What is the new law on less healthy food in the UK?

Key takeaways

• New LHF advertising laws take effect in January 2026, with a voluntary compliance period from October 1, 2025.
• Paid social and influencer activations featuring identifiable LHF products are prohibited. Even brand-led ads must avoid naming or showing LHF items.
• To stay compliant, marketers must run audience checks, implement validation workflows and include LHF and HFSS clauses in contracts.

What are the restrictions on advertising less healthy foods in the UK?

The UK restrictions now prohibit all advertising for a designated group of less healthy foods. The UK government has tightened its controls on unhealthy food advertising in an effort to reduce childhood obesity rates, which have risen since the COVID-19 pandemic.

Earlier regulations restricted advertisements for foods and drinks high in fat, sugar, or salt (HFSS), with a specific focus on content aimed at under-16s. However, in the latest updates, the government has introduced a new subcategory within HFSS: LHF. 

LHF products face stricter placement and promotion limits, especially across paid social and influencer marketing.

Which bodies oversee regulations around LHFs?

Here are the regulatory bodies that oversee HFSS and LHF regulations:

• Ofcom sets and enforces broadcast rules for TV.
• The Advertising Standards Authority (ASA) handles complaints and checks whether brands comply with guidelines.
• The Committee of Advertising Practice (CAP), a sister body of the ASA, is responsible for creating advertising codes.
• The Influencer Marketing Trade Body (IMTB) works closely with other advertising bodies to provide guidance, outline best practices and help the industry comply with regulations.

What are LHFs?

Less healthy foods (LHFs) are unhealthy food or drink products that are high in fat, sugar, or salt (HFSS) while being low in beneficial nutrients, such as protein, fibre, fruits, nuts, or vegetables. To be classified as an LHF, a product must also fall under one of the UK government’s 13 defined “junk food” categories, as determined by the UK’s Nutrient Profiling Model. 

The meaning of food advertising regulations: What is the difference between HFSS and LHF?

An HFSS is a food or drink that is high in fat, sugar, or salt. LHF products are a subset of HFSS products that regulators believe have the most significant impact on child obesity. 

It’s worth really understanding the difference between these two distinct nutritional classifications, as the rules surrounding them vary significantly 

Under advertising rules, influencers cannot promote HFSS products if:

• 25% or more of the influencer’s audience is under 16
• The promotional content includes under-16s 
• The ad uses characters or themes that appeal to children
• The ad contains discounts or offers, such as buy-one-get-one-free

HFSS rules apply only when the content counts as advertising under ASA definitions.

An LHF is an HFSS that also falls under one of the 13 government-defined categories of unhealthy foods. 

Regulators view LHFs as particularly problematic. As a result, they face tighter advertising restrictions and brands can no longer pay to promote them on social media. 

Given that HFSS products are subject to less stringent rules than LHFs, it’s worth pinpointing exactly where your products fall within the classifications. 

What are the new advertising regulations in the UK for 2025?

Here are the new UK rules around LHFs coming into force on 5 January 2026:

• TV and on-demand: Broadcast and on-demand services must not include advertising or sponsorship for LHF products between 5:30 a.m. and 9:00 p.m.
• Online and social media: Paid-for online advertising of identifiable LHF products aimed at UK users is prohibited at all times. This includes display ads, paid social, influencer marketing, native ads, programmatic and paid placements.

Promotions on your own channels and unpaid organic content are allowed. Brand adverts that do not make an LHF product identifiable are exempt. The legal test is whether a consumer could reasonably identify the ad as being for a particular LHF. 

What counts as “paid”?

Paid-for advertising includes monetary payments, affiliate commissions or any other incentive that could reasonably be seen as payment, such as free products or gifted tickets to events.

Put simply, if any content appears to be an ad, regulators will treat it as such.

Exemptions to LHF regulations

There are exceptions to LHF legislation that marketers must be aware of:

• Audio-only channels are largely unaffected. Podcasts, radio and music streaming services aren’t covered by the online paid-ad ban in the same way as visual content. However, it’s worth checking CAP and ASA guidance, as these channels still fall under HFSS regulations. 
• SMEs are exempt. The government has said the exemption will generally apply to firms with fewer than 250 employees. However, SMEs still need to adhere to promotional and placement guidelines.
• B2B activity is out of scope. Business-to-business advertising isn’t restricted—realistically, B2B brands aren’t marketing to children.
• Brand advertising exemption. Currently, ads that promote the overall brand and don’t identifiably show or name an LHF product are exempt unless the brand is intrinsically tied to LHFs. 

Expect these rules to keep changing. Regulatory updates are ongoing, so staying informed is crucial.

Where and when do these "junk food" restrictions apply?

The new regulations on unhealthy food have been in the works for a long time. Initially, they were set to come into force on 1 October 2025. However, the October deadline is now considered voluntary. The full ban will be enforced from January 5, 2026.

Which types of social media content are affected?

• Paid influencer collaborations
• Organic creator posts used by brands 
• Paid amplifications

In short, all paid online advertisements are restricted at all times. They also apply to any broadcast or live channels before 9 pm. 

How the new rules around unhealthy food advertising affect influencers in the UK

When the original HFSS regulations were introduced, brands increasingly turned to influencers to promote products. But the new LHF rules directly impact influencer content.

Restrictions that influencers must be aware of around LHFs include:

• No brand paid for content promoting LHFs 
• While you can promote the brand, don't name an LHF product or show it in packaging or out, including illustrations, animations or AI representations

Here are the rules influencers need to follow when promoting HFSS products that aren’t LHFs:

• Influencers cannot promote HFSS products with ads that include under-16s (even influencers, actors or brand ambassadors) 
• Influencers cannot promote HFSS products if their audience is made up of 25% or more under-16s
• No discount codes or promotions, such as buy-one-get-one-free or loyalty programs
• Do not feature characters, celebrities or creators popular with children
• No “overconsumption” content, such as hauls, challenges or eating contests