The world of food and drink marketing isn’t bracing for HFSS – it’s already deep in it. If you’re running an FMCG brand, you’ve spent years navigating HFSS restrictions, adapting your portfolio, tweaking pack claims, and navigating store placement limitations. But now, the spotlight has shifted to advertising – and the new LHF advertising restrictions that came into force on 5 January 2026 have added another layer.
With the 2026 restrictions now in place since the 5th of January, it’s time to sharpen your strategy, protect your visibility, and turn compliance into competitive advantage.
Here’s a practical refresher on the LHF and HFSS framework, followed by smart, actionable ways to thrive in a world where traditional media channels are no longer as open a platform as they once were.
Table of Contents
- HFSS vs LHF: Two Different Restrictions
- What Are HFSS Products?
- What Is the New LHF Legislation?
- What Does This Mean for Food & Drink Brands?
- Where Budget Is Flowing Now
- What Brands Can Do Under LHF and HFSS – Alternative Advertising Strategies
- Ensuring Your Brand Is LHF and HFSS Compliant
- Conclusion – Understanding HFSS Legislation
HFSS vs LHF: Two Different Restrictions
Before we dive in, let’s clear up a common misconception. HFSS and LHF aren’t the same thing – they’re two separate sets of advertising restrictions that both apply, and LHF is significantly more restrictive.
HFSS (High in Fat, Salt or Sugar) refers to the existing ASA advertising rules that have been in place for years. These restrictions prevent HFSS products from being advertised in media that’s “commissioned for, principally directed at, or likely to appeal particularly to audiences below the age of 16.” Basically, you can’t advertise HFSS products where more than 25% of the audience is kids. These rules remain fully in force.
LHF (Less Healthy Food and Drink) refers to the new advertising restrictions that came into effect on 5 January 2026. These are much stricter:
- TV watershed: LHF products cannot be advertised before 9pm
- Online ban: LHF products cannot appear in paid online advertising at any time
Here’s the crucial distinction: LHF is a subset of HFSS. For a product to be classified as LHF, it must meet two criteria:
- It must be HFSS (score 4+ for food or 1+ for drinks using the Nutrient Profiling Model)
- It must fall within one of 13 specific product categories: soft drinks with added sugar, savoury snacks, breakfast cereals, confectionery, ice cream, cakes, sweet biscuits and bars, morning goods, desserts, sweetened yoghurt, pizza, chips/fries/potato products, and ready meals/sandwiches/breaded products
This means a product can be HFSS but not LHF (if it’s not in those 13 categories). However, every LHF product is definitely HFSS. Both sets of rules apply simultaneously – you need to comply with both, and follow whichever is stricter for your specific products.
Throughout this guide, when we talk about HFSS, we’re referring to the broader category and the existing restrictions. When we talk about LHF, we’re referring specifically to the new 2026 restrictions and the subset of products they affect.
What Are HFSS Products?
You can’t just look at a chocolate bar and say “yep, that’s definitely HFSS.” The UK has this thing called a Nutrient Profiling Model that does all the heavy lifting. Think of it like a calculator that weighs up all the bad stuff (energy, saturated fat, sugar, sodium) against the good stuff (fruit, vegetables, nuts, fibre, protein).
The next question is: What is the criteria for HFSS? If a food scores 4 points or more, or a drink scores 1 point or more, it’s officially classed as HFSS (High in Fat, Sugar or Salt). This means some products you wouldn’t expect can fall into the HFSS category – like breakfast cereals, certain yogurts, or even some fruit juices.
The take away from this is: don’t guess. Use an HFSS calculator online and find out exactly where your products stand.
What Is the New LHF Legislation?
As of the 5th of January, 2026, LHF products can no longer be advertised on TV before 9pm. No more reaching families during dinner time, no more kids’ programming slots, no more early evening ad spots.
Not only that, online advertising for LHF products has been hit with restrictions too. We’re talking social media, display ads, video content – basically anywhere you’d normally try to catch people’s attention online.
If you’ve been following LHF/HFSS legislation UK developments, you’ll know this has been brewing for a while. The groundwork was laid with HFSS legislation 2021 consultations, then formalised through HFSS legislation 2022 when the Health and Care Act passed. What we’re seeing now with the LHF advertising restrictions is the final piece of the puzzle falling into place.
The government has released official HFSS guidance – but fair warning, it’s not exactly written with marketers in mind. It’s dense, technical, and not always easy to apply to real-world campaigns.
Key Dates to Know
- October 1st, 2025: The original date for restrictions to start, which was postponed.
- January 5th, 2026: LHF restrictions came into force.
- Right now: The restrictions are live – compliance is mandatory.
Here’s something that might surprise you though – the ban applies to products, not companies. So, if you can do brand advertising without shoving your HFSS products in people’s faces, you’re still good to go pre-9pm.
Who Gets a Free Pass?
Not everyone’s in the same boat with LHF restrictions. Small and medium businesses (under 250 employees) get exemptions from the LHF rules, though they still need to comply with existing HFSS restrictions. Makes sense really – these rules would absolutely crush smaller players if applied the same way across the board.
Plus, if you’re clever about brand advertising that doesn’t feature recognisable HFSS products, you can still play in the unrestricted space.
What Happens if You Mess Up?
The Advertising Standards Authority (ASA) isn’t messing around with HFSS compliance. Get it wrong and you’re looking at advertising bans, public naming and shaming, and potentially hefty fines if Ofcom gets involved.
The ASA’s approach is pretty straightforward – someone complains, they investigate, and if you’ve broken the rules, you’re in trouble. Better to get ahead of this than spend your time explaining why you thought that 7pm chocolate ad was totally fine.
What Does This Mean for Food & Drink Brands?
If your products fall under LHF classification (HFSS plus one of the 13 categories), there are now significant restrictions on when and where you can advertise them.
For many FMCG (CPG) brands, television advertising during peak family viewing hours was a cornerstone of their marketing strategy. The pre-9pm slot captures families during dinner time, children’s programming, and early evening shows – exactly the audience many food brands want to reach. Losing this opportunity means rethinking entire campaign strategies.
The impact extends beyond just TV advertising. Online advertising restrictions will affect social media campaigns, display advertising, and digital video content. This is particularly challenging given how integrated digital marketing has become across all consumer touchpoints.
However, it’s not all doom and gloom. The restrictions have created a more level playing field where creativity and strategic thinking are more valuable than simply having the biggest advertising budget. Brands who have adapted quickly and innovatively may find themselves with competitive advantages.
Where Budget Is Flowing Now
The LHF advertising restrictions have created a massive redistribution of marketing spend. TV and digital budgets that were locked into annual plans are suddenly looking for new homes, and that money needs to go somewhere.
Smart brands are moving fast. Sampling programmes are being scaled up, experiential activations are being booked out months in advance, and outdoor advertising inventory is getting snapped up. The marketing channels that remain unrestricted – which happen to be exactly the channels Relish specialises in – are seeing unprecedented demand.
Here’s the advantage: brands that moved early are already seeing the benefits. While competitors scramble to figure out their compliance strategy, first-movers have secured partnerships, booked premium activation spaces, and are already connecting with consumers through channels that often deliver better ROI than traditional advertising anyway.
If you haven’t pivoted yet, the opportunity is still there – but it’s shrinking. The brands winning right now are the ones treating this as the opportunity it is, not just a problem to manage.
What Brands Can Do Under LHF and HFSS – Alternative Advertising Strategies
Whether your products are HFSS, LHF, or both, these channels remain effective and compliant:
Product Sampling
This one’s a no-brainer. Product sampling has always been brilliant for FMCG brands, and guess what? HFSS legislation doesn’t touch it. You can still hand out samples in stores, at events, or send them through the post.
The beauty of sampling is that it often works better than advertising anyway. People get to actually try your product, which is way more convincing than any 30-second TV spot. Just make sure you’re not turning your sampling into advertising with loads of promotional messaging – keep it simple and let the product do the talking.
Experiential Marketing
Experiential marketing is where HFSS brands can really shine. Think brand experiences, pop-up events, interactive installations – anything that gets people engaging with your brand rather than just seeing an ad.
The trick here is focusing on your brand story, your values, what you stand for – rather than pushing specific products. Done right, this approach can create much deeper connections with consumers than traditional advertising ever could.
Sponsorship and Event Marketing
Sports sponsorship, music festivals, community events – all still fair game. In fact, sponsorship might become even more valuable because everyone’s going to be fighting for these unrestricted opportunities.
The key is making sure your sponsorship activities are about brand association rather than product promotion. Get people thinking positively about your brand, and they’ll seek out your products naturally.
CRM & Loyalty Programs
Here’s where having existing customer relationships really pays off. Your email marketing, loyalty app notifications, personalised offers – none of that’s going anywhere. These channels are gold because you’re talking to people who’ve already chosen to engage with your brand.
Plus, these customers are way more receptive to your messaging because they’ve opted in. Make the most of these direct relationships – they’re going to become increasingly valuable.
Owned Channels
Your website, your social media profiles, your branded content – this is all still yours to do with as you please. In fact, owned media just became more important than ever for HFSS brands.
Content marketing, SEO, social media engagement – these strategies can keep your brand visible and connected with consumers. The secret is creating content that people actually want to consume, rather than just pushing ads at them.
In-Store Activations (with Conditions)
The good news is that a lot of in-store marketing can continue. Floor displays, promotional signage, in-store events – these can all help maintain visibility right where it matters most: at the point of purchase.
Just be aware that some specific in-store placement restrictions might apply separately, so check the detail rather than assuming everything’s fine.
Ensuring Your Brand Is LHF and HFSS Compliant
HFSS compliance isn’t just about understanding the advertising rules – it’s about taking a comprehensive look at your entire business approach.
Product Reformulation – A Longer-Term Play
Reformulation is worth mentioning, but let’s be realistic: if you haven’t already reformulated your products by now, it’s not going to help you with the current restrictions. Successful reformulation takes months or even years of R&D, consumer testing, and gradual rollout.
That said, it’s still worth considering as part of your longer-term strategy. BBrands that can successfully reformulate to get below the HFSS thresholds (or reformulate to move out of the 13 LHF categories) will have unrestricted advertising freedom while competitors remain limited. It’s a significant competitive advantage – just not one that solves your immediate compliance needs.
If reformulation is on your radar, start the process now for future flexibility. But for your current marketing challenges, focus on the channels and strategies that work within the restrictions as they stand today.
Marketing Strategy Pivot
You can’t just take your previous campaigns and try to squeeze them into the new rules. You need a completely fresh approach that focuses on brand building and lifestyle positioning rather than product promotion.
The brands that have nailed this transition will probably end up with stronger, more meaningful relationships with their customers than they had before. Sometimes constraints force creativity, and creativity drives better results.
Reviewing Creative and Media Plans
Every single piece of creative you’ve got needs checking. Current campaigns, planned activities, evergreen content – all of it. Your creative teams need to understand exactly what crosses the line from brand advertising into product promotion. And your media planning needs a complete overhaul as well.
Legal & Compliance Checks
If you haven’t already established robust compliance processes, do it immediately. The ASA is actively enforcing these restrictions, and waiting will only increase your risk.
Your marketing teams need ongoing training on what crosses the line from brand advertising into product promotion. Set up clear approval workflows for all creative, and schedule regular audits of your current campaigns and evergreen content. Work with legal experts who understand both LHF and HFSS guidance inside and out – this isn’t an area for guesswork.
Remember, fixing compliance issues after an ASA complaint is far more expensive and damaging than preventing them in the first place.
Conclusion – Understanding HFSS Legislation
HFSS legislation is the biggest shake-up food and drink marketing has seen in decades. But here’s the thing: change creates opportunity, and the brands using this as a chance to innovate rather than just a problem to solve are going to come out on top.
The restrictions came into force in January 2026. If you’re only now starting to plan your approach, you’re behind.
The worst thing you can do is nothing. Many brands waited too long to adapt, and they’re now playing catch-up. Start now, be strategic, and remember – your competitors are dealing with exactly the same challenges. The ones who adapt fastest and smartest will win.
Need Support Adapting Your Marketing for the HFSS Era?
Navigating LHF and HFSS compliance while keeping your marketing effective isn’t something you have to figure out alone. At Relish, we’ve been helping FMCG brands crack the code on smart marketing strategies that work brilliantly within these new rules. Whether you need guidance on reformulating products, want to explore creative advertising alternatives, or just need someone who gets it to walk you through your options, we’re the team that makes this stuff make sense.
Speak to a Relish Brand Ambassador to hear what we could be doing for your brand.
