LHF rules mean more than compliance - they demand reinvention

The conversation around less healthy food (LHF) advertising is shifting from simple compliance to real responsibility. Rather than seeing upcoming restrictions as a setback, the industry is embracing them as a catalyst - a prompt to respond creatively and build trust with consumers. At a recent breakfast hosted by Campaign and Pinterest, the mood was clear: this is a pivotal chance for brands to do good, for both society and their business.

After nearly a decade of collaboration and consultation, LHF rules are set for a “good faith” launch in October, with full enforcement by January 2026. The details matter: no LHF ads before 9pm on TV and a 24-hour online blackout. It’s more than a media update. It's an open invitation for brands to rethink, reset and lead the way forward.

Those who adapt early will be best placed to strengthen loyalty, boost recall, and create positive change, delivering results that go beyond the bottom line.

Impact: will the new regs ruin Christmas?

It might be ice-cream weather right now but the marketing world is getting ready for Christmas and all the hopes and dreams that intense period offers for brands. 

And businesses with LHF products have already started to think differently.

Laura Boothroyd, UK and Ireland media director for Mars Wrigley, believes the regulations just accelerate or continue the diversification of the media landscape. “This enables us to look at different channel mixes,” she told the group.

“Out-of-home is something that we haven’t traditionally done much in and we’re looking to do more cinema. Audio is an exciting space for us as well and we’re looking to use print tactically. We’re looking holistically at all of the different channels.”

Stephen Woodford, CEO of the Advertising Association, urges a softly-softly approach, even in this “voluntary” period from October to January. “Advertisers and agencies have always pushed the boundaries. This case is one to be really cautious about – if in doubt, don’t do it.” 

Woodford’s strong advice to brands is that any short-term gain by flouting the incoming regulations would be undone by serious reputational damage. He also reiterated his assertion that legislation is a blunt instrument and that Sir Keir Starmer’s government had worked collaboratively and empathetically with the industry. “Self-regulation is much more agile and much more responsive than passing a law,” he added.

Creative execution: performance vs brand building 

One of the big debates is around what good creative ad content will look like for a brand that is firmly in the LHF space. 

Naureen Mohammed, CPG director at Pinterest, notes that the new regulations are prompting brands to revisit the balance between performance campaigns and long-term brand building, seeing opportunity in reaching audiences who are actively seeking inspiration and making decisions.

Jack Perlman, head of media planning at OMD, agrees with the principle but has cost concerns, certainly for TV ads. “We have to take this period really seriously and test into it,” he said. “The biggest TV shows will likely be post-9pm and that’s where some of your big brand building audiences are. If some brands can only advertise then, that will affect price. So brands will need to work out where the next best place is for them to deliver that impact. More brands will probably adopt more rigorous and detailed measurement.”

Shifting priorities: value of the PESO

Brand priorities are indeed shifting. Boothroyd admits she is “looking at all communication touch points now”, adding: “We’ve always been strong in the paid media space but what we're now focusing on is the PESO model (paid, earned, shared, owned), working out how we can bring that earned thinking up front, rather than it being a bolt on.”

That raises the issue of influencers and Jake Matthews, paid social business director for Coca-Cola at EssenceMediacom, part of WPP Media, urges brands to be “very vigilant in the influencer space”. Influencer content is, by design, less curated and more organic, which can leave brands exposed. “I’m working closely with our influencer team to make sure that we have a vetting process in place,” he said. “A lot of partners are introducing creative marketplaces where they can source creators.”

The new order: collaboration and centralisation

Collaboration is one of the buzzwords for brands as they seek to navigate this new reality. 

Ben Sonnenthal, business director at EssenceMediacom, part of WPP Media, describes the mapping out of new, end-to-end processes with Tesco, ensuring agencies and brands co-create briefs and solutions.

And at Galaxy, a period of experimentation has led to “centralised content approaches”, said UK brand director Romi Mackiewicz. She notes that it’s “quite challenging to get agencies to adapt to how we build ideas and a consistent story across everything.”

In fact, Matthews says, the UK regulation is forcing a rethink of how advertising is approached across the rest of Europe too. Teams that operated in silos are now being much more collaborative. “That’s really positive in terms of breaking down silos and making sure we have that holistic view,” he said. “The aim for us is as much consistency across Europe as possible.”

The new regulations will also encourage “a higher appetite for innovation”, believes Pinterest’s CPG lead Angus McLean, particularly in driving positive brand-led diversification within digital and social platforms such as Pinterest, where discovery and inspiration are already core to the experience.

Already, there’s “a lot more bravery and more single-minded approaches” from brands,  Mackiewicz told the table, noting out-of-home work from Kellogg’s, Heinz and McDonald’s. 

Ultimately, marketers are re-examining brand strategy as they navigate the new regulatory landscape - with a rethink of media strategy at the heart of it.

Curious how your brand can thrive under new rules? Reach out to your Pinterest team to explore tailored testing opportunities, or apply for a free ads consultation.