What Counts as HFSS Food in Scotland?

What "relevant food" means in the framework

The Food (Promotion and Placement) (Scotland) Regulations 2025 restrict the promotion and placement of relevant food — the statutory term used for products that fall within the Scottish HFSS regulatory framework. Not all food sold in retail premises is relevant food. Classification depends on two things: the product category into which the food falls, and whether the food meets the applicable nutrient profiling criteria for that category.

This page explains how the classification framework is structured at a general level. It does not classify specific products. Whether any particular product constitutes relevant food depends on the statutory provisions and the application of the nutrient profiling mechanism to that product.

Product category first, then nutrient profiling

Classification under the Regulations works in two stages. First, the product must fall within a defined product category that the Regulations bring into scope. Second, the product must meet the nutrient profiling criteria applicable to that category.

Not all food categories are captured by the Regulations. Certain product categories are excluded from the framework by definition. Where a category is within scope, the nutrient profile of the specific product then determines whether that product is relevant food for the purposes of the restrictions.

This two-stage structure means that food in an in-scope category is not automatically relevant food — it must also meet the profiling threshold. Equally, food that is nutritionally similar to HFSS products may not be relevant food if it falls within an excluded category.

The role of the nutrient profiling mechanism

The Regulations refer to a nutrient profiling model used to determine whether a product in an in-scope category qualifies as relevant food. The model assesses defined nutritional components of the product against criteria set out in the statutory framework.

The profiling mechanism is defined by reference within the Regulations. This page does not reproduce the profiling calculation, provide a scoring tool, or offer worked examples for specific products. The nutrient profiling page explains the role of the mechanism within the wider framework. The HFSS Regulations publication provides detailed commentary on how classification operates in practice.

Composite and prepared foods

Questions commonly arise around composite foods — products made up of multiple ingredients, or foods prepared and sold within a retail setting. Classification depends on whether the product falls within a category captured by the Regulations and whether it meets the defined profiling criteria. The Regulations address the method of classification. This page does not determine the status of composite or prepared foods.

Classification determines whether the restrictions apply to a product

Whether a product is relevant food is the threshold question for both the promotion restrictions and the placement restrictions. A product that is not relevant food is not subject to the restrictions, regardless of where it is displayed or how it is promoted. A product that is relevant food is subject to the restrictions within qualifying premises.

Classification is therefore distinct from scope. Scope concerns whether the Regulations apply to the business and premises. Classification concerns whether a specific product is relevant food. Both questions must be answered by reference to the statutory framework.

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