HFSS Scotland
Scotland's HFSS promotion and placement rules come into force on 1 October 2026. This hub covers who is in scope, what counts as HFSS food, what is restricted, and how enforcement works.
The Food (Promotion and Placement) (Scotland) Regulations 2025 restrict how foods high in fat, sugar or salt (HFSS) can be promoted and placed in retail premises. The rules come into force on 1 October 2026.
The framework affects product classification decisions, promotional activity, store layout, and how enforcement is applied across different retail settings.
Supporting explainers covering scope, classification, promotion rules, placement restrictions, enforcement context, and regulatory interpretation are grouped below. The Food (Promotion and Placement) (Scotland) Regulations 2025 provide the statutory foundation for the framework.
Featured publication
HFSS Promotion & Placement
How the Scottish Retail Restrictions Operate in Practice
Focused legislative commentary explaining the structure and operation of the HFSS promotion and placement restrictions in Scotland, covering scope, relevant food classification, promotion rules, placement rules and enforcement context.
A plain-English overview of the structure and purpose of the Scottish HFSS statutory framework.
Read moreExplainerHow scope and application works under the Scottish HFSS framework, including the employee threshold and floor area criteria.
Read moreExplainerWhy the employee threshold is commonly misunderstood and how scope actually works under the statutory criteria.
Read moreExplainerA structured plain-English guide to the statutory criteria that determine whether the Regulations apply to a specific business.
Read moreExplainerThe commencement date for The Food (Promotion and Placement) (Scotland) Regulations 2025 and what it means in practice.
Read moreHow the two-stage category and nutrient profiling classification process works under the Scottish HFSS framework.
Read moreExplainerThe role of the nutrient profiling mechanism in determining whether a product in an in-scope category qualifies as relevant food.
Read moreExplainerWhy there is no simple universal HFSS food list, and how product classification actually works under the statutory framework.
Read moreExplainerThe HFSS rules do not ban the sale of food. This page explains what the Regulations actually restrict and where the 'junk food ban' description comes from.
Read moreReferenceA concise reference guide to the core terms used in the Scottish HFSS promotion and placement framework.
Read moreHow the Regulations restrict volume-linked price promotions of HFSS food in qualifying retail premises.
Read moreExplainerHow the promotion restrictions address volume-linked price incentives and why classification depends on statutory definitions.
Read moreExplainerHow the Regulations restrict the placement of HFSS food in defined retail locations, including entrance areas and checkout areas.
Read moreExplainerHow the placement restrictions apply to checkout areas and why prominence alone does not determine classification.
Read moreHow enforcement responsibility is structured, which authorities are involved, and how compliance assessment may arise in practice.
Read moreExplainerHow regulatory issues may arise, how they may be addressed, and the statutory enforcement context.
Read moreExplainerHow HFSS promotion and placement issues may be encountered during routine regulatory activity or targeted review by local authority officers.
Read moreExplainerHow media and trade summaries often diverge from the statutory structure, and how to engage with the framework directly.
Read moreExplainerWhy the Scottish and English HFSS frameworks are separate instruments, and where reading one jurisdiction's material as if it applied to the other causes confusion.
Read moreFrequently asked questions
Do the HFSS rules apply to all food businesses in Scotland?
No. Application depends on the statutory criteria in the Regulations, including an employee threshold. Businesses below that threshold are generally outside scope. Floor area is also relevant to certain placement restrictions. Whether the Regulations apply to a specific business depends on those statutory criteria.
Is there a definitive list of HFSS foods in Scotland?
No. The Regulations do not operate through a named product list. Whether a product is relevant food depends on the category it falls into and whether it meets the nutrient profiling criteria established within the statutory framework. Classification is determined by the Regulations, not by a published register.
Are multibuy promotions restricted under the Scottish HFSS rules?
Volume-linked price incentives, meaning promotional mechanisms where a price advantage depends on purchasing multiple units, are among the types of promotion addressed by the Regulations in qualifying premises. Whether a specific offer falls within the restricted category depends on the statutory definition.
Are checkout displays affected by the HFSS placement restrictions?
The placement restrictions address defined retail areas including areas associated with checkouts. Whether a specific display falls within a restricted area depends on the statutory description of that area, not on its prominence or traffic level alone.
Does floor area decide whether a business is in scope?
Floor area is relevant to certain placement restrictions, but the primary threshold for scope is the employee threshold. A business below the employee threshold is generally outside scope regardless of premises size. Floor area affects whether specific placement restrictions apply within qualifying businesses, not overall scope.
Continue exploring HFSS
HFSS Promotion & Placement
Practical Food Safety Series publication covering scope, relevant food classification, promotion rules, placement rules, and enforcement context in Scotland.
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