Could LHF regulations kick-start a new era of brand advertising? Learn how to be creative while meeting regulation through range-led storytelling and creator collabs – with an insider guide to flexing your ad strategy on digital platforms.
As the UK’s LHF (less healthy food) regulations move from theory to reality, food and drink advertisers are entering one of the most significant regulatory shifts the industry has seen in years. As of 5 January 2026, new restrictions on paid-for online advertising of LHF products have come into force, though many advertisers opted to comply voluntarily with the restrictions from October 2025. For consumer packaged goods brands, supermarkets and quick service restaurants alike, the question is no longer if these rules will change advertising plans – but how to adapt to them in a way that protects brand momentum, creativity and long-term growth.
Brand advertising: your biggest opportunity
One of the most important clarifications in the legislation – reinforced by formal guidance from the Advertising Standards Authority (ASA) – is the brand advertising exemption. Paid-for brand ads are allowed, provided they don’t depict a specific LHF product. This applies regardless of whether a brand’s portfolio skews heavily towards LHF products or includes a well-known ‘hero‘ item.
In practice, this creates a powerful opportunity. By continuing to invest in upper-funnel storytelling – highlighting values, heritage, community initiatives, sponsorships, or non-LHF product ranges – brands can still use culture-led creativity on digital platforms to drive discovery, relevance and brand affinity at scale.
Accountability in a creator-led ad ecosystem
Another area of uncertainty has been responsibility. The rules are clear: the advertiser (the party paying to place the ad) is ultimately accountable for compliance. That’s especially relevant in an ecosystem built on creators, affiliates and partnerships. Crucially, while paid-for ads for LHF products are restricted, compliant ads can still link to environments where LHF products are sold subject to meeting certain requirements. Understanding where the ad ends, and the retail experience begins, is key.
Understanding what’s actually restricted
A key challenge with LHF is complexity. The legislation doesn’t restrict all food and drink advertising, only paid-for online ads for identifiable LHF products. LHF is a subset of products that are high in fat, salt or sugar (HFSS), defined by a product’s nutrient profile and whether it sits within specific ‘less healthy’ categories set out in law. Some products or brands that may not instinctively be thought of as indulgent, such as certain granolas or yoghurts, can still fall into scope, making clarity essential.
Just as important is the concept of paid-for. Boosted posts, affiliate content, gifted creator partnerships and some retail media placements can all count as paid advertising. Meanwhile, organic content on a brand’s own digital channels is out of scope, as long as it isn’t paid to be amplified. Understanding these distinctions is the first step in building a compliant – and confident – strategy.
What this means for your strategy
Regulatory compliance and creativity need not be mutually exclusive. TikTok has developed an industry-aligned LHF resource guide with advisory input from the Internet Advertising Bureau UK (IAB UK), designed to help brands understand what the rules mean in practice and how to continue telling powerful stories on TikTok in a compliant way.
Regulation often forces a rethink of creative habits. And that can be a good thing. TikTok’s unique format already encourages brands to move beyond traditional product-centric advertising towards ideas that feel native, entertaining and rooted in culture. Our guide breaks down what ‘depicting a specific LHF product’ actually means – from packaging and product names to audio cues, colours and visual cues – and how advertisers can avoid inadvertently triggering the ‘identifiability test’ used by the regulator.
“The LHF regulations undoubtedly change the focus of food and drink advertising, but they don’t have to limit ambition,” says Cassandra Russell, head of luxury, CPG and autos at TikTok. “On TikTok, we’re already seeing partners lean into brand-led storytelling, creator collaboration and culture-driven ideas that build long-term equity, complying with the new regulations, without relying on product-centric messaging. This shift can be a real creative unlock for brands willing to rethink how they show up.”
How to work with creators in TikTok
Our guidance also outlines how brands can work confidently with creators on TikTok, including where gifted products, affiliate links or paid collaborations bring content into scope. It also addresses common questions around TikTok Shop, livestreaming and linking to retail environments. Within the guide, practical, platform-specific scenarios that show how brands can interpret the rules creatively include:
● Creator collaborations that focus on experience rather than menu items, highlighting atmosphere, service or community, without showing identifiable LHF products.
● Range-led storytelling that spotlights non-LHF products within a wider portfolio.
● Brand-first narratives that leverage sensory cues, humour and cultural moments to hint at product types without naming or showing specific LHF items.
● Retail and delivery platforms leaning into convenience, choice and service, rather than individual restricted products.
These examples aren’t prescriptive. Instead, they serve as starting points to show that compliance doesn’t mean playing it safe or going silent, but instead calls for greater intentionality in what brands foreground creatively.
The LHF rules will undoubtedly change how food and drink brands advertise online. But with the right understanding, they can also be a catalyst for more creative, brand-led storytelling, shifting focus to brands’ broader identity, values and the emotional connection they inspire. And for brands willing to adapt, that shift can become a competitive advantage.
“The introduction of the LHF restrictions marks a significant moment for digital advertising, particularly for food and drink brands navigating increasingly complex rules,” says Beth Rogers, public policy manager at IAB UK.
“What’s crucial is that advertisers clearly understand what is – and isn’t – in scope, so they can continue to advertise responsibly with confidence. This resource is designed to provide practical clarity on how the legislation works in real-world scenarios, helping brands adapt their strategies while maintaining trust, creativity and compliance in a rapidly evolving online ecosystem.”
The full TikTok LHF resource guide, informed by advisory input from IAB UK, includes detailed breakdowns of the rules, creative scenarios and platform-specific guidance. Download it now.
Disclaimer
The views and opinions expressed in this article are solely those of TikTok, have not been independently reviewed or verified by William Reed, and do not necessarily represent the views of William Reed. This article does not constitute legal advice and you should always take legal advice tailored to your specific circumstances
