How to rethink visibility as HFSS advertising bans take effect

Key takeaways:

• From January 2026, HFSS advertising bans sharply limit where bakery and snack brands can promote less healthy products, particularly across TV and paid digital media.
• Brand-only messaging, owned channels and retail media are becoming critical as appetite-led product advertising disappears from many high-impact spaces.
• The restrictions are pushing producers to rethink product mix, reformulation and creative strategy at the same time, not as separate decisions.

January 5, 2026 has been hanging over the industry for a long time. This morning, it stops being theoretical. From today, the UK’s restrictions on advertising foods high in fat, salt or sugar are fully enforceable – and for bakery and snack producers, the implications go well beyond pulling a few ads.

The policy aim hasn’t changed: To reduce exposure to advertising for less healthy food, particularly where children are likely to see it. What has changed is the commercial reality. Categories built on familiarity, indulgence and repetition – from cakes and cookies (biscuits) to potato chips (crisps), bars and sweet snacks – now face hard limits on where they can show up, even when demand remains strong.

Most large producers have already adjusted course. Since October, voluntary compliance has stripped HFSS-heavy campaigns out of TV schedules and digital plans. Creative has been reworked, media buys reshuffled, launches delayed or softened. But until now, there was still a sense of transition. From today, there isn’t.

For bakery and snack brands alike, this lands awkwardly. Many of the sector’s best-selling products were never designed to be marketed quietly. Visual appeal, familiarity and impulse have always done the heavy lifting. Now, in many of the most effective channels, that appeal can’t be shown at all.

What’s now off-limits

The sharpest change is online. From today, paid-for digital advertising for identifiable less healthy food and drink products is banned in the UK. Social media ads, paid search, display, online video, influencer activity where payment is involved – all are caught if the product falls in scope. That affects everything from iced cupcakes and chocolate cookies to flavored potato chips and confectionery-style snacks.

TV remains available, but only just. HFSS advertising is now restricted to post-9pm on UK broadcast and regulated on-demand services. For brands that relied on daytime and early evening slots to drive reach, frequency and seasonal momentum, that’s a meaningful loss of scale.

Whether a product is restricted comes down to the nutrient profiling model. Products scoring above the fat, salt or sugar threshold – and sitting in defined categories – are classed as less healthy. That leaves many mixed portfolios split. One SKU can still be advertised freely, another effectively silenced, even though shoppers see them as part of the same brand family.

Enforcement now sits squarely with the Advertising Standards Authority, with Ofcom providing statutory backup for broadcast. Early rulings will matter across both bakery and snacks. They’ll shape how cautious brands feel they need to be and how much creative risk survives the first wave of complaints.

The rise of restraint

This isn’t a total shutdown. Brand-only advertising remains allowed, provided no identifiable HFSS product appears. On paper, that sounds like flexibility. In reality, it’s narrow ground for marketers.

A familiar pack outline. A distinctive product shape. A background shot consumers immediately recognize – whether that’s a croissant silhouette or a ridged potato chip. Any of these could be enough to tip an ad into non-compliance. For now, most brands are playing it safe as they wait to see how tightly regulators interpret ‘identifiable’.

There are still channels left standing. Audio-only formats, such as radio, sit outside the ban and remain relevant for both impulse snacks and everyday bakery items. Digital out-of-home remains untouched, keeping brand presence alive in transport hubs, forecourts, convenience stores and retail media environments. Owned channels – websites, organic social and CRM – aren’t restricted by the paid online rules, though existing advertising standards still apply.

What’s changing fastest is instinct. Bakery and snack marketing has always leaned into appetite. Now, many teams are being pushed toward abstraction – talking about moments, values, texture, enjoyment or brand purpose without showing the food itself. That’s unfamiliar territory for categories built on visual temptation, and not every brand will find it comfortable.

Why this isn’t just a marketing issue

The advertising restrictions don’t sit in isolation. They bleed straight into product strategy.

Brands with lower-sugar, higher-fiber or portion-controlled lines now have more room to stay visible in paid media. Those without them may find growth harder to sustain, regardless of underlying demand. Over time, that dynamic is likely to influence reformulation priorities, innovation pipelines and which SKUs get investment.

Retail dynamics are shifting, too. As national advertising options narrow, the spotlight moves further instore; toward price, promotions, private label and retailer-controlled media. For branded suppliers, that puts added pressure on margins, differentiation and shelf storytelling.

There’s also an uneven edge to the rules. They apply mainly to larger businesses, leaving smaller producers with greater advertising flexibility. That could quietly favor challengers and regional brands online, while multinationals absorb the compliance burden.

All of this flows from legislation rooted in the Health and Care Act 2022, but the consequences are commercial, not legal. From today, bakery and snack brands are operating in a market where what they make – and how they’re allowed to talk about it – are more tightly linked than ever.