About the author
James Peach,
Senior Pre-Sales Consultant – FMCG Regulatory Specialist, NIQ Brandbank
HFSS Promotion and Placement (GB)
The UK’s efforts to tackle obesity and improve public health through restrictions on the promotion of foods high in fat, sugar, and salt (HFSS) continue to progress. With both the Promotion and the Placement provisions of the England regulations now fully implemented, Wales and Scotland are set to introduce similar measures—Wales in March 2026 and Scotland in October 2026.
While initial indications suggested that Scotland and Wales might incorporate restrictions on Temporary Price Reductions (TPRs) and meal deals within their HFSS regulations, both nations have opted not to include these measures, thereby aligning their provisions more closely with those in England. It should be noted, however, that important differences remain—such as varying approaches to volume promotions already on-pack prior to October 2025 across different jurisdictions.
Links to relevant authoritative guidance are included at the end of this article.
HFSS Data Needs
Helpfully, there is alignment across the nations on the nutrient profiling model to be used, as well as the regulated product categories. This enables businesses to operate within a unified Great Britain market in respect of these aspects. This consistency also significantly increases the value and practical application of digital product data.
NIQ Brandbank HFSS (Promotion and Placement) Data
NIQ Brandbank remains the market leader in HFSS-specific product data, providing the only comprehensive two-part HFSS compliance solution available to businesses.
How It Works
(Part I)
Data provided directly by manufacturers and suppliers remains the gold standard, as they are best positioned to determine the precise quantities of all elements required to calculate an accurate nutrient profile score. Leveraging this principle, NIQ Brandbank’s Promotion and Placement HFSS-specific attribution within its Shopper Experience Platform enables suppliers to deliver exactly that—accurate, reliable data, including (among other details) the nutrient profile score and the relevant regulated categories for their products.
(Part II)
Acknowledging two critical factors—first, that not all suppliers will provide complete HFSS data, and second, that obligated parties such as retailers require full visibility of HFSS statuses across their entire range—NIQ Brandbank also offers a trusted, Trading Standards-assured solution: delivering estimated nutrient profile scores at scale.
Using a methodology developed in collaboration with Cambridgeshire and Peterborough Trading Standards Service to mitigate missing or ambiguous on-pack information, this solution complements supplier-provided data in two important ways:
- It fills gaps left by suppliers who have not provided definitive HFSS data via our Shopper Experience Platform.
- It may be used as a validation tool for HFSS data submitted directly (and separately) by suppliers to obligated parties.
Furthermore, the Trading Standards assurance provides potential tangible benefits for businesses operating in England through our Co-ordinated Primary Authority partnership with Cambridgeshire and Peterborough Trading Standards Service. For further details—including how to join our Regulated Group and access the Assured Advice (which outlines when it may be appropriate to rely on NIQ Brandbank’s estimated HFSS data to achieve compliance)—please follow the link.
HFSS Advertising (UK)
In addition to the Promotion and Placement regulations, UK-wide HFSS Advertising restrictions were introduced in October 2025, with enforcement scheduled to begin in January 2026.
While the same nutrient profiling model applies to both sets of regulations, there are notable differences in scope and category alignment. Although most regulated categories are consistent, some key variations remain. Furthermore, the scope of products differs significantly: Promotion and Placement rules apply only to prepacked foods within regulated categories, whereas Advertising restrictions cover all foods within those categories (whether or not they are prepacked). A helpful way to think of this is as follows:
- If a product falls under Promotion and Placement restrictions, it will also be subject to Advertising restrictions.
- If a product is subject to Advertising restrictions, it may not necessarily fall under Promotion and Placement rules.
NIQ Brandbank HFSS (Advertising) Data
In addition to providing HFSS Promotion and Placement data (and further to Part I of our two-part solution detailed above), NIQ Brandbank also enables suppliers to provide definitive HFSS information for Advertising regulations.
Given the subtle yet important differences between these regulatory frameworks, suppliers can submit data into clearly designated HFSS Advertising-specific attributes in the NIQ Brandbank systems, ensuring that data users—such as retailers—have a clear and accurate understanding of each product’s compliance status under both sets of rules.
Further to Part II of our two-part solution detailed above, as both regulatory frameworks utilize the same nutrient profiling model, NIQ Brandbank is able to provide nutrient profile score estimates at scale, enabling businesses to make informed, advertising-related compliance and strategic decisions*.
For further information or support regarding any of the HFSS-related solutions outlined above, please contact your NIQ Brandbank Account Manager.
In the meantime, the following resources provide additional guidance and assistance:
Shopper Experience Platform Attribute Completion Guidance
The below link will take you to guidance documents on how to complete the HFSS-specific attributes in NIQ Brandbank’s Shopper Experience Platform (SXP).
Government Guidance
Promotion and Placement:
- Scotland – Awaited
Advertising:
*It should be noted that, while the estimated nutrient profile scores are applicable to both the Promotion and Placement, and the Advertising regulations, the Trading Standards assured-status (referenced above) only applies to their use in respect of the Promotion and Placement regulations at this time.
