HFSS GUIDE FOR MARKETERS AND INFLUENCERS

6 Jan

ARE YOU MARKETING HFSS PRODUCTS? KNOW THE RULES BEFORE YOUR NEXT CAMPAIGN.

The UK’s High Fat, Sugar and Salt (HFSS) advertising regulations came into force on 5 January, marking a major shift for food and drink brands, marketers and influencers. These rules significantly change how HFSS products can be advertised, promoted and positioned across media, retail and social platforms.

This HFSS guide for marketers and influencers explains what qualifies as an HFSS product, outlines the key advertising restrictions, and shows how brands and creators can deliver compliant, effective campaigns without risking penalties or reputational damage.

What are HFSS foods?

HFSS foods are identified using the UK Nutrient Profiling Model (NPM), which assesses products based on their nutritional content per 100g. The model scores items based on energy, saturated fat, total sugar, and sodium. These are balanced against positive elements such as fruit and vegetable content, fibre and protein. Products scoring above set thresholds are classified as HFSS and treated as “less healthy” for advertising and promotional purposes.

Examples of HFSS products:

Confectionery and chocolate.
Sugary drinks and energy drinks.
Crisps, savoury snacks, and processed foods.
Certain bakery items and desserts.

Correctly identifying whether a product is HFSS is the foundation of compliant marketing.

What are the UK HFSS regulations?

Regulations restrict how these “less healthy” products can be advertised and promoted. It is crucial for marketers and influencers because HFSS rules directly limit when, where and how you can promote many popular food and drink brands, especially to under‑16s and during peak media times. HFSS regulation is part of broader efforts to tackle obesity, particularly among children, where high consumption of energy-dense, nutrient-poor foods is linked to overweight and diet-related diseases. Policymakers target marketing and in-store visibility because these activities strongly influence purchasing behaviour, impulse buys and children’s food preferences.

HFSS advertising rules

UK HFSS regulations restrict the marketing of “less healthy” food and drink products, particularly where children are likely to be exposed.

The rules aim to reduce obesity and diet-related disease by limiting the influence of marketing on children’s food choices. Policymakers focus heavily on advertising, promotions and in-store visibility because these factors strongly affect impulse purchasing and brand preference.

For marketers and influencers, HFSS regulations directly impact:

Campaign planning.
Media buying.
Influencer partnerships.
Promotional mechanics.
In-store and experiential activity.

HFSS advertising rules explained

HFSS advertising rules place restrictions on paid advertising and prominent placement across multiple channels.

Key restrictions include:

Broadcast advertising: HFSS products cannot appear in or around children’s programming or restricted time slots.
Digital and social media: Paid ads and influencer content promoting HFSS products must not target under-16s.
Influencer marketing: Paid posts, sponsored content, and gifted collaborations are increasingly treated as advertising under HFSS rules and may therefore be restricted or prohibited, particularly where content is targeted at or likely to appeal to under-16s.
Retail and promotions: HFSS products face limits on prominent in-store placement and promotional mechanics.

As a result, brands must rethink their creative strategy, channel selection, and the role of influencers in HFSS campaigns.

How HFSS rules affect influencer marketing

Influencers remain a powerful marketing channel, but HFSS compliance is critical because many influencer collaborations are now classified as advertising under HFSS rules. Compliance depends on how content is targeted, disclosed and creatively executed.

Key requirements for creators include:

Clear disclosure of paid partnerships (#ad).
No child-appealing imagery, language or targeting.
Platform-specific compliance with advertising rules.

For example, a compliant campaign would be one in which an adult-focused lifestyle influencer shares a clearly disclosed HFSS brand partnership without child-focused cues. Non-compliant would be content targeted at under-16s or using cartoons, games, or child-appealing content.

The future of food and drink marketing under HFSS

Marketers are shifting spend toward non-HFSS ranges, owned channels, PR, and storytelling‑led campaigns that emphasise brand values, lifestyle, and wellness rather than overt product pushing of HFSS lines. Brands are also using influencers more in offline formats (for example, DOOH or events) where some HFSS rules are looser, while relying on organic, user‑generated content rather than clearly paid posts.

HFSS will push marketers and influencers towards authentic, long‑term community building, where brand love and lifestyle relevance matter more than short‑term promotional bursts.

Those who understand HFSS rules can turn them into a competitive advantage by investing early in compliance, audience data (to avoid under‑16s), and creative, story‑driven collaborations that remain powerful but stay on the right side of regulation.

Consequences of non-compliance

HFSS non‑compliance can lead to financial penalties, formal enforcement action, and serious reputational damage for brands, retailers, and agencies that promote high-fat, salt and sugar-rich products.

Non-compliance can result in:

Improvement or stop notices.
Financial penalties (commonly around £2,500 per breach).
Removal or cancellation of ads and media bookings.
Loss of retailer promotional privileges.
Public rulings that damage brand trust.
Loss of influencer or commercial partnerships.

Regulators, platforms, and retailers are becoming increasingly strict, making HFSS compliance a commercial necessity rather than just a legal one.

HFSS compliance checklist

Before Launch:

Confirm whether the product is HFSS using the NPM model.
Define target audience (exclude under-16s where required).
Select compliant channels and placements.

Creative & Content:

Avoid child-appealing imagery, language or formats.
Ensure influencer disclosures are clear and compliant.
Focus on brand storytelling over product-led promotion.

Media & Activation:

Check broadcast and digital restrictions.
Review in-store placement rules.
Ensure experiential activations follow location guidelines.

Post-Campaign:

Keep compliance records.
Review platform or regulator feedback.
Apply learnings to future campaigns.

How Creatisan helps brands stay HFSS compliant

Navigating HFSS regulations demands smart planning, creative thinking and operational precision.

At Creatisan, we support brands, retailers and agencies with HFSS compliant:

Experiential activations and sampling.
Influencer and creator campaigns.
Shopper marketing.
Retail marketing and in-store execution.
Fulfilment and promotional logistics.

By embedding compliance into creative strategy from day one, we help brands deliver impactful campaigns that engage audiences responsibly and protect long-term brand value.

If you’re planning an HFSS-sensitive campaign, our team can help you stay compliant without compromising creativity.

Frequently Asked Questions

Q: What is HFSS?

A: HFSS refers to food and drink products high in fat, sugar or salt, classified using the UK Nutrient Profiling Model based on nutrient content per 100g.

Q: Can influencers promote HFSS products in the UK?

A: Yes, but influencer content must comply with UK HFSS advertising rules, include clear disclosures and avoid targeting children.

Q: Are HFSS giveaways and competitions allowed?

A: HFSS giveaways and promotions are subject to the same advertising and placement restrictions as other HFSS marketing activity.

Q: Which channels are most restricted for HFSS advertising?

A: Channels aimed at children, including TV, digital platforms and social media targeting under-16s, face the strictest HFSS restrictions.

Q: How can brands stay compliant with HFSS regulations?

A: Brands should integrate compliance into campaign planning, use accurate audience data, brief influencers clearly and select appropriate media placements.

Sources:

ActivateInfluence

Lauren Vanderplank

HFSS GUIDE FOR MARKETERS AND INFLUENCERS

THE POWER OF EXPERIENTIAL