Last updated: 29/10/2024
Restrict in-store HFSS positioning
Restrict in-store checkout, end-of-aisle, and entrance sales of food and drinks high in fat, salt, and sugar (HFSS)
- Very high impact on obesity
A percentage estimate of how much the policy would reduce national obesity rates
- Relative reduction in obesity prevalence: 16%
- 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: £0.2m
- Benefit to governments per year: £10bn
What is the policy?
This policy relates to existing UK legislation that prevents the promotion of HFSS products by location. As outlined in the legislation, the policy restricts the placement of HFSS products in key locations including store entrances, aisle ends and checkouts in retail stores over 185.8 square metres (m2) or 2,000 square feet (sq ft). These restrictions apply to medium and large businesses (with 50 employees or more).
Recent context
In response to the rising prevalence of childhood obesity, in 2018 the UK Government announced its intention to restrict the promotion of HFSS products by location and price through legislation. Following a series of consultations, the restriction of HFSS products by location came into force on 1 October 2022. It is currently the only legislation to be implemented from the set of proposals the Government outlined between 2018–2020, with the others having been delayed to 2025.
In Wales, the Welsh Government is planning to introduce new legislation to restrict the placement of HFSS products. The legislation will be introduced in 2024 and rolled out across Wales by 2025.
In Scotland, consultation took place in 2024 to introduce regulations that restrict the location placement of HFSS products in the following locations: any area within two metres of the checkout facility, any area within two metres of a designated queuing area or queue management system, end of aisles, store entrances, covered external areas, and free-standing displays. Consultation closed in May 2024 with decisions due within the 2024/25 Scottish Parliamentary session.
Case studies
Tobacco Display Ban, UK
The Tobacco Display Ban has been effective since 2012 in large stores and since 2015 in smaller stores. The law was enacted as part of the Health Act 2009 in response to concerns over tobacco marketing’s influence on smoking rates, and prohibits the display of tobacco products in stores in England, Wales, and Northern Ireland. This legislation requires stores to conceal cigarettes and tobacco products from public view, aiming to deter young people from smoking and support adults in quitting. Exceptions include temporary displays for people over the age of 18 years. Retailers bear responsibility for compliance, facing criminal charges, including fines up to £5,000 and imprisonment, for non-compliance.
An evaluation report for the effect of this ban in Scotland published in 2020, showed that compliance was very high, successfully reducing the visibility of tobacco products in retail settings and in turn reducing the risk of smoking. However, cues were still highly visible, especially in retail stores in the more deprived neighbourhoods.
Considerations for implementation
The restriction of HFSS products by location came into force on 1 October 2022, and while research shows that generally compliance is good in store, some stores disregard the legislation. Moreover, the ability for large businesses to circumvent restrictions, as seen by current qualitative evaluations, should be addressed through specific implementation rules for large retailers. For example, there is evidence of retailers creating in-aisle displays and strategically placing floor stickers to enhance the visibility of HFSS products. Another approach involved situating pallets containing HFSS foods in various locations throughout the store that would regularly change.
Exceptions to the legislation mean that HFSS products are still placed in prominent locations and there is a call for these key exemptions to be addressed.
Estimating the population impact
We estimated that the continuation of this policy would reduce the prevalence of adult UK obesity rates by approximately 16%
Estimating the per-person impact
We estimated that this policy would reduce average daily calorie intake by approximately 60 kcal per person
A UK Government Impact Assessment estimates that this policy would reduce daily calorie intake by 60 kcal for adults and 67 kcal 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 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 15%–16% 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) | 5–18 (England) | Adults (Scotland) | 5–18 (Scotland) |
| 16% | In progress | 16% | In progress |
Cost and benefits
Cost over 5 years
We estimated that this policy would cost the governments approximately £0.2 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 approximately £72,000, with an annual cost of £0.1 million over the next four years. We used the UK Government Impact Assessment to establish the costs.
| Group affected | Cost | Horizon | Detail |
| Costs | |||
| Government | £72k | One-off | Enforcement costs (initial) |
| Government | £0.1m | Annual (5 years) | Enforcement costs |
| Industry (Retail) | £0.1m | One-off | Familiarisation costs |
| Industry (Retail) | £3.1m | One-off | Product assessment costs (initial, for current products) |
| Industry (Retail) | £0.7m | One-off | Knowledge sharing costs |
| Industry (Retail) | £1.3m | One-off | IT system costs |
| Industry (Retail) | £10.8m | Ongoing (every two years) | Product assessments for new and reformulated products |
| Industry (Retail) | £42m | One-off | Store planning and arrangements |
| Industry (Retail) | £1bn | Annual (5 years) | Lost profits |
| Industry (Manufacturers) | £1.2bn | Annual (5 years) | Lost profits |
Total annual benefit
We estimated that this policy would have an annual benefit of approximately £10 billion
Using analysis conducted by the Tony Blair Institute and Frontier Economics we estimate this policy would result in benefits of approximately £10 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 | 47,900 |
| Hypertension | 28,300 |
| Coronary heart disease | 13,500 |
| Colorectal cancer | 3,700 |
| Gall bladder disease | 61,000 |
| Ovarian cancer | Not statistically significant |
| Stroke | 7,500 |
| Liver cancer | 500 |
| Depression | Not statistically significant |
| Musculoskeletal disease | 19,100 |
Behind the averages: impact on inequalities
Many convenience stores (those that are small or micro, or below 2,000 sq ft) are not in scope of this policy. There is some evidence that people with a lower socioeconomic status shop more frequently at convenience stores and thus would experience the benefit of this policy to a lesser extent than people from a higher socioeconomic status.
There is no evidence that this policy would 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 Very 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