Less Healthy Food restrictions and the reimagined media landscape

So, farewell then, perfectly stacked burger, and bowls full of sugary cereal. The days of seeing these products outside of adult time TV and online at all times are numbered. From January 5, 2026, those beguiling pre-9pm TV ads and indeed all paid online advertising for ‘Less Healthy Foods’ (LHF) will be heading for a legislative timeout.

The UK’s Less Healthy Food (LHF) restrictions, also known as HFSS (High in Fat, Salt, and Sugar) regulations, are poised to trigger a profound transformation across the advertising landscape, with brands looking for new ways to entice the customer, whilst the customer may feel that their naughty pleasure has been sent to its room, and they’ll have to go and find it if they really want it.

Those brands who have been reliant on TV will need to reconsider scheduling strategies, focusing on later evening slots, which is likely to push up costs, or diversifying their media mix to compensate for lost reach and awareness during restricted hours. But perhaps the biggest impact will be on those brands who have relied upon digital heavy approaches. No more paid search (although who googles Pringles?), display ads, video pre-rolls, sponsored content or paid social media posts.

Whether ‘brand’ as opposed to ‘product’ will also be restricted is still up for consultation. Either way it is likely to make brands re-appraise their messaging, open the door for innovative storytelling and a return to some of those marketing fundamentals. 

The appeal of OOH

This renewed need for brand building, reach, and impact, is of course a perfect opportunity to look to OOH as a compelling channel for those brands impacted by this new legislation. OOH has self-regulated for many years when it comes to HFSS foods and now presents a key avenue for brands to maintain (and actually increase) reach in a visually impactful format.

In this new environment where direct product promotion is restricted, building brand awareness and mental availability becomes imperative. One of OOH’s key strengths is its ability to create powerful and memorable impressions with consumers as they go about their day-to-day journeys. 

And those journeys inevitably involve a trip to the shops or a supermarket where OOH works in proximity to and on the journey to retail locations, helping to influence purchase decisions at a critical stage.  

And whilst the creative canvas afforded by pre-roll video, and social media is no longer available, maybe it’s time for those brands to make a creative pivot. The creative canvas of OOH is almost without borders. It encourages visually compelling, contextually relevant, unmissable and engaging messaging. Already we are seeing a number of FMCG brands such as Kellog’s, Heinz, Cornetto and Haagen-Dazs using their distinctive brand assets, without product shots, to leverage the OOH environment. Indeed, one of our own clients, a chocolate brand, preparing for this new legislation, tested OOH in specific regions and identified new roles for the medium in the purchase process. As a result, they saw a 20%+ sales uplift and a doubling of purchase consideration. Their spend in OOH has now tripled.

Large-format digital billboards, D6’s close to a store, street furniture and experiential activations all offer opportunities to capture audience attention. And with advances in programmatic DOOH (pDOOH) and dynamic creative tools advertisers can tailor their messaging around triggers such as location, time of day, weather, and real-time audience location data, to enhance the effectiveness and relevance of OOH campaigns. These technological advances in OOH are blurring the lines between physical and digital worlds.

Simplicity and intrigue

LHF restrictions represent a bit of a watershed (pun intended) moment for the industry, presenting challenges for brands used to the reach and engagement TV and digital afforded. There is an obvious creative challenge too. How do they tell stories without what is seen as traditional story-telling media in their arsenal? Maybe it’s time to return to a little simplicity and intrigue in our creative treatments?

Ultimately, brands will need to re-appraise how they show up and re-consider their channel mix. OOH’s brand building capability, almost unparalleled reach (at a time when reach is increasingly hard to achieve), its ability to drive mental availability and trust, its proximity to purchase, and a creative canvas that is only limited by the imagination will serve LHF brands well.

Those who embrace this shift with carefully planned media strategy planning and creative ingenuity will be the ones to thrive in this new media landscape.

It’s time for brands to ‘think outside the bun’!

Alex Marks - Head of Marketing