HFSS Placement Restrictions in Scotland

What the placement restrictions address

The Food (Promotion and Placement) (Scotland) Regulations 2025 restrict the placement of food high in fat, sugar or salt (HFSS) within defined areas of qualifying retail premises. The restrictions apply where a business and its premises meet the statutory criteria within the Scottish HFSS regulatory framework, including where applicable a floor area threshold relevant to certain placement provisions.

This page provides a general overview of how the placement restrictions are structured. It does not classify specific retail layouts, determine whether particular areas fall within a restricted category, or provide a compliance assessment for any business. Classification depends on the statutory definitions.

Which retail areas are addressed

The Regulations restrict the placement of relevant food in areas defined within the statutory framework. The categories described include specified entrance areas, checkout areas, and other defined display locations set out in the Regulations.

The statutory definitions describe the areas in question. Whether a given area within a specific retail premises falls within a restricted category depends on how the statutory definition applies to the configuration of that premises. Prominence of location does not by itself determine whether an area is restricted — the statutory description is the controlling reference point.

How placement classification works in practice

Modern retail configurations — including service counters, self-checkout points, entrance displays, concessions, and promotional islands — may raise questions about whether a particular display location falls within a restricted category. These questions turn on how the statutory definitions apply to the specific physical layout of the premises.

This page explains that classification depends on the statutory framework. It does not determine the classification of specific areas. Where questions arise about the application of the placement restrictions to particular retail formats, the statutory wording remains the controlling reference and the HFSS Regulations publication provides detailed commentary on how these definitions interact with retail practice.

Placement and promotion are separate restrictions

The placement and promotion restrictions are distinct elements of the regulatory framework. A product or display may engage the placement restriction without engaging the promotion restriction, or engage both. Each element of the framework must be assessed separately against the statutory provisions.

Further context on how the promotion restrictions are structured is available in the supporting explainer page.

Related HFSS resources

Frequently asked questions