What are the HFSS regulations and How are They Shaping Influencer Campaigns?

Understanding the HFSS and LHF Regulations

What is being banned? Key HFSS/LHF restrictions explained

On 5th January 2026, the UK government began enforcing its ban on advertising for ‘Less Healthy Food’ (LHF) products across licensed TV and paid online media.

The new rules stipulate that you cannot:

• Advertise LHF products before the 21:00 ‘watershed’ on Ofcom-licensed TV services
• Promote LHF products through paid online content at any time

A critical point is the promotion of the products that are banned. This means the product must not be identifiable. This includes:

• Product imagery & packaging
• Specific product names prominently featured
• Distinctive characteristics (including shapes, colours, and designs)
• Branding combos that signal to a specific product – excluding parent company logos

What are HFSS and LHF? Defining “Less Healthy” Products

HFSS stands for “high in fat, salt and sugar”. Any food or drink product can fall into this classification based on the application of the UK government’s Nutrient Profiling Model, which evaluates items on their nutritional content.

Food and beverage products gain and lose points based on their quantity of nutritional levels, including:

• Calories
• Sugar
• Salt
• Fat
• Protein
• Fibre
• Fruit and vegetable content

Similarly, products will lose points based on their levels of saturated fat, salt, and sugar, providing an overall score and determining whether a product falls within the HFSS bracket. For beverages, a score of 1 or less is qualified as an HFSS product. For food, products that score 4 or less are recognised as HFSS products. 

If a product meets a particular HFSS threshold score (which will differ depending on whether it’s a food or drink) and falls into one of 13 defined food categories, it is also defined as a ‘Less Healthy Food’ (LHF) and subject to the new advertising ban.

So, while your product might be HFSS, it’s only affected by the new restrictions if it’s defined as an LHF.

What products are affected?

Typical product types impacted by the new ban include high-sugar soft drinks, chocolate, ice cream, sweets, fast food, ready meals and other convenience foods like pizzas. That’s in addition to a number of products from wider categories that fall afoul of nutritional limits. 

A product being in one of these categories doesn’t automatically mean a ban, though. Low sugar versions or new formulations may allow products to fall outside of the HFSS threshold, meaning they can still be advertised as before.

Here are the 13 categories as laid out by the regulation:

1. Prepared soft drinks containing added sugar ingredients.
2. Savoury snacks whether intended to be consumed alone or as part of a complete meal
3. Breakfast cereals
4. Confectionery including chocolates and sweets.
5. Ice cream, ice lollies, frozen yoghurt, water ices and similar frozen products.
6. Cakes and cupcakes.
7. Sweet biscuits and bars based on one or more of nuts, seeds or cereal.
8. Morning goods, such as croissants, pains au chocolat and similar pastries.
9. Desserts and puddings
10. Sweetened (whether with sugar or otherwise) yoghurt and fromage frais.
11. Pizza (except plain pizza bases).
12. Roast potatoes, potato and sweet potato chips, fries and wedges, potato waffles, novelty potato shapes (such as smiley faces), hash browns, rostis, crispy potato slices, potato croquettes.
13. Any of the following:

• 1) Products that are marketed as ready for cooking or reheating without requiring further preparation and intended to be consumed as a complete meal.
• 2) Products, other than products that contain pastry, in or with a sauce (but not a marinade, glaze, dressing, seasoning or similar accompaniment) that are marketed as ready for cooking or reheating without requiring further preparation and intended to be consumed as the main element of a meal.
• 3) Breaded or battered products

Who’s affected?

Every type of business is required to comply with these new regulations, whether you’re a brand, a vendor, or an influencer.

If you don’t comply with the new rules, you could face enforcement action by the Advertising Standards Authority (ASA) and Ofcom.

Among influencers, food creators are going to bear the brunt of the new rules, as they won’t be able to put out bread-and-butter paid content types like tastings, product partnerships, and ingredient reviews. Creators who are typically aligned with HFSS products, like gaming influencers, will be impacted but could pivot towards other product verticals to make up for lost revenue.

Why have HFSS/LHF regulations been introduced?

The restrictions were introduced as a part of the Department of Health’s ongoing drive to reduce childhood obesity, with an ambition to:

• Halve childhood obesity by 2030
• Reduce the gap in obesity for children in the most and least deprived areas by 2030

Why Influencers Are Under the HFSS Spotlight

Restrictions on HFSS advertising for television, specifically targeting under 16s, or with high child viewership, have already been in place for some time. That’s alongside bans on celebrity or cartoon-character promotion of HFSS products to children, as well as limits on HFSS ads across websites and print media that have significant child audiences.

Influencers and social media marketing have, until now, been relatively unrestricted when it comes to advertising HFSS products to under-16s – something the UK government is keen to address. 

While influencers have a much looser association to the products compared to the companies themselves, they are increasingly the ones on screen and actively promoting them to audiences. Despite having a distinctly organic or editorial feel, the vast majority of influencer content falls under the remit of “paid-for advertising or promotion”.

These new rules are designed to bring online and influencer marketing in line with other media channels, as well as those applied to ‘legacy’ influencers. The government now fully recognises that social influencers and online creators are just as important and effective as celebrities, characters and mascots when it comes to advertising reach and impact. 

That understanding comes with clear consequences for influencers.

Specific Restrictions for Influencer Content

Regulatory changes can get complex, and sometimes feel hard to apply in the real context of ‘what can I post this week’- so let’s make this as simple as possible:

It affects paid promotion

Influencers – in almost all circumstances – are paid to work with brands. That doesn’t just mean money. Even if they’re given products, tickets, or any other kind of benefit for their involvement, it counts as ‘paid-for advertising’.

Even if the influencer isn’t receiving anything in return, if the content is ‘paid for’ by a brand in terms of its creation or display on social platforms, it counts as paid promotion and is therefore subject to the new rules.

It’s a product ban

So, while influencers will almost always find themselves in paid media, the ban only restricts the direct promotion of HFSS products in that space.

That means brand storytelling, abstract adverts, or other forms of creative content that do not feature the product are not affected – so influencers can be part of them without a problem.

What does this mean for influencer marketing?

When you put these things together, there are two key takeaways for influencer content:

• The HFSS product can’t be identifiable
• Brands and influencers need to get creative

The Future of Food and Beverage Influencer Marketing

Adapting Product & Content Strategy

Sharp limits have been placed on the type of content marketing that can be done for Less Healthy Food products, but there’s still endless scope for powerful, impactful marketing that indirectly leads to the sales you or your partners are looking for.

Brand storytelling

Without the product, brands themselves will have to do a lot more heavy lifting in the HFSS market. This means bringing brand values, brand history and cultural relevance to the forefront, and making them the new heart of your content.

This is naturally going to be much harder for brands with less defined identities, while established and multinational brands have a strong legacy of brand work (as well as higher creative budgets) to leverage.

Community Generated Content (CGC)

In today’s world, anyone can be an influencer. And in their own, small way, everyone who posts is an influencer.

While you can’t pay or give freebies to individuals to market your products, brands can still engage everyday users and encourage them to create organic content about your products.

Comedy and Reactivity

In certain HFSS verticals, like fast food, brands have already been waking up to the power of brand personification over straight product marketing. 

In markets where the products themselves are similar, humorous, conversational, witty interactions – often in direct, sometimes brutal response to users, or even rival brands – have proved a massive hit among Gen Z audiences on social media.

Don’t think you have to get on that level to do this, though. As every brand is unique, so its flavour of personification will be too.

Reformulated products

If you can’t conceive of a way to successfully pivot your content marketing approach, there are still other options.

One way to keep everything ‘just as it was’ is to reformulate your product so it falls under the thresholds for being categorised as a Less Healthy Food. That might be less sugar, less salt or fat, or fewer calories. These products could also benefit from additional nutritional contents including added protein and/or fibre.

Do that, and you can avoid all the recently applied restrictions altogether. 

Adapting to a Healthier Marketing Era

Key Takeaways for Brands and Influencers

For affected brands, these changes will probably overturn the entire influencer marketing strategy you have for certain product ranges. If you want to keep moving onwards and upwards, we recommend:

Make organic content rise again

You might not be able to use influencers anymore, but consider how you can make your brand itself more ‘influencer-like’. That might be by humanising the brand itself, or by platforming its leaders and employees.

Develop deeper messages

With direct product marketing out of the picture, you’ll need to focus on longer-term, deeper cutting brand messaging. Rather than trying to get your users to see and buy a particular product, you need them to buy into your brand.

Invest in your community

Your community of customers, users and followers are an ocean of untapped potential. Try seeing every single one of them as a super-micro-influencer. Think about how you can leverage them to tell your brand story, and further engage their peers through organic content and communication.

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At the Goat Agency, we don’t see regulatory changes as obstacles. We see them as creative challenges (and we love creative challenges).

If you need help adjusting your strategy and spotting the new opportunities unearthed by this seismic shift in advertising rules, get in touch.