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The HFSS opportunity: The power of packaging in an age of restriction

Callum Sanders, ZEAL

This October, regulations on high-fat, salt and sugar foods are set to come into force restricting these products’ promotion radically.

Callum Saunders, Planning Director at ZEAL Creative, says that packaging will be the controllable giving marketers leverage once the regulations arrive.


Almost half of businesses feel unprepared for the implementation of HFSS legislation, which limits promotion of products high in fat, salt and sugar.

This is hardly surprising, given the ongoing lack of clarity – but the long-touted restrictions are now a matter of mere months away, and marketers need to control the elements that stay within their sphere of influence.

Location restrictions, a TV watershed and an outright ban on all paid digital advertising are all designed to restrict external marketing activity, yet packaging remains an intrinsic and even more critical controllable in an uncharted HFSS landscape.

So how can marketers leverage it to its full, post-HFSS potential?

Category visibility and navigation

For decades now, HFSS brands have used off-shelf and additional siting to place themselves in front of shoppers, but restriction to respective categories and permanent siting makes the aisle the new battleground for brands.

The harder it is for a shopper to find your brand, the easier it is for them to select a competitor brand or another product that’s part of their repertoire. Standing out on-shelf is more vital than ever.

Are your distinctive assets punching through hard enough? Is your packaging in need of a redesign? Is there a conversation with category teams, buyers and space planners to start brand blocking or re-merchandising?

In an age of restriction, your packaging is a permissible media space and, for larger sized products such as cereal, a really big piece of owned media estate: Navigating shoppers and ensuring that you are seen in your respective categories is more critical than ever.

Digital equity and experiences

Packaging doesn’t just house physical products; it can wrap up innovative digital experiences. Paid-for digital activity may be restricted, but owned media, content and platforms remain permissible and packaging offers a viable gateway to drive traffic and engagement.

On the one hand, this could be as simple as driving digital traffic through a written URL or a QR code. This could be a deeper engagement delivered through AR – think digital games or quizzes for products consumed in social settings like crisps and beer. It could bring brand purpose to life through videos or deeper storytelling through immersive digital content. The possibilities are endless.

It’s easy to get drawn into a discussion around metrics and engagement numbers here, all of which would vary wildly – a rich experience delivered on a premium spirits brand may prove more engaging than a URL on a commodity product, for instance.

In essence, marketers must shift the way they think about packaging: Test-and-learns will be critical in the new landscape.

Packaging as a gateway to shopper data

With opt-in communication and owned platform permissibility, shopper data has become a currency that HFSS brands need to trade in. Your packaging becomes an evergreen touchpoint, which can help customer marketing databases and support direct shopper communication.

Smart brands have been making concerted efforts to collect shopper data over the past few years – Coca-Cola’s continued push of D2C offerings and digital couponing and sampling is a perfect case in point.

Your packaging can effectively invite shoppers to exchange their data with you, but the exchange must be value-driven.

Access to exclusives? Early bird news? New product samples? Incentivising this value exchange will all depend on your brand, category and marketing strategies.

Fundamentally, all marketers should view their packaging as a brand touchpoint that lives on retailers’ shelves and insider shoppers’ homes, and as such offers an always-on opportunity to glean opt-in shopper data for direct marketing purposes.

On-pack value and the race for ‘new space’

We can see how retailers are responding to incoming restrictions through the new ‘hotspots’ and feature zones that are being trialled within different stores. Packaging becomes a key tool in helping HFSS brands to unlock that space and achieve incremental space within the category itself.

The role of on-pack promotions and partnerships have always been critical in helping to unlock feature and display and that remains paramount in the HFSS landscape. It’s just the types of feature and display that will be different.

On-pack promotional activity should be a key strategic tactic for brands, not just as we enter an era of legislative restriction, but also as we face an economic epidemic.

Squeezed living costs have always stimulated the ‘lipstick effect’ and the truth is that HFSS products always do well in these market conditions as they offer moments of affordable indulgence and enjoyment. Using on-pack promotions to unlock space and add value to shoppers will be really important in 2023 and beyond.

Limited editions, scarcity and word of mouth

Lastly, packaging also offers consumers and shoppers a social currency that supports brands when their own social engagement will be restricted. If you can’t pay to talk to new shoppers about your products, then packaging can be a key tool in stimulating shoppers to talk about you themselves.

As humans, we’re psychologically disposed to value what is rare and this scarcity bias compels shoppers to take action. Limited editions and exclusives not only drive engagement and action, but they also generate organic social sharing, word of mouth and press coverage.

Limited edition packaging offers a vehicle to get people talking about brands with each other – an invaluable tool in an age where digital advertising and sponsorship is limited.

Maximising the power of your packaging

One of the biggest HFSS frustrations for marketers, brands and agencies has been the ongoing lack of clarity and detail, with huge voids in knowledge and policy remaining. But HFSS is coming and inertia is not an option.

There are many different tools, tactics and approaches marketers need to work through as we transition into this new environment.

But packaging remains a powerful and controllable touchpoint that is restriction-free. Using it to its full potential is no longer a ‘nice to have’, but a strategic imperative to ensure that restrictions don’t restrict you from shoppers’ baskets.

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