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HFSS Rules Could Be “the Creative Catalyst the Industry Didn’t Know It Needed”

01/10/2025
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New rules on ‘less healthy food' advertising come into play on a voluntary basis in the UK today… but could the rules inadvertently usher in a golden age of brand building? asks LBB’s Laura Swinton Gupta

“Christmas ads without mince pies?!!” says Saatchi & Saatchi’s Caroline Paris in mock horror.

From today, people in the UK should notice a lot less food porn on their screens. Brands will be expected to comply with new regulations about the advertising of ‘less healthy food and drink’  (LHF)on TV and in online spaces. As of today (October 1 2025), adherence to the rules will be on a voluntary basis, but the rules will become legally enforceable from January 5 2026.

Simply put the rules will see restrictions on when and where advertising of HFSS (that’s high fat, sugar and salt) foods can appear. HFSS products can’t be shown on TV and streaming services before 9.30pm, and they can’t appear on paid online advertising (though they can appear on non paid for posts).

The next three months will be a chance for marketers and their agencies to get their heads around the real world implications of the rules. But there could be an unexpected silver lining to all of this. While advertisers are not allowed to show unhealthy products in their ads before the watershed, there is an exemption for brand advertising, as long as the brand isn’t inextricably linked to an unhealthy product. So for those who bemoan a swing away from brand building, we could see a return to a more creative, longer-term and less literal approach to advertising, particularly from the food sector and supermarkets.

The proof of the pudding will be in the eating (a metaphorical pudding, of course, hopefully not breaching any guidelines), but there’s a surprising taste of optimism around…



Chris Camacho, CEO, Cheil UK

This crackdown might just be the creative catalyst the industry didn’t know it needed. Pre-watershed restrictions are forcing FMCG brands to stop shouting about sugar and start saying something meaningful. That’s not a limitation, it’s an opportunity. We’re entering a new era where emotional resonance, cultural relevance and long-term storytelling will matter more than a fleeting product claim.

The brands who already have a clear purpose and point of view will find themselves at an advantage, while others will be forced to rediscover who they are and what they stand for. That’s no bad thing. This could usher in a golden age of brand building, one where the work moves hearts, not just units.

In the end, less airtime for HFSS products doesn’t mean less impact. It means better thinking, bolder ideas and brands that actually matter in people’s lives. Brands should see this as an opportunity, not a barrier.


Claire Haddrill, client partner, senior director, Ogilvy PR Social & Influence


HFSS legislation offers a strategic inflection point for brands. It is challenging brands to be smarter, more authentic, and more creative.


This legislation forces brands out of the comfort zone of paid media and into a space where authentic connection truly thrives. It’s a chance to build lasting relationships with consumers and collectively contribute to a healthier future.


HFSS demands innovation. It’s about telling richer stories and engaging consumers on a deeper, more meaningful level. Smart brands will seize this, not only to demonstrate responsibility and build trust with stakeholders, but to completely reset their communication strategy. This will be the golden age for earned media. There is no better channel to generate organic visibility and build brand credibility.


HFSS shouldn’t just be about compliance; it's about embracing social change to build trust, showcasing creativity, fostering loyalty through meaningful engagement, embracing new platforms and ultimately, outperforming those who simply tick boxes.


Jon Evans, chief customer officer, System1 and host of Uncensored CMO

We’re about to see a revolution in food advertising, but it’s one I’m surprisingly optimistic about. Creativity thrives on limitations, and removing product as the centre of FMCG food ads will push marketers to focus on an even more vital ingredient - brand. Brand building leads to long-term growth and it’s my hope the ban will encourage brands to invest in creative consistency, developing assets and ideas that can work over time.



Look at McDonalds’ ‘Raise Your Arches’ - a great ad which doesn’t show food or restaurants! Or the beautiful slice-of-life ads from Cadbury where the focus is firmly on people and moments not product. Haribo’s hugely popular adults with kids’ voices creative devicedoesn’t need the sweets to work. That’s just three examples of brand-led campaigns that have been massive successes. The transition won’t be easy, but replacing food porn with a lasting brand relationship might be just what FMCG marketing needs.




Caroline Paris, group creative director, Saatchi & Saatchi

HFSS regulations are limiting if we think about reaching audiences in the way we always have. And as we realise the extent of those challenges (Christmas ads without mince pies?!!) we, as creative thinkers, are forced to find the opportunities.

So yes, more brand work will exist in TV, and OOH will drive product reach. But, for me, what feels exciting is the thought that we’re entering a golden age for organic social. A space that will play a pivotal role for brand building and product education.

However, in a world where consumers have to choose to follow your brand on social, the value exchange has to be worth it. This means that creating content people actually want to engage with is a must. Forget trend-jacking and being the 978th brand to replicate what everyone else did yesterday. Social is in its entertainment era and brands will need to start creating their own IP, stepping away from the boundaries of brand guidelines, to create culture-first content consumers actually care about and want to share.



Danny Hunt, creative director, Lucky Generals

It’s the 80’s. Posh guys in pinstripes with names like Henry and Hugo can be seen snivelling into their luncheons all over Soho. The multibillion-pound industry of cigarette advertising has just taken a beating. The new law states you can no longer show people using the product. This is bad news for agencies. How do you advertise something that you can’t show? What will one do?

Then someone has an idea.

Surrealism.

A few D&AD pencils later and we’re left with all these wonderful posters from Silk Cut. And they’re unlike anything anyone has ever seen before. No product. No people. No headline. Just big beautiful surreal visuals. And what was a problem goes on to change the way the industry thinks about posters. Now, I’m not saying getting people to smoke stinky fags was a good thing. Or that posh guys in pinstripe suits are cool. But what I am saying is I’m not worried. Putting a line through what’s been done before is no bad thing. Restrictions just mean you need to think differently. Be more creative. So, let’s do like the old boys did and maybe we can change how things are done too. Minus the suits.

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