Key takeaways:
- From January 2026, HFSS promoting bans sharply restrict the place bakery and snack manufacturers can promote much less wholesome merchandise, notably throughout TV and paid digital media.
- Model-only messaging, owned channels and retail media have gotten vital as appetite-led product promoting disappears from many high-impact areas.
- The restrictions are pushing producers to rethink product combine, reformulation and inventive technique on the similar time, not as separate choices.
January 5, 2026 has been hanging over the trade for a very long time. This morning, it stops being theoretical. From in the present day, the UK’s restrictions on promoting meals excessive in fats, salt or sugar are totally enforceable – and for bakery and snack producers, the implications go effectively past pulling just a few advertisements.
The coverage intention hasn’t modified: To cut back publicity to promoting for much less wholesome meals, notably the place kids are prone to see it. What has modified is the business actuality. Classes constructed on familiarity, indulgence and repetition – from desserts and cookies (biscuits) to potato chips (crisps), bars and candy snacks – now face laborious limits on the place they will present up, even when demand stays sturdy.
Most giant producers have already adjusted course. Since October, voluntary compliance has stripped HFSS-heavy campaigns out of TV schedules and digital plans. Artistic has been reworked, media buys reshuffled, launches delayed or softened. However till now, there was nonetheless a way of transition. From in the present day, there isn’t.
For bakery and snack manufacturers alike, this lands awkwardly. Lots of the sector’s best-selling merchandise have been by no means designed to be marketed quietly. Visible attraction, familiarity and impulse have at all times carried out the heavy lifting. Now, in most of the simplest channels, that attraction can’t be proven in any respect.
What’s now off-limits
The sharpest change is on-line. From in the present day, paid-for digital promoting for identifiable much less wholesome foods and drinks merchandise is banned within the UK. Social media advertisements, paid search, show, on-line video, influencer exercise the place fee is concerned – all are caught if the product falls in scope. That impacts every part from iced cupcakes and chocolate cookies to flavored potato chips and confectionery-style snacks.
TV stays obtainable, however solely simply. HFSS promoting is now restricted to post-9pm on UK broadcast and controlled on-demand companies. For manufacturers that relied on daytime and early night slots to drive attain, frequency and seasonal momentum, that’s a significant lack of scale.
Whether or not a product is restricted comes all the way down to the nutrient profiling mannequin. Merchandise scoring above the fats, salt or sugar threshold – and sitting in outlined classes – are classed as much less wholesome. That leaves many combined portfolios break up. One SKU can nonetheless be marketed freely, one other successfully silenced, regardless that consumers see them as a part of the identical model household.
Enforcement now sits squarely with the Promoting Requirements Authority, with Ofcom offering statutory backup for broadcast. Early rulings will matter throughout each bakery and snacks. They’ll form how cautious manufacturers really feel they should be and the way a lot artistic danger survives the primary wave of complaints.
The rise of restraint
This isn’t a complete shutdown. Model-only promoting stays allowed, supplied no identifiable HFSS product seems. On paper, that appears like flexibility. In actuality, it’s slim floor for entrepreneurs.
A well-recognized pack define. A particular product form. A background shot shoppers instantly acknowledge – whether or not that’s a croissant silhouette or a ridged potato chip. Any of those could possibly be sufficient to tip an advert into non-compliance. For now, most manufacturers are taking part in it secure as they wait to see how tightly regulators interpret ‘identifiable’.
There are nonetheless channels left standing. Audio-only codecs, similar to radio, sit outdoors the ban and stay related for each impulse snacks and on a regular basis bakery objects. Digital out-of-home stays untouched, holding model presence alive in transport hubs, forecourts, comfort shops and retail media environments. Owned channels – web sites, natural social and CRM – aren’t restricted by the paid on-line guidelines, although current promoting requirements nonetheless apply.
What’s altering quickest is intuition. Bakery and snack advertising has at all times leaned into urge for food. Now, many groups are being pushed towards abstraction – speaking about moments, values, texture, enjoyment or model objective with out displaying the meals itself. That’s unfamiliar territory for classes constructed on visible temptation, and never each model will discover it comfy.
Why this isn’t only a advertising difficulty
The promoting restrictions don’t sit in isolation. They bleed straight into product technique.
Manufacturers with lower-sugar, higher-fiber or portion-controlled traces now have extra room to remain seen in paid media. These with out them might discover development more durable to maintain, no matter underlying demand. Over time, that dynamic is prone to affect reformulation priorities, innovation pipelines and which SKUs get funding.
Retail dynamics are shifting, too. As nationwide promoting choices slim, the highlight strikes additional instore; towards worth, promotions, personal label and retailer-controlled media. For branded suppliers, that places added stress on margins, differentiation and shelf storytelling.
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There’s additionally an uneven edge to the foundations. They apply primarily to bigger companies, leaving smaller producers with better promoting flexibility. That might quietly favor challengers and regional manufacturers on-line, whereas multinationals take up the compliance burden.
All of this flows from laws rooted within the Well being and Care Act 2022, however the penalties are business, not authorized. From in the present day, bakery and snack manufacturers are working in a market the place what they make – and the way they’re allowed to speak about it – are extra tightly linked than ever.
A artistic wake-up name
New analysis suggests the most important problem going through meals manufacturers isn’t regulation – it’s consciousness. The UK’s New Urge for food, a Client Navigator report from dentsu, a world advertising, media and inventive group, discovered that 60% of UK shoppers stay unaware of the brand new promoting restrictions on much less wholesome foods and drinks, regardless of years of trade preparation. As soon as knowledgeable, 67% help the foundations and 74% imagine they are going to encourage more healthy consuming habits.
The analysis highlights rising expectations of manufacturers. 44% of shoppers say manufacturers – not authorities or retailers – ought to take duty for more healthy merchandise, but belief stays fragile. Solely 18% totally belief well being claims made by manufacturers, and practically 1 / 4 say they don’t belief them in any respect. Value is one other barrier, with greater than a 3rd of Gen Z, Millennials and Gen X citing affordability as the most important impediment to consuming higher.
In response to Jessica Tamsedge, UK&I CEO at Dentsu Artistic, shoppers want to manufacturers for management and confidence. “Within the context of Much less Wholesome Meals and Drink (LHFD) regulation, that is about making more healthy decisions really feel rewarding, not restrictive. Reformulation is anticipated, however creativity sells it. The manufacturers that act rapidly and collapse the false dichotomy between well being and style will set the usual for the following chapter of meals advertising.”
Whereas the trade usually refers to HFSS, LHFD is the authorized time period used within the regulation and by enforcement our bodies. Each depend on the identical nutrient profiling mannequin, however the wording issues in terms of compliance and interpretation.
