As the UK enters its first full year under new HFSS advertising restrictions, many food and drink brands face profound changes in how they reach consumers. Ofcom’s rules enforce a 9pm TV watershed for less healthy products and a 24‑hour restriction on paid online advertising for the same categories.
But while many of the formats HFSS brands once used have effectively disappeared overnight, demand hasn’t. Shoppers still plan weekly meals, prepare for gatherings, and look for moments of indulgence.
To stay relevant, brand activity must now do the work of both awareness and consideration, showing up at the right moment, for the right people to drive action.
This is where 2026 offers some relief. The year is packed with high-intent moments that naturally compress decision-making. Events like the Winter Olympics and the FIFA World Cup act as accelerants, not because of sport itself, but because of what people do around them.
In those windows, branding alone can still move the needle. The catch is precision. You need to know who you are reaching, and you need to reach them while intent is forming, not after it has passed.
Understanding audiences at a person level
Sport is one of a few cultural spaces where mass attention, emotion and shared experience still collide. It is little surprise a recent Sports Business Journal study found that 66% of consumers say they are more likely to purchase from companies that sponsor sports they like.
When audiences are thinking about food, drink, travel or social plans connected to what they are watching, attending or organising, they are innately more receptive. In these moments, brand association can be enough to influence behaviour.
HFSS regulations make broad frequency‑based campaigns less efficient, but they amplify the value of precision. The advantage lies in knowing who you are reaching, not merely how many. Advertisers must rely on first‑party data and cross‑channel identity resolution to reconstruct the customer journey.
When viewing, engagement, and purchase signals can be meaningfully connected, brands can still guide audiences from awareness to action via more sophisticated sequencing.
Find out more about Epsilon COREid, the industry’s most accurate, stable identity graph
Three channels where branding works harder under HFSS
Connected TV plays a critical role in this new mix. It offers premium environments that suit brand storytelling and allows advertisers to stay present as attention shifts from live moments to highlights, recaps and related viewing.
The challenge is fragmentation. CTV audiences are spread across platforms, broadcaster apps and devices, which risks duplication and wasted frequency unless advertisers know who they are reaching. When the same individual can be recognised across screens, planning becomes far more precise.
Collaborations such as Roku x Currys demonstrate how viewing data integrated with retail signals can turn exposure into verified purchase movement even without direct product promotion.
Read about Epsilon and Currys’ award-winning CTV campaigns here
2. Audio, reinforcing intent when people are on the move
Audio complements this approach by reaching people as they move through their day. Commuting, shopping and preparing for social plans are moments where brand reminders can be especially effective.
When audio is connected to the same audience spine as CTV, it becomes reinforcement rather than repetition. A household that engaged with branded video content but has not yet acted can be reached again when intent is resurfacing. The message remains brand-led, but timing and context do the work.
3. Retail media, bringing action back into reach
Retail environments complete the journey. Many retailer-owned channels sit outside HFSS restrictions, allowing brands to reintroduce product messaging at the point where decisions are finalised. In-store screens, digital out-of-home, in-basket placements and retailer audio can all act as prompts that connect brand memory to immediate action.
The Co-op's research reinforces the point. A brand activation in-store delivered a 12% sales uplift in-store and a 3% uplift at neighbouring retailers, demonstrating that lower-funnel tactics can also deliver a ‘halo’ of brand impact when aligned with wider activity.
The 2026 HFSS Advertising Playbook
The opportunity in 2026 isn’t to find loopholes but to re‑engineer brand activity around audience intent and compliant sequencing. The new brand playbook under HFSS looks like this:
HFSS redefines the rules of engagement, but it does not remove the opportunity to grow. Brands that align their storytelling, sequencing, and measurement will find that 2026 isn’t a year of limitation, it’s the start of a more intelligent, precision‑led era for brand marketing.
