5 ways UK marketers can combat the HFSS ad ban

Agnese Rondoni

With obesity being a major cause of illness, governments across the globe are prioritising the promotion of healthy and sustainable eating. In light of this, the UK Government has introduced new legislation, due to take place April 2022, that aims to restrict the advertisement of certain food and drink products. Here, we examine how brands can get ready …

What is HFFS?

HFSS refers to food or drink products deemed unhealthy by the Department of Health because they are high in fat, sugar, or salt (HFSS). The UK Government has introduced a Nutrient Profiling Model, which is a tool to assess if a product falls into a non-healthy category and will therefore be subject to HFSS regulations.

What are the HFFS restrictions?

  • The total ban of the placement of HFSS products at key selling locations such as store entrances
  • The total ban of advertising HFSS products before 9pm on TV
  • Restrictions on multi-buy promotions, for example: ‘Buy one get one free’, ‘Three for two’, ‘Five for £5’, ‘Extra free’ or ‘Buy four and save 10%’ deals
  • Restrictions on free refills of ‘sugar-sweetened drinks’
  • The limitation of displays and sponsored online adverts promoting HFSS

These restrictions may lead to several implications for both retailers and brands, such as loss of revenue from promotion constraints in high-traffic, high-visibility, and high-margin sites within stores.

Early estimations show that retailers are expected to lose around £17.1m and brands about £30m per year in advertising revenues.

We’ve assessed the literature and latest thinking on the restrictions to provide you with a summary of recommendations for brands:

1. Assess which products fall under the policy’s remit

Brands could consider a series of initiatives to face the new legislation. A first action may be to assess which products fall under the policy’s limitations. In fact, not all the products that at a first glance may appear to be HFSS may actually be, and vice versa.

Where feasible, product reformulation should be considered in order to limit the impact of the new policies to a smaller segment of products. For example, Kellogg’s UK is cutting the sugar content by 10% across its kid’s cereal range.

2. Champion distinctive, brand-led advertising strategies

Alternatively, it will be key to maintain engagement by developing or keeping high levels of emotional closeness to your brand. To do this, brands must utilise brand-led advertising focussed on brand values rather than product specifics, which so far is not included in the restrictions. Not only this, but brand values are increasingly important to consumers in making their purchasing decisions.

In a recent advertising example, McDonald’s focused its comms on an initiative of promoting free football sessions for children in over 160 locations across the UK – a message that highlights the brand values, without showing any products. Product-specific ads can then complement this on TV after 9pm, where most British people claim to watch TV between 18:00 and 00:00.

3. Transform online content strategies to prioritise organic over paid-for exposure

Brands also need to adopt alternative and innovative strategies to engage with consumers directly, by creating informative experiences and growing organically online using owned channels. In 2015, it found that owned media channels are one of the most trusted sources of marketing for consumers, providing the opportunity to connect with consumers in a relevant and authentic way.

Pop-Tarts is a brand that uses their owned social media channels to create a tone of voice that would engage and appeal to a young target audience, making it easy for people to relate to them. Dove is another great example – a brand that uses their platforms to bring their purpose of improving self-esteem to life, encouraging women to share genuine images of themselves, in an effort to break beauty stereotypes.

4. Embrace potentially new channels that have not always been prominent in the media mix

Other channels can also be explored that are not currently bound by restrictions due to fewer children being exposed. For instance, radio is still very popular and there is growing engagement in podcasts. The Eve Sleep mattress brand grew awareness and sales in the UK with a podcast about the negative impact of hitting snooze.

Audio channels also provide opportunity to localise messaging, and innovation in voice-activated devices also creates new ways to engage with consumers. In the UK, Coca-Cola used voice technology to turn its TV advertising into a mass marketing mechanism by encouraging consumers to ask their voice assistant to ‘send me a sample’.

5. Rethink in-store activation and shopper marketing

Where restrictions are impacting placement of products in retail, it is important to choose appropriate packaging for your products to reflect the brand identity and create engagement at the point of sale. Packaging can make your products stand out from the crowd. In fact, a recent study conducted in Europe showed that 56% of European consumers discover new products directly in the store. In this context, an appropriate packaging design, both distinct and concise in style, can help attract new consumers.

There still appears to be some uncertainty and outstanding questions that require clarity in the restrictions. Regardless, an important part of the planning process will involve consideration for how TV and online advertising will continue to play a vital role for HFSS-restricted products – particularly as both channels are hugely important in reaching large audiences and driving brand engagement.