2025 HFSS Ad Ban: What it Means for Advertisers

“Junk food” brands have a monumental challenge in 2025 – navigating the waters of new legislation enforced by law in the UK.

What is HFSS Legislation?

HFSS stands for High in Fat, Salt and Sugar.

The UK’s High Fat, Sugar and Salt (HFSS) legislation aims to restrict the promotion and advertising of less healthy food and drink products, particularly those high in fat, sugar, and salt.

This article covers every angle of the recent announcements to be enforced starting in October.

We’ll also share direct, tangible advice for brands to diversify their search approach.

 

What products are classified as HFSS?

The short and sweet:

Under the new legislation, significant changes are on the horizon, but only for large businesses with more than 250 employees.

1. HFSS ads banned on TV before 9 pm (from 1 Oct 2025).
2. All paid ads for affected products to be banned under HFSS legislation 24/7 (includes search, display, social, and influencer).
3. Only large businesses (250+ staff) are affected.
4. B2B wholesalers are impacted if promoting HFSS products to the public.
5. Internal comms and B2B trade ads are not affected.
6. Brand-only ads may be allowed, but ASA guidance is still evolving.
7. Owned content (e.g. websites, organic posts) remains unrestricted.
8. Radio, podcasts, OOH, and direct mail are exempt.
9. Responsibility for breaches:
   1. TV = broadcaster.
   2. Online = advertiser (incl. agencies & affiliates).
10. Enforced by ASA (online) and Ofcom (TV).
11. Non-compliance risks: public rulings, takedowns, fines.
12. Brands shifting to SEO, PR, reformulated products, and brand-led ads.

The implications of HFFS legislation in search marketing

SEO/ Search

1. SEO search will be largely unaffected but may become more competitive as more larger brands battle it out on SERPs, shifting their budgets to organic visibility due to the ban on HFSS paid ads.
2. ’SERPs will be the new online battleground for brands impacted by the legislation.

Paid Media

1. HFFS banned for brands marketing to the public, provided they have a staff headcount of more than 250.
2. Paid media advertisement is not banned for b2b businesses, so long as they’re not targeting the public.

Brands with sub-250 staff will be affected, and responsibility will lie with search platforms to enforce new rules. It wouldn’t be surprising if Google and Meta enforced a blanket across all HFFS brand ad accounts.

Digital PR

1. Paid-for affiliate links will be banned.
2. Earned organic links are allowed, which will be a key driver for brand growth and search visibility.

 

What our Head of SEO says:

“With paid ads off the table, brands must lean into SEO as a powerful alternative to help maintain visibility and engagement without breaching new regulations. This can be achieved through clear ingredient-rich product pages, educational content that answers nutrition queries, and user-generated reviews that build confidence in your brand. This shift drives sustainable traffic and creates trust and authority in an increasingly conscious consumer landscape.”

 

Dave Ryan, Head of SEO, has 14 years of experience in search.

 

What our Head of Digital PR says:

“With the latest regulations announcement, it’s crucial for brands to build awareness with their audience. This can be through promotional content, but also through authentic storytelling. Share your brand values, create engaging news stories that capture attention, and demonstrate real impact to earn trust.

By combining PR, content, and strategic partnerships, you can raise your profile, build credibility, and establish connections with your audience while driving backlinks to boost site visibility, increase traffic and strengthen authority.”

Alana Mustill, Head of Digital PR, 10+ years in PR

 

Which brands will lose from the new legislation?

If we’re talking about the brands affected by the legislation, it’s any that have become too reliant on the allure of healthy ROAS in paid media.

Paid media has been a staple model for propelling growth at an efficient cost since its inception. Business owners love it because of a studious £X in £X out thinking.

The time of only thinking like this is at its sunset for HFFS. Brands & marketing leaders who can only operate in this mindset will crash and burn.

 

Which brands will win from the new legislation?

Those with the guts and, unfortunately, the cash flow to invest in organic brand visibility in the long term.

Wins in year one of investing in search can sometimes be nominal; we advise clients to take at least a two-year view of search. The two-year time horizon is typically where we see the fruits of labour and profits surge.

So, who will be the winners? I’m casting my eye on the logos already at the top of the market. They’ll already be investing lofty sums into paid media campaigns; these budgets will be shifted to growing SERP visibility and brand reach – (the latter through earned Digital PR).

However, smaller logos in the space still have room for success. They’ll be forced to make their organic marketing spend work harder.

 

What would my go-to SEO tactics would be if I were in the affected HFFS bracket?

1. Search hard for the high opportunity, low-competition SERP real estate.
2. Be the first to stock emerging products.
3. Be clever in developing semantic relevance for high-yield products.

A shining example of all the above is a brand I’ve talked about a few times called CandyMail UK. Our Salience Confectionery Index found them to be experiencing significant triple-digit growth.

Why?

Clever recentering of their site around “PRIME HYDRATION”. At the time, they ranked P1 for several head terms.

(165,000/ mo searches)

Napkin maths:

Assume an average CTR of 20%

A conversion rate of 5% (We see conversion rates as high as 10% with our clients)

An average order value of, say…£10

=

£16,500 /monthly revenue

£198,000 /year 💸💸💸

 

How?

They made a core category for the brand and placed it as the most significant category in their mega nav. Coupled with that, they have created one of the most comprehensive collections of the infamous PRIME product.

Pardon the pun, but it’s a “PRIME” example of making organic £££ work harder.

 

This is a big opportunity for mid-market SMEs in paid media.

Those with the most significant budgets (brands with 250+ staff) are being wiped from keyword auctions.

The biggest spenders, poof, gone. This is assuming my take that all HFFS brands are blanket banned by Google is incorrect.

I’m hoping I’m dead wrong on this, as it’ll give way to some of the most dramatic disruptions to the market from exclusively SMEs. Something morally, we can all get behind.

If you’re in this unaffected bracket, develop a comprehensive paid search strategy right now in preparation for October, when these new rules come into play.

This is your chance to make it to the big leagues.

The rationale behind the HFSS ad ban

Public health concerns

The UK government introduced the HFSS ad ban to address rising levels of childhood obesity. Health campaigners argue that children are heavily influenced by the marketing of food and drink products high in fat, salt, and sugar. The restrictions aim to reduce children’s exposure to advertising that promotes unhealthy dietary choices.

Related reading: HFSS Ad Ban: Timeline and Expert Reactions

Historical context and precedent

The HFSS ad ban follows a regulatory trajectory similar to previous public health interventions, such as the tobacco advertising ban (1965 TV, 2003 print and outdoor) and the sugar tax (2018). Some campaigners suggest HFSS regulation could eventually lead to tobacco-style controls. Alcohol advertising regulations also serve as a partial precedent, particularly targeting and time-based restrictions.

Relevant section: Comparisons with Past Advertising Bans

 

Key components of the HFSS ad ban

Overview of The Food (Promotion and Placement) (England) Regulations 2021

The Food (Promotion and Placement) (England) Regulations 2021 underpin the restrictions, setting the legal framework for what constitutes HFSS and specifies how such products can be marketed and promoted in retail and advertising environments.

New restrictions and their scope

Impact on broadcast television

From October 2025, HFSS products may not be advertised on broadcast television before 9 pm. This includes all national broadcasters and on-demand content accessible before the watershed.

Changes for streaming services

Streaming services with UK audiences must comply with the same watershed rules, banning HFSS advertising before 9 pm. Further clarification from Ofcom is expected on how this will be enforced across subscription and ad-funded models.

Outdoor media regulations

Outdoor media (e.g. billboards, bus stops, transport ads) isn’t covered by the HFSS online or TV advertising ban. That means HFSS products can still be promoted in public spaces – at least for now. However, local authorities like Transport for London (TfL) have already introduced their own HFSS bans on public networks, and similar policies may follow elsewhere. While national regulation stops short of restricting outdoor media, advertisers should watch for local changes and growing political pressure to close this gap.

Digital advertising limitations

“The ban includes a full prohibition on paid online advertising of HFSS products. This covers paid search (Google Ads, PPC), display ads, video pre-rolls, and sponsored influencer content. Only organic content and brand advertising without product mentions are allowed.”

See full details: Impact on Paid Search Advertising (PPC)

Targeting and age restrictions

While the intent is to reduce exposure to children, the digital advertising ban is universal – HFSS products cannot be promoted in any paid online space, regardless of targeting options or age-gating mechanisms.

 

Consequences for non-compliance

Legal obligations for advertisers

Brands and agencies must audit campaigns to ensure HFSS products are not being advertised in restricted formats. The regulations apply to any paid space, including affiliate and influencer media, where the advertiser is responsible for the promotion.

Related:  Impact on Affiliates and Influencer Marketing

Penalties and enforcement

Ofcom and the ASA will oversee enforcement. Advertisers found in breach may face fines and public censure. Platforms like Google and Meta will be expected to remove or block non-compliant ads targeting UK users.

Adapting to the new advertising landscape

Developing alternative marketing strategies

Brands are shifting focus to brand-level advertising, organic content, and owned media channels. There’s an emphasis on storytelling, social engagement, and user-generated content.

Linked section: Impact on Organic Search (SEO) and Content Marketing

Focusing on non-traditional channels

With paid digital off-limits, HFSS brands are investing in out-of-home advertising, direct mail, PR, cinema, and in-store promotions – none of which fall under the scope of the online ban.

Promoting healthier product alternatives

Brands are reformulating products to bring them below HFSS thresholds. These can then be freely advertised online and on TV. Many are launching sub-brands and healthier ranges to maintain visibility in compliant formats.

See also: Prospects for Further Regulation.

Overview of TfL’s ban

Transport for London introduced a similar HFSS ad ban across its network in 2019. The ban included buses, tube stations, and all TfL-owned ad spaces.

Public health outcomes

Initial studies reported a 7% drop in weekly household purchases of HFSS products compared to control groups. Health campaigners view this as evidence of reduced exposure leading to healthier buying habits.

Lessons learned from TfL’s implementation

TfL’s rollout showed that clear rules and firm enforcement work. Advertisers didn’t kick up a fuss – they adapted quickly, switching to brand-focused ads or highlighting products that had passed the criteria. The straightforward guidelines meant fewer breaks against new rules and less room for interpretation.

Potential challenges for advertisers

Maintaining brand visibility

Without access to paid digital media, maintaining mental availability is more difficult. Advertisers must lean on organic visibility and customer loyalty.

Related insights: Focusing on SEO and Content

Managing consumer perception

Brands risk being seen as unhealthy or outdated if they fail to adapt. Those who pivot towards healthier offerings and creative messaging will likely retain relevance.

Long-term implications for the food and advertising industry

Shifts in consumer behaviour

We anticipate that market exposure to HFFS products will lead to declining consumer interest and an increase in lower-calorie and reformulated alternatives. The advertising landscape may contribute to long-term changes in food choices.

Evolution of marketing strategies

We expect teams to focus on SEO, content marketing, and performance-driven PR. Campaigns will move towards value-based messaging and brand equity building.

Prospects for further regulation

Many see the HFSS ad ban as the start of wider restrictions. Plain packaging, tighter rules on in-store promotions, and health warnings on labels are all being discussed. Industry groups aren’t waiting around – they’re already gearing up for more policy changes.

Several measures and evaluations are planned to enforce compliance with the UK’s upcoming 2025 HFSS (High in Fat, Salt, or Sugar) advertising restrictions and measure their effectiveness.

 

 

Measuring the effectiveness of the HFSS ad ban

Post-implementation reviews:

1. The government must review the regulations every five years, publishing a report detailing the findings.

Impact assessments:

1. Evaluations will focus on changes in children’s exposure to HFSS advertising and subsequent effects on dietary habits and obesity rates.
2. Previous studies, such as the Transport for London (TfL) advertising ban, , indicating potential positive outcomes.

Exceptions to HFSS classification

Children’s products:

1. Certain products, including infant formula, baby foods, meal replacements, and foods for special medical purposes, are exempt from the restrictions.
2. Products that fall within the specified categories but have a lower score on the UK’s Nutrient Profiling Model (NPM) are not classified as HFSS and, therefore, are

Business size exemption:

1. Small and medium-sized enterprises (SMEs) with fewer than 250 employees are exempt from the HFSS advertising restrictions.

Brand-only advertising:

1. Advertisements that promote a brand without featuring or referencing HFSS products may be permitted. However, if the brand is closely associated with HFSS products, such ads may fall under the restrictions.

These measures aim to reduce children’s exposure to unhealthy food advertising, thereby contributing to improved public health outcomes.

HFSS Advertising Ban – FAQs

1. What products are in scope?

The ban targets food and drink products considered less healthy – those high in fat, salt or sugar (HFSS). It’s a two-step test:

1. The product is one of 13 categories linked to childhood obesity – think fizzy drinks, crisps, sweet cereals, chocolate, ice cream, pizzas, etc.
2. It must also score above a certain level on the government’s Nutrient Profiling Model: 4+ for food,1+ for drink.

If it ticks both boxes, it’s classed as HFFS and the new advertising restrictions apply.

Some products are excluded. If a product falls in a category but has been reformulated to score lower on the NPM, it’s not considered HFSS. Exemptions apply to baby food, meal replacments, and medically required products.

2. Who’s responsible if the rules are broken?

It depends on where the ad appears.

1. The broadcaster or platform is on the hook for TV or on-demand services.
2. For online ads, the advertiser carries the can. That includes the Brits, their agency, or anyone paying to promote an HFSS product.

TV rules will be enforced by Ofcom who will be overseeing serious breaches. Together, they’ll ensure HFSS ads don’t slip through the net.

 

3. When does the ban kick in?

1 October 2025.

It’s been delayed several times, but the government says this date is final. After that, HFSS ads:

1. Can’t air before 9 pm on TV.
2. Can’t run online (paid marketers have until then to get their houses in order).

 

4. Who does this apply to?

Any UK business with 250+ employees that advertises HFSS products.

Small and medium-sized enterprises (SMEs) are exempt.

The rules cover:

1. Broadcast TV
2. UK-regulated streaming
3. Paid digital channels (search, social, affiliate, influencers etc.)

Even ads on non-UK sites (if aimed at UK users) are included. Agencies, brands, and platforms all have a role to play in staying compliant.

 

5. What’s happened so far?

This didn’t come out of nowhere:

1. 2019–2020: Consultations began.
2. 2021: Government announced a 9 pm TV watershed to be enforced in the years to come + “”.
3. 2022: Made law under the Health and Care Act.
4. 2023: Final date pushed to Oct 2025.
5. 2024: Secondary rules, SME exemptions, and definitions published.
6. 2025: ASA/Ofcom finalising guide. There’s also been a public consultation on tricky edge cases like IPTV (internet-delivered TV), which regulators are still working through.

6. Why does this matter?

From a public health angle, the UK has a real issue with childhood obesity.  . Advertising plays a role in the government’s decision to reduce HFSS exposure at the source.

For the industry, this is a significant shift. Brands that rely on digital campaigns or daytime TV to shift HFSS products will have to rethink everything – from product development and messaging to media planning.

It’s not just a legal issue, it’s also a reputational one. Nobody wants to be the brand caught flouting rules meant to protect kids.

 

7. What’s happening with the final guidance?

ASA and CAP ran a public consultation, took legal advice, and are now revising the guidance based on industry feedback.

One of the big questions is about advertising: Can brands thrive without showing food? The answer is maybe – but tread carefully.

What’s closely linked to HFSS products? Even a logo or slogan might land you in hot water.

8. What exactly does the ban involve?

Two big rules:

1. TV & streaming: No HFSS ads before 9 pm (TV watershed).
2. Online: No paid HFSS ads at all, ever (for brands that fit the criteria).

The digital ban includes:

1. Paid search (Google, Bing).
2. Display.
3. Sponsored social content.
4. Influencer campaigns.
5. Pre-roll video and more.

Only organic, unpaid content (e.g., your website and social media accounts) is exempt.

Brand-only ads are a grey area. Theoretically, they’re allowed, but only if they don’t hint at specific HFSS products. If your logo or slogan brings them to mind, you’re likely still in breach.

SMEs (under 250 employees) are fully exempt from the ban.

Some formats are also out of scope:

1. B2B marketing
2. In-store promos
3. Retailer sites where products are sold
4. Radio and podcasts

Their line is that this is one of the most authoritarian HFSS ad regimes in the world. From October 2025, if you’re a brand selling sugary or salty stuff, your options will narrow fast.

Need more on this? The rules are backed by a stack of guidance and legislation, including:

1. UK: HFSS ad restrictions
2. ASA/CAP guidance
3. Industry analysis from Sedgwick, Taylor Wessing, and others