From January 2026, UK food and drink advertising will face its biggest shake-up in decades. The new HFSS (high fat, salt or sugar) restrictions aren’t just another compliance box-tick, they’re a cultural signal that the way less healthy foods are promoted is changing for good. This presents an opportunity for PR agencies to shift focus from paid social to earned media.
We’ve seen this story before. When tobacco lost its above-the-line channels, brands pivoted into music, fashion and sport sponsorships that defined cultural moments. Alcohol marketers have worked within sponsorship and advertising codes for years. Now, HFSS categories face their own turning point. The question is not how to skirt the rules, but how to build stronger, more creative strategies within them, tweaking paid strategies and focusing on consumer PR and media relations and organic social.
What’s actually changing
- Paid digital ads for HFSS products will be banned at all times.
- TV ads for HFSS products won’t run before 9pm.
- Influencer content becomes restricted if any value changes hands (cash, gifts, affiliate).
- Organic and earned media remain permissible, provided they follow ASA/CAP rules.
The foods in scope are broad, cakes, biscuits, chocolate, crisps, sugary drinks, ice cream, desserts, sweetened cereals and many ready-to-eat meals. For supermarkets, cafés, bakeries and food brands, this means many of the most profitable lines can no longer be amplified through paid channels and they need to double down on more classical retail PR strategies.
Where brands can still play
The restrictions close off some doors, but they also leave important routes open:
- Brand-led advertising – companies can still run paid campaigns that promote the brand rather than specific HFSS products. Logos, values, community activity and corporate positioning are all in play.
- Audio-only advertising – podcast and music streaming ads are exempt, providing a compliant digital channel.
- B2B paid activity – recruitment, franchising and trade campaigns sit outside HFSS rules.
- Organic social – owned channels can continue to show products, provided claims are accurate and content avoids child appeal.
- PR and earned media – completely outside the HFSS rules, giving brands a powerful lever to maintain visibility.
What this means for PR and marketing professionals
Retailers will lose the quick wins of online promotions and multipacks. Seasonal campaigns built around confectionery and snacks will have to be re-engineered. Restaurants and cafés will find it harder to spotlight bestselling desserts or bundle deals. Challenger brands built on influencer gifting will face the same walls as bigger rivals.
Where the opportunity lies
This isn’t the end of food marketing. It’s the end of relying on paid promotion as the default lever. Consumers are already more influenced by authenticity, transparency and values-based storytelling than by the next Instagram giveaway.
That means PR and earned media, which sit entirely outside the HFSS restrictions, will take on new importance. Organic social, too, can thrive if it becomes about dialogue and lifestyle storytelling rather than product pushing. Brands that lean into provenance, community and purpose will not only stay compliant but also build deeper trust.
The new playbook
What comes next is not about loopholes. It’s about building a communications ecosystem where earned, organic and experiential activity do the heavy lifting, and where brand campaigns are used strategically in paid.
For some, that shift will feel uncomfortable. But for brands prepared to embrace it, the rewards are real: stronger trust, long-term brand equity and an edge over competitors still clinging to old paid models.
HFSS is not the end of food marketing – it’s the start of smarter, more sustainable food marketing.
HFSS FAQs – what brands need to know
1. What does HFSS actually stand for?
HFSS means foods high in fat, salt or sugar. The government uses a nutrient profiling model to decide what’s in scope.
2. Which foods are affected?
Cakes, biscuits, chocolate, crisps, sugary drinks, ice cream, desserts, sweetened cereals, and many pizzas, ready meals and savoury snacks. In practice, most indulgent or convenience products fall under HFSS.
3. What advertising is restricted?
- Paid-for digital ads (search, display, social, video) for HFSS products (but not brand).
- TV ads for HFSS products before 9pm.
- Influencer content if any value is exchanged (cash, gifts, affiliate links).
4. What advertising is still allowed?
- Brand-only campaigns (paid ads that promote the company, values, or community activity, but don’t show or name specific HFSS products).
- Audio-only ads (podcasts, music streaming).
- B2B campaigns (recruitment, franchising, supplier partnerships).
- PR and earned media (completely exempt).
- Organic social (permitted, provided it complies with ASA/CAP rules).
5. Does this mean I can’t show my products online at all?
No. You can still use products in organic social and PR coverage. The restrictions only apply to paid digital, broadcast TV before 9pm, and paid influencer posts.
6. Can I still work with influencers?
Yes, but only on brand-led campaigns where no specific HFSS product is shown or named. If influencers receive free products or payment tied to HFSS items, that content counts as paid advertising and would be banned.
7. What about seasonal campaigns?
You’ll need to rethink them. Chocolate eggs at Easter, festive desserts at Christmas or birthday cake promotions can’t run in paid digital ads. But you can still tell those stories through PR, organic social and brand campaigns.
8. Who enforces the rules?
Ofcom and the Advertising Standards Authority (ASA) share enforcement. Non-compliance could mean campaign bans, fines and reputational damage.
9. When do the rules take effect?
Voluntary compliance begins in October 2025. Full enforcement begins on 5 January 2026.
10. What should brands do now?
- Audit products to confirm HFSS status.
- Shift paid budgets into brand, audio and B2B activity.
- Build a PR-led strategy to replace lost reach.
- Train teams and agencies on compliance.
