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PRP (37-01-03) Restricting promotion of food and drink high in fat, sugar and salt Research Specification


Published: 19 September 2023

Version: 1.0 September 2023

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Timetable and Budget

Deadline for Stage 1 Applications 24 October 2023, 1PM
Notification of outcome of Stage 1 Application 09 January 2024
Deadline for Stage 2 application 20 February 2024, 1PM
Notification of outcome of Stage 2 Application June-July 2024
Earliest Potential Project Start July 2024
Project Duration 30 Months
Budget £650,000 to £700,000


The National Institute for Health and Care Research (NIHR) Policy Research Programme (PRP) invites proposals for a single research project to evaluate the implementation of restrictions in retail stores on the promotion of food and drink high in fat, sugar or salt (HFSS) by location (introduced in 2022) and by volume price (expected to be introduced in England in 2025).

The aim of these policies is to help improve people's diets and reduce children's sugar intake by restricting HFSS products from key promotional locations in retail stores (such as check outs) and by restricting the use of volume price promotions for HFSS products which encourage consumers to buy more of these products (such as ‘3 for the price of 2’).

This is a significant opportunity to support policymakers in the Department of Health and Social Care (DHSC) to prevent and reduce overweight and obesity by helping people to make healthier choices and reduce overconsumption of HFSS food and drink.


Obesity is one of the biggest health problems this country faces. Around two-thirds of adults are above a healthy weight[1], and over a fifth of children in England are living with overweight or obesity by the time they start primary school aged 5, and this rises to over one third by the time they leave aged 11 [2]. Regular overconsumption of food and drink high in calories, sugar and fat can lead to weight gain and, over time, obesity, which in turn has a significant impact on health and wellbeing and increases the risk of obesity-related diseases.

There has been growing concern about the impact of promotional offers on influencing and shaping purchases toward less healthy products. Evidence shows promotions are effective at influencing purchases and tend to be heavily skewed towards less healthy options [3]. Location promotions often lead to ‘pester power’ from children [4].

In 'Childhood Obesity: a plan for action, chapter 2', published in June 2018 [5], the government announced its intention to ban promotions of HFSS products by location and price through legislation and consult on how this policy should be implemented. Following consultation, the government announced in ‘Tackling obesity: empowering adults and children to live healthier lives’, published in July 2020 [6], that it would introduce legislation to restrict promotions of HFSS products by location and price in retailers that sell food and drink in-store and online in England.

Promotion of HFSS products will be restricted as follows:

  • Location restrictions will apply to store entrances, aisle ends and checkouts and their online equivalents (that is, entry pages, landing pages for other food categories, and shopping basket or payment pages). These restrictions were introduced in October 2022.
  • Price promotion restrictions will apply to volume-price promotions such as Buy-one-get-one-free and two-for-price-of-one. These restrictions are likely to be introduced in October 2025.

The 2004/2005 Nutrient Profiling Model will be used to define whether a product is HFSS [7]. Prepacked food and drink in the following categories will be in scope of the restrictions: soft drinks, cakes, chocolate confectionery, sugar confectionery, ice cream, morning goods (for example pastries), puddings, sweet biscuits, breakfast cereals, yoghurts, milk-based drinks with added sugar, juice-based drinks with added sugar, pizza, ready meals, meal centres, including breaded and battered products, crisps and savoury snacks, chips and similar potato products.

The restrictions will apply to medium and large retailers (with 50 or more employees). Exemptions will apply to micro and small businesses (fewer than 50 employees). Exemptions for location restrictions apply to stores that are smaller than 185.8 square metres (even if they are part of a medium or large business with 50+ employees); and specialist retailers that sell one type of food product category, e.g. chocolatiers or sweet shops. Further details on the policy can be found in the consultation outcome [8].

A Post Implementation Review will be required for each of these regulatory policies within 5 years of their implementation dates. This will support the Regulatory Policy Committee in reviewing the regulations and whether they should be retained. In addition, there is a legal requirement under the Regulatory Enforcement and Sanctions Act to review enforcement practices, specifically the use of fixed penalty notices. This research will contribute to the review process by providing robust evidence.

Research priorities

Research Requirements

Research is needed to explore the implementation of restrictions on the promotion of HFSS food and drink by location and evaluate the outcome on businesses, individuals and families. Research is needed to provide pre-implementation data before the restrictions on volume price promotions are introduced. A mixed method approach will be appropriate. Data collection and analysis should be appropriate to the intended objectives of the restrictions. Applicants should design a robust project to answer the policy questions set out below.

Further research will be required, following the introduction of the volume price promotion regulations currently planned for October 2025, to support the Post Implementation Review of this policy. DHSC and the NIHR will make a decision about commissioning this further phase of the research once the regulations are in place.

DHSC understands that it will not be possible to isolate and assess the independent impact of the regulations to restrict the promotion of HFSS products by location on the prevalence of overweight/obesity in adults and children. We are aware that specific actions or policies aim to contribute to alleviating obesity but won’t be individually responsible for solving it. Applicants should consider a “Theory of Change” which defines indicators of progress and articulates the links through which “attribution” could be considered plausible. Projects should aim to show whether and how the policy has contributed to the Government’s aim of reducing overweight and obesity and supporting people to choose a healthier diet.

Applicants should show awareness of the difficulties in engaging stores in research and should explain how they will overcome these difficulties.

Retailer practices – retail promotional environments

Research is required to understand how the current retail promotional environment supports consumers to make healthier choices. We would like to know how stores use locations and volume price offers to promote HFSS and non-HFSS products. This might include how stores use layout, fixed shelving, temporary promotional bins or stands and visual cues such as banners or shelf signage, as well as price promotion offers such as ‘buy one get one free’.

The research should identify and provide examples of any positive or negative features and innovations in the promotion of HFSS and non-HFSS food, or other products. The research should take place across stores of different types and sizes. The research should highlight any negative unintended consequences of the regulations. Possible examples include the use of locations restricted for HFSS products for unhealthy non-food products such as alcohol or vaping products. We would like to know how stores combine location and price-promotions for HFSS and non-HFSS products.

This research is expected to take place before the planned introduction of the volume-price regulations. Therefore, the research should provide baseline data on how consumers are exposed to price promotions in store.

Retailers’ views and responses to the promotion restrictions

The research should seek to establish the experiences and views of a range of food retailers on the restrictions on promotions of HFSS foods. We are particularly interested in: whether the impact on retailers differs across different types of businesses; the costs for businesses of implementation; and, whether guidance and implementation support has helped ensure full implementation of the policies. For example, we are interested to know:

  • The differences in retailers’ corporate stance/strategy in relation to improving healthier sales and the extent to which they are aligned with the regulations;
  • The experiences of implementing the location regulations and how these differ across different retailer types. We would like to know what has been difficult and what has gone well, how helpful the guidance was, and what preparations are they making for the introduction of the volume-price regulations;
  • How the regulations are being implemented across the company (for example have they been implemented nationally or only in England, and is there variation across local stores);
  • How much it has cost stores to implement the regulations, including which aspects of implementation have been most costly and whether any implementation costs are ongoing;
  • What contact they have had with enforcement agencies in relation to the restrictions and has this been positive or negative? Have they experienced any consumer complaints or investigations by enforcement agencies? Have they had any penalties imposed due to breaches of the regulations? Do they perceive that there has been a level playing field in terms of implementation and enforcement of the restrictions?;
  • The extent to which the regulations have stimulated reformulation and introduction of new HFSS-compliant healthier own-brand products;
  • How the introduction of the regulations has impacted on relationships with manufacturers and suppliers;
  • What retailers’ own data and insights indicate about the impact of the location regulations on consumers (e.g. through retailers’ sales data and customer satisfaction data);
  • How the cost of living crisis has impacted on implementation and outcomes.

Consumer perspectives

The research should explore customers’ experiences of food shopping since the introduction of the location promotion restrictions and before the introduction of the volume-price promotions. We are interested in collecting survey data that will help us understand how consumers relate to promotional practices in food stores and how this might change over time and after the introduction of the volume-price promotions. We are particularly interested in:

  • What importance consumers attach to purchasing healthy food in relation to other factors (such as price or convenience), how this is reflected in shopping behaviours (e.g. where and how they shop), and if consumers look at nutritional labelling or ingredients lists on food products and how they use these;
  • In relation to less healthy products, how aware are customers of promotions, campaigns and marketing practices deployed by stores, including the use of layout and locations within stores. What are their views of these? and do they believe that these influence their shopping? Do customers experience pester power from children in relation to less healthy products?
  • How customers view price promotions (including price reductions, loyalty card prices and other price-related offers). This includes how often customers take advantage of these offers, and if they buy more than they need as a result of an offer, do they end up consuming the additional product before the next shop or do they store it until it’s needed;
  • To what extent consumers are aware of reformulation and their experience of purchasing reformulated or healthier products.

Policymakers are keen to capture the perceptions of a cross-section of the population with the opportunity to establish whether there are differences in the responses given by people from minority ethnic groups, different household types, different geographical locations (i.e. rural, urban and coastal locations) deprivation, socio-economic status and different shopping behaviours (e.g. shopping to a list or browsing).

Additional qualitative research that will explore these differences in more depth would be helpful but is considered optional and should only be offered if budgets allow.


The research should establish how the regulations on promotions have been enforced across England. We are interested in understanding the scale and nature of activity as well as understanding whether enforcement has been adequate to ensure that consumers benefit from the regulations. In particular, there is a need for specific data on the extent to which enforcement agencies have used the provision for issuing fixed penalty notices. Questions could include:

  • How is enforcement for this policy organised and resourced and what are the costs of the provision of enforcement?
  • Are enforcement agencies taking a proactive or reactive approach to enforcing the restrictions?
  • What are the experiences of enforcement agencies in relation to:
    • how many complaints have been made?
    • what aspects of the regulation trigger the most complaints?
    • how easy have the regulations been to enforce?


The research should assess how the promotions regulations have impacted on the scale and pace
that retailers and manufacturers have:

  • reformulated existing food products to achieve a healthier nutrient profile;
  • introduced new, healthier products within the food categories in scope of the regulations.

We are interested in trends originating from prior to the introduction of the regulations. For example:

  • How many new/reformulated products are brought to market and in which categories?
  • What are the characteristics of new/reformulated products introduced over this time period in terms of their nutritional characteristics and compliance with the NPM score threshold?
  • How does reformulation/introduction of HFSS compliant products affect the product portfolios of large manufacturers/retailers?
  • How does this activity vary by food category and for businesses of different sizes and in the context of wider market trends (e.g. new market trends such as the growth in plant-based foods and the cost of living crisis)?
  • What have been the experiences of manufacturers and retailers of the technical aspects of reformulating products to achieve scores below the NPM threshold as well as consumer responses to HFSS compliant products and how has this shaped future thinking?
  • Has the NPM score mechanism created opportunities for companies to ‘game’ the system to produce HFSS compliant products with unhealthy characteristics?

Areas out of scope for this programme of work

Any work targeting promotions in the Out of Home (OOH) sector are out of scope for this programme of work.

Micro and small businesses and specialist retailers are out of scope for this programme of work as they are exempt from the location restrictions.


Eligibility for the NIHR PRP is laid out in our Standard Information for Applicants and applies to all calls unless otherwise stated in the individual research specification.

Expertise required

The work will require expertise in:

  • mixed-methods research;
  • policy evaluation research;
  • conducting research in food retail environments. Applicants should show awareness of the difficulties in engaging stores in research and should explain how they will overcome these difficulties;
  • understanding healthy weight food policy, particularly the restrictions on the promotion of HFSS food and drink by location and volume-price.


Outputs should include:

  • interim reports and updates as agreed at project scoping;
  • draft publishable report and final publishable report, with executive and lay summary in a form suitable for policy colleagues in a 1:3:25 format;
  • and a presentation of findings to DHSC colleagues and key stakeholders.

The successful applicant will produce a final report, fully accessible to policymakers and members of the public and circulate to DHSC. When the study is complete, the successful applicants will place a final report summary on the NIHR Policy Research Programme website, where outputs resulting from public expenditure are available for public scrutiny. It is important the final report summaries are easily accessible to lay readers.

Applicants are asked to consider the timing and nature of deliverables in their proposals. Policymakers will need research evidence to meet key policy decisions and timescales, so resource needs to be flexible to meet these needs. A meeting to discuss policy needs with DHSC officials will be convened as a matter of priority following contracting.

Budget and duration

Funding of £650,000 to £700,000 is available for this research. Costings can include up to 100% full economic costing (FEC) but should exclude output VAT. Applicants are advised that value for money is one of the key criteria that peer reviewers and commissioning panel members will assess applications against.

We expect research projects to be completed within 30 months of contracting.
Costings can include up to 100% full economic costing (FEC) but should exclude output VAT. Applicants are advised that value for money is one of the key criteria that peer reviewers and commissioning panel members will assess applications against.

Management arrangements

A research advisory group including, but not limited to, representatives of DHSC, other stakeholders, and the successful applicants for the research should be established. The advisory group will provide guidance, meeting regularly over the lifetime of the research. The successful applicants should be prepared to review research objectives with the advisory group, and to share emerging findings on an ongoing basis. They will be expected to:

  • Provide regular feedback on progress
  • Produce timely reports to the advisory group
  • Produce a final report for sign off

Research contractors will be expected to work with nominated officials in DHSC, its partners and the NIHR Central Commissioning Facility. Key documents including, for example, research protocols, research instruments, reports and publications must be provided to DHSC in draft form allowing sufficient time for review.

Guidance on Health and Care Inequalities and associate data collection within NIHR PRP Research

Health and care Inequalities is a high priority area within the Department of Health and Social Care and the NIHR and is often present in a majority of funded projects.We are now assessing all NIHR research proposals in relation to health inequalities. We ask that you please clearly identify in the research plan section of the application whether your application has an inequalities component or theme as well as how this research hopes to impact inequalities or not. Please also detail the core set of inequality breakdown data that will be collected, if applicable. More information on this request can be found in the Standard information for applicants.

References and key documents