By David Spinner, Industry Director of CPG at Teads
At the start of this month (October ’25), the UK Government’s long touted new regulations on advertising high fat, sugar and salt (HFSS) foods were introduced. While currently on a voluntary basis, in a matter of months (from January 5th, 2026) the new restrictions will be legally enforceable.Â
The rules will mean HFSS products can’t be shown on TV and streaming services before a 9.30pm watershed and nor can they appear on paid online advertising. But these rules are more than a compliance hurdle; they’re a catalyst to modernise planning, creative and media. Indeed, brands that act now will protect reach, preserve equity and unlock growth as the restrictions roll out.
Where some see restrictions, others see opportunities. Working closely with CPG brands navigating HFSS, it’s the ones preparing early by mapping portfolios and testing compliant creative are already finding new ways to grow despite the restrictions. There are four elements to the approach.
Future-proof the strategy
Start with mapping your portfolio and create a living SKU matrix by HFSS status. This involves mapping status – HFSS/non-HFSS/reformulation – against role, penetration driver/trade-up/seasonal hero etc. Brands can then instantly clarify which products can be advertised freely, which ones need timing constraints added, and for which, reformulation can be a lever of change.
Introduce a two-track creative system. One is brand-led (compliant anytime), involving storytelling around a masterbrand or range without showing an identifiable HFSS product. Instead, the focus should be on provenance, craft, occasions or responsibility. The second track is product-led (conditional) for specific HFSS items, planned around permissible windows (for example, TV/BVOD post-watershed) and compliant channels.
Planning should be anchored to demand rather than calendars, with bursts of activity aligned with seasonal and cultural signals. Think Sunday peaks, festive phases, sport and entertainment, rather than rigid media schedules.
To ensure maximum flexibility, if compliance guardrails are baked into briefs, contracts and trafficking, creative swaps or timing shifts can easily happen without renegotiation as HFSS guidance evolves.
What this looks like in omnichannel execution
Start by owning the biggest screen and then extend. For instance, CTV/BVOD delivers cinematic attention and signals quality while premium open-web video and display extend reach, sustain salience and strengthen associations in quality editorial.
Sequencing the story means you can keep distinctive brand codes consistent across every format. So, leading with CTV builds desire, which can then be reinforced with cutdowns, high-impact display and contextual partnerships.
Timing and controlling exposure are central to this stage. By using time windows smartly, brand-led work will fuel salience as well as launches across channels, while product-led activations can focus on regulatory-compliant windows that fit with retail cycles and seasonal peaks. Effective reach should be prioritised over volume – so be ready to cap frequency, manage overlap and favour high-attention supply – and in that way, each impression works harder for the brand.
Precision targeting in a post-HFSS world
Where once performance ruled the roost, in a post-HFSS world it is context. Replace fragile third-party audience hacks with contextual intelligence; category adjacencies such as recipes, gifting, entertainment; seasonality, sentiment and publisher affinity. Context ensures relevance and compliance simultaneously.
Use first-party data sparingly but smartly. CRM and retailer partnerships are a source for modelling and measurement, not endless micro-targeting, and brands will be better served by keeping cohorts broad, consented and transparent.
To determine if you’re being compliant, consider whether a less-healthy product is identifiable. Pressure-test creative executions before airing and if there’s any doubt, default to brand-led. In addition, curated, brand-safe publishers and inclusion lists reduce invalid traffic and guarantee ads are seen by real people in trusted environments.
Collaborative creative development
Creative strategy has never been more vital than in the post-HFSS world. Whether you are relying on existing creative that needs to be split from a brand versus product orchestration, or you are launching an entirely new creative approach, testing and learning are key to ensuring your brand continues to grow.
For post-watershed, HFSS product advertising, optimising assets to generate the most amount of impact possible will be key to drive cut-through.
With new testing capabilities using AI, there is the opportunity to do this quickly & efficiently whilst aligning with other measurement requirements.
Measuring proves it works
Success can only be determined if results are measured, but you need to define success upfront. For brand goals, focus on deduplicated reach, incremental reach points, attention/quality exposure, and brand lift (recall, favourability, consideration). Where possible, connect these to retail outcomes or MMM inputs.
Cross-media measurement will clarify what each channel truly adds, particularly CTV and premium open-web alongside walled gardens. To validate your mix of brand-led vs product-led executions use A/B or geo designs. When something works, bake it into playbooks and packaging. And finally, governance matters so keep a compliance log of creative signoffs, channel/timing approvals and screenshots of live placements. Make approvals frictionless for legal and agency partners.
The mindset shift
HFSS doesn’t mean smaller ambition; it means smarter ambition. Success will come from brand-first storytelling on the biggest screen, extended into premium contexts; product-led work, carefully timed and compliant; and media measured on quality exposure and incremental reach, not raw volume.
Brands that embrace this mindset will enter 2026 stronger; they will have cleaner supply chains and repeatable models for growth, ready for whatever the rulebook demands next.
