From January 2026, the UK’s new Less Healthy Food and Drink (LHF, including HFSS - high fat, sugar and salt) advertising restrictions will come into force, reshaping how FMCG brands market to consumers (although industry has agreed to abide by the restrictions until they come into force).

While the changes are complex, and sit alongside the existing HFSS rules, this is not just a compliance hurdle. For marketers ready to adapt, it’s a defining moment to reset strategy, showcase values, and seize first-mover advantage.

Why the LHF rules matter now

The legislation prohibits paid online ads for LHF products and bans their promotion on TV and ODPS before 9pm. It affects everything from paid search and display to influencer partnerships and branded social content. And although formal enforcement begins in January, retailers agencies and media owners are acting now under a voluntary agreement, aligning with the original deadline of October 2025.

This represents one of the biggest shifts in UK advertising in a decade. Retail media, in particular, is set for disruption. But with change comes opportunity.

The consumer shift: health, value, and relevance

Consumers are already on a path the legislation supports. According to dentsu’s latest Q2 2025 UK Consumer Navigator report, trust is now the third most influential factor on brand choice across all UK age groups, only outpaced by value for money and loyalty rewards in how shoppers decide where to spend. In a landscape where marketing for LHF products will be increasingly limited, trust becomes a vital currency. Brands that lead with integrity, invest in healthier choices, and communicate transparently are far more likely to earn long-term loyalty. Inaction, by contrast, risks eroding credibility at a time when consumers are paying closer attention than ever.

Build brand, not just awareness

The restrictions limit product advertising, but not brand storytelling. In fact, brand advertising that doesn’t feature specific HFSS products is intended to still be permitted under the rules and Government consultation on supplementary brand exemption regulations has just concluded.

This means a pivot is essential: from promoting individual products to promoting brand values. Done well, this builds long-term equity and resilience.

Rethink creative and customer experience

Marketers now need to build creative strategies that both comply and convert. That means:

• Designing for brand presence with care: Consider subtle brand-building cues that do not directly or indirectly depict or reference specific LHF products, whilst being mindful that legislation defines depiction broadly to include names, text, imagery, sound cues, jingles, or any combination of branding techniques.
• Emphasising compliant product lines: Many brands are reformulating products to fall outside HFSS restrictions, a strategy that can unlock full media access.
• Building value into CRM: Dentsu’s CMO Navigator: CXM report shows that brand loyalty is now a priority growth driver for most CMOs, with customer experience, personalisation and automation leading the charge.

Reformulate for reach

Product reformulation may feel operational; but it's a growth lever. Some of the largest FMCG brands are already investing in changes that bring products into compliance and maintain advertising freedom.

Beyond compliance, reformulation supports growing consumer demand for healthier lifestyles. That’s especially relevant in a retail context where Gen Z and Millennials are fuelling shifts toward sustainable, ethical, and lower-processed choices.

Think retail-first, not digital-last

With online ad options tightening, in-store media and retailer-owned (as opposed to paid-for) digital formats will become more valuable. Retailers will be critical partners, offering potentially safer inventory like in-store radio and display, and brand pages that feature compliant product lines. Using retailer data to make other channels more efficient will become more prominent, within the LHF rules.

Keep measurement meaningful

While ROI remains important, LHF restrictions force a broader lens. Performance must now be measured by:

• Incrementality: Are your compliant strategies driving new impact?
• Brand metrics: Does awareness, recall or favourability shift?
• First-party data growth: Is your audience engaging with brand experiences?

Retail media measurement is still evolving: but savvy marketers will align with retailers and platforms to establish clearer standards.

Don't miss the bigger picture

The government’s stated objectives of the regulations are to reduce children’s exposure to less healthy food and drink advertising, encourage healthier choices, and support product reformulation, while balancing potential impacts on the advertising and media industries.

Leading brands must avoid the temptation to hunt for loopholes and instead use LHF regulation as a moment to lead on issues that matter. Our Voices Amplified research shows that brands that communicate clearly on societal issues, such as health, inclusion, and wellbeing, enjoy stronger consumer preference and significantly higher advocacy, with a +40 point NPS advantage over those that don’t. In a climate where trust is driving purchase decisions, brands that act with integrity and transparency will be those that consumers reward.

What’s good for society is increasingly good for business. And the LHF challenge is a rare chance to prove that alignment in action.

Win by doing the right thing

LHF advertising restrictions compliance isn't the end of food and beverage marketing. It's the start of a smarter, more creative, and more accountable future. Brands that embrace the spirit of the legislation, by reformulating products, leading with brand purpose, and rethinking their creative and media strategies, can build greater trust, increase customer loyalty, and stand out in a crowded market. Those who lead with responsibility will win consumer preference in the long term.

Ready to take the lead on LHF?

Whether you're reassessing your media strategy, exploring reformulation, or looking to future-proof your brand storytelling, we can help.

Get in touch with our team to turn compliance into competitive advantage.

For more information on the regulations, you can find the government legislation here, and advice from the Advertising Association here.