The UK Implements "Junk Food" Advertising Regulations: Daytime TV and Internet Targeted—What Changes and How Does the World Differ?

1. What Started First? Focus on "Daytime TV" and "Paid Online Ads"

The new UK rules are broadly based on the following two pillars.

• Television (Broadcast) and On-Demand Programs:Between 5:30 AM and 9:00 PM, advertisements for "identifiable products" that fall under LHF (Less Healthy Food/Drink) are prohibited

• Internet (Paid Online Ads):Prohibited at all times (24 hours)

The government has designed the rules to "reduce exposure itself" by targeting time slots and environments where children are likely to come into contact. The implementation date is January 5, 2026, as specified in the government's announcement and guidance, as well as the advertising regulatory authorities' operational policies. GOV.UK+2GOV.UK+2

2. What is "HFSS/LHF"? — There is a "Determination Method" Rather Than a "Perceived Junk"

In news headlines, it is often summarized as "junk food," but under the system, the target is determined not by a "rough impression" but by a legal determination. In the UK, the main approach is as follows.

• LHF (Less Healthy Food/Drink) = A concept for advertising regulation that may be targeted

• The determination is basically "two-step"

  1. Whether it falls under one of the 13 categories

  2. **Nutrient Profiling Model**: Whether it scores above a certain level (e.g., "4 or more points" for food, "1 or more points" for beverages)

This method of determining by "category × nutrient score" is designed to be broader than just regulating "children's programs," so it also affects children watching family programs, sports, and variety shows during the day. GOV.UK+1

3. Which Media are Targeted? — "TV," "On-Demand," and "Paid Online"

The key point of operation is that it changes based on "where the ad was placed."

• Television (Broadcast): NG from 5:30 AM to 9:00 PM

• On-Demand Program Services (ODPS): NG from 5:30 AM to 9:00 PM

• Paid Online Ads:NG 24 hours

This arrangement is clearly indicated in the operational announcements from the ASA (Advertising Standards Authority). asa.org.uk

The important point here is that "online" does not mean "all prohibited," but legally, the focus is mainly on "paid online ads" (which affects what is "allowed/gray" as discussed later).

4. What is an "Identifiable LHF Product"? — It's More Likely to Be Out if the Product is Recognizable

According to the ASA's explanation, the prohibition targets cases where "identifiable" LHF products are shown in the advertisement. asa.org.uk

Practically, the following elements make it more likely to be judged as "identifiable" (risk assessment points for companies):

• Packaging, logos, distinctive shapes, product names, product photos

• Images or visuals that clearly identify the product

• Appeals directly linked to "buying/eating the product" (price, limited time, purchase pathways, etc.)

Conversely, this is also where it can easily conflict with the "brand advertising exception."

5. What is Included in the 13 Categories? (A Rough List)

The UK guidance organizes the LHF categories that may be subject to regulation (though there are many details, the direction is towards "high sugar, high fat, high salt" that children tend to consume). GOV.UK+1

For example (rephrased for general understanding):

• Chocolate and sugar confectionery

• Cakes and biscuits

• Ice cream, etc.

• Snack foods (crisps, etc.)

• Sweetened beverages (sugar-containing drinks)

• Processed food groups with high sugar or sweetness, etc.

And here is a point where disputes can easily arise in practice, even "healthy-looking foods" can be subject to regulation depending on the nutrient profile determination or category application, as reported. The Guardian

6. What is "Prohibited" and What is "Allowed/Exempt"?

Here, practical decisions change between "TV" and "Internet," so it's safer to understand them separately.

6-1. The Most Understandable Prohibition: Showing LHF Products on Daytime TV

• Ads where LHF products are identifiable on TV/On-Demand from 5:30 AM to 9:00 PM are NG asa.org.uk

6-2. The Next Less Understandable Prohibition: "Paid Online Ads" on the Internet

• Paid online ads are prohibited at all times (if LHF products are identifiable, it's out) asa.org.uk+1

The interpretation of "paid" here is practically important. For example,

• Search ads, display ads, social media ad distribution, video ad placements

• Affiliate marketing (depending on the contract form)

• Influencer "tie-ups"
  , etc., are areas where **advertising spaces with a flow of money** are likely to be included (checking with each company's legal and media rules is essential).

6-3. What About Brand Advertising? — It Can Be Both a "Loophole" and a "Safety Valve"

A major point of discussion during the implementation process was the handling of "brand advertising (corporate ads that do not show products)." As a result, the government organized it in the direction of establishing a "clear exception for brand advertising," which also led to the postponement of the implementation date. Financial Times+1

However, from the perspective of health organizations, there is a strong concern that "allowing brand advertising leaves brand affinity in children, weakening the aim," making it a "design point that influences effectiveness." The Guardian+1

7. Why Was the Implementation Delayed? — From "October 2025 → January 2026"

Initially, the start was expected on October 1, 2025, but it was eventually moved to January 5, 2026. In reports and industry explanations, reasons for the postponement include "confusion in interpretation (especially brand advertising)" and securing preparation time. Financial Times+2Campaign Live+2

On the other hand, the government has explained that it requested voluntary early compliance from October 2025 "for preparation." IAB UK

8. What Should Businesses Do? (A Practical Checklist for Advertisers, Agencies, and Media Companies)

From here, we summarize in order of "most likely to cause problems" from a practical perspective.

8-1. Creative Inventory: Check if "Products are Identifiable"

• Ensure that product cuts/packaging/product names do not appear in daytime TV slots

• Even