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Earlier this year, the UK Government released new guidance for its Less Healthy Food (LHF) and products high in fat, salt or sugar (HFSS) policies, including a new restriction on advertising which will come into effect on 5 January 2026. James Nevard, head of qualitative research at Linney, explores how retailers are profiting despite the regulatory challenges surrounding popular foods that have been designated ‘less healthy’.

For food and beverage retailers, the UK government’s Less Healthy Food (LHF) regulation may feel like another compliance burden. But for forward-thinking brands, it presents a meaningful opportunity to innovate, align with evolving consumer values and shape a healthier, more sustainable food future.

With terminology and timelines often overlapping, and the difference between 'HFSS' and 'LHF' sometimes unclear, getting to grips with these frameworks is key to navigating what comes next.

HFSS vs LHF: What’s the difference?

'High in fat, salt and sugar' (HFSS) refers to how food and drinks are assessed under the UK government’s Nutrient Profiling Model. If a product exceeds nutritional thresholds, it is classified as ‘less healthy’ and becomes subject to promotional restrictions.

Since October 2022, HFSS products have faced in-store limitations, including bans on display in high-traffic areas, like aisle ends and checkout zones. From October 2025, volume promotions – such as buy one get one free – will also be prohibited for these products.

Meanwhile, Less Healthy Food (LHF) regulations are focused on advertising, particularly online and on TV. To fall under LHF, an item must be both HFSS and part of one of 13 defined product categories, including sugary cereals, crisps, chocolate and ice cream.

From October 2025:

• LHF products will be banned from appearing in paid-for online advertising at any time

• They’ll be blocked from TV and on-demand ads before 9pm

While the term HFSS remains central to how products are nutritionally assessed and promoted, LHF describes how that assessment is applied in legal contexts, particularly in relation to media and advertising. Together, these frameworks are reshaping how and where brands can present less healthy products to consumers.

While this creates short-term disruption to established marketing tactics, it also opens the door for smart brands to build new, more relevant relationships with today’s health-conscious shoppers.

Seeing behavioural shifts

The expected effects of LHF on consumer behaviour are nuanced. While in-store HFSS rules may reduce impulse purchases, demand for indulgent products is unlikely to vanish. Cultural food habits are deeply embedded and will not shift overnight.

Unlike the Soft Drinks Industry Levy (often referred to as the 'sugar tax'), which directly influences manufacturers to reformulate by increasing product costs, LHF does not directly impact pricing – it regulates visibility. As a result, its influence on consumer behaviour is likely to emerge more slowly, with changes in how people discover and consider products, especially online.

This shift means brands must be more deliberate in how they stay connected with consumers. It is not just about compliance – it is about finding new ways to guide shoppers without alienating them.

From ‘less visible’ to ‘more valuable’

Because LHF limits traditional media presence, brands are having to refine how they speak to consumers. Tone and language play a growing role.

Research consistently shows that positive framing – emphasising what a product is 'high in,' like protein or fibre – has greater appeal than negative phrases like 'low fat' or 'sugar-free,' which can imply compromise. This response is rooted in well-documented cognitive biases, notably loss aversion – the tendency for people to prefer avoiding losses over acquiring equivalent gains. Shoppers are more likely to support choices that feel empowering and additive, rather than restrictive or depriving.

As a result, many brands have embraced 'permissible indulgence,' creating products that feel like a healthier twist on an old favourite. These are snacks and treats positioned as more responsible choices, even if they’re not fully 'healthy' in strict nutritional terms.

This approach taps into the emotional side of food: enjoyment, comfort and reward. It doesn’t demand a complete behavioural shift, but gently reframes how consumers view familiar products.

Bridging lifestyle and legacy

Food behaviours rarely change through hard switches. Consumers prefer gradual shifts and familiar reference points.

Smart brands are creating entry points that balance healthy improvements with low-friction choices. McDonald’s long-standing option of substituting fruit for fries in Happy Meals is a prime example of subtle, customer-friendly change. Likewise, Walkers’ 'Yummy With' range helps maintain flavour recognition while offering reduced-salt options.

Mixed multipacks that combine standard and healthier items can also work well. By presenting these options side by side, consumers can make more intentional decisions without abandoning established preferences.

These methods prevent consumers from feeling deprived of their preferred products while gently introducing alternatives, sidestepping the pushback that often comes with trying to replace favourites overnight.

The flexibility factor

With future food legislation likely to touch on ultra-processed products and stricter front-of-pack labelling, brands must remain agile. Timelines may be uncertain, but momentum is clear, and consumer expectation keeps rising.

Rigid strategies won’t work in a progressively regulated market. Brands need to embed responsiveness into their core processes – from R&D and formulation to campaign messaging and packaging. The ones that succeed will treat adaptability as a strength rather than a reactive fix.

In today’s constrained marketing space, innovation isn’t optional. Brands must develop ways to connect emotionally, communicate benefits clearly, and creatively replace now-restricted promotional channels with more engaging storytelling.

What’s next?

Alongside these restrictions, the food and drink world is rapidly shifting towards functionality and personalisation. Food retailers are already highlighting protein content and gut health benefits, but the next big wave may involve products designed to support mental well-being, sleep and focus.

For example:

• Functional drinks like those from Trip are gaining popularity. Their CBD-infused fizzy beverages promise calm and clarity, packed into appealing, lifestyle-focused packaging.

• Grenade bars strike the balance between performance and indulgence, combining protein with the format of a sweet treat.

• Enriched snacks, including added-prebiotic crisps or fortified granolas, combine classic consumption patterns with new nutritional relevance.

These examples show that health and indulgence don’t need to be at odds. In fact, the brands that offer both stand to build the most relevance in the years ahead.

Navigating the new food frontier

Ultimately, brands that thrive under HFSS and LHF rules will be those that treat legislation not as a threat but as an invitation to evolve.

Traditional promotional levers are changing, but the appetite for indulgent food isn’t going away. Consumers still want familiarity. They still want joy from eating. What is changing is the lens through which they evaluate those experiences – and who they trust to deliver them responsibly.

By aligning product development with wellness trends, refining marketing language to reflect real behavioural insight, and building trust instead of visibility, retailers can transform regulatory shifts into catalyst moments – moments that drive not just compliance, but competitive growth.