ACS has urged retailers in Wales to ensure their businesses are ready for the introduction of restrictions on the placement and promotion of HFSS (high fat, salt, sugar) products, coming into force on Thursday March 26th.

The regulations closely follow those already in place in England, and will introduce the following measures:

• For retailers with more than 50 employees: Restrictions on the promotions of multibuys (for example 3 for 2) and additional volume (for example 50% extra free) of HFSS products
• For retailers with more than 50 employees and relevant floor space over 2000 sq ft: Restrictions on the placement of HFSS products at the end of aisles, within 2m of checkouts and queueing areas, and near the entrance of a store (dependent on store size)

The key difference between England and Wales is the treatment of on-pack price promotions. In Wales, the regulations do not restrict products with volume price promotions on their packaging from being sold, but retailers must not apply the promotion at the point of sale. There is no transition period for this and retailers must clearly tell customers that the promotion shown on the packaging does not apply.

The Welsh Government guidance asks retailers to both clearly communicate to customers that restricted on-pack promotions do not apply, and to confirm the revised price of any affected products. The guidance states that businesses should ensure their chosen method for communicating this is sufficiently clear so as not to mislead consumers. It is recommended that for any product with restricted on-pack promotions, shelf edge labels are used to communicate the policy and the revised price to customers. Retailers should also ensure that their EPoS and self-service till systems do not apply the promotional price when scanned.

Regulations on volume promotions came into force in England in October 2025, with location restrictions having been in force in England since 2022.

ACS’ detailed guidance on preparing for the HFSS regulations is available here