Approach to navigating the new restrictions in the UK.

With the new Advertising Standards rules coming into place at the start of 2026, HFSS (High Fat, Salt or Sugar) & LHF (Less Healthy Food) brands will be forced to explore new, compliant routes to market and communication.

Having reviewed the new rules and guidance, one thing stands out: For many, ‘brand’ will be the most important thing to focus on. Are you effectively able to communicate your brand identity and message when the product can’t be the central point? When your features and development need to be translated in a way that can’t be depicted plainly, is the brand sharp enough to be recalled, without holding the item?

This change is neither out of the blue nor unexpected. The UK Government has had comparable legislation in the pipeline for over 20 years, and the push for a healthier advertising system to younger audiences has undergone evolution, particularly in the last few years. Consultations in 2019 and 2020 proposed extending previous restrictions, and the 2026 rules are nothing but a rubber-stamped version of steady moves towards a ban for marketing to minors, already confirmed in 2022.

And we’re not alone. A US news report looking at American health for 2025-2030 expressed a warning against levels of obesity with the confectionary industry being one of the main targets.

Rules Recap

So, before we explore this new age, let’s take a quick look back at what they are asking brands to do. The rules in short:

1) The brand is ultimately accountable for compliance - This is even more relevant in advertising ecosystems built around creators, affiliates and partnerships.

2) There’s now a total ban for all paid online advertising  for LHF products. HFSS restrictions were already present and applied to LHF products such as the 9pm watershed on all broadcast advertising and promotional pricing on products.

Crucially, while paid-for ads for Less Healthy Food (LHF) products are restricted, compliant ads can still link to channels and locations where LHF products are sold, subject to meeting certain requirements. Understanding where the ad ends and the retail experience begins is key to helping brands unlock the opportunities, whilst staying on the right side of the rules.

TikTok has also developed an industry aligned LHF resource guide with advice from IAB UK to help brands understand what the rules mean in practice, and how to still tell stories on platform, but this is only one area. The restrictions are widespread so how must brands tackle this new regulatory frontier?

The Simple Solution

For me, two solutions stand out.

The first is simple and, if it’s an option for your brand, the easiest way to continue to leverage an advertising ecosystem you have in place: advertise the healthier product.

The priority for brands is to understand the new rules in detail – and to distinguish between products classified as LHF and those subject only to HFSS restrictions. One is fundamentally prohibitive; the other can be solved through creative minds and strong creative partnerships.

The non-LHF product, which may hold much of the brand equity of the wider portfolio, could bear the weight of awareness, relevancy and allow the family of products to remain visible. The strength of the whole brand has done the heavy lifting. A particular SKU is simply there to ‘spot’ (as you would in a weightlifting gym) for the whole brand, pulling the HFSS ones along in its wake.

For those brands without a healthier option to focus on, a different strategy and approach to media is required.

But before we dive into that, let’s look at the context. The reality is that the physical product will be at the mercy of the legislation within retailers and instore compliance teams, so any strategy must take into consideration both the marketing of the product and its availability. Shopper prime locations, digital POS formats and in-aisle reformulations are a side of the coin that may not be overcome in the previous ways and perhaps this places even greater emphasis on the awareness side (of the coin).

The Holistic Solution

The second solution revolves around brand messaging and is a more holistic approach based on three core marketing pillars. These are:

1. Maximising your brand’s own channels
2. Doubling down on range-led storytelling
3. Reframing the communications

1. Maximising your brand’s own channels

Let’s start by looking at how to maximise your brand’s owned channels. These go far beyond DTC storefronts, websites, and social profiles.  In many cases, they’re more abstract — the spaces and cultural territories where a brand consistently shows up, contributes, and becomes known. When a brand repeatedly and distinctively occupies a space, that space effectively becomes an owned channel.

Take Dr Martens for instance. The brand has been known for years as the shoe of rebellion. Seen as a symbol of individuality, tough and non-conforming. This distinctive cultural position meant that they were adopted by many subcultures over time: Punks, Goths, Indie, Ska / Two-Tone, Grunge, Queer Culture, Britpop even. And the space they played in was music. Usually loud, real and raw.

Dr Martens therefore has the license to use music as its own channel to get the brand message across through the lifestyle and lives of its consumers: this is earned relevance.

Nowadays, this often takes the form of strategic or tactical partnerships, but overly commercial, irrelevant or short-term collaborations won’t work to the discerning consumer. To own the channel, you must truly become part of it and build a greater story than the product.

2. Range-led storytelling

Storytelling isn’t a new phenomenon. It’s arguably one of the oldest forms of communication. However, when thinking about brands, how much is the storytelling focused on a particular product versus the journey to it? The space around it? The source of the need? Our purchase decisions aren’t made in a vacuum and are the sum of the beliefs we have about the product and what it will do for us. So, what do they look like?

If we think about our product in audio and visual cues, we see that the story around it is as, if not more, important than the item itself. A certain crunch can evoke a particular feeling. A flash of Purple (Pantone 2685 C to be exact) signals a memory as much as a gorilla playing the drums. You get the picture.

It is with these cues that we build the wider brand story and start to think in product range messaging rather than singular focus. What can several products together represent? One of the ways we achieve this is through CGI. LHF restricts advertising the product itself, but as we’ve found, that’s only part of our purchasing decision and the reinforcement of the qualities of the product, both tangible and intangible, help build a story that carries all the way to the supermarket. For instance, CGI can create both hyper real and experience focused content, created to enhance the story and feeling around the product all whilst the product and/or product environment itself is absent.

3. Reframing communication  

LHF restrictions haven’t happened in a bubble, and the future of how consumers experience and search for things has drastically evolved over the past few years. Audience segmentation has followed with more fluid designations of the consumer and, with AI-led search, we are now in an era where the multi touchpoint journey requires our full attention. It’s from here we must change our viewpoint.

Understanding which type of content should be served at each stage and how this can be versioned across each platform – seeded and un-seeded – and what can bring real value to consumers in order to feed into their later (or nearer) purchase decisions is paramount. Not only should we think of voice and authority, but we must think on how we’re communicating it within our existing brand DNA - whilst being able to deliver it at the speed our consumers move.

Final Thoughts

This conversation requires a real look at one’s own activities and how we think of brand communications, but these three pillars (reframing communications, range-led storytelling & own channel touchpoint thinking) are our guide to cutting through, delivering a compelling story and getting our consumers to see us [DH6] even when the product can’t take centre stage. We’re having these conversations with clients and creating strategies to win in 2026. We’d love to speak to you, so get in touch!