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What this guide covers and why it matters now
HFSS legislation has fundamentally changed the commercial landscape for food and drink in the UK. Fifteen major categories, from confectionery and cereals through to ready meals and bagged snacks, face restrictions on advertising, in-store placement and promotional activity for products that score above the threshold on fat, salt and sugar. The regulations have reshaped how products reach consumers, how portfolios are structured and how innovation pipelines are prioritised.
The commercial implications are significant. Products classified as HFSS can no longer be placed at store entrances, aisle ends or checkouts. Advertising restrictions limit when and where these products can be promoted. Promotional mechanics including multi-buy and extra-free offers are restricted. Industry estimates suggest these measures could cost manufacturers hundreds of millions of pounds in displaced revenue, with the most exposed portfolios facing substantial volume losses.
This guide is written for heads of innovation, NPD directors, category leads and commercial directors at food and drink manufacturers who need a clear framework for responding. It lays out five distinct strategic options, each with real brand examples, commercial trade-offs and practical guidance on when each approach makes sense. Most portfolios will need a combination of strategies rather than a single answer, and the guide is designed to help leadership teams assess which blend fits their specific situation.
The guide is not a summary of the regulations. It is a strategic playbook for what to do about them.
Contents
- Introduction: the scale of the challenge and why attack is the best form of defence
- What HFSS legislation means: the scoring framework, which categories are affected, and how products are classified
- The commercial implications: advertising bans, placement restrictions, promotional limitations, and the revenue at risk
- The five strategic options: a framework for choosing the right response
- Option 1: Stick. When the product cannot change and the right call is to protect what you have
- Option 2: Reformulate. Reducing fat, salt and sugar to bring the product below the threshold
- Option 3: Renovate. Going beyond reduction to add nutritional value and reframe the proposition
- Option 4: Innovate. Building HFSS-compliant products from the ground up
- Option 5: Takeover. Acquiring compliant brands to rebalance the portfolio
- Choosing your combination: which options fit which portfolio shapes
- Next steps: how to move from strategy to action
Three numbers from the guide
40%
of take-home food and drink spending in the UK is estimated to be on products classified as HFSS.
760 of 1,445
brands sold in a single grocery store had entire ranges that failed the HFSS threshold, according to one industry study.
£700m
the estimated cost to manufacturers of in-store placement restrictions alone, according to the Food and Drink Federation.
Download the full guide
22 pages. Five strategic options. Real brand examples. Yours in exchange for an email address.
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The five options at a glance
Every food and drink manufacturer facing HFSS pressure has five strategic levers. Most will need a combination. The guide walks through each one in detail with real examples.
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When compliance is not feasible and the right call is to protect the existing product.
Some products cannot be reformulated without destroying what makes them sell. In those cases, the strategic response is to accept the restrictions, manage the commercial impact, and invest in portfolio balance elsewhere. The guide covers when this is the right call and how to manage the trade-offs, including the advertising and placement options that remain available.
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Reducing fat, salt and sugar to bring the product below the HFSS threshold.
The most direct route to compliance, but rarely as simple as it sounds. Reducing one ingredient almost always has knock-on effects elsewhere. The guide covers how to approach reformulation strategically, what the common pitfalls are, and when reformulation alone is not enough.
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Going beyond reduction to add nutritional value and reframe the entire proposition.
This is the option the guide recommends most strongly for manufacturers willing to take the longer view. Rather than simply removing what is bad, renovation adds what is good. Fibre, protein, functional ingredients, improved nutritional labelling. The guide covers how this approach changes the conversation from defensive to offensive, and why it aligns with where consumer demand is heading.
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Building HFSS-compliant products from the ground up.
For portfolios where the core range will stick or reformulate, there is a compelling case for new innovation designed to be compliant from day one. The guide covers what this looks like in practice, why fresh innovation needs to work harder than ever to justify its shelf space, and what successful compliant launches have in common.
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Acquiring compliant brands to rebalance the portfolio.
If the portfolio needs rebalancing and the budget allows, acquiring brands that are already compliant is a pragmatic option. The guide covers recent examples, what to look for in acquisition targets, and why even acquired brands may need some level of reformulation post-acquisition.
Need help putting one of these options into action?
Three FIS Group challenge areas that connect directly to the strategic options in this guide.
Create and Refine Ideas
Options 3 (Renovate) and 4 (Innovate) of the guide cover ground that maps to our Create and Refine Ideas work: ideation, concept development, co-creation and the methodologies that turn HFSS pressure into proper product innovation rather than incremental reformulation. If your HFSS response involves building genuinely new propositions or reframing existing ones with added nutritional value, this is the challenge area where the relevant FIS Group services sit.
Build, Test and Refine What Wins
Option 2 (Reformulate) of the guide maps directly to our Build, Test and Refine What Wins work: product testing of reformulated products against the original and against competitors, sensory work, claims validation, recipe development. Critical for getting reformulation right rather than compromising the product. If your HFSS response is reformulation, this is the challenge area where the relevant FIS Group services sit.
Unlock Growth Opportunities
The strategic framework section of the guide (choosing the right combination of options for your business, sequencing the portfolio response) maps to our Unlock Growth Opportunities work: opportunity mapping, platform and territory building, future food pipeline scoping in the context of regulatory pressure. If your HFSS response needs to start with strategic portfolio decisions before specific product work begins, this is the challenge area to explore first.
FAQ
What is HFSS?
HFSS stands for high in fat, salt and sugar. It refers to a set of UK regulations that restrict the advertising, in-store placement and promotion of food and drink products that score above a defined nutritional threshold. Fifteen major categories are affected, from confectionery and cereals to ready meals and bagged snacks.
Which food categories are affected by HFSS legislation?
Confectionery, cereals, soft drinks, bagged snacks, ice cream, cakes, biscuits, morning goods, desserts, yogurt, pizza, chips, ready meals, chocolate and sugar confectionery, and breaded and battered products. The guide covers all fifteen in detail.
Is this guide free to download?
Yes. The full 22-page guide is free to download in exchange for an email address. We will send you a confirmation email with the download link. No payment required.
Who is this guide written for?
Heads of innovation, NPD directors, category leads and commercial directors at food and drink manufacturers whose portfolios include products affected by HFSS legislation. It is also useful for own label development teams at retailers and for foodservice operators managing menu compliance.
What are the five strategic options in the guide?
Stick (accept restrictions and protect the product), Reformulate (reduce fat, salt or sugar to bring the product below threshold), Renovate (go beyond reduction to add nutritional value), Innovate (build compliant products from the ground up), and Takeover (acquire compliant brands). Most portfolios need a combination of two or more.
Is the guide up to date?
The guide has been updated to reflect the current state of HFSS legislation and the latest industry examples. If the regulatory landscape changes further, we will publish an updated edition and notify subscribers.
Can FIS Group help us implement one of the five options?
Yes. Our service architecture runs across six challenge areas covering the food and drink commercial cycle. For HFSS work specifically, three challenges are most relevant: Create and Refine Ideas (for renovation and innovation programmes covering Options 3 and 4), Build, Test and Refine What Wins (for reformulation product testing covering Option 2), and Unlock Growth Opportunities (for the strategic framework work of choosing which combination of options fits your portfolio). Contact the guide’s authors directly for a scoping conversation, or use the related challenge routing in section 9 to explore the challenge area that fits your specific HFSS question.
Are there any exemptions from HFSS legislation?
Smaller businesses with fewer than 50 employees are exempt from the placement and promotion restrictions. The guide covers the full scope of exemptions and how they apply.
Need a strategy for your specific portfolio, not a general guide?
This guide covers the framework. If you need the answer for your specific brands, your specific categories and your specific commercial constraints, that is what the consultancy does. Twenty minutes on a call with the people who wrote this guide, or explore the six challenge areas to find the right route into a conversation.