U.K. Junk Food TV Ban Forces Supermarkets to Rethink Holiday Advertising

The U.K.’s advertising rules for high in fat, sugar, or salt products (HFSS) have reshaped how supermarkets approach the most important window of the year.

The 9:00 p.m. watershed and the ban on paid online ads for less healthy food have removed many familiar festive visuals from television.

Christmas advertising, once dominated by indulgent food imagery, now looks markedly different across major broadcasters.

Supermarkets have shifted away from product-led creative toward brand storytelling built on characters, mood, and atmosphere.

Media budgets are also changing, with outdoor formats gaining prominence as brands seek compliant visibility.

The result is the first widely observed “low-fat” Christmas on British screens.

A Different Kind of Christmas Story

Major grocers moved quickly to adjust their creative under the new rules.

Morrisons ran a holiday campaign without showing food at all, focusing instead on suppliers and their year-round effort.

Waitrose built its Keira Knightley-led film around a mystery narrative, with a brief appearance from a homemade pie that qualifies under exemption rules.

Asda and Lidl, meanwhile, leaned into humor and characters, allowing the season to feel festive without triggering the ASA’s identifiability test.

Even Marks & Spencer, which publicly criticized the policy, shifted its tone rather than pulling back.

Data from DAIVID shows “festive craving” responses fell 24%, while nostalgia and adoration rose by 6% and 10%.

Viewers are responding differently, but they are still responding.

Several broader creative lessons emerge from how these retailers adapted to the new regulation:

• Narrative now carries the seasonal signal. Characters and story beats replace food imagery as emotional anchors.
• Tone matters more than product presence. Viewers engage with the atmosphere even when consumption cues disappear.
• Compliance rewards creativity. Constraints are pushing agencies to rethink familiar holiday formulas.

When visual shortcuts disappear, storytelling fundamentals become the main driver of recall and emotional response.

Where the Money Is Moving

The HFSS ban has reshaped media planning alongside creative strategy.

Food companies increased outdoor advertising spend by 28% between 2021 and 2024 as billboards and transport media remain largely exempt.

Brand-only advertising has become a safe route, keeping supermarkets visible without showing restricted items.

Retailers are also leaning on non-HFSS categories, including fresh produce and reformulated staples, to maintain screen presence.

Research from the University of Leeds found that earlier HFSS restrictions led to nearly 2 million fewer junk food purchases across major supermarkets.

The government estimates the expanded ban will remove 7.2 billion calories from children’s diets each year.

These figures are now influencing both creative and commercial decisions, and media flexibility has become a competitive advantage as regulation redirects spend across channels.

Our Take: Has the Holiday Magic Really Changed?

I don’t think the magic is gone, it has just shifted form.

For years, festive food imagery acted as a shorthand for warmth and generosity.

With this removed, brands and agencies are leaning more heavily on character, humor, and music to carry emotion.

Viewers are talking more about who appears on screen, and this change favors brands with a strong sense of voice and narrative discipline.

I believe the season still belongs to supermarkets, just under different creative rules

In other news, our 2025 holiday ad trends report shows brands leaning toward human-made storytelling as audiences grow more selective about AI-generated campaigns.

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