3 ways you can get ahead of the HFSS storm

Posted on March 9, 2022

Updated on March 9, 2023

5 min read time

What is HFSS? Why are these regulations coming into force? And what does this mean for you as a brand or retailer?


If you want to learn more about the elusive and ever-changing HFSS governmental regulations, we’re here to answer your questions.


We’ve partnered with The Grocer to host an interactive panel discussion on the



The panel features:

  • Henry Dimbleby – Leader of the Government’s National Food Strategy and Co-Founder of Leon Restaurants
  • Lottie Unwin - Founder of the infamous community of challenger brands, The Copy Club.
  • Annie Henderson – General Manager and Head of Customer Success at ProQuo AI – the world’s first AI-Powered Brand Management platform

Below are the 3 most important takeaways from the session.



First, why is the government imposing regulations around food and drink?


The impact the food system has on our societies, economies, and planet is monumental.


The government explains how food is by far the largest source of environmental destruction, as the single biggest cause of water pollution and the main source of deforestation. They show how diet-related diseases are now the largest avoidable cause of ill health.


Yet, as a nation we continue to prioritize high in fat, salt and sodium foods over healthier options. Companies desperately need help to end this cycle. And that’s why the government has decided to financially incentivize these businesses to help them make the transition over to healthier foods.


Enter, HFSS


The HFSS legislation refers to a series of restrictions that will be imposed on foods that are high in fat, salt and sugar. These range from financial taxes to limits on pack sizes and rules around targeting in advertising.


Some of these laws are further along in the process and are close to being finalized, whereas others are still in the early stages with much to be decided on.


To help you to get ahead of this HFSS legislation, we will explore 3 key areas that are at risk of being impacted:

  • Product
  • In-store activations
  • Advertising and communications

What’s going on with product?


HFSS will be defined on a product level by a ‘Nutrient Profile Score’. Every product will be rated with negative points for calorie density, saturated fat, sugar and sodium and positive points for protein, fibre, fruit, veg and nuts. Combining these points will give brands an overall nutrient score and a score of over 4 will mean a product is defined as HFSS.


From a product perspective, brands are facing difficult questions about how to evolve in this new universe. This is more difficult for the indulgent brands, like chocolate, crisps and treats. They must now decide whether to innovate and risk sacrificing on taste or to stay the same and deliver on what their customers originally bought into.


This is made even more uncertain because the impact of these changes is still not decided. So, brands are having to make big decisions without visibility into the full consequences.


There are 3 key considerations to make when deciding whether to innovate:


1. Is reformulation the right strategic decision from a brand-building perspective?

2. Could reformulation unlock new audiences?

3.Will this affect how your current audience engages with your brand?


Reformulation doesn’t need to be a defensive strategy.


On ProQuo AI, we’re seeing brands approach HFSS as an opportunity to unlock new audiences. Brands are using our creative testing solution to try out different product claims to see which has a higher impact.


One brand tested a product with a sugar-free claim against a product with no claim. On ProQuo, they saw the same openness to trying the product, but the response was different between Users and Non-Users.


The existing audience scored the brand highly in emotional factors, like Innovation and Integrity after they saw the claim, whereas the new audience scored the brand highest on Relevancy. This suggests HFSS could be a key gateway for this brand to expand reach and engage with an entirely new group of people.


To test your packaging, products, claims or advertising when creating HFSS-compliant campaigns, click here.


creativelab - proquo scores


How can we expect in-store activations to change?


The in-store activation laws have been passed and are set to begin in October 2022. We will see restrictions on volume and price promotions for HFSS foods. This will cover pricing deals, like ‘extra free’, free refills of fizzy drinks and product positioning in stores - not being able to sell products at store entrances or aisle ends.


These rules will be governed by retailers who will face the challenge of trying to generate revenue while complying with new restrictions. However, there is still a lot of ambiguity in this area, as even terms like ‘front of store’ are yet to be defined and no specific plans have been set in supermarkets.


To get ahead, brands should ensure they have a clear promotional strategy and a clear idea of how they will monitor the impact of this strategy.


On ProQuo AI, brands are using our platform to strategize, monitor and plan ahead.


Our virtual marketing calendar allows brands to plot their activities in advance so they can have full visibility as to what’s coming.


The advantage of using this planner over an Excel is that it is fully integrated into the brand’s live performance monitor. This monitor works in real-time, alerting you to changes in your category, competition and brand – so you’re always the first to know, and the first to act.


Because your calendar is integrated with this monitor, you’ll be able to see how the context around your brand is affecting your marketing plans. When it comes to HFSS, this kind of data is invaluable, enabling brands to see how shifting promotional strategies will impact people’s feelings on the category and their brand in the long run.


If you want to be alerted to real-time changes in your category after HFSS takes flight, check out how ProQuo can help.


Will we need to adapt our advertising and communications?


In January 2023, TV and online advertising bans are proposed to come into effect. For TV, there will be a watershed from 9pm – 5:30am every night for brands who advertise HFSS products. And online, there has been an outright ban of advertising these products during these hours. There are also tighter rules on targeting, with brands on social platforms unable to target more than 25% of their audience at under 16’s.


However, this legislation still hasn’t been confirmed and companies are continuing to fight against these restrictions.


There are 2 key considerations to make when deciding how to approach your advertising and comms:


1. Which media channels will help you to land your messages?

2. What changes to your communication will feel authentic to your brand?


On ProQuo AI, we can see that brands are currently working hard to determine the best channels to use for future communications and the best types of advertising. Those who typically spent a large proportion of their budget on TV will now have to adapt, considering other mediums as well.


Some brands are worried messages won’t land as effectively as before. Others are moving towards brand-focused advertising over product and are testing this out on our platform to see how audiences react.


The best way to experiment with new messaging and concepts is to keep an open dialogue with your consumers and be open to feedback. On ProQuo AI, we’re seeing brands interact more with their audiences, asking custom questions to see how consumers feel about new messaging in real-time.


Because you can also segment these responses by Users, Non-Users, age and gender, it also helps these brands to be more experimental not just with messaging but targeting too.


custom question



The key to keeping ahead of HFSS is staying alert to how people’s needs across categories are changing, so you can be sure the products, strategies and communications you’re developing will resonate.


To keep on top of these changes, ProQuo’s real-time brand monitor is essential. Every day, it keeps an eye on how your brand and competition are performing.

homepage - summary


ProQuo’s AI even identifies the shifting needs in your category as they happen, alerting you when you need to take action, and showing you what to do to make the most out of this opportunity.


This makes strategizing easy.






And throughout this entire process, you can use our creative testing solution to sense check ads, communications and concepts, in just a matter of hours.


creativelab - detailed report



People’s relationships with brands and categories are going to change but as long as you have an AI-Powered system to keep you alert to these movements, you’ll always be one step ahead.


And if you want to find out how ProQuo AI can help you ride the HFSS storm, click here.


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