CAP publishes updated draft LHF guidance for industry consultation

The Committee of Advertising Practice (CAP) has released updated draft guidance for industry consultation relating to implementation of the LHF online ad ban (previously often referred to as the HFSS online ad ban) that is coming into force on 1 October 2025.

CAP - which is tasked with producing industry guidance with support from co-regulators Ofcom and the ASA - consulted on initial draft guidance last year. This process resulted in an update last month where CAP stated that: “The consultation process has caused us to rethink and potentially revise aspects of the guidance we consulted on.” 

Revisions to the guidance relate to how the restrictions apply to brand advertising (i.e. ads that do not show or directly refer to LHF products). The original guidance reflected CAP’s understanding of the intended scope of the restrictions, based on the Government’s statements about the policy which consistently said that brand ads could continue to run from 1 October. However, the consultation on the previous version of the guidance identified that, because the law does not explicitly exempt these ads, the guidance cannot categorically state that they are out of scope - this will depend on the content and context of individual ads. 

As a result, CAP has revised its draft guidance and is consulting on the updated version, which states that: “Restrictions can also apply to advertising that does not explicitly depict or directly refer to a specific less healthy product, if people in the UK could reasonably be expected to identify the advertisement as being for an identifiable less healthy product.” The guidance contains a full explanation of what this means and you can read it in full here. 

The industry now has until 5pm on Tuesday 18 March to respond to the consultation on the draft guidance. IAB UK will be responding on behalf of our members - please join our Policy Community if you would like to be involved and regularly updated on this process. 

For more on the background of the LHF online ad ban, listen to Beth Rogers - our Public Policy Manager - on The IAB UK Podcast.