How CPG brands can prepare for HFSS regulations with UK-based retail partners

The UK Government’s proposed introduction of new legislation targeting high fat, salt and sugar (HFSS) products is set to become law in October 2022.  If implemented in its current form, the legislation has significant implications on many brands and retailers. The scope will limit promotional activity and in-store merchandising locations for several categories such as soft drinks, confectionery, breakfast cereals, treats, beverages, crisps and snacks as well as pizzas and ready meals. (Full details on the proposals can be found here.)

In anticipation of HFSS legislation many leading retailers and brands have begun adjusting in-store and promotional plans.  We have seen some retailers test new store merchandising concepts, which provide good insight to the likely strategy most retailers will adopt to comply.

 This article provides an overview of some key implications of HFSS regulations as it affects in-store activities and retailer collaboration; offers guidance for how brands can correct their category plans accordingly and work with retail partners to ensure compliance and continue to support growth objectives. 

Our guidance will cover the following:

1. Scenario plan assortment changes to the main fixture
2. Estimate where demand will flow with adjacent categories or main fixtures
3. Create assortment recommendations focused on replenishment and on-shelf availability
4. New store activations for gondola ends and key seasonal events
5. Ensure the brand portfolio is optimised for HFSS or identify new opportunities
6. Create compelling insights and recommendation to retail partners

HFSS legislation implications

The legislation as drafted includes many products deemed HFSS under the UK Food Standards Agency’s Nutrient Profiling criteria. Historically, these categories have often been heavily promoted in terms of store location (gondola end, front of store, impulse) as well as promoted with price and volume driver deals. Under the new rules, neither of these will be permitted.

Stores over 2,000 square feet or with 50 employees will be subject to the measures, so all major multiples will have to comply. The expectation is that a six-month grace period to implement the changes (due from October 2022) will be allowed. This means now is the time brands should be coming together with retail partners to discuss next steps.

The central category strategy questions that arise for both retailer and brand will be:

• Where will volume flow (lost or transfer to main category aisle)?
• What will be the replenishment considerations for those impacted categories (change space, rationalise SKU or facings, macro space switching)?
• Will packaging have to change to ease replenishment e.g. with no front of store promotional pallets, should products be smaller on the main space available?
• How will a retailer cost effectively activate key season and promoted occasions that can longer be at front of store or gondola ends?
• Should store macro layout fundamentally change from traditional categories to more of an occasions/needs state, with complimentary categories located together?
• How to optimise the space in the checkout zone, a traditional location for many HFSS impulse products. COVID-19 has profoundly influenced how UK shoppers queue, and this will be the case for some time. However, the checkout area will remain a key impulse zone.

How can brands prepare and help win retailer influence with category strategy

1. Scenario plan assortment changes to the main fixture

Think how main fixture space could be utilised given some possible scenarios: products from secondary fixtures move to the main aisle; should space be made available for new SKUs, and what happens to the current space (facings)? What if we started from a blank fixture?

In many scenarios, understanding transferable demand (switching) behaviour between products by shoppers will be essential. We would advocate an incrementality-based model, utilising shopper behaviour metrics. Alternative scenarios will apply for each retailer, channel and category and, as the HFSS regulation impact is better understood, scenario planning that is flexible and dynamic will be essential.

2. Estimate where demand will flow with adjacent categories or main fixtures

It seems highly likely that retailers will not simply use existing category space. They may well evolve the space allocation for volume driver categories. The loss of promo volumes on certain categories may not easily flow to newly promoted categories. Retailers may consider expanding or reducing categories in line with volume and replenishment drivers. Being able to quantify and model the impact of flow across categories can be achieved by using macro space analysis of sales, together with shopper decision structures and hierarchies.

3. Create assortment recommendations focused on replenishment and on shelf availability

In the early phases of HFSS regulations implementation, retailers will probably focus on strategies to maintain volumes and support efficient in-store replenishment, avoiding risks of out-of-stock situations. Often seasonal (Easter, Christmas, Valentine’s Day) and highly promoted categories (soft drinks, beers) drive promotional volume through front of store, FSDU and gondola ends. If these are removed or reallocated, these products – often big-box, high-volume with minimal replenishment demands (pallet in/out) – will need replacing somehow.

Retailers will be looking for recommendations that can counter these constraints in the main fixture. Building assortment recommendations that account for pack size, shippers, sell and fill rates to avoid on-shelf availability (OSA) issues will be well received. This could be a combination of current space utilisation, complementary categories (occasions) or innovative pack redesigns. Range rationalisation will likely be a feature of a retailer’s approach to OSA and brands should have prepared category recommendations to offer or counter.

4. New store activations for gondola ends and key seasonal events

We have seen retailers like Tesco and Sainsbury test new merchandising approaches, changing the use of gondola ends to HFSS compliant offers or re-thinking the space. Having flexible approaches to activation that can be easily ‘wheeled in and out’ even in the main aisle is likely to be a feature. Key seasonal events drive volume and these categories will remain, likely just in a different location. 

Brands should be able to bring insights and visually compelling sell-in stories to retailers of how a new activation can be delivered in store, efficiently, flexible and drive volume. Rapid test and learn approaches are more likely to get retailer traction as best practise develops.

5. Ensure the brand portfolio is optimised for HFSS or identify new opportunities

For certain categories and products, the Nutrient Profiling criteria will make it impossible to reformulate the product without losing its purpose and appeal. Chocolate is an indulgent treat/gift/occasion category and will remain so. With HFSS bringing in promotional limitations on the category, there may now be new opportunities to consider complementary products and/or categories that can be promoted as an occasion e.g. chocolate and fruit combinations, gifting etc.

For categories that have come under the HFSS remit during its draft stages, like pizza, ready meals and yoghurts, product reformulation opportunities should be explored where feasible. It may be more appropriate to consider the facings afforded to products that are not HFSS-compliant. The development of assortment recommendations that factor in nutritional values and demand occasions are achievable with modern advanced analytics assortment tools.

6. Create compelling insights and recommendations for retail partners

Retailers and brands alike are facing new challenges and uncertainties to which both must quickly adapt. No one party has all the answers and this opens up a significant opportunity for brands to bring new perspectives and insights to their retail partners. 

Retailers will initially be focused on recommendations that will drive anticipated lost volume with minimal supply chain and store operations implications. It is quite possible retailers could take the opportunity to pause traditional range review calendars, joint business planning and top-to-top conversations while they focus on HFSS compliance. Right now, brands should be developing scenario plans that can be easily translated in retail execution. The imperative is to get ahead of the curve before the legislation is finalised