Our response to the Government’s HFSS advertising policy
The government’s decision to restrict advertising for high fat, sugar, and salt (HFSS) foods marks a major shift in public health policy, aiming to curb the UK’s rising levels of obesity, particularly among children, protect vulnerable communities, and reduce the financial burden of diet-related illness on the NHS.
This overview outlines the key areas of support, constructive criticism, and actionable recommendations proposed by Think Through Nutrition. Our response highlights both the strengths of the policy and opportunities for improvement to ensure it is fair, evidence-based, and impactful.
The policy in context
The HFSS regulations target three main areas:
In-store promotions: Restrictions on the placement of HFSS foods in prominent locations.
Volume-based pricing: Limitations on multi-buy deals such as “buy one get one free.”
Advertising: A ban on HFSS marketing online and before 9pm on television.
Thirteen food categories are included under these regulations, ranging from breakfast cereals and confectionery to savoury snacks and ready meals. Only products deemed “less healthy” under the Nutrient Profiling Model (NPM) are subject to restrictions, based on their score for both “positive” (e.g., fibre, protein, fruit, vegetables, nuts) and “negative” (e.g., sugar, salt, saturated fat) nutrients.
The intention is clear: limit children’s exposure to unhealthy foods while encouraging healthier eating habits. However, it is essential to look at how this policy will operate in practice and the broader implications for public health and consumer behaviour.
Strengths of the HFSS policy
Addressing childhood obesity: Evidence strongly supports the role of advertising in shaping food preferences, particularly among children. Restricting HFSS advertising could help reduce children’s calorie and sugar intakes and create healthier food environments.
Clear categories: By focusing on specific food categories and their nutrient profiles, the policy provides a structured approach to identifying less healthy products.
Systemic action: The policy acknowledges that diet is influenced by factors beyond individual choice, including marketing and food industry practices.
Challenges of the HFSS policy
Risk of overgeneralisation: The NPM is a blunt tool that may categorise nutrient-dense foods, like porridge oats, alongside genuinely unhealthy products. For example, processed variations of porridge may exceed the threshold, sending a misleading message about inherently healthy staples.
Unintended consequences: Products with health benefits, such as fortified yoghurts for children (valuable sources of calcium and vitamin D despite containing small amounts of sugar), may be unfairly penalised under the current system. This risks discouraging foods that can be part of a balanced diet.
Limited scope: While the policy includes online advertising and TV before 9 pm, it excludes outdoor advertising (e.g., billboards, bus stops, train platforms), overlooking a significant driver of consumer behaviour, particularly in areas with high footfall where children are frequently exposed to marketing (e.g. on the way to school or during daily activities).
Potential solutions
Refining the Nutrient Profiling Model (NPM)
One way to address the limitations of the NPM is to combine detailed nutrient profiling with intuitive visual cues. Singapore’s “Healthier Choice” symbol provides an excellent example. This system grades products from “A” (healthiest) to “E” (least healthy) and uses simple logos with brief explanations like “lower in sugar.” Such visual cues reduce the cognitive burden on consumers, making healthier choices more accessible in fast-paced environments.
The UK’s traffic light labelling system, while informative, requires interpretation of percentages relative to Recommended Daily Allowances (RDAs). A simplified and standardised symbol could make healthier options easier to identify, particularly for time-pressed families. This approach would help in the recognition of healthier choices and also prevent the dismissal of slightly less “perfect” but nutrient-dense options, such as lightly sweetened kids’ yoghurts, as viable choices.
Comprehensive advertising restrictions
Expanding restrictions to include outdoor advertising would ensure a more consistent and impactful reduction in HFSS marketing exposure. This is especially relevant for children who encounter these ads on their way to school or during other daily activities. Conversely, increased advertising of certified healthier choices and its associated symbol (if implemented) is crucial in building awareness and influencing purchase choices especially for those in younger age groups. Policies must create an environment that nudges healthier choices through all available channels.
Broader support for healthy eating
The success of advertising restrictions hinges on addressing systemic barriers to healthy eating, including:
Affordability and accessibility: Ensuring nutritious foods are affordable and readily available to all households.
Education and guidance: Supporting families with clear, evidence-based information about making healthier dietary choices.
School and community initiatives: Promoting healthy eating habits through programmes in schools, hospitals, and other community settings.
Balancing regulation with realism
Policies must strike a delicate balance between reducing exposure to genuinely harmful products, like confectionery and sugar-sweetened beverages, and supporting realistic, sustainable dietary improvements. Encouraging gradual and mindful shifts towards selecting “better” options, even if not “perfect,” can achieve more meaningful results than demonising entire food groups. For example, while plain Greek yoghurt may be the gold standard, slightly sweetened options remain a far better choice than sugary desserts.
The bigger picture
Diet-related ill health costs the UK an estimated £268 billion annually, a burden exacerbated by an NHS in crisis. Transforming the nation’s dietary habits requires a multifaceted approach, including:
Systemic change: Reforming food industry practices to prioritise health over profit.
Sustainable nudges: Combining advertising restrictions with tools like simplified labelling and positive reinforcement for healthier choices.
Holistic policies: Integrating advertising restrictions with broader strategies that address affordability, education, and community support.
Conclusion
The government’s HFSS advertising restrictions present a significant opportunity to address the UK’s diet-related health challenges. However, for these measures to be truly effective, they must be part of a larger, cohesive strategy that tackles systemic barriers to healthy eating while avoiding unintended penalties for nutrient-dense foods. By refining the Nutrient Profiling Model, expanding advertising restrictions to outdoor spaces, and ensuring healthier products are both affordable and accessible, we can create an environment where healthier choices are the easier choices.
Call to action: To achieve lasting impact, the government must refine the nutrient profiling system, broaden advertising restrictions, and champion systemic change Think Through Nutrition urges policymakers to prioritise practical, evidence-bases solutions that make healthy choices accessible and achievable for all.
Closing statement: With the right balance of regulation, education, and industry reform, we have a unique opportunity to create an environment where healthier choices are the easier choices. Think Through Nutrition stands ready to support the government’s efforts to build a healthier future for all.
Written by
Melanie Wilkinson, RNutr
Scientific Research Manager