Since 5th January 2026, the UK food and beverage advertising market has fundamentally shifted. New restrictions on Less Healthy Food and drink (LHF) advertising are now in force, sitting alongside existing HFSS (High in Fat, Salt or Sugar) rules and long-standing protections for children. If you’re a food and beverage brand with LHF products, you’ve likely felt the headache.

Here’s the thing though. LHF advertising restrictions don’t have to mean creative death. At jellybean, we’ve found that brilliant creative doesn’t fight the rules, it dances with them. When you understand the LHF compliance boundaries, you discover possibilities others miss. This guide will demystify the new LHF regulations, clarify what’s in and out of scope, and show you where the creative opportunities still exist for LHF food and drink marketing. Because trust us, they’re there.

Setting the Scene: How We Got Here

The UK’s journey towards stricter food advertising regulation has been building for years, and it’s worth understanding the timeline:

  • July 2017: HFSS product advertising restrictions introduced
  • October 2022: In-store and online display restrictions for HFSS products implemented
  • October 2025: BOGOF and multibuy restrictions came into force
  • January 2026: New LHF TV and paid online advertising restrictions launched

And we’re not done yet. From 1st January 2028, the Soft Drinks Industry Levy threshold will lower from 5g to 4.5g of total sugars per 100ml, and milk-based drinks with added sugar will be brought into scope.

Understanding the Three-Tier Food Advertising System

Right, here’s where it gets a bit messy. There are three overlapping sets of advertising restrictions that food and drink brands need to work through. Understanding how they work together is crucial for compliance.

Tier 1: Existing HFSS Restrictions Since 2017

What qualifies as HFSS? Products scoring 4+ points for food or 1+ points for drink on the Nutrient Profiling Model (NPM).

Key HFSS advertising restrictions:

  • Cannot be advertised in media where more than 25% of the audience is under 16
  • Cannot appear in or adjacent to TV programmes likely to appeal to under-16s
  • Outdoor ads should avoid placement within 100m of schools

Content restrictions for ads targeting under-12s:

  • No promotional offers
  • No licensed characters or celebrities popular with children (equity brand characters owned by the brand are still fine)

Tier 2: New LHF Restrictions Since January 2026

LHF is a sub-category of HFSS with stricter advertising restrictions:

What qualifies as LHF? Food and beverage products that both:

  • Fall into specific LHF product categories (soft drinks, snacks, cereals, confectionery, ice cream, cakes, puddings, etc.)
  • Score 4+ points for food or 1+ points for drink on the NPM

Where are LHF ads restricted?

  • On television between 5:30am and 9:00pm
  • In on-demand programme services between 5:30am and 9:00pm
  • In paid online media at any time

This last one is the killer for food marketing strategies. Unlike HFSS rules which focused on audience composition, LHF advertising rules create blanket bans on paid online advertising including social media for specific identifiable products. It’s a significant shift for UK food brands.

Tier 3: General Children’s Advertising Rules

Beyond HFSS and LHF compliance, broader rules protect children:

  • Ads must not condone unhealthy lifestyles or poor dietary habits
  • Can’t encourage excessive consumption or disparage good dietary practices
  • Must maintain age-appropriate messaging and tone

The crucial bit: these three tiers work together. A food and drink advertisement might tick the LHF compliance box but still breach HFSS placement restrictions or general children’s protection rules. So, you need to consider all three.

LHF Advertising in 2026: What’s in Scope vs. Out of Scope

For an ad to fall under LHF restrictions, it must satisfy ALL of these:

  • Be identifiable as a specific LHF product: Would an average consumer recognise the ad as promoting a specific less healthy food product, either through direct depiction or imagery/branding uniquely tied to that product?
  • Be placed in restricted media: TV (5:30am–9pm), ODPS (5:30am–9pm), or paid online (including social media)
  • Be from a non-SME advertiser: Small and medium enterprises are exempt from LHF advertising restrictions

The Identifiability Test for LHF Compliance

This is where food and beverage marketing gets nuanced. The ASA assesses whether the average consumer would recognise your ad as promoting a specific LHF product, even if it’s not explicitly shown. They consider:

  • Pack shots, logos, brand characters tied to one product
  • Flavour-specific imagery (orange chocolate, strawberry yoghurt)
  • Music, colours or themes identifying a specific LHF product
  • Realistic imagery indistinguishable from an LHF product
  • Brand names identical to product names (unless established before July 2025)

Your Safe Zones: Major Exemptions from LHF Advertising Restrictions

1. Out of Scope Media

These channels remain unrestricted for food and drink advertising:

  • Outdoor advertising (although HFSS states that outdoor ads should avoid placement within 100m of schools)
  • Radio
  • Cinema
  • Print
  • TV after 9:00pm
  • Organic social media (owned channels, no paid promotion)
  • Own websites and apps
  • B2B / professional closed loop communications like email or trade websites

2. Brand Advertising Exemption

This is your golden ticket for LHF compliant marketing. Ads can promote a company, master brand or range of food and beverage products provided they don’t depict a specific LHF product.

What qualifies for the brand exemption?

  • Single logo-based brand awareness
  • Product promotion using generic imagery (e.g., raw ingredients)
  • Product promotion using non-LHF variant imagery
  • CSR campaigns without product focus

3. B2B Advertising and Non-UK Audiences

Both business-to-business food marketing and advertising not targeted at a UK audience is also exempt from the LHF restrictions, assuming it is clear that the messaging and imagery is targeting a professional audience.

Your Danger Zones: What to Absolutely Avoid in LHF Advertising

Clear Red Flags in restricted media:

  • Pack shots of specific LHF products
  • Imagery or characters representing specific less healthy food products
  • Music, colours, logos or flavours uniquely identifying a specific LHF product
  • Using similar non-LHF products to represent LHF products

The Grey Areas in Food and Drink Marketing:

Recipe content: Generally acceptable as consumers must make it themselves rather than purchase it ready-made. LHF products can appear alongside non-LHF ingredients, but you can’t prominently feature a specific branded LHF product, particularly if you’re the brand owner.

Coupons: Acceptable for LHF products provided the coupon itself doesn’t depict a specific LHF product. If a specific less healthy food product is prominently visible on the coupon, that’s not acceptable under LHF compliance rules.

Influencer gifting: Payment has an incredibly broad definition under these advertising restrictions. Even gifting products without obligation likely constitutes payment if there’s an expectation of content being created, therefore it would fall under paid and not be allowed if shared outside of your own channels (posting on your own channels is however allowed).

Finding Creative Freedom: Where the Opportunities Are for Food Brands

Alright, here’s where it gets exciting. Despite everything we’ve just covered, there’s genuinely enormous creative potential for food and beverage brands willing to think strategically. The secret? Stop mourning what you can’t do and start exploring what you can under LHF regulations.

Master Brand Advertising

Build food marketing campaigns around your brand and not specific products. Think emotional storytelling that evokes feeling rather than features. CSR initiatives that demonstrate values. Generic ingredient imagery. Lifestyle moments. Brand heritage stories that remind people why they fell in love with you in the first place. Here’s the beautiful thing: LHF restrictions are on what you show, not how you make people feel. Emotional resonance, humour and compelling narratives build brand love without depicting specific products. Its time to go back to the Mad Men days of tapping into the emotion you want to evoke not the nuts and bolts of what you are selling.

Leverage Unrestricted Media

Outdoor (not close to schools), radio, cinema, print and post-9pm TV remain completely unrestricted for food and drink advertising. This is your playground. Go bold. Beyond paid advertising, earned media is also exempt from LHF restrictions: PR coverage from press releases, editorial features and news stories all sit outside the regulations. PR stunts, brand activations, experiential marketing, sampling campaigns and live events also remain wide open. These channels offer opportunities to create buzz, generate word-of-mouth and build brand presence without the constraints of paid digital advertising restrictions.

Build Organic Social Communities

Your owned channels are unrestricted under LHF advertising rules. Focus on growing organically through social competitions, user-generated content, community-building, valuable long-form content and interactive experiences that give people a reason to engage. You can still work with influencers on a paid-for basis, but the content created can ONLY be posted on your owned channels.

Storytelling Over Product Shots

Here’s the beautiful thing: LHF restrictions are on what you show, not how you make people feel. Emotional resonance, humour and compelling narratives build brand love without depicting specific less healthy food products. Some of the most effective food and beverage advertising is the stuff that stays with you because it makes an emotional connection.

Our Take: Why This Could Actually Be Good for Food Marketing

Here’s something we genuinely believe at our food marketing agency: before these LHF regulations, too much food advertising was lazy. Show the product, slap a logo on it, job done. The new LHF advertising restrictions force food and drink brands to work harder to build emotional connections, tell better stories and create genuine brand value beyond product features.

Some of the most iconic advertising never showed the product. Guinness’s Surfer with the horses. Countless Coca-Cola brand-building campaigns. These LHF compliance requirements are pushing the food and beverage industry towards that kind of creative and emotive thinking, and that’s not necessarily a bad thing for UK food brands.

Yes, the LHF compliance burden is real. Yes, it requires expertise in food and beverage marketing. But for brands willing to invest in strategic, thoughtful creativity, this is an opportunity to stand out. The food and drink brands that will thrive are those that view these LHF rules not as barriers, but as guardrails helping them build something more meaningful. Not to mention a positive step to address our national obesity crisis and improve the health of our children.

Ready to turn LHF advertising constraints into creative opportunities? Let’s talk. Get in touch to discuss how we can help your food and beverage brand thrive in this new (and ever-evolving) era of UK food marketing.

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Disclaimer: Content correct at time of publishing on 21.01.26. This does not constitute legal advice. We strongly recommend seeking independent legal counsel for your specific circumstances. 

Liv Martin
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