Reminder: HFSS restrictions take effect from 1 October 2026
The Food (Promotion and Placement) (Scotland) Regulations 2025 come into force on 1 October 2026, restricting the promotion and placement of certain prepacked foods high in fat, sugar or salt (HFSS).
The promotion restrictions apply to businesses with 50 or more employees, while the location restrictions apply to businesses with 50 or more employees and a shop floor area of at least 2,000 sq ft. Retailers operating under a symbol group or franchise agreement should check with their symbol group or franchise partner to confirm whether the regulations apply to them.
Products in scope include certain confectionery, biscuits, cakes, sugary soft drinks, ice cream, savoury snacks, breakfast cereals, sweetened dairy products, pizzas and ready meals. Not every product within these categories will be affected, with products assessed using the UK Nutrient Profiling Model.
Promotion restrictions
Certain volume price promotions on HFSS products will be prohibited, including:
Buy one get one free
3 for 2
3 for £10
50% extra free
Buy 6, save 25%
Free refills of soft drinks with added sugar will also be restricted.
Location restrictions
For businesses in scope operating stores with a shop floor area of at least 2,000 sq ft, HFSS products cannot be placed in prominent locations, including:
Store entrances
Checkouts and designated queuing areas
End-of-aisle displays
Covered external areas
Equivalent restrictions will also apply to prominent locations online.
Local authorities will enforce the regulations. Retailers should review the Scottish Government’s implementation guidance ahead of 1 October 2026 and seek advice from their local authority where necessary.
The Scottish Government implementation guidance can be found here: Food (Promotion and Placement) (Scotland) Regulations 2025: implementation guidance - gov.scot
SGF will also be publishing a guide very shortly to support convenience retailers with complying with the regulations.
