The Scottish Government has published The Food (Promotion and Placement) (Scotland) Regulations 2025, which have now been laid before the Scottish Parliament.
This step delivers one of the first actions under the Population Health Framework, a long-term strategy to improve health and reduce inequalities by focusing on prevention and tackling root causes such as diet, poverty and community environments. Measures like HFSS promotion restrictions form part of its early actions.
The regulations aim to make promotions healthier and reduce overconsumption of high fat, sugar and salt (HFSS) products. They are accompanied by the final Business and Regulatory Impact Assessment (BRIA), which explains how the new rules will affect businesses and the economy. For retailers, this includes compliance costs, operational changes such as store layout adjustments, and impacts on promotions and sales. The BRIA also weighs these against public health benefits and incorporates feedback from businesses to ensure the approach is practical and proportionate.
A full suite of impact assessments will be published on the Scottish Government website alongside the BRIA, including Equality Impact Assessment, Island Community Impact Assessment, Fairer Scotland Duty Summary and Child Rights and Wellbeing Impact Assessment.
The regulations align with equivalent policy in England and Wales and will come into force on 1 October 2026, giving businesses time to prepare.
The restrictions will affect businesses with 50 or more employees, but symbol groups are not exempt.
The regulations will:
- Restrict the promotion of pre-packed food and drink products within targeted HFSS food categories, such as confectionery, cakes, crisps, and sugary soft drinks.
- Restrict price promotions of HFSS products, such as multi-buy offers (buy one get one free, two for a pound etc.) and free refills of soft drinks with added sugar
However, meal deals and temporary price reductions (eg 20% off for a defined length of time) are excluded from the proposals.
- Stores measuring 2,000sq ft and over will also have to restrict displaying HFSS food and drink in prominent locations as follows:
- checkout areas
- end of aisles
- covered external areas
- store entrances
But free standing displays will not be subject to restriction.
Work is under way with key stakeholders to deliver clear implementation guidance based on material published elsewhere in the UK.
