Scotland's new food promotion rules arrive on 1 October 2026, and they could reshape the commercial landscape for a significant chunk of the UK's food and drink market. The regulations will restrict where and how products high in fat, sugar or salt (HFSS) can be promoted inside larger retail stores. Checkout displays, aisle-end promotions, multibuy deals and certain seasonal promotions will disappear for products that fail the UK Nutrient Profile Model.
The stakes are substantial. Before England introduced its HFSS placement restrictions in 2022, affected products represented roughly £18bn in annual UK food and drink sales, around 16% of the market at the time according to Kantar data cited in the article. England's existing rules have already changed shopping behaviour. A University of Leeds study examining sales data from 480 supermarket stores across England found that HFSS placement restrictions introduced in October 2022 were linked to around two million fewer in-scope HFSS products being sold per day, based on analysis of 11.6 billion product sales across Tesco, Sainsbury's, Asda and Morrisons over a 30-month period.
Who faces the rules
Scotland's Food (Promotion and Placement) (Scotland) Regulations 2025 will apply to businesses with 50 or more employees selling pre-packed food in stores larger than 2,000 square feet, as well as online retail environments. Products classed as HFSS across categories including cakes, biscuits, confectionery, savoury snacks, breakfast cereals, pizzas, ready meals, desserts, sweetened yoghurts and soft drinks with added sugar will fall into scope. Online retailers will face equivalent placement restrictions on homepage promotions and checkout areas. Free refills of sugary soft drinks will also be restricted.
Reformulation becomes commercial strategy
Reformulation itself is not new. Manufacturers have been quietly changing recipes for years, responding to retailer nutrition targets, ingredient price swings or shifting consumer tastes. Salt reduction programmes have run for more than a decade, followed by sugar targets, fibre enrichment, protein claims and calorie reduction.
What has changed is the urgency and the commercial consequences. Products failing to comply with the nutrient model will lose access to some of the most valuable promotional space in supermarkets. This has pushed reformulation higher up the priority list across product development teams.
Scottish SME manufacturers are getting practical support. FDF Scotland has launched a new grant fund worth up to £5,000 to help smaller food and drink businesses cover reformulation costs including trial ingredients, nutritional analysis, consultant support and laboratory testing. Applications close on 31 May 2026.
The technical challenge
Reformulation is more complicated than cutting an ingredient. Sugar affects browning, texture and shelf life. Salt plays a role in flavour and preservation. Fat contributes texture and eating quality. Remove or reduce one element too aggressively and the final product can behave very differently during production or taste noticeably different once it reaches shelves. That complexity explains why some reformulation projects take years rather than months.
Case studies show the balancing act at work. Growers Garden, a farmers' collective based in Cupar, Fife, reformulated its broccoli crisps by cutting salt levels by more than 40% while also reducing potato content to improve the product's HFSS and VAT positioning. The company worked to lower salt levels in stages after finding larger substitutions affected flavour and texture, eventually trialling calcium chloride in small increments. The reformulation helped the product gain approval for use in Scottish schools and the NHS.
Tower Bakery, a family-owned business based in Abernethy, Perthshire, worked on fibre-enriched morning rolls after Stirling Council requested products with improved nutritional profiles for schools. The bakery more than doubled fibre levels in the rolls from 2.1g per 100g to 4.3g per 100g while maintaining the appearance of a traditional white morning roll.
Consumer acceptance and price
Public opinion on the rules is broadly supportive. A survey of 1,968 shoppers in England, published in 2023 in BMC Medicine by researchers from the University of Southampton, found 71.4% viewed the legislation as a good first step towards healthier eating. However, almost 90% said the affordability of healthier food was equally or more important than restricting HFSS promotions.
Manufacturers face conflicting consumer demands. Shoppers still want indulgence and value, but they are also paying closer attention to labels, protein content, fibre and ingredient familiarity. That leaves product developers trying to satisfy multiple demands at once. Consumers expect healthier products to taste exactly the same as before, creating a commercial risk.
Opportunity within regulation
Few in the industry see reformulation purely as a regulatory burden. Some manufacturers are using reformulation projects to reposition products altogether. Instead of only talking about what has been reduced, brands are increasingly promoting what has been added back in: fibre, seeds, protein, wholegrains or functional ingredients linked to satiety and digestive health. That approach can help products feel more premium rather than simply "less bad".
Manufacturers that successfully navigate reformulation may gain stronger health credentials, improved retailer relationships and access to promotional freedoms unavailable to competitors that remain classified as HFSS. For many, reformulation is now becoming part of long-term product strategy rather than a temporary response to one set of regulations.