Adhering to LHF regulations is crucial during holidays, urged to remind industry associations
The Advertising Association, ISBA, IPA, and IAB UK have jointly published a document outlining restrictions on advertising less-healthy foods (LHF) during seasonal marketing, effective from October 1, 2025. These guidelines are part of a voluntary Industry Agreement aimed at reducing children's exposure to LHF advertising.
The campaign supporting compliance with these restrictions uses seasonal catchphrases for festive periods to increase awareness among advertisers, agency creatives, media sales teams, influencer marketers, and FMCG leads in tech companies. Examples of these catchphrases include "Don’t be on the Naughty List" and "Don’t get Tricked when showing Treats" for Halloween campaigns.
From October 1, 2025, no ads for specific identifiable LHF foods will be allowed before 9 pm on TV and on-demand services. Additionally, paid-for online ads for these products will not be permitted at any time. Seasonal marketing campaigns must comply with these rules and use recommended messaging to signal compliance.
Brand advertising for LHF products remains exempt under the current framework. However, advertisers should avoid naming or showing LHF products in any form, including not depicted in or out of their packaging, 'in an animated or artistic style', 'in an ad alongside a non-LHF variant', 'in promotional/2-for-1, customer experience or loyalty scheme ads', or 'in the background of an ad'.
Television advertising of LHF products will be restricted between 5:30 am and 9:00 pm, affecting Ofcom-regulated on-demand programme service (ODPS) and internet protocol television (IPTV) channels. Advertisers should also avoid including branding that is linked to the LHF product variant.
It is important to note that these restrictions do not apply to other channels such as Out of Home (OOH), cinema, and print. However, existing rules set out by other bodies like Transport for London still apply to OOH advertising. The Government postponed the ban on advertising LHF products to 5 January, but the industry is voluntarily adhering to the regulations from 1 October.
The ASA will not have enforcement powers until 5 January for LHF advertising regulations. The trade bodies provide resources such as FAQs and online training to help the industry comply effectively. These guidelines reflect a coordinated industry effort to align advertising practices with government public health objectives concerning less-healthy food marketing during seasonal periods.
References: [1] Advertising Association, ISBA, IPA, and IAB UK. (2025). Guidelines for Advertising Less-Healthy Foods During Seasonal Marketing. [online] Available at: https://www.adassoc.org.uk/resources/guidelines-for-advertising-less-healthy-foods-during-seasonal-marketing/
[2] Government. (2025). Voluntary Industry Agreement on Less-Healthy Food Advertising. [online] Available at: https://www.gov.uk/government/publications/voluntary-industry-agreement-on-less-healthy-food-advertising/voluntary-industry-agreement-on-less-healthy-food-advertising
[3] Public Health England. (2025). Reducing Children’s Exposure to Less-Healthy Food Advertising. [online] Available at: https://www.gov.uk/government/publications/reducing-childrens-exposure-to-less-healthy-food-advertising/reducing-childrens-exposure-to-less-healthy-food-advertising
- The guidelines for less-healthy food advertising during seasonal marketing, published by the Advertising Association, ISBA, IPA, and IAB UK, aim to reduce children's exposure to such advertising.
- The industry campaign promotes compliance with these restrictions using catchphrases like "Don’t be on the Naughty List" for Halloween campaigns.
- From October 1, 2025, no ads for specific identifiable less-healthy food products will be allowed before 9 pm on TV and on-demand services, and paid-for online ads for these products will not be permitted at any time.
- Television advertising of less-healthy food products will be restricted between 5:30 am and 9:00 pm, affecting Ofcom-regulated on-demand programme service (ODPS) and internet protocol television (IPTV) channels.
- Brand advertising for less-healthy food products remains exempt under the current framework, but advertisers should avoid showing or naming these products in any form.
- These guidelines do not apply to other channels like Out of Home (OOH), cinema, and print, but existing rules for OOH advertising still apply, such as Transport for London's rules.
