The festive season is traditionally a time of national culinary overindulgence but eagle-eyed viewers may have noticed that this year’s crop of big-budget Christmas TV ads have been decidedly lean and sugar-free.
From Tesco and Waitrose to Marks & Spencer and Asda, the UK’s biggest exponents of extravagant festive food marketing have put their Christmas ads on a diet to comply with new regulations banning junk food products from appearing in TV ads before 9pm.
The UK advertising watchdog will officially start cracking down on ads featuring junk food on TV – and in paid online advertising at any time of day – from 5 January. But the UK advertising industry voluntarily chose to start adhering to the new rules from October, making this TV’s first-ever low-fat, low-sugar and low-salt Christmas.
Gone are shots of Christmas puddings and sweet treats, while healthy products have made a conspicuous appearance. Advertisers have had to cleverly market a wide range of other food to stay within the complex new rules.
In the climax of Waitrose’s Christmas romance ad, Keira Knightley receives a home-baked pie, while in Lidl a young girl grabs apples for a last-minute addition to the family festive shop.
Meanwhile, Asda used the fresh fruit and vegetable aisle for the Grinch to make his big entry into one of its supermarkets, and Morrisons opted not to show any products at all.
Quirks under the regulations rule out showing gravy on the traditional Christmas dinner’s roasted meat centrepiece in festive ads. However, a “marinade, glaze, dressing, seasoning rub or similar accompaniment” will keep the advertising watchdog away, according to the government’s new rules.
“Advertisers are having to be very strategic,” said Richard Exon, the co-founder of the ad agency Joint. “There is an upside for creativity here. It’s less about the products and more about brands and messaging and keeping to the spirit and letter of the legislation. Mainstream premium brands will be very careful not to breach regulations. A big dollop of common sense will be needed in the first quarter next year.”
While on-screen viewers are enjoying a merry Christmas, off screen the road to the introduction of the rules has been a bitter battle between health campaigners and the food industry.
In 2020, Boris Johnson’s government promised to implement a ban on products that were high in fat, salt and sugar (HFSS) online and before 9pm on TV saying it would come into force in 2023.
The ban was predicted to affect hundreds of millions of pounds of advertising spend. The original proposals meant that healthy foods such as avocados would be banned, but products such as McDonald’s chicken nuggets and some fries passed the HFSS nutrient profile test.
In a reworking of the plan, there has been a rebranding of the government’s initiative to tackle soaring childhood obesity to restrictions on “less healthy food”.
There are 13 categories of banned products, although these can make it on screen if it is possible for a food company to reformulate ingredients to meet the HFSS test, and there is an extensive list of often incongruous exceptions and caveats.
Many items perceived as less healthy are not restricted, such as bacon, cheese, savoury pastries such as sausage rolls, Pot Noodle and Nutella. “Party snacks” are also allowed to be shown, and as such feature heavily in a number of advertisers’ Christmas campaigns this year.
Conversely, items often perceived as healthier are restricted, such as “sandwiches of any kind”, pretzels and “all products predominantly found in the breakfast cereal aisle”, which includes porridge oats and muesli, according to the regulations.
Some products that have been reformulated to meet the junk food nutrient rules are still banned as they are perceived to contribute to the obesity issue, such as certain ranges of crisps, chips and pizza.
“Are we ready? Yes,” said an executive at one big food retailer. “But it is far too complex. There is going to be a long period where the advertising watchdog has to work through complaints from those looking out for products that may break the rules.”
Earlier this year, health campaigners were outraged when the government decided to allow companies that make junk food, such as a McDonald’s or Cadbury, to run brand ads as long as they did not show an “identifiable” product.
This followed a threat of legal action against the proposed blanket ban by the food industry. Allowing brand ads would mean that Cadbury could run its famous drumming gorilla ad, for example, before the watershed so long as there were no images of chocolate bars.
“This government pledged to raise the healthiest generation of children ever and yet they’ve ignored the evidence, instead pursuing a policy that essentially enables business as usual,” said Fran Bernhardt of the campaign group Sustain. “Industry will be celebrating another ruined health policy, while the UK’s children have been let down once again.”
Earlier this month, the Food Foundation released its annual report, which found that food companies had been shifting their ad spend into other media before the TV and online ad ban.
Food companies’ spend on outdoor media such as billboards and poster sites – which are only subject to junk food ad bans if they are located within 100 metres of premises such as schools or leisure centres – rose 28% between 2021 and 2024.
The report found that McDonald’s had increased its outdoor advertising spend by the biggest percentage across the three-year period.
While viewers are unlikely to have picked up on the trimmer advertising this Christmas, they may well do when Easter rolls around: Shots of chocolate eggs are banned, and so, too, the quintessential hot cross bun, unless food companies can come up with a healthy-eating version.
“Advertising agencies are problem-solvers,” said Paul Bainsfair, the director general of the trade body the Institute of Practitioners in Advertising. “They have just had to adapt and use their ingenuity to find solutions for their clients – something they have always been so good at.”
