Last updated: 10/09/2024
Restrict advertising of HFSS products
Restrict advertising for HFSS products: implement a 2100-0530 watershed for TV and online advertising, alongside strict limitations on online paid advertisements, as well as prohibiting all HFSS advertisements on public transport, including bus stops, train stations, and tube stations (via national regulation)
- Very high impact on obesity
A percentage estimate of how much the policy would reduce national obesity rates
- Relative reduction in obesity prevalence: 16%
- High evidence quality
A rating of the strength of evidence, accounting for both reliability and validity of the evidence
- Reliability and validity rating: 4/5
- High cost to governments
Cost to UK and devolved governments over 5 years
- Costs to governments over 5 years: £95m
- Benefit to governments per year: £10bn
What is the policy?
This policy restricts advertising of food and drinks classified as high in fat, salt, and sugar (HFSS). As outlined in government reports and previous localised policy implementations the policy would:
Introduce a 21:00 TV watershed for advertising HFSS products and a restriction of paid-for HFSS advertising online
This means all on-demand programme services (ODPS) under the jurisdiction of the UK, and therefore regulated by Ofcom, would be included in the TV watershed for HFSS advertising and non-UK regulated ODPS would be included in the restriction of paid-for HFSS advertising online because they are outside UK jurisdiction.
Introduce a national rollout of the restriction of all outdoor advertising of HFSS on public transport, as done in London.
This means advertisers who produce, sell, retail, distribute or promote food or non-alcoholic drinks must ensure the product featured is HFSS compliant (according to the Nutrient Profile Model). The restriction would apply to HFSS advertising on buses, bus stops, and railway and tram stations.
Recent context
Evidence suggests that HFSS foods and drink adverts can influence food behaviours by changing dietary norms and shifting population-level food and drink preferences. Advertising can affect adult behaviour as well as children’s food choices, resulting in pressure being put on parents to buy unhealthy foods.
The regulation of advertising in the UK is the responsibility of the Advertising Standards Authority (ASA). In 2007, Ofcom initiated a ban on TV advertising for HFSS products during children’s programming. Fully enacted by 2009, these restrictions prevent the airing of adverts for HFSS products during timeslots dedicated to children’s shows and around programmes that attract a significantly large young audience. Following an initial consultation in 2019, the UK Government announced its intention to extend these existing advertising restrictions and implement a 21:00 watershed on TV for advertising HFSS products in July 2020. The implementation of extended restrictions was initially scheduled for January 2023. It was postponed by a year and has now been further delayed to 1 October 2025.
Advertising laws are established for the whole of the UK and are not devolved. Accordingly, the context is the same in both Scotland and Wales. There are currently no regulations that restrict the advertising of ‘less healthy’ foods outdoors. The Welsh Government’s Healthy Weight, Healthy Wales strategy pledged to restrict unhealthy food and drink advertising, sponsorship and promotions in public spaces by 2030. This includes bus and train stations, sporting events, school zones, hospitals and leisure centres. The Scottish Government’s Diet and Healthy Weight Delivery Plan contains an action to engage with local authorities, transport companies and media agencies to develop a code of practice to restrict the marketing and promotion of HFSS, particularly to children. This has yet to be developed.
Case studies
HFSS advertising restrictions, Chile
Chile first passed a law to implement advertising restrictions on HFSS products in 2012. The restrictions, which include child-based and time-based components, are among the most stringent in the world. In the first phase (2016), HFSS adverts were banned in TV programming where children constitute at least 20% of the audience. In the second phase (2018), HFSS ads were prohibited on TV and during cinema screenings from 06:00 to 22:00.
An evaluation found the regulations to have considerably reduced children’s exposure to HFSS marketing. By 2019:
- Chilean children’s exposure to TV ads for regulated food and drinks had decreased by 73%
- TV advertising for unhealthy food and drinks decreased by 64%.
These restrictions were part of broader reforms, including mandatory front-of-pack warning labels on HFSS products, bans on promoting such products in schools and bans on child-directed marketing techniques.
Advertising restrictions through TfL, London, UK
In 2019, the Mayor of London implemented restrictions on the advertising of HFSS through Transport for London (TfL). This included transport on the London Underground (rapid transit) network, the TfL rail network, transport vehicles run by TfL (including some buses, trains, and taxis), and outdoor spaces owned by TfL (eg, bus stops and land outside train stations).
Per the TfL Advertising Policy, both direct marketing of HFSS products and incidental images of HFSS products in advertisements are prohibited. Brands with more diverse product ranges (eg, drinks companies) may have low or zero-calorie alternatives that allow continued brand advertising.
Considerations for implementation
Secondary legislation is required to define technical aspects, such as which businesses fall within the policy’s scope. The Department of Health and Social Care (DHSC) conducted a consultation on the Statutory Instrument for screen advertising, with implementation planned for 1 October 2025.
The ASA will provide non-legislative guidance on the restrictions, following a consultation that closed in March 2024. This guidance will aim to minimise potential loopholes in the policy.
For a nationwide ban on outdoor HFSS advertising on public transport networks, the policy must align with existing legal and regulatory frameworks. This may require new legislation or amendments. Clear enforcement mechanisms and penalties for non-compliance should be established at national or local government levels to ensure fairness across public transport operators.
Estimating the population impact
We estimated that this policy would reduce the prevalence of adult UK obesity rates by approximately 16%
Estimating the per-person impact
We estimated the combination of policies to restrict marketing of HFSS would reduce adults’ daily calorie intake by approximately 46 kcals
We conducted two rapid evidence reviews to identify the impact of screen advertising and outdoor public transport restrictions.
For screen advertising, we identified two meta-analyses that evaluated the impact of unhealthy food advertising on children and adults respectively. A meta-analysis published in 2016 by Boyland et al. reviewed experimental studies investigating the impact of unhealthy food screen advertising exposure and subsequent food intake in adults. Their study found no change in calorie intake following exposure to unhealthy food advertisements. In contrast, a meta-analysis published in 2019 by Russell et al. evaluated the impact of screen advertising on children’s food intake from experimental studies. They found that food advertising from television and advergame sources compared with non-food advertising increased daily calorie intake among children/adolescents by an average of 58 kcal. When modelling the impact for children we assumed that this effect would be applied once per day (that is, the policy would have the same effect for individuals watching for one hour as it would for those watching for three hours).
For outdoor public transport advertising restrictions, we estimated impact using data published in the evaluation of the TfL advertising ban. Yau et al. (2022) evaluated the impact of HFSS advertising restrictions, implemented across the London transport network in February 2019, on HFSS purchases. They found the following effects:
- The study found an association between the implementation of restrictions on outdoor HFSS advertising and relative reductions in energy, sugar, and fat purchased from HFSS products.
- The study found that on average, households in the intervention group purchased 1,001 fewer calories from HFSS products (a relative reduction of 6.7%) compared to the control group.
- Using the mean household size of 2.4 people in the sample, and assuming an even energy distribution, this equates to a relative reduction in purchased energy of 417 kcal per person per week.
- We divided 417 by 7, making the assumption that the average daily calorie deficit was about 59.6 calories per person.
- We then apply a compensation effect of 23%, therefore the calorie reduction per person per day is 46 kcals
When modelling the effects for adults we combined the findings from studies of restricting screen advertising and outdoor advertising and estimated the average daily calorie deficit as a result of both policies would be 46 calories per person per day.
When modelling the effects for children, we used findings from Russell et al. which indicates screen restriction would result in a calorie deficit of 58 kcal for children. We then apply a compensation effect of 23% to estimate the calories reduced per person per day is 44 kcals.
Changes in the prevalence of people living with obesity
Analytical modelling found that this policy would reduce the prevalence of adults living with obesity by approximately 16%.
Table 1 shows the percentage reduction of adults moving from BMI≥30 into a healthier BMI category following introduction of advertising restrictions. Due to differences in baseline population demographics, this policy would be slightly more effective for children in Scotland compared to those in England.
Adults (England and Wales) | Children (England and Wales) | Adults (Scotland) | Children (Scotland) |
16% | Analysis underway | 16% | Analysis underway |
Estimating the population reach
In our analytical model, we applied the effect sizes to people living with overweight or obesity. For adults, that is people aged 18 or above with a BMI of 25+. For children, that is children with a BMI value equivalent to the 85th percentile or greater.
Cost and benefits
Cost over 5 years
We estimated that this policy would cost the governments approximately £95 million over five years
We commissioned HealthLumen to estimate the cost of implementing marketing restriction policies to both industry and governments over a five-year period.
Table 2 below shows a detailed breakdown of costs. The upfront enforcement set up cost to the governments is estimated at approximately £2 million, in addition to an annual enforcement and monitoring cost of about £18.5 million.
The upfront costs to the industry is estimated at around £14 million. The primary drivers of cost to the industry are estimated to result from lost advertising revenue, specifically from screen advertising restrictions, approximately £27 million per year.
Costs for Restricting Screen Advertising: | |||
Group affected | Cost | Horizon | Detail |
Government | £0.9m | One-off | Enforcement set up |
Government | £46.4m | Annual (5 years) | Enforcement costs |
Industry | £4.7m | One-off | Transition costs |
Industry (Advertising Businesses) | £0.1bn | Annual (5 years) | Lost advertising revenue to advertisers (TV and online) |
Costs for Restricting Advertising on Public Transport: | |||
Group affected | Cost | Horizon | Detail |
Government | £0.9m | One-off | Enforcement set up |
Government | £46.4m | Annual (5 years) | Enforcement costs |
Industry | £4m | One-off | Familiarisation costs |
Industry | £4.7m | One-off | Transition costs in the first year |
Total annual benefit
We estimated that this policy would have an annual benefit of approximately £10 billion
Using analysis conducted by the Tony Blair Institute and Frontier Economics we estimate this policy would result in benefits of approximately £10 billion per year. Approximately two-thirds of this saving would benefit individuals (via quality-adjusted life years, and informal social care). The remaining third relates to savings that benefit the state via NHS treatment costs, productivity and formal social care.
Impact on disease incidence
We commissioned HealthLumen to report disease incidence avoided if the policy were implemented. Table 3 presents a summary of incidence avoided. These estimates do not represent the total health benefits.
The specific diseases selected are those where there is good evidence that living with obesity is associated with the development of the disease.
Disease | Incidence avoided |
Type 2 diabetes | 48,650 |
Hypertension | 28,561 |
Coronary heart disease | 13,064 |
Colorectal cancer | 3,441 |
Gall bladder disease | 61,436 |
Ovarian cancer | Not statistically significant |
Stroke | 7,527 |
Liver cancer | 409 |
Depression | 664 |
Musculoskeletal disease | 18,404 |
Behind the averages: impact on inequalities
Some groups have been found to be more exposed to HFSS advertising, including socioeconomically disadvantaged groups. This may contribute to the higher prevalence of obesity and diet-related diseases we see in disadvantaged groups. Secondary analysis of the TfL evaluation described above found that greater benefits (eg, a 37% higher gain in quality-adjusted life years) were expected to accrue to individuals from the most socioeconomically deprived groups.
There is a risk that continuation of this policy could exacerbate weight stigma.
Rating the strength of evidence
We asked experts working in the fields of obesity, food, and health research to rate the strength of the evidence base for each policy, taking into account both reliability (size and consistency) and validity (quality and content) of the evidence. Policies were rated on a Likert scale of 1–5 (none, limited, medium, strong, and very strong evidence base). The Blueprint Expert Advisory Group rated this policy as having a Strong evidence base.
Enforce front-of-pack labelling
Enforce the provision of front-of-pack labelling, similar to Nutri-Score, on retail packaging