<img alt="" src="https://secure.peak2poem.com/196389.png" style="display:none;">

HFSS Regulations UK: Digital Shelf Strategies for Category Management

8 min read
Lady looking at HFSS graphs and data drinking a coffee

UK HFSS regulations have changed how brands compete online. With paid promotional placements banned and volume promotions restricted from October 2025, brands see 4% sales change for every 1% shift in organic search ranking. The £18 billion worth of affected products (16% of the UK food and drink market) cannot appear in sponsored search, homepage banners, or checkout suggestions. Early data shows brands investing in digital shelf capabilities are capturing disproportionate market share whilst competitors struggle.

 

Since UK HFSS regulations banned promotional placements in October 2022, brands using digital shelf analytics report measurable competitive advantages. Understanding how HFSS legislation impacts organic search rankings, product availability, and category positioning has become essential for UK food manufacturers managing NPM scores across retailer websites. The nutrient profiling model scoring determines which products face restrictions, making digital shelf monitoring critical for compliance and performance optimisation.

This isn't just a compliance challenge, it's a category management opportunity. Brands that transform their retailer relationships from transactional conversations to strategic partnerships are winning share. Here's how to turn HFSS restrictions into competitive advantage online.

 

Timeline of HFSS advertising and promotion restrictions from October 2022 to January 2026

 

Five Critical E-Category Management Strategies for HFSS Compliance and Growth

 

1. Map Where Demand Moves Online

When HFSS products lose their promotional visibility, shoppers don't disappear. They search differently, browse other categories, and make alternative choices. Understanding these new paths matters.

Which search terms are growing?

Which categories are seeing increased traffic?

Which non-HFSS products are capturing the searches your restricted products used to win?

Strategic planning means answering these questions before your competitors do. Digital shelf analytics platforms track these search behaviour shifts in real-time, enabling brands to identify emerging opportunities and adjust category strategies accordingly.

 

2. Prioritise Availability Over Promotion

Without stock, nothing else matters. Real-time availability tracking across all online retailers lets you spot problems immediately. If a product goes out of stock, you can pause retail media spending on that SKU instantly, avoiding wasted investment on products customers cannot buy.

In the HFSS era, consistent availability matters more than intermittent promotional spikes. Brands with superior digital shelf monitoring capabilities maintain higher in-stock rates, directly protecting market share when promotional levers are restricted.

 

3. Optimise Your Portfolio With Nutrition in Mind

Look at your product range through a new lens. Which SKUs can still access premium online placements? Which need reformulation to improve their NPM score? Which require complete repositioning?

Understanding NPM scores and how HFSS product classification affects your portfolio becomes essential. The nutrient profiling model determines whether products exceed thresholds for fat, saturated fat, sugar, and sodium. Digital shelf analytics help you monitor which products fall into restricted categories and track reformulation success across retailers.

For categories where reformulation isn't feasible, explore complementary products and new consumption occasions. The goal is understanding your portfolio's strengths and weaknesses in the HFSS landscape.

 

4. Bring Category Insights to Retailers

Move beyond talking about your brand alone. Bring intelligence that helps retailers understand their entire category. Show them which promotions face restrictions across all brands, not just yours. Identify where shoppers are struggling to find what they need. Suggest improvements that benefit the whole category.

E-category management requires this broader perspective. Tesco's stated goal to increase "healthy food" share from 58% to 65% by 2025 creates partnership opportunities. Asda requires "highest impact" suppliers to join data platforms measuring health scores. These signals are clear: category conversations must address health holistically, not just sales and profit.

 

5. Use Shared Data Infrastructure

The GS1 UK productDNA platform shows what's possible. Asda, Morrisons, Sainsbury's, Ocado, and Waitrose share a standardised HFSS data source. Suppliers manage product classifications once and share to multiple retailers simultaneously. This reduces admin whilst improving accuracy and enables sophisticated category analysis across retailers.

Brands using digital shelf analytics platforms with GS1 UK productDNA integration can verify their NPM scores are correctly reflected across all participating retailers, ensuring HFSS compliance whilst reducing administrative burden.

 

What Retailers Want From Brand Partners

Industry experts emphasise collaboration.

Michele Dainty from Pladis: "Collaboration is key... We're all in it together." Helen Johnson from Capture/SMG notes: "HFSS is a real inflection point in the industry because it's forcing brands to think differently about awareness, reach, and connection."

 

Retailers need partners providing market intelligence, consumer behaviour analysis, and strategic recommendations that improve total category performance, not just individual brand outcomes.

Tesco voluntarily implemented HFSS multibuy bans from October 2022. Sainsbury's publicly committed to maintaining original HFSS timelines regardless of government delays. These retailers are testing new approaches and need brands who can help them navigate this complexity.

Build relationships on category vision, not transactional discussions. Bring data-driven insights and shared understanding that category health drives mutual success. Digital shelf analytics provide the foundation for these strategic conversations, offering category-level intelligence that helps retailers optimise their entire online grocery offer.

 

Digital Shelf Analytics: Essential HFSS Compliance and Performance Tool

With organic search replacing paid promotion as the primary visibility driver, digital shelf analytics becomes business-critical. The top three organic search positions capture approximately 70% of all clicks, whilst 70% of users never scroll past the first page. Share of search represents 83% of a brand's market share, making search performance the single most predictive indicator of online success.

Understanding NPM Scores and Digital Shelf Compliance

HFSS product classification depends on NPM scores calculated from nutritional content. Products exceeding specific thresholds face promotional restrictions. Digital shelf monitoring tools verify that product classifications are correctly reflected across retailer websites, preventing compliance violations that could result in penalties or retailer relationship damage.

Real-time digital shelf analytics track how NPM score changes from reformulation affect product visibility and performance. Brands can measure the commercial impact of achieving non-HFSS status by monitoring search ranking improvements, promotional access, and sales trends.

Content quality drives organic performance. High-quality product photography influences 90% of consumers as the most important purchase factor. Product videos can boost browsing time by 340%. Complete product descriptions and keyword optimisation in titles and attributes directly impact search algorithms.

When hundreds of products update formulations simultaneously to improve NPM scores, you need systematic verification that updated nutritional information and optimised content are properly implemented across all retailers.

 

Real-Time Monitoring Requirements:

  • Product availability tracking (without stock, other metrics become irrelevant)
  • Ratings and reviews monitoring for reformulation acceptance
  • Banner ad placement tracking for HFSS compliance verification
  • Sponsored search monitoring to spot competitive patterns
  • Digital taxonomy compliance as retailers reconfigure categories
  • NPM score accuracy across retailer systems

 

Competitive Intelligence Capabilities:

  • Track all promotions across the category over time
  • Calculate restriction risk for every brand
  • Monitor how different retailers interpret HFSS regulations
  • Identify which competitors are reformulating successfully
  • Benchmark organic search performance against category leaders

Different retailers interpret HFSS regulations differently. Full visibility across retailer implementations prevents tactical mistakes and identifies where specific strategies succeed. You need real-time monitoring across retailers, product rank tracking with keyword performance insights, competitor intelligence on pricing and promotional activity, and the ability to adjust quickly based on market trends.

The investment rationale is straightforward: non-HFSS products showed 16.2% spending growth versus 5.7% for HFSS products in early post-implementation periods. Brands investing in reformulation and digital shelf capabilities captured disproportionate share as competitors struggled. First movers in organic search optimisation and content excellence secured visibility positions that compound over time.

The window is narrowing as HFSS multibuy ban October 2025 and HFSS advertising restrictions January 2026 approach.

 

Understanding the HFSS Digital Retail Framework

HFSS products can appear in organic search results when customers explicitly search for them but cannot appear in any paid, sponsored, or promoted position. This means traditional retail media strategies (sponsored product tiles, paid search placements, featured listings) are prohibited for HFSS brands on grocery retailer websites.

Products exist on natural category pages and appear in relevant search results, but any algorithmic promotion, payment-driven prominence, or merchandising preference violates regulations.

 

Key digital restrictions effective since October 2022:

  • Homepage hero banners with direct "add to basket" functionality
  • Checkout page cross-sells and upsells
  • Pop-up promotions and "brand burst" features
  • Featured product carousels on homepages
  • Sponsored search results and paid listings
  • Algorithm-driven recommendations outside category context

Volume price promotions ("buy one get one free," "3 for 2") face restriction from October 1, 2025, whilst comprehensive advertising restrictions launch January 5, 2026. Only businesses with 250+ employees globally face the advertising ban, and only those with 50+ employees must comply with promotion restrictions.

The regulations affect thirteen product categories including soft drinks with added sugar, savoury snacks, breakfast cereals, confectionery, ice cream, cakes, sweet biscuits and bars, morning goods, desserts, sweetened yoghurt, pizza, potato products, and ready meals.

 

How Leading Brands Are Responding

Walkers committed £35 million over three years for reformulation and innovation. Their 45% Less Salt range now appears in 1 in 6 UK households. Core flavours (Salt & Vinegar, Prawn Cocktail, Smoky Bacon, BBQ, Roast Chicken, Pickled Onion) achieved non-HFSS status through years of rigorous testing. The entire Doritos brand underwent reformulation in 2024 to maintain advertising capability for the £271 million brand.

These reformulations required careful NPM score management, with brands balancing nutritional improvements against taste preservation. Digital shelf analytics helped these brands measure the commercial impact of reformulation by tracking search visibility changes, promotional access restoration, and consumer response through ratings and reviews.

Mars Wrigley's Triple Treat range (Mars, Snickers, Galaxy, and Bounty variants made with 75% fruit and nuts) generated only £1.9 million in sales for the year to July 2024 despite premium pricing and £1 million marketing investment. Consumer reviews cited "soapy" taste, forcing rebranding. The failure shows a fundamental tension: consumers don't buy chocolate to be healthy.

Market dynamics shifted measurably. Kantar data showed £82 million shifted away from HFSS products in the 12 weeks to March 2023, with £34.4 million moving to healthier non-HFSS alternatives. Spending on non-HFSS products increased 16.2% year-over-year whilst HFSS product spending grew only 5.7%. Non-HFSS impulse products demonstrated 5.6% sales growth versus 0% for HFSS products.

 

How eStore Enables HFSS Success

eStore's digital shelf analytics platform provides the capabilities brands need to win in the HFSS era through three critical areas:

 

Comprehensive Monitoring & Intelligence

Real-time visibility across retailers identifying exactly where products can and cannot appear. Track organic search performance by keyword and category. Monitor competitive activity including how competitors redistribute promotional spend. Automated HFSS compliance verification prevents costly violations.

Our digital shelf monitoring tracks NPM score implementation across retailers, alerting you immediately if products are incorrectly classified or if competitors gain promotional access they shouldn't have.

 

E-Category Management Support

Category-level analytics providing insights beyond your brand portfolio. Understand how the entire category is performing under HFSS regulations. Identify where demand is shifting. Calculate restriction impact across all brands, not just yours.

This broader perspective enables the strategic retailer conversations that build lasting partnerships and secure category leadership positions.

 

Strategic Retailer Partnership Tools

Data-driven insights formatted for retailer conversations. Integration with GS1 UK productDNA platform. Benchmarking capabilities demonstrating category leadership. HFSS compliance documentation supporting joint business planning.

 

Asda Xpert: The HFSS Advantage

eStore's exclusive partnership with Asda delivers unique capabilities unavailable through traditional digital shelf analytics. As the only provider with direct access to Asda's proprietary retail data, brands using Asda Xpert gain retailer-verified insights enabling genuine collaboration.

This partnership addresses HFSS challenges specifically. Verified NPM classifications eliminate compliance uncertainty. True visibility into shopper behaviour and conversion enables sophisticated category strategies. Retailer-aligned reporting strengthens your position in category discussions.

With HFSS regulations reshaping promotional access, privileged insight into how shoppers navigate restricted categories becomes invaluable competitive advantage.Comparison of banned HFSS sponsored listing versus permitted organic product placement with ranking benefits

 

Taking Action: Your HFSS Roadmap

 

Category winners invest now in three capabilities:

 

1. Reformulation Strategy (if applicable)

Develop HFSS-compliant products maintaining taste and texture whilst meeting nutritional thresholds. This requires sophisticated ingredient science and extensive consumer testing. Walkers required years of rigorous testing through a six-step process with 63 flavour variations. Timelines stretch years, not months.

Digital shelf analytics help you track reformulation success by monitoring how improved NPM scores affect search visibility, promotional access, and sales performance across retailers.

 

2. Digital Shelf Excellence

Implement real-time monitoring across all retailers. Launch organic search optimisation programmes. Invest in content quality initiatives. Build HFSS compliance verification systems.

Remember: 4% sales change for every 1% shift in organic search ranking makes this capability business-critical. Digital shelf analytics platforms provide the foundation for measuring and improving these critical performance drivers.

 

3. Strategic Retailer Partnerships

Build relationships on category vision rather than brand-specific transactions. Bring data-driven insights. Adopt test-and-learn collaboration approaches. Share understanding that category health drives mutual success.

E-category management requires digital shelf analytics that show category-level performance, not just your brand's metrics. Retailers value partners who help them understand their entire category under HFSS regulations.

The evidence demonstrates early movers capture lasting advantage. Walkers' reformulated products appear in 1 in 6 UK households. Non-HFSS products are growing 16.2% versus HFSS 5.7%. Reformulated products are winning category placements. Brands with compliant portfolios gain promotional access competitors lack.

The window for competitive repositioning is narrowing. With HFSS multibuy ban October 2025 and HFSS advertising restrictions January 2026 approaching, brands treating HFSS restrictions as obstacles rather than opportunities will find themselves disadvantaged.

In the HFSS era, the most valuable real estate isn't a physical store location. It's the top three organic search results.

Digital shelf analytics showing product rankings, search trends and competitor performance for breakfast cereals

 

Frequently Asked Questions About HFSS Regulations

 

What are HFSS regulations?

HFSS regulations restrict the promotion and advertising of food and drink products high in fat, salt, or sugar. Products are classified using the nutrient profiling model (NPM score). Restrictions include bans on volume promotions, prominent online placements, and paid advertising for products exceeding nutritional thresholds.

 

When do HFSS advertising restrictions start?

HFSS advertising restrictions launch January 5, 2026, prohibiting TV and paid online advertising before 9pm for businesses with 250+ employees globally. Volume promotion restrictions begin October 1, 2025, for businesses with 50+ employees.

 

How do HFSS rules affect digital shelf performance?

HFSS regulations eliminate paid promotional placements, making organic search performance critical. Products cannot appear in sponsored search, homepage features, or checkout recommendations. This shifts competitive advantage to brands with superior content quality, availability, and organic search optimisation.

 

What is an NPM score?

An NPM (Nutrient Profiling Model) score determines HFSS classification based on nutritional content. Scores calculate points for fat, saturated fat, sugar, and sodium content. Products exceeding thresholds face promotional restrictions. Digital shelf analytics help brands monitor NPM score implementation across retailers.

 

How can digital shelf analytics help with HFSS compliance?

Digital shelf analytics platforms monitor product classifications across retailers, verify NPM scores are correctly reflected, track organic search performance, identify compliance violations, and provide competitive intelligence on how other brands navigate HFSS regulations. Real-time monitoring prevents costly mistakes whilst identifying growth opportunities.

Ready to turn HFSS regulations into competitive advantage? Contact eStore to discover how our digital shelf analytics platform and exclusive Asda partnership can transform your category management strategy.

David Halls
David Halls
David Halls
VP of Sales