Consultation on restricting promotions of high fat, sugar and salt foods

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Closes 21 Oct 2026

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Consultation Questions

1. Are you responding on behalf of an organisation?
(Required)
2. If you are responding on behalf of an organisation, please state what type of organisation it is.
(Required)
3. Do you agree that restrictions on the promotion and placement of products high in fat, sugar and salt (HFSS) should be introduced in Northern Ireland?
(Required)
4. Do you agree that a legislative approach should be considered for Northern Ireland similar to England, Scotland and Wales?
(Required)
5. Are there any considerations specific to Northern Ireland that should be taken into account regarding the proposals in this consultation?
6. Do you agree with the proposed product categories that would be subject to HFSS promotion restrictions in Northern Ireland?
(Required)
7. Do you agree that non‑prepacked products should remain out of scope (consistent with England, Wales and Scotland), except for soft drink refills?
(Required)
8. Which approach should be used to determine which products are in scope of restrictions? Option 1) Use the existing 2004/05 Nutrient Profiling Model; Option 2) Use the updated 2018 Nutrient Profiling Model; or Option 3) Use the 2004/05 Nutrient Profiling Model and review at a later date.
(Required)
9. Do you have evidence on the challenges or operational issues businesses may face if the 2018 Nutrient Profiling Model is applied in Northern Ireland, including impacts on product classification?
10. Do you agree with the proposal to restrict multibuy and volume promotions (e.g., “3 for 2”, “BOGOF”, extra‑free offers) for HFSS products in Northern Ireland?
(Required)
11. Do you agree with restricting the placement of HFSS products in the following in-store locations: a) store entrances; b) covered external areas; c) checkouts and queuing areas; and d) aisle ends?
(Required)
12. Do you agree that equivalent restrictions (both volume price and location) should apply to online retail environments (e.g., homepages, pop-ups, checkout pages)?
(Required)
13. Do you agree with prohibiting free refills of sugar sweetened soft drinks in Northern Ireland?
(Required)
14. Do you agree that the volume price and location restrictions should apply only to retailers with 50 or more employees?
(Required)
15. Do you agree that location restrictions should apply only to stores with a relevant floor area of 2,000 square feet or more?
(Required)
16. Should specialist retailers that sell one type of food product e.g. chocolatiers or confectioners, be exempt from location restrictions?
(Required)
17. Do you agree with the proposed exemptions (e.g., micro and small businesses, care homes, educational settings)?
(Required)
18. Do you have evidence on how the proposals may impact small and micro-businesses that may be in scope due to an association with a franchise or symbol group?
19. Do you agree that local councils should be the enforcing authorities for HFSS promotion restrictions in Northern Ireland?
(Required)
20. Which enforcement approach do you consider most appropriate for Northern Ireland, and why? Option 1) Enforcement through improvement notices and criminal prosecution only; or Option 2) Explore the introduction of monetary sanctions as an alternative to criminal prosecution (while progressing the policy initially with the approach outlined in Option 1).
(Required)
21. If local councils were to enforce the policy, what resources do you think would be required to support enforcement?
22. Do you have evidence on any challenges that may affect the ability to enforce the policy in a proportionate and consistent way in Northern Ireland?
23. Do you agree that a lead in period of 12 months is appropriate to allow preparation for implementation of the policy?
(Required)
24. Are there specific operational barriers that should be considered when determining implementation timelines?
25. Do you have evidence on the potential health impacts of the proposed restrictions in Northern Ireland?
26. Do you have evidence on how the proposed restrictions may impact businesses, including compliance costs, operational and supply chain impacts, product reformulation, and competitiveness between larger and smaller retailers?
27. Do you have evidence on the potential impacts of the proposed restrictions on consumers, including impacts on household food budgets, consumer perceptions of fairness and choice, the extent to which promotions influence purchasing behaviour, and whether the restrictions may support healthier default choices for families?
28. What impacts, if any, do you think the proposed policy would have on people on the basis of their: age, sex, race, religion, sexual orientation, pregnancy and maternity, disability, gender reassignment and marriage/civil partnership?
29. Are there population groups or communities who may be disproportionately affected, positively or negatively, by the proposals. Please list below
30. Do you have any additional comments or evidence not covered elsewhere in this consultation?