Why action is needed to tackle price and location promotions of HFSS products

31 August 2022
Price promotions encourage individuals to buy more. From products to services - promotions, together with advertising, are the most targeted form of marketing, appealing to people from all demographic groups1, and especially to young people. Less healthy food and drink are largely purchased on promotion, encouraging increased consumption2. It is clear therefore, that price promotions on unhealthy, high fat, salt and sugar (HFSS) food and drink have a harmful effect on our health, with evidence demonstrating the need for imminent action.

Why action on promotions is needed

In the UK, 3 in 10 food and drink items are purchased on promotion and promotions are responsible for an 18% incremental increase in the volumes of food we buy.2,3 In Scotland, the majority of these foods are from discretionary categories (36.9%) as opposed to non-discretionary categories (24.7%). In 2020, crisps and snacks were reported to be the most purchased items on promotion, from all the categories reported.4 Food and drink higher in sugar are both more likely to be promoted and for longer (more deeply promoted) than products where sugar is naturally present such as milk and fruit and vegetables (with the exception of fruit juice).3 

Price promotions can include temporary price reductions (TPRs), the most common type of price promotion in Scotland, multibuys or extra free in addition to non-price promotions such as placement at checkouts, end of aisle and front of store displays, banners and prize draws.

Whilst promotions do make products cheaper, the evidence clearly highlights that promotions encourage individuals to buy more (almost 20% as a direct result of promotions) encouraging over consumption and excess purchasing, and increasing take home food and drink volumes.1,5 As a result, consumers tend to increase their consumption of these products, which are usually HFSS. Therefore, excessive consumption of HFSS products leads to excess calorie consumption and weight gain over time. Evidence from Cancer Research UK,2 shows that consumers who buy a high amount of their food and drink on promotion, purchase around a fifth more HFSS products, and are 28% more likely to have obesity and 13% more likely to be overweight than low promotional shoppers.2

Evidence also highlights that food and drink price promotions influence consumers to spend more. Research has shown that the cost to consumers can reach £1,300 per year, and very few know how to find the best deals.6,7 

Promotions also include non-price location promotions, such as end of aisle, front of store and checkout displays, which are intended to create an impact and increase chances of purchasing.8 Studies show that removing unhealthy foods from checkouts and nearby aisle-ends led to approximately 1,500 fewer portions of confectionery being sold in a supermarket each week 9 with 76% fewer purchases of sugary confectionary, chocolate and potato crisps to be eaten ‘on-the-go’ from supermarkets with checkout food policies compared to those without and 17% fewer small packages of these items were bought and taken home from supermarkets immediately after introducing a checkout food policy.10,11  

There has been limited policy action

The intent for legislation in Scotland has been voiced by the Scottish Government since 2018.  Following a consultation held by the Scottish Government from October 2018 - January 2019 regarding the restriction of HFSS product promotions, it was subsequently announced in September 2019 the intention to introduce restrictions of a range of price and location promotions, including multibuys (Buy One Get One Free and Extra Free), location promotions such as end of aisle and shelf displays and instore advertising. 8,12

However due to the COVID-19 pandemic, the Scottish Government paused the legislation due to the unprecedented challenges on the Scottish food and drink retail industry, with plans to implement the restrictions once the economic challenges of the pandemic had lessened. The Scottish Government is now holding a new consultation on restricting promotions of HFSS foods, which closes on the 23rd September. We have recently published our response to the consultation to outline our position on the topic, and encourage others to respond it. We will publish an updated final response to the consultation, ahead of the deadline. Whilst there is a lot to welcome and support within the proposals there are also areas where we want to see the action that was originally promised in 2018.

The current cost of living crisis will only make everyday living more challenging for many individuals and families across the country. The evidence clearly highlights, as mentioned above, that contrary to belief, promotions increase costs to consumers rather than help them to save money, as well as being harmful to health and contributing to an unhealthy weight. It is therefore now more important than ever to strive for healthy weight, creating a food environment which makes the healthy option the easy option.

In recent months, we have seen several devastating plot twists by the UK Government, that will set back the progress that was being made in tackling promotions, marketing and advertising. Despite passing new legislation the implementation dates for various parts have been pushed back and are under threat.

The introduction of legislation which restricts such promotion of unhealthy products is an important step in putting the health of the Scottish population first.12,13 We support the introduction of legislation to restrict price and location promotions of HFSS products and urge the Scottish Government to reintroduce this legislation as soon and as rigorously as possible.

Action is needed now - our key asks for price promotions

Promotions are designed to encourage impulsive purchases of less healthy food and drink products, increasing the amount purchased. These are purchases which wouldn’t have initially been made if the promotions weren’t there.

There is clear evidence that change is needed. Polling from the Food Foundation highlights that 81% of households would prefer promotions on core essentials such as meat and dairy, fruit and veg and pasta and rice, rather than on discretionary products such as sweets and confectionery.14 Furthermore, 76% of individuals agree that multi-buy offers encourage the consumption of more food.15 By restricting promotions, the purchasing and consumption of these foods will reduce, helping in the long term to not only lower obesity prevalence and obesity related morbidity and mortality, but help to alter the wider food environment and the food choices available to both children and adults, benefiting the health of the whole population.1,2,5

The consultation on promotions currently being held by the Scottish Government presents an opportunity for action to address the harms caused by price and location promotions of HFSS products. We urge the Scottish Government to act to address all types of promotions of unhealthy HFSS products and to introduce legislation as soon as possible.

Our key asks for policy action are:

  • Promotions restrictions should apply to as many types of price and location promotions as possible, including multi-buys, loyalty pricing, checkouts and end of aisles displays
  • Temporary Price Reduction promotions to be included in any price promotion restrictions
  • Restrictions on price promotions must include non-pre-packed products
  • Promotions restrictions must also apply online, for both price and location promotions
  • Restrictions on promotions must apply across both retail and OOH
  • Businesses must be enabled, encouraged and incentivised to increase the amount of healthy foods on promotion


1. GOV.UK. (2021). Consultation outcome. Restricting promotions of products high in fat, sugar and salt by location and by price: equality assessment. GOV.UK. Available from: https://www.gov.uk/government/consultations/restricting-promotions-of-food-and-drink-that-is-high-in-fat-sugar-and-salt/outcome/restricting-promotions-of-products-high-in-fat-sugar-and-salt-by-location-and-by-price-equality-assessment [Accessed 12 August 2022].

2. Coker, T., Rumgay, H., Whiteside, E., Rosenberg, G. and Vohra, J. (2019). Paying the price: New evidence on the link between price promotions, purchasing of less healthy food and drink, and overweight and obesity in Great Britain. Cancer Research UK. Available from: https://www.cancerresearchuk.org/sites/default/files/paying_the_price_-_full_report.pdf [Accessed 12 August 2022].

3. Public Health England. (2015). Sugar Reduction: The evidence for action. Annexe 4: An analysis of the role of price promotions on the household purchases of food and drinks high in sugar. Public Health England. Available from: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/470175/Annexe_4._Analysis_of_price_promotions.pdf [Accessed 12 August 2022].

4. Food Standards Scotland. (2019). Exploring the impact of COVID-19 on retail purchase and price promotion in Scotland: 2019-2020. Aberdeen: Food Standards Scotland. Available from: https://www.foodstandards.gov.scot/downloads/Final_Report.pdf [Accessed 12 August 2022].

5. GOV.UK. (2021). Consultation outcome. Restricting promotions of products high in fat, sugar and salt by location and by price: government response to public consultation. GOV.UK. Available from: https://www.gov.uk/government/consultations/restricting-promotions-of-food-and-drink-that-is-high-in-fat-sugar-and-salt/outcome/restricting-promotions-of-products-high-in-fat-sugar-and-salt-by-location-and-by-price-government-response-to-public-consultation [Accessed 12 August 2022]

6. Sustain. (2022). Calls for Number 10 to stick to plan to ban junk food BOGOFs. Sustain. Available from: https://www.sustainweb.org/news/may22-will-government-backtrack-bogof-ban/ [Accessed 12 August 2022].

7. Neilan, C. (2016). Bye-bye Bogof? Supermarket deals days’ numbered as new research finds consumers spend £1,300 a year more when they take up buy-one, get-one-free offers. CityA.M. Available from: https://www.cityam.com/bye-bye-bogof-deals-days-numbered-as-new-research-finds-consumers-spend-1300-a-year-more-when-they-take-up-buy-one-get-one-free-offers/ [Accessed 12 August 2022].

8. The Scottish Government (2018.) Reducing Health Harms of Foods High in Fat, Sugar and Salt. Consultation Paper. Scottish Government. Available from: https://www.gov.scot/publications/reducing-health-harms-foods-high-fat-sugar-salt/ [Accessed 12 August 2022].

9. WHO. (2022). European Regional Obesity Report. Copenhagen: WHO Regional Office for Europe. Available from: https://apps.who.int/iris/bitstream/handle/10665/353747/9789289057738-eng.pdf [Accessed 12 August 2022].

10. Ejilerskov, K.T., Sharp, S.J., Stead, M., Adamson, A.J., White, M. and Adams, J. (2018). Supermarket policies on less-healthy food at checkouts: Natural experimental evaluation using interrupted time series analyses of purchases. PLOS Medicine 15 (12), e1002712. Available from: https://doi.org/10.1371/journal.pmed.1002712 [Accessed 12 August 2022].

11. University of Cambridge. (2018). Removing sweets and crisps from supermarket checkouts linked to dramatic fall in unhealthy snack purchases. MRC Epidemiology Unit. University of Cambridge. Available from: https://www.mrc-epid.cam.ac.uk/blog/2018/12/18/removing-sweets-and-crisps-from-supermarket-checkouts-linked-to-dramatic-fall-in-unhealthy-snack-purchases/ [Accessed 12 August 2022].

12. Obesity Action Scotland. (2021). Tackling promotions must be next on the list. Obesity Action Scotland. Available from: https://www.obesityactionscotland.org/blog/tackling-promotions-must-be-next-on-the-list [Accessed 12 August 2022].

13. Obesity Action Scotland. (2022). A week of devastating plot twists. Obesity Action Scotland. Available from: https://www.obesityactionscotland.org/blog/a-week-of-devastating-plot-twists/ [Accessed 12 August 2022].

14. Food Foundation. (2022). Our reaction as policies to protect children's health are delayed by Government. Food Foundation. Available from: https://www.foodfoundation.org.uk/news/our-reaction-policies-protect-childrens-health-are-delayed-government [Accessed 16 August 2022].

15. Obesity Health Alliance. (2021). Ending promotions of unhealthy foods and drinks – briefing paper. Obesity Health Alliance. Available from: https://obesityhealthalliance.org.uk/wp-content/uploads/2021/03/2021.-Ending-promotions-of-unhealthy-food-and-drink-Briefing-Paper.pdf [Accessed 12 August 2022].