounded in evidence suggesting that retail price promotions significantly influence consumer choices, and children’s sugar and calorie intake (1, 2, 3, 4). The restrictions prohibit the placement of HFSS food and drink items which contribute significant sugar and calories to children’s diets and are of most concern for childhood obesity at store entrances, checkouts and end-of-aisles. The restrictions also apply to the online equivalent marketplaces for medium and large businesses (eg, Tesco Groceries).
Businesses not in scope of this policy were micro or small retailers (businesses with under 50 employees) and the OOH sector (even if they sell prepackaged HFSS food and drinks). For more examples of businesses that are not in scope of the current restrictions, please see the UK Government’s Implementation Guidance.
In Wales, the consultation on restrictions and promotions of HFSS products also applies to online purchasing, with the intention that the legislation will mirror the location restrictions for online equivalents (for example, pop-up page prompts and at the checkout stage). Online restrictions and promotions are not within the initial legislations that followed this consultation, with the Welsh Government stating that they are reviewing the evidence.
In Scotland, the Scottish Government 2024 consultation on restricting the location promotion of HFSS food in retail and OOH settings would apply to the equivalent locations online including home pages, certain searching or browsing pages, popup pages, favourites pages and shopping basket or checkout pages.
Case studies
Tobacco Online Advertising Prohibition Act, Australia
The Tobacco Advertising Prohibition Act 1992 came into effect in Australia in 2012, making it an offence, with certain limited exceptions, to publish a tobacco advertisement on the internet.
The Act imposes point-of-sale restrictions to the sale of tobacco products through retail websites. This is an example of promotional restrictions towards targeted products to reduce prominence in online settings. The Act applies to any website where consumers can purchase tobacco products. The regulation mandates that product displays must not highlight tobacco products more prominently than other products. This means using a standardised layout and format, with only black text on a white background, ensuring no tobacco product stands out.
Additionally, any content that might make the product more attractive online is prohibited. This includes images of tobacco products and promotional words or images such as ‘lite’ or ‘discount’. Further, access restrictions require that customers navigate through age verification before accessing any tobacco advertisements. Each tobacco retail website is responsible for implementing its own system to comply with these regulations.
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 the impact on daily calorie reduction using a Cochrane review meta-analysis conducted by Hollands et al. (2019). This review reports a meta-analysis of 24 peer-reviewed randomised control trials (RCTs) testing the effectiveness of the location of food products on participants’ purchasing and consuming behaviour. It was found that mean energy intake on an average snack occasion would be reduced by 38 kcal (18.9%) with lower proximity (CI: -53 kcal to -23 kcal).
- Further, we used a dataset built for Nesta’s analysis on how eating out contributes to people’s diets? for our analysis. This dataset was developed with the OOH subset of Kantar’s Worldpanel service to capture purchases of food and non-alcoholic beverages for OOH consumption in 2021. Nesta’s analysis uses a subset of this data for the period 1st April 2021 to 31st December 2021 for individuals aged 18 and above, at its core, combined with nutritional data(for more information see Nesta’s report linked above). We use the same data for our analysis focussed on online purchases via third party delivery apps and restaurant owned web and apps.
- We estimate that approximately 11% of the calories purchased in the OOH sector are purchased online. Therefore, to find the change in daily energy intake calories we calculated the proportion that this forms of the 38 kcal reduction, if on average, the daily energy intake from the OOH sector is 296 kcals. This is equal to approximately 0.7 kcals. In addition, we accounted for a compensation effect of 23% to calculate the reduction in energy intake per person per is 0.6 kcals.
- Note: All analysis and interpretation was conducted independently of Kantar Worldpanel. Kantar has not independently verified the findings.
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 percentile following introduction of this policy (five-year follow up).
After five years of policy implementation, 0.1%–1% of the UK population would move to a healthier BMI category as a result of this policy.
| Adults (England and Wales) | Children (England and Wales) | Adults (Scotland) | Children (Scotland) |
| 0.1% | Analysis in progress | 0.2% | Analysis in progress |
Cost and benefits
Cost over 5 years
We estimated that this policy would cost the governments approximately £0.05 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 direct costs to the governments are estimated at approximately £50,000. For more details please see the cost appendix.
| Group affected | Cost | Horizon | Detail |
| Government | £11k | One-off | Enforcement cost (initial) |
| Government | £38k | Annual (5 years) | Enforcement costs (ongoing) |
| Industry (Retail) | £0.2m | One-off | Familiarisation costs |
| Industry (Retail) | £0.1m | One-off | Product assessment costs (initial, for current products) |
| Industry (Retail) | £0.2m | One-off | Knowledge sharing costs |
| Industry (Retail) | £0.2m | One-off | IT system costs |
| Industry (Retail) | £0.1m | Annual (5 years) | Ongoing product assessments |
| Industry (Retail) | £1.8m | Annual (5 years) | Lost profits |
| Industry (Manufacturers) | £2.4m | 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
Access and digital exclusion
This policy aims to make it easier for customers to choose healthier options on online delivery platforms. Focusing on delivery platforms alone, could exacerbate inequalities in people without internet access and those who do not use, or don’t know how to use, technological devices. Therefore those purchasing meals in a physical restaurant or takeaway would not benefit from this policy. A 2019 study reported that the number of food outlets that people have access to through the leading online food delivery platform in the UK, is double for those living in the most deprived areas compared to people living in the least deprived areas, and so it has the potential to decrease health inequalities.
There is no evidence that policies that restrict the promotion of HFSS foods online exacerbate weight stigma.
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.
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