Confusing. Concerning. Challenging. UK retailers tell us how their HFSS plans are going so far.

Confusing. Concerning. Challenging. UK retailers tell us how their HFSS plans are going so far.

November 2021: Spoon Guru’s HFSS Readiness Survey has produced some concerning insights from 11 of the UK’s top supermarkets.

Key survey findings from the UK’s top supermarkets:

  • Every supermarket thinks there will be challenges
  • 87% think the extension should be increased by 6 months or more
  • Only 50% are aware of what the HFSS legislation will entail
  • 59% are concerned about the overall effect
  • Almost a quarter (23.76%) are not confident that they have the necessary tools
  • 100% have a wider customer health strategy planned in addition to HFSS

What is the HFSS Legislation?

In 2018, the UK government published the Childhood Obesity Plan to help curb this growing health crisis. As part of this plan, legislation is being introduced that will require retailers to limit the promotion of food and beverage products that are High in Fat, Salt and Sugar (HFSS), both in store and online. This is simply known as the HFSS Legislation.

Under the new rules, as of October 2022 food & beverages that have been classified as HFSS (according to a calculation developed by the Food Standards Agency) will no longer be allowed to be promoted in store at or near aisle ends and checkouts, nor their online equivalents such as entry pages, landing pages, shopping basket or payment page. Additionally, product promotions such as 3 for 2 or buy-one-get-one-free will no longer be possible on HFSS products.

HFSS readiness

With preparations for the new legislation underway, we asked those working in the UK’s retail industry about their readiness levels. We found that although the legislation has already been pushed back by six months, 87% of those working in the top supermarkets think this should be extended by at least another six months, with 50% believing it should be extended by more than 7 months. 

So why the call for delay? Currently only half are aware of what the HFSS legislation will entail, while the other half are still somewhat unsure. However, despite this level of uncertainty, every supermarket has begun their HFSS planning journey.

Retailers are anxious about the challenges

Every single supermarket we spoke to thinks there will be hurdles to overcome, and 59% expressed concern around the legislation. The anticipated challenges range from the technical difficulties associated with ongoing compliance, to simply having the capacity to take on and continuously manage these changes. Some of the most telling concerns playing on people’s minds are: keeping product catalogues updated and compliant (37%), breaking the rules set out in the legislation (35%), limited team capacity & budget (28% & 27%), data accuracy (25%) and not having the right tools (24%).

That said, there are tools that retailers believe can help them. These include better risk assessment guidelines for products near the HFSS compliant threshold (51%), up-to-date information on legislative changes (44%), technology & SaaS tools (41%), and consumer buying behaviour analysis and forecasting (39%).

Anticipated changes in consumer behaviour

Most supermarkets agree that changes will affect their consumer journeys and help nudge them towards a healthier lifestyle in some way. 64% think that consumers will opt for healthier choices all or some of the time, with less than 1% disagreeing with the suggestion. On top of this, every supermarket we spoke to already have planned a wider health strategy to encourage customers into healthy eating in addition to their ongoing planning for HFSS.

While the UK government is spearheading childhood obesity with this new HFSS legislation, it’s clear that retailers have already taken the initiative to step up and help improve the health of the nation themselves. However with new legislative obligations comes a new set of challenges and concerns. 

The right people with the right tools for the job

Taking a DIY approach is fine for some jobs, but for more complicated tasks, it’s best to call in a specialist. Spoon Guru specialises in providing innovative modular tech solutions based on both CPG product and customer basket health & nutrition data. Our expert team of health and technology specialists have designed and developed the HFSS Index to help retailers understand, implement, and remain compliant with the incoming HFSS legislation. 

Our system utilises existing government Nutrient Profiling Models (NPM) alongside a proprietary fruit, vegetable and nut (FVN) scoring system, enabling accurate HFSS analysis at speed across tens of thousands of SKUs. Our base-level solution allows retailers to identify HFSS for their own label products with 100% accuracy at scale, or by category for national brands. For any products near the HFSS threshold we will perform a manual risk assessment using our QA team and isolate borderline products for review. Additional HFSS services include the HFSS Tag, Smart Swaps Similarity Engine and a Retailer Health Score to track the health of each shopper’s basket, allowing you to track and report health changes in shopper behaviour.


Survey notes: 100 respondents from 11 UK retailers

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