HFSS advertising restrictions for brands – challenge or opportunity?

The UK Government has announced details of planned restrictions for the advertising of high fat, sugar and salt (HFSS) products including a 9pm watershed for TV and on-demand services and a restriction of paid-for HFSS advertising online.

Jul 30, 2021

by Hey Human

While many marketers are grappling with massive changes in buying behaviours and attitudes due to the global pandemic many FMCG marketers still see these HFSS restrictions as a far greater challenge than any of the changes created by what we have described as ‘brand dispersion.’  There is no doubt that the restrictions will challenge existing marketing models and demand investment in new thinking and making change stick, but will there also potentially be an upside?

Is anticipating marketing restrictions ‘an insurance policy that always pays out?’

We have had experience in working in restricted markets globally at HeyHuman for many years and had anticipated the HFSS restrictions due to this. We consulted with clients long before these restrictions started to become a reality.  It was in one of these sessions that a client expressed an opinion that has influenced our approach ever since, that preparing for any restrictions that might affect your brand and its activation is ‘an insurance policy that always pays out.’

It was a point well made, that a focus on much-needed simplicity and clarity in both strategy and communications demanded a level of insight, focus, and excellence that all marketers strive for, a level higher than seems acceptable in more ordinary times.  It forced marketers to scrutinise their brand portfolio, individual brands and their assets to a level that is rare, and invest in fixing their areas of weakness, from understanding audience segments to understanding their key brand assets (KBAs) and addressing skill gaps in their teams.

How might HFSS restrictions change the strategic foundations for brands?

Brand-only advertising, both online and on TV, will still be allowed when HFSS restrictions come into force, so brands will still be able to advertise, but without HFSS products. They will also be allowed to promote products on their own websites and social media accounts.  With this scenario in mind, these are some of the considerations that marketers need to think about for future restrictions:

  • Developing deeper levels of audience understanding, even when many direct channels may disappear, because you will be connecting with them via other audiences (e.g. retailers) and newer channels. This may seem to be a surprising approach, but it is one we have seen restricted brands use to trigger growth in the early years of restrictions.
  • Scrutinise and develop your brands – in a more restricted world do you really understand your KBAs, is your brand portfolio clear and differentiated, is the same true for your brand positionings and brand messaging? These all need to be judged with simplification at their heart, because opportunities to communicate and connect will be more limited.
  • New approaches to NPD – obviously products need to be developed in relation to HFSS restrictions where possible but those new products that will still fall under these restrictions need to be super simple to communicate and drive scale quickly in a restricted environment where channels such as TV can no longer do the same amount of heavy lifting.

How might HFSS restrictions change activation models for brands?

As channels become restricted obviously this will demand new communication planning models in response, triggering new roles for existing touchpoints and new touchpoints:

  • Looking differently at product packaging, seeing it as an active communication channel and investing in the potential of limited edition packs (LEPs).
  • Embracing face-to-face marketing in new ways that drive scale but also deliver connections with your brand.
  • Embracing and investing more in social as a key channel post-restrictions
  • Consider embracing independent retailers as a channel previously neglected but with both prominence and potential after restrictions start.

Anticipating restrictions can trigger unexpected growth

It would be a cliché to turn to comparisons with creativity being triggered by restrictions in the context of HFSS marketing, but we have seen clients steal share and grow through the implementation of restrictions. The three common traits of these clients are that they grasped the nettle early, they didn’t settle for the most obvious solutions, and they saw these restrictions as an opportunity to push the quality of their marketing to a new level.

There is both challenge and opportunity ahead.