How Will The HFSS Ban Change Food Advertising?


Is this the end of an era for British food ads? As promised, Boris Johnson announced last week that restrictions on the advertising of High Fat, Sugar and Salt (HFSS) foods. The Government proposes a near-blanket online ban and a TV ban before the 9PM watershed – limits which would be some of the most severe in the world for food marketers. These proposed restrictions are still subject to consultation and won’t impact until the end of 2022.

The ad industry is pushing back hard, pointing out that the effectiveness of such a ban on people’s calorie counts will be minimal. But the high visibility and symbolic toughness of the ban is likely to carry it through, and the Government will hope for cascading effects as brand owners shift emphasis to products that don’t fall under the HFSS definition.

So is this doomsday for food advertisers? Not necessarily. A pre-watershed ban is nothing new – the drinks industry has dealt with one for years – and manufacturers have escaped the harder-line proposals which were floated, like forced debranding or a complete TV ban. Brand ads, and ads for non-HFSS products in the same ranges (like Coke Zero) are likely to escape.

But with the scope for advertising limited, effectiveness will be more important than ever. Food businesses will have to pull every creative lever to build brands and keep them top of mind once the new legislation hits. Advertising for food brands will be scarcer and more expensive.

The end of food porn?

So how can brands maximise effectiveness within this new dawn? At System1, we know and have proven that effective, high ROI advertising is advertising that generates positive emotion. For instance, in the UK breakfast cereals category – one of those which will be targeted by the ban – we found that adding emotional response to a share-of-voice model massively improved its ability to predict market share change. The more people feel, the more they buy. Our Test Your Ad Pro product is designed to measure emotional effectiveness and draw out the reasons.

The FaceTrace of System1’s Test Your Ad maps the increasingly positive emotional journey experienced by viewers throughout the Kellogg’s ad.

In the past, food brands and retailers have often fallen back on the “food porn” approach – showing tempting products and lots of them. That often scores well but may not be so effective post-ban – especially if the public agrees with the Government that HFSS brands carry some blame for a rise in obesity. And they may even tempt future lawmakers to attack the content as well as the timing of ads.

Fortunately, food brands have plenty of other options.

Creative routes to food advertising effectiveness

Advertisers have always found ways to make great ads without dwelling on the product. Cadbury’s classic “Gorilla” is a great example – not a sugary slab of chocolate in sight, but a 5-Star performer back in its day using cultural reference and metaphor to evoke joy.

So if brands do decide to back away from all those luscious product shots, what might they do instead?


Effective emotional ads often aim for a laugh, like last year’s lockdown classic from Maltesers with four friends talking home baking.


Long-running food brands can play on nostalgia and heritage. This Werthers’ ad from 2019 has plenty of product shots but doesn’t need them: the emotional core is in the tradition and taste of bygone days.

Great Stories

Putting your brand at the centre of an ad can mean showing how it fits into customers lives – no need for many products in this lovely story of a Mum and son from McDonalds from last November.


Nestle’s 2018 “Bubblophone” for Aero captures the idea of indulgence and delight in only 20 seconds – a great short ad that shows the power of an original idea.


All the great right-brained ways of making ads more effective work for food too – this year’s Kelloggs campaign makes brilliant use of Plastic Bertrand’s old “Ca Plane Pour Moi” hit, for instance.

Fluent Devices

Now might be a time for food advertisers to start working on characters they can reuse to build brand Fluency even with no products around – like this mole used by Ambrosia in last Autumn’s 5-Star ad.

Charity Work

Finally, we’d expect to see more UK brands emphasising their charity efforts and social responsibility – like Primula do in this simple 4-Star ad.

That’s just the tip of a mighty iceberg of food ads which don’t rely on gooey, sticky, salty, fatty, close-ups to be effective. We won’t pretend the new limits won’t be painful when they come in, but at System1 we believe that the sheer creativity of UK advertisers will find a way through.

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