Christmas may seem a long way away, but brands will already be rethinking their approach to festive ads in light of the upcoming restrictions on advertising less healthy food and drink (LHF) products, which will be banned on pre-watershed TV and all paid online advertising. And although enforcement has been pushed back to January 2026, advertisers and media owners have agreed to abide by the new rules starting in October 2025.
The exemption for brand advertising means that TV mainstays such as Iceland and M&S will still be on our screens come Christmas, but they will look different this year. For instance if they still want to feature celebrities gloating over heaving tables of baked goods, they will have to wait until after 9pm. And while many brands will showcase reformulated products that no longer fall under the scope of the regulation (PepsiCo for example has changed the Doritos recipe to make them compliant), others will shift their marketing strategies to focus on brand advertising.
“People will need to think more creatively, and there will be way more brand advertising,” comments Samira Brophy, Senior Director, Creative Excellence UK at Ipsos. “Then they’ll have to put the other pillars of their product advertising, such as promotions for particular flavours, after 9pm.”
She uses the example of McDonald’s eyebrows-based ‘Raise Your Arches’ campaign, which avoids showing any fast-food products. Aldi’s Kevin the Carrot is also safe from the regulation, providing he sticks to advertising vegetables. Nigella Lawson’s Greggs ad on the other hand, in which the celebrity chef extols the virtues of their festive bakes, would be strictly post-watershed.
Media pick ‘n mix modelling
But the regulation will also require agencies to get more creative with their media planning. For advertisers who want to show off their LHF products, out-of-home (OOH), audio, print and organic digital remain open to them under the new legislation, which could potentially move more performance budgets into those channels. For example if TV is doing more brand-building, OOH is well placed to do more of the product work, given the ability of the channel to drive consumers to nearby restaurants.
“This is going to force people to think about more of the campaign ecosystem, and how they can really maximise the different channels, and start to think about how everything is building the picture of the brand,” says Samira Brophy. “I think the big winners, like OOH, audio and channels like Spotify, are going to gain a lot more advertisers as a result. And it might end up being quite good for some of the publishers as well, at least the physical versions.”
Sinead Coogan Jobes, Head of Policy & Public Affairs at IAB UK, agrees that planners will require more diversity in their media plans, with digital out-of-home (DOOH) likely to play a key role.
“It’s likely that we will see a more diverse media mix for food and drink brands as advertisers rebalance campaigns to meet the restrictions,” she says. “That will mean rethinking the status quo and require advertisers and planners to think strategically about where spend is allocated post 1st October. But there are still options, whether that’s spotlighting healthier products, taking a brand-led approach, or targeting channels that are exempt from the ban like DOOH.”
And while the TV restrictions could result in significant loss of reach for some advertisers, Rhian Feather, Chief Planning Officer at media agency OMD UK, notes that evolving measurement products are helping planners resdistribute media spend across different channels.
“Media will be planned in the same way it always has been, it’s just the channels and the dayparts that some of that is possible in will have changed,” she comments. “Econometrics and testing will help us fill in some of the gaps and understand the role for each channel in the holistic plan.”
Video on the menu
The “biggest game-changer” however, according to Samira Brophy, are the restrictions on digital advertising, with all paid digital (including influencer content) falling under the scope of the ban. She argues that this could result in “more effective” social ads, as the channel becomes a hub for brand advertising, and advertisers seek greater returns on potentially higher investment. Social video could even start to look more like TV advertising, according to IAB UK, with 73 percent of all social display ad spend going towards video last year.
“We’re already seeing paid social advertising evolve with the ongoing rise of social video, allowing advertisers to execute brand-led campaigns in imaginative, creative and highly compelling ways,” says IAB UK’s Sinead Coogan Jobes. “Social video ads are perfectly placed to bring brand stories to life in a similar way to traditional TV spots. When it comes to using social as a brand channel, the introduction of the LHF ad ban is likely to further entrench that trend towards compelling video content.”
At the same time, the exemption for organic digital advertising means brands can still feature LHF products on their own websites and social media channels, so long as they have not paid to promote them.
“This could encourage more brands to think creatively about their social strategies to maximise the effectiveness and traction of organic posts, something supermarkets like Waitrose and M&S have been doing very effectively via an employee-led approach to content,” says Coogan Jobes.
OMD UK’s Rhian Feather suggests this opens up further opportunities for creativity in planning media between organic and paid digital channels.
“There is something interesting in the use of owned activity alongside paid-for advertising,” she says. “Out of any changes such as this come opportunities for creativity to create new rules.”
Waitrose for example used a serialised approach to their ‘Sweet Suspicion: A Waitrose Mystery’ ads at Christmas, a whodunnit about a mystery thief stealing a missing pudding. And although the ads showed products that would be restrictive, Brophy suggests the campaign points towards innovative ways in which brands can use different channels to tell a story under the new legislation.
“A whodunnit where the product is actually missing was a stroke of genius, and a good step in the right direction,” she says. “You could even do it in chapters where you don’t show the product on TV or paid digital, but then if you want to see what it is you’re pushed towards the brand’s website or socials, or OOH can complete the picture for you. So I think there’s going to be lots of exciting and creative thinking off the back of this.”
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