The UK’s new law on less healthy food advertising: a practical guide for marketers

The UK government is introducing stricter rules on the advertising of less healthy foods (LHFs). From 5 January 2026, brands will no longer be permitted to promote identifiable LHF products online, including through paid social and influencer marketing.

As influencer marketing has matured, regulatory compliance is now a baseline expectation. With the introduction of LHFs as a distinct regulatory category, marketers must clearly understand how food classifications work, where restrictions apply, and how to operationalise compliance. Failure to do so can result in ad removals, warnings and reputational damage.

This guide explains what qualifies as an LHF, how the rules differ from existing HFSS regulations, and what brands should do now to prepare.

Key takeaways

• The LHF ad ban takes effect on 5 January 2026, with voluntary compliance from 1 October 2025

• Paid online advertising of identifiable LHF products is prohibited at all times

• Brands must implement audience checks, validation workflows and updated contracts to remain compliant

What are the new restrictions on less healthy food advertising?

The updated legislation bans advertising for a defined group of less healthy foods as part of the government’s efforts to reduce childhood obesity.

Previously, restrictions focused on foods high in fat, sugar or salt (HFSS), primarily where ads were directed at under-16s. The new rules introduce LHFs as a stricter subcategory of HFSS, subject to tighter controls, particularly across paid online media and influencer marketing.

Who regulates LHF and HFSS advertising?

Food advertising in the UK is overseen by several bodies, including Ofcom, the Advertising Standards Authority, and the Committee of Advertising Practice. Industry guidance is also provided by the Influencer Marketing Trade Body.

What counts as a less healthy food (LHF)?

An LHF is a food or drink that is:

• High in fat, sugar or salt

• Low in beneficial nutrients

• Included in one of the government’s 13 defined “junk food” categories under the Nutrient Profiling Model

Only products that meet all three criteria are classified as LHFs.

HFSS vs LHF: why the difference matters

HFSS is a broad nutritional classification. LHFs are a subset of HFSS products considered to pose the greatest risk to children’s health.

HFSS products can still be advertised under strict conditions. LHFs cannot be promoted through paid online advertising at all.

HFSS advertising restrictions apply when content qualifies as advertising and include limits around under-16 audiences, child-appealing creative, price promotions and overconsumption messaging.

What changes in January 2026?

From 5 January 2026:

• TV and on-demand: LHF ads are banned between 5:30am and 9pm

• Online and social: Paid-for advertising of identifiable LHF products is prohibited at all times

Unpaid organic content and brand advertising that does not identify an LHF product may still be allowed. The legal test is whether a consumer could reasonably identify the ad as promoting a specific LHF.

What counts as “paid” advertising?

Payment includes fees, affiliate commission, free products, gifting or any incentive that could reasonably be viewed as compensation. If content looks like an ad, regulators will treat it as one.

What marketers must do to stay compliant

Compliance now starts before a creator is selected.

If a product is an LHF, you cannot run paid online ads for it. You may advertise the wider brand, provided it is not solely associated with LHFs and no LHF product is identifiable.

For HFSS and food-related brand activity, marketers should:

• Run audience demographic checks, including age split and engagement integrity

• Include HFSS and LHF clauses in contracts

• Use structured content validation and approval workflows

• Document disclosures, consent and ad labels

• Avoid content targeted at under-16s

Regulators are already enforcing these standards. Domino's Pizza was reprimanded by the ASA over a paid YouTube advert linked to Minecraft, after failing to adequately prevent HFSS advertising from reaching under-16s. While the ruling resulted in a warning, it reinforced expectations around proactive audience and placement checks.

Exemptions to be aware of

• Audio-only media such as podcasts and radio are largely unaffected by the online ban, though HFSS rules still apply

• SMEs with fewer than 250 employees are generally exempt

• B2B advertising is out of scope

• Brand advertising is permitted where no LHF product is identifiable

Guidance is ongoing, and further updates are expected.

Influencer marketing implications

Influencers must not publish paid content that promotes or visually references LHF products, including packaging, illustrations or AI-generated imagery.

HFSS products that are not LHFs may still be advertised, but existing restrictions apply, including limits around under-16 audiences, promotions, child-appealing creative and overconsumption formats.

Quick compliance checklist

✔️ Confirm whether the product is HFSS or LHF
✔️ Validate audience age distribution
✔️ Avoid identifiable LHF visuals or cues
✔️ Use brand- or lifestyle-led messaging where appropriate
✔️ Add clear disclosures such as #Ad
✔️ Document approvals and assessments

Avoid combining subtle visual or verbal cues that together reveal an LHF product indirectly.

The stakes are rising for UK brands

In 2025 and beyond, influencer marketing compliance in the UK is non-negotiable. Scrutiny is increasing, and brands must evolve their processes accordingly.

With reliable audience data, structured workflows and tools such as Kolsquare, teams can reduce risk while continuing to run effective, responsible influencer campaigns aligned with the UK’s tightening regulatory landscape.