Food Management Today quotes Jamie Cartwright on new legislation relating to foods high in fat, sugar and salt (HFSS)

Legislation restricting multibuy promotions on foods high in fat, sugar and salt (HFSS) has now come into force, with restrictions applying to large retailers and online shops.

The ban had been delayed initially until 2022, but continued to be delayed until 1st October 2025. It restricts price promotions such as buy-one-get-one-free offers deals granting consumers more of a product for the same price, such as 50% extra free. It also restricts reference pricing, for example ‘was/now’ prices and comparisons to recommended retail prices.

In an impact assessment published by the Department of Health and Social Care, it was said that price promotions on so-called “unhealthy” products “could lead to excessive consumption of goods which are associated with a greater propensity to create impulse purchases and act as a significant contributor to weight gain”.

Jamie Cartwright, Partner in our Dispute Resolution team, comments on the new legislation in an article for Food Management Today, and explains what the implications will be for fast-moving consumer goods (FMCG) brands:

This latest extension of HFSS restrictions has been a long time coming, with roots in proposals dating back to the May Government.

"For FMCG brands, the challenge will be finding creative and compliant ways to get their products in front of consumers. This sits within a broader regulatory environment that is already moving towards restrictions on TV advertising and even the role of influencers in marketing.

"It is important to stress that these rules are not a complete solution: they address the pre-packed food environment, but not out-of-home consumption. As such, this is another step in the journey rather than the end point.

Read the full article here.