HFSS rules didn’t kill Christmas ads – they just invited fruit & veg to the party | Comment & Opinion

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Lidl

Source: Lidl Christmas advert 2025

This, they said, would be the year HFSS regulations killed Christmas adverts. M&S chairman Archie Norman even warned the festive ads might disappear altogether. Lidl GB chief Ryan McDonnell echoed concerns the new rules would strip the season of its sparkle.

So, we were all intrigued to see how supermarkets would respond. Would brussels sprouts be elevated to centre stage? Would we see a sleigh-load of apples and carrots replacing chocolate coins and candy canes?

Not quite. As the ads began to drop like little grocery snowflakes, there was no traditional table groaning under the weight of Christmas puddings, mince pies and pigs in blankets. Instead, supermarkets made some neat strategic sidesteps as they leant into popular characters, brand-led storytelling and the all-important sentiment (John Lewis, you’ve done it again).

Asda was first out of the gate, the distraction of the Grinch allowing it to focus on value and vegetables (the only nod to seasonal indulgence was a cameo from a HFSS-compliant chicken skewer). McDonnell had warned that Lidl’s offering would be “a lot more conservative”, and he wasn’t wrong. Sticking strictly to the letter of the soon-to-be legislation, its ad showed a child reaching excitedly for… an apple. It’s the advertising equivalent of being told to eat your vegetables.

For its part, Sainsbury’s bought back the BFG, while also sneaking some treats in under the slightly dubious ‘party food’ exemption. And despite its earlier warnings, M&S took the same not-really-in-keeping-with-the-spirit-of-things approach, delivering a campaign bursting with traditional party food.

Both the latter two are technically compliant, landing on just the right side of the rules, which – we mustn’t forget – remain voluntary until January next year.

But will they work? Eight of last year’s 10 “most effective” Christmas ads would not be allowed under the new rules. Without CAP guidance to cut through the confusion of what is allowed, it’s understandable some retailers have chosen to play it safer than others.

The HFSS rules haven’t killed Christmas ads, they’ve just reshaped them.

By taking up the challenge of putting healthier food in the spotlight, brands had a chance to redefine what festive marketing looks like. And while some may have struggled, others have shown festive magic doesn’t need sugar-coating.