HFSS Advertising Regulations: What the New Rules Mean for Promotional Marketing

The new HFSS advertising regulations came into force on 5 January, marking a significant shift for brands and marketers working with promotional campaigns. While the changes introduce new considerations, they also present an opportunity for the industry to adapt, innovate and continue delivering responsible, creative marketing.

HFSS Advertising Regulations: What the New Rules Mean for Promotional Marketing

The new HFSS advertising regulations came into force on 5 January, marking a significant shift for brands and marketers working with promotional campaigns. While the changes introduce new considerations, they also present an opportunity for the industry to adapt, innovate and continue delivering responsible, creative marketing.

What the new rules cover

The updated HFSS regulations introduce stricter restrictions on the advertising of foods and drinks high in fat, sugar and salt. From 5 January, advertisements for identifiable less healthy products are restricted on TV and online, with broadcast ads banned before 9:00 pm and paid-for online advertising prohibited at all times.

These rules sit alongside existing UK Advertising Codes, which already limit HFSS marketing that is directed at or likely to appeal to children under 16 — including placement in media where children make up a significant proportion of the audience.

While the details can be complex, the focus is clear: reduce children’s exposure to less healthy food marketing and encourage brands to communicate responsibly.

Understanding the guidance

The Advertising Standards Authority (ASA) — working with CAP and BCAP, has issued guidance to help advertisers interpret how the new restrictions apply in practice. A key point is the concept of identifiability: if an HFSS product can reasonably be identified in an ad, the restrictions will apply.

The guidance also helps distinguish between product advertising (which may be restricted) and brand advertising (which can generally continue, provided no specific less healthy product is identifiable).

These interpretations are not rigid legal tests but are intended to support a consistent understanding of the rules and how they should be applied across different media.

“Regulatory change will always create complexity, but it also creates space for innovation. The key is understanding the rules clearly and using them as a framework for smarter ideas — not a barrier to them.”

Samuel Winterbourne

The IPM is here to help

To help marketers navigate these changes with confidence, the IPM has developed a nutritional profiling tool designed to support early decision-making and campaign planning. The tool enables brands and agencies to assess whether products fall within the HFSS restrictions, helping identify potential risks before activity goes live and reducing the likelihood of costly rework or non-compliance.

Alongside this, the IPM’s Legal Advisory Service is on hand to provide practical, industry-specific guidance. The service is available to both members and non-members; however, IPM members benefit from preferential rates, with a number of free advisory cases included each year, depending on membership level. This ensures members can access expert regulatory support quickly and cost-effectively as part of their wider membership benefits.

Whether you’re planning a new campaign or reviewing existing activity, the IPM is here to support you every step of the way.

What the new rules cover

The updated HFSS regulations introduce stricter restrictions on the advertising of foods and drinks high in fat, sugar and salt. From 5 January, advertisements for identifiable less healthy products are restricted on TV and online, with broadcast ads banned before 9:00 pm and paid-for online advertising prohibited at all times.

These rules sit alongside existing UK Advertising Codes, which already limit HFSS marketing that is directed at or likely to appeal to children under 16 — including placement in media where children make up a significant proportion of the audience.

While the details can be complex, the focus is clear: reduce children’s exposure to less healthy food marketing and encourage brands to communicate responsibly.

Understanding the guidance

The Advertising Standards Authority (ASA) — working with CAP and BCAP, has issued guidance to help advertisers interpret how the new restrictions apply in practice. A key point is the concept of identifiability: if an HFSS product can reasonably be identified in an ad, the restrictions will apply.

The guidance also helps distinguish between product advertising (which may be restricted) and brand advertising (which can generally continue, provided no specific less healthy product is identifiable).

These interpretations are not rigid legal tests but are intended to support a consistent understanding of the rules and how they should be applied across different media.

“Regulatory change will always create complexity, but it also creates space for innovation. The key is understanding the rules clearly and using them as a framework for smarter ideas — not a barrier to them.”

Samuel Winterbourne

The IPM is here to help

To help marketers navigate these changes with confidence, the IPM has developed a nutritional profiling tool designed to support early decision-making and campaign planning. The tool enables brands and agencies to assess whether products fall within the HFSS restrictions, helping identify potential risks before activity goes live and reducing the likelihood of costly rework or non-compliance.

Alongside this, the IPM’s Legal Advisory Service is on hand to provide practical, industry-specific guidance. The service is available to both members and non-members; however, IPM members benefit from preferential rates, with a number of free advisory cases included each year, depending on membership level. This ensures members can access expert regulatory support quickly and cost-effectively as part of their wider membership benefits.

Whether you’re planning a new campaign or reviewing existing activity, the IPM is here to support you every step of the way.

Become an IPM Member

IPM membership connects you to expert guidance, industry insight and a powerful professional network. From regulatory support to best-practice resources, becoming a member helps you stay informed, compliant and ahead in promotional marketing.

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