Will a Grinch-like ASA steal our Christmas supermarket ads?

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From Kevin the Carrot to a talking oven mitt, from Roald Dahl’s Big Friendly Giant to an animated fairy, the blockbuster ads from supermarkets this past Christmas were once again a creative and commercial triumph.

Indeed, these festive specials have become as much a fixture of Christmas as mince pies, as quintessentially British as the half-time Super Bowl ads scream USA. As well as generating hundreds of millions of pounds of marketing spend, they bring joy to millions of households.

Yet, in keeping with the atomic cloud of misery that has hovered over 2025, this year it looks like Christmas advertising will be cancelled, at least in its current joyous form.

Under the ASA’s Grinch-like interpretation of the new HFSS ad rules, it’s not just ads for specific unhealthy products that will be stolen from our screens, but scores of non-specific, non-product-based brand ads too. It has left supermarkets, fast food chains and fmcg companies in limbo over their main marketing showpiece of the year.

As we report, no less than eight of the 10 “most effective” Christmas ads of last year, according to Kantar, would not be permitted under the rules, including the above supermarket ads, as well as those for Cadbury, KFC and Coca-Cola.

Is this really what the government intended with its junk food crackdown?

Take the Sainsbury’s 2024 Christmas ad. Featuring amazing special effects of the Big Friendly Giant, it was rich with images of fresh fruit & veg. But it also featured HFSS treats, albeit unbranded ones. And according to the latest guidance from advertising bosses, it would fall foul of the government’s incoming regulation.

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Time pressure

What makes matters worse is that the ASA’s consultation is not expected until May. This is the time of year when the UK’s biggest supermarkets and fmcg brands plan their most important marketing campaigns. And they are facing a much shorter window than usual, whatever the outcome.

Last month, Labour media minister Chris Bryant told the Advertising Association’s conference he wanted the ban to be “proportionate and sensible” and allow incentives for brands to promote healthier products. So it might not be a curtain call for the sumptuous Christmas spread of supermarket goodies and treats that traditionally feature in those ads after all.

On the other hand, if ministers do look to water down the regulations, it could well be lawyers for food campaign groups, rather than fmcg giants, that look to take action.

Campaigners told The Grocer last year, when the ASA’s first interpretation of the rules came out, that it had “loopholes big enough to drive a Coca-Cola truck through”.

If the government were to add those loopholes back in, they will be back on the march.

Yet with fears over the economy and growth in short supply, the last thing the industry needs is a massive hole in its marketing strategy.

If only this was all just a trogglehumper or a bogthumper: one of those bad dreams the BFG keeps locked away to avoid frightening the children. Alas, it’s all too real.