From January 2026, new UK advertising restrictions on products high in fat, salt and sugar (HFSS) will come into force. While the rules have been discussed for several years, their delayed implementation has lulled many brands into a false sense of security.

That delay is now over.

For marketers working in food, drink, retail, leisure and FMCG, the next 12–18 months will be critical. Decisions made now about media mix, creative strategy and measurement will determine whether brands adapt or scramble at the last minute.

Importantly, not all media channels are affected equally. Some will face significant limitations. Others remain unchanged. Understanding that distinction and acting on it early is where those clever advertisers will gain an advantage.

Brands like KFC will be impacted by the new regulations.

Let's start with a quick refresher. What are the HFSS rules?

HFSS refers to products deemed less healthy under the UK’s nutrient profiling model. From January 2026, advertising restrictions will apply across TV and online channels, designed to reduce children’s exposure to HFSS messaging.

The key changes include:

A 9 pm watershed on TV advertising for HFSS products
Paid-for online advertising restrictions, including social media and display
Greater scrutiny on targeting, placements and formats
A shift from voluntary compliance (from October 2025) to full enforcement in 2026

The new rules intend to reduce exposure, especially among younger audiences. But the practical impact for advertisers is more complex, particularly for brands that rely heavily on TV and digital performance media.

The problem with a TV-and-digital-first mindset

For many brands, TV and online channels sit at the heart of their media plans. That’s understandable because they offer scale, fame and (in the case of digital) easy reporting.

However, HFSS restrictions expose a weakness in narrow media planning.

When access to certain formats is restricted by time, targeting or content rules, brands that rely on a small number of channels lose flexibility. Campaign reach becomes fragmented. Costs increase. Planning becomes reactive rather than strategic - it's a recipe for poor outcomes.

This is where broader media thinking is totally necessary.

Out-of-home advertising

One of the most important and often misunderstood aspects of the HFSS changes is that out-of-home (OOH) advertising remains unaffected.

OOH has long operated under clear CAP Code rules and does not rely on behavioural targeting, cookies or personal data. It is a public, transparent medium, viewed by regulators as lower risk in terms of exposure control.

For advertisers navigating tighter restrictions elsewhere, this matters.

OOH offers:

Consistent reach across broad audiences
High visibility in real-world settings
Creative freedom within existing guidelines
Planning certainty at a time of regulatory change

Crucially, it allows brands to maintain presence and mental availability even as other channels become more constrained.

HFSS stands for High Fat, Sugar and Salt.

Why does this matter?

HFSS planning shouldn’t be treated as a legal exercise alone. It’s an opportunity to reassess how brands build themselves, not just a short-term response.

Advertising effectiveness research has long shown that brands grow by being consistently remembered, not by chasing immediate clicks alone. Restrictions on performance media may feel uncomfortable, but they also force a healthier balance between brand-building and activation.

OOH, audio, sponsorship, contextual placements and other broadcast-style channels play a vital role here. They don’t replace digital performance media, instead they complement it.

Brands that understand this now will be better placed to adapt creatively and commercially.

Creative considerations under HFSS

HFSS rules don’t just affect where you advertise; they influence how you communicate.

We expect to see:

Greater focus on brand-led creative rather than product-heavy messaging
Increased use of seasonal, contextual and location-based storytelling
Clever use of non-product cues such as brand assets, tone and distinctive design

This is where channels like OOH excel. They reward clarity, simplicity and memorability. When done well, they reinforce brand recognition without relying on overt product claims.

For many advertisers, this will require a mindset shift away from optimisation dashboards and towards creative quality and consistency.

Measurement still matters

A common concern we hear, though, is: “How do we measure effectiveness if digital options are limited?”

The answer is not to abandon measurement, but to broaden it.

HFSS-safe planning needs a more balanced measurement framework, including:

Share of search and brand search uplift
Footfall and location-based proxies
Brand tracking and awareness studies
Pre- and post-campaign surveys
Sales correlation over longer timeframes

This approach gives a more realistic picture of how media works together, rather than over-crediting the last click.

It also sits better with how real people experience advertising, which is generally across multiple touchpoints, not in neat attribution silos.

So what do we think advertisers should be doing now?

With 2026 approaching quickly, the worst thing brands can do is wait.

Here are five practical steps advertisers should be taking now:

1. Audit your current media mix
Understand how exposed your plan is to HFSS-affected channels. If TV and paid social dominate, the risk is high.

2. Test alternative channels early
OOH, audio and contextual placements shouldn’t be last-minute additions. Testing now will build confidence, benchmarks and learning.

3. Review creative strategy
Move towards brand-led creative that works across multiple channels.

4. Update measurement frameworks
Ensure success isn’t defined purely by clicks or short-term conversions. Build in brand metrics.

5. Plan for continuity, not disruption
Avoid going dark. Consistent presence matters more than ever.

HFSS restrictions will undoubtedly change how some brands advertise. But change doesn’t have to mean compromise.

Channels like out-of-home have always provided stability, reach and trust. In a more regulated advertising environment, those qualities become even more valuable.

At Hello Starling, we help advertisers navigate these changes. If you’d like to sense-check your 2026 plans, we’re always happy to talk.

Need some help navigating media plans?