BOGOFs (Buy-one-get-one-free). Once synonymous with the supermarket experience, and inspiring a myriad of similar multi-buy type deals. Together with sweets at the checkouts, they rightfully became the twin target of public health efforts in the mid-late 2010s to reduce excess calories in our shopping baskets, and make healthier choices easier. Evidence showed that price promotions were concentrated on less healthy products and had a strong impact on purchasing and consumption behaviour, and so were seen as a priority to address.
Overweight and obesity in adults is linked to at least 13 types of cancer. While this is mainly because a healthy, balanced diet helps to keep a healthy weight, diet can also directly affect cancer risk irrespective of weight loss. We want to see healthier environments created for everyone. Back in 2019 we analysed Kantar data of supermarket sales, producing a report which bolstered the evidence base in support of action. Restricting price promotions was the central ask of our ‘Scale Down Cancer’ campaign in devolved nations, and at Westminster it sat alongside our call for a junk food ad ban. With legislation passed in England in 2022, and commitments made by the Scottish and Welsh Governments, change seemed imminent.
However, politics (and lobbying by parts of the food industry) got in the way. It was only on 1 October 2025 that volume-based price promotions on less healthy food were finally implemented in England – three years after their location-based counterparts, and seven years after being first proposed by the then government. It has taken almost as long to happen in Wales and Scotland, with both sets of promotions restrictions only coming into force this year (on 26 March and 1 October respectively). Northern Ireland will hopefully complete that journey soon too, with similar measures currently being consulted on.
The political headwinds – including rising food prices, wider cost-of-living pressures, and industry demands for less regulation – may not have gone away. But restricting price promotions on less healthy food and drink has become generally accepted, beyond a few industry voices and free market advocates.
As our past research found, people generally intend to make healthier choices when they shop; yet then struggle to do so in practice – with tempting offers on less healthy products being part of the problem. Restricting such promotions has always been backed by the public, albeit at less high levels compared to some of the other policies recently implemented to reduce childhood obesity.
There’s also no credible evidence that such policies negatively affect food prices overall. Indeed, the UK Government’s updated impact assessment highlights that consumers “may experience an increase in consumer surplus” – a technical term for getting better value for money out of their shop. That’s in addition to the £2.7billion net benefits in England over 25 years that the Government estimates will result from the policy’s implementation.
Over the past few years retailers started to make the shift away from volume-based price reductions, partly in expectation of the legislation coming in. Tesco and Sainsbury’s voluntarily implementing the restrictions in 2022 showed that not all parts of industry were opposed, and their experience since has helped give governments confidence to push on. Likewise the successful implementation, positive impact and academic evaluation protocols of location-based restrictions in England. There seems to have been a virtuous circle across the UK: with passage and enactment of legislation in one nation acting as a model for others to follow. This policy alignment across the four nations has likely been appreciated by retailers as much as civil servants: simplifying their processes and keeping their economies of scale.
However, businesses’ ability to adapt and to find creative ways of maximising their profits is a double-edged sword. This past year, we’ve anecdotally seen retailers take advantage of loopholes to continue promoting HFSS products. Some have shifted such promotions to temporary price reductions, meal deals and other marketing tactics which are not covered by the regulations; whilst others have refocused their multi-buy promotions on HFSS products in categories which are not in scope, and/or select sugary or calorific products which would fail the revised Nutrient Profile Model but pass the currently adopted one.
There hasn’t been a post-implementation review or formal evaluation (which there should be), so we can’t yet fully assess industry’s response. The lack of robust monitoring and enforcement – with Trading Standards teams significantly under-resourced – adds to the uncertainty that the full benefits to public health and to families’ pockets are being realised.
Yet there is cause for optimism. The UK Government has consulted on adopting the 2018 Nutrient Profile Model – which is better aligned to scientific evidence on free sugars and fibre intake – as the definition on what is allowed to be promoted. The government response is due shortly: we hope they withstand the heavy lobbying by multinational food manufacturers intended to scupper this move. Governments across the UK should also act on the recommendations of the Health and Social Care Select Committee to strengthen the regulations, including by extending the definition of a prominent location on a website to ‘special offers’ pages, and reviewing enforcement processes and resources. These measures would also help provide greater opportunities to shift promotions onto healthier products.
Ultimately, a comprehensive approach is needed to make healthy food more affordable, accessible and widely marketed than less healthy alternatives. The UK Government has committed to introducing mandatory reporting and targets for all large food businesses. Taking the learnings from the price promotions experience, the Government should now push forwards with confidence with the Healthier Food Standards; starting with launching the consultation before the end of this year.