Updated: February 2026
TV and Online Advertising Ban
As of 5 January 2026, the UK’s HFSS advertising restrictions are now legally in force. The rules prohibit advertising for products classified as high in fat, salt or sugar (HFSS):
- On TV before the 9pm watershed
- Across paid online advertising, including social media, display advertising, video, and paid search
This final element of the HFSS restrictions is designed to reduce population exposure, particularly among children, to HFSS food advertising. The specific focus on digital marketing reflects the highly targeted nature of these environments, which are more difficult to regulate using time-based controls alone.
Importantly, the ban applies regardless of whether advertising is explicitly targeted at children. This represents a notable shift from earlier regulatory approaches, moving instead towards a blanket restriction on paid online HFSS advertising.
The food industry finds itself in an uncertain position. The HFSS legislation’s latest restriction on volume promotion is now legally enforceable, yet the government has simultaneously signalled its intention to repeal these very rules earlier this year. For food manufacturers, this creates a challenging question: how do you plan for compliance when the regulatory ground keeps shifting?
Start your reformulation journey by assessing your products with our free HFSS calculator.
Early Observations from the Market
Although enforcement is still in its early stages, the first month has already revealed several practical implications for food manufacturers and brand owners.
Analysis from Ebiquity suggests that media owners and advertising platforms are interpreting the HFSS advertising rules conservatively. In practice, this has led to:
- More rigorous pre-clearance processes for advertising campaigns
- Greater scrutiny of HFSS classification before media spend is approved
- Reduced willingness from platforms to accept campaigns where HFSS status is unclear or close to the compliance threshold
This cautious approach appears to be driven not only by regulation but also by risk management, as platforms seek to avoid post-launch compliance issues.
How Are Brands Adapting Their Advertising Strategies?
In response, manufacturers and brand owners are adjusting both how (and what) they promote.
Firstly, the ban applies to products, not companies. Brand-level advertising remains permitted, provided it does not feature or promote specific HFSS products. As a result, some manufacturers are shifting towards brand-building campaigns that focus on values, provenance, or corporate messaging rather than individual SKUs.
Secondly, non-HFSS products remain fully promotable. This is accelerating efforts to diversify product ranges and prioritise reformulated or inherently compliant products within marketing plans. For manufacturers with mixed portfolios, advertising spend is increasingly being directed towards non-HFSS lines that retain full access to paid digital and pre-9pm TV channels.
Thirdly, not all channels are affected by the ban. HFSS advertising restrictions do not apply to out-of-home and audio advertising, print media, or organic digital activity. As a result, many brands are actively re-evaluating their media mix, redistributing budgets towards unaffected channels while reassessing the role of paid digital advertising within HFSS-constrained portfolios.
Nutrient Profiling Model Update (2018 Review)
Updated technical guidance for the Nutrient Profiling Model (NPM) was released on 27 January 2026. While HFSS compliance continues to be assessed using the 2004 Nutrient Profiling Model, the updated guidance provides valuable insight into how future policy may evolve.
The original NPM was developed over two decades ago, and since then, there have been significant advances in nutritional science. The 2018 review aims to modernise the framework, shifting the focus away from isolated nutrients and towards overall dietary quality. The update also aligns the NPM more closely with the Eatwell Guide, first published in 2016 as a replacement for the original Eatwell Plate.
What Are the Key Differences?
- Total sugars have been replaced with free sugars, reflecting stronger evidence linking free sugar consumption to adverse health outcomes
- Sodium has been replaced with salt, aligning the model more closely with how nutrition is declared and communicated in the UK
- Thresholds for “A” (negative) points have been lowered, while “C” (positive) point thresholds have increased
- Seeds are now included alongside nuts within the fruit, vegetable, nut and seed (FVNS) component, recognising their comparable nutritional composition
- Fibre must now be calculated using the AOAC method only, including resistant starch and lignin alongside non-starch polysaccharides
- Starchy carbohydrates, including tubers, are explicitly excluded from FVNS
- Fibre points have increased to a maximum of 10, up from 5 previously, while protein and FVNS remain capped at 5 points each
Together, these changes signal a stronger policy emphasis on fibre and overall nutritional balance as key contributors to healthier diets.
What Does This Mean in Practice?
It is critical to note that current HFSS regulations remain based on the 2004 NPM, meaning compliance thresholds have not changed. However, the updated model offers a strong indication of how health-focused regulation may evolve. Rather than rewarding narrow reformulation strategies focused on single nutrient reduction, the updated framework places greater emphasis on overall nutritional balance. This reinforces the importance of comprehensive reformulation strategies that combine the reduction of negative nutrients with the meaningful addition of positive nutritional value.
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Written: October 29th 2025
The Current State of HFSS Legislation 2025
As of the 1st of October 2025, volume price promotion restrictions on products high in fat, salt, or sugar are now in force across England, as outlined in the official government guidance on HFSS promotions and placement. This means retailers with 50 or more employees can no longer offer:
- Buy-one-get-one-free (BOGOF) deals on HFSS products
- Multi-buy promotions (e.g., ‘3 for £10’)
- Promotional offers indicating a product is free (e.g., ‘50% extra free’)
These restrictions sit alongside the location restrictions introduced in October 2022, which already banned HFSS products from prominent in-store positions like checkouts and aisle ends.
Meanwhile, HFSS advertising restrictions, originally scheduled for the 1st of October 2025, have been delayed until the 5th of January 2026. However, industry stakeholders, including major broadcasters like ITV and Channel 4, along with online platforms and publishers, have voluntarily committed to comply from October onwards, creating a de facto enforcement date even without legal requirement.
Repeal on the Horizon: What Does It Mean for Compliance?
In July 2025, Labour’s 10-year NHS health plan announced the government “expects to be able to repeal legislation restricting volume price promotions and aisle placement” as part of introducing what it calls “smarter regulation.”
Instead of prescriptive bans, the government plans to introduce mandatory reporting requirements for large food businesses, requiring them to disclose the proportion of their sales classified as “healthy.” Targets would then be set to gradually improve the nutritional quality of the average shopping basket, with businesses retaining freedom to decide how to meet these targets, whether through reformulation, new product lines, or layout changes.
The timeline for this repeal is unspecified, and the details of the new system are still being negotiated with the Food Strategy Advisory Board.
This leaves manufacturers in a peculiar limbo: complying with regulations that may soon be repealed, preparing for restrictions that might never fully materialise, and investing in changes that could become irrelevant.
Why HFSS Compliance Still Matters
Despite this uncertainty, there are compelling reasons why focusing on HFSS compliance remains the right strategic choice.
While specific mechanisms may change, the direction of travel is unmistakable. Even if current restrictions are repealed, they will be replaced with outcome-focused regulations requiring businesses to demonstrate healthier product portfolios. The government’s commitment to tackling obesity has not wavered; only the methodology is evolving.
Furthermore, the reformulation work done now will not be wasted. Whether you are meeting current HFSS thresholds or preparing for future mandatory health targets, improving your products’ nutritional profiles positions you advantageously for any regulatory scenario. In like manner, consumer attitudes have fundamentally changed. Public awareness of ultra-processed foods, sugar content, and nutritional quality continues to grow.
