The changing landscape of food advertising
How brands are winning at Christmas now that the food they can advertise is being more tightly regulated.
Food and Christmas. A pairing so perfect they fit together like milk and cookies, like Santa and his sleigh, like Hugh Grant and Martine McCutcheon in Love Actually. Christmas is about the food. And not just because we love to eat (although we do). Our food choices at Christmas are different to the rest of the year, adding something unique and different to the season, magical, special, festive. Food also brings people together. It provides a focus for shared community. And an opportunity to show the people closest to you what they mean to you. After all, tis’ the season of giving. Food is at the very centre of our holiday traditions.
And brands know it. Millions of marketing pounds are spent every year by supermarkets and food businesses trying to convince you that they are the only choice for this years all important Christmas food purchases. Spare a thought then for marketers in the UK this Christmas, who have had the unenviable task of trying to convince you of all this, while being able to show less food in their advertising that ever before. Let us explain.
HFSS (High Fat Salt Sugar) Regulations and their impact on UK Food Advertising
Over the last few years, the UK government has passed legislation putting restrictions on the promotion and sale of HFSS (High Fat Salt & Sugar) products as part of their wider strategy to tackle Obesity. This particularly focuses on products that scored low on the Nutrition Profiling Model (NPM).
In 2022 this initially began with legislation limiting where major retailers could display HFSS products, banning them from store entrances, aisle ends and checkout/queuing areas. Further legislation then turned its attention to promotion and offers, restricting deals on BOGOF (Buy One Get One Free) offers for HFSS products.
For advertisers, legislation had introduced the prospect of limiting when and where HFSS products can be advertised. In 2025 further consultation led to the introduction of restrictions on LHF (Less Healthy Food & Drink) products and the way they are advertised.
Regulations that limit TV advertising of LHF products after the 9pm watershed and put limits on paid online advertising were scheduled to come into force in October 2025 but were subsequently delayed until 5 January 2026 to allow time for further clarifications of the new rules.
However, the government did ask advertisers to begin voluntarily complying with the rules from October 20251. Most of the 2025 Christmas adverts we have seen were produced with this change to the rules in mind, as food brands grapple with the question of how to advertise food products in the future.
So, if you noticed that there are far fewer sweet treats, Christmas puddings and salty snacks in this year’s Christmas advertising than ever before, then you are right.
Have the public noticed the change?
The eagle eyed among you may have noticed that there are far fewer sweet treats, Christmas puddings and salty snacks in this year’s Christmas advertising than ever before. If you did congratulations, treat yourself to a mince pie.
One of the most common questions we’ve had this year from food advertisers is around whether anyone has actually noticed this change. In a recent Ipsos Fast Facts survey of UK adults aged 18-75, just 25% claimed to have noticed a different in how food is being shown in festive advertisements this year2.
We then asked those people whether they thought the food more or less healthy than usual and only 31% thought the food was healthier. 23% actually thought the food was looking less healthy than usual. That means, in practice only 8% of British adults have noticed the food choices have changed and felt they were healthier3.
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Perhaps that is not surprising, most Brits don’t spend their days following the latest developments in government legislation. Of those who noticed a difference in the festive food advertising, just 53% claimed to have any knowledge at all of the policy restricting food advertising and only 20% claimed to be ‘fully aware of it’ 4. That’s not even counting the majority of Brits who didn’t notice a change in the first place.
Has this affected the way they have received the Christmas adverts in 2025?
There is a wider question about whether this change has affected the way the Christmas advertising has impacted on the public, regardless of whether they noticed this change or not.
It’s not uncommon for brands to run story driven brand ads at Christmas, less about product, more about that Christmas feeling. But this year some brands have chosen to tell those stories without visual reference to the food products themselves. We know that clear, focused shots of appetising food products can make a big difference to the persuasive power of the ad and impact its ability to drive short term sales.
For example, a recent analysis of the Ipsos ad testing database (Creative SPARK) illustrates that consumer perceptions that an ad contains ‘appetising’ food is one of the key drivers of Creative Effect (the ability of the advert to impact on short term sales).
This is because it affects the potential of the ad to influence behaviour change – food & drink ads in the UK with high Appetising scores averaged a Behaviour Change Index score of 127 (vs average UK ad score of 100), whereas those with low perceptions that the product is appetising scored a below average 685.
In both 2024 and 2025 we’ve been using Ipsos Fast Facts to track the reaction to the Christmas campaigns in the UK. Let’s focus on the primary adverts from 8 major supermarkets (Tesco, Sainsbury’s, ASDA, Morrisons, Aldi, Lidl, Waitrose, M&S Food) once the campaigns were established (last 2 weeks of Nov, first week of Dec).
The change in the way the food is displayed has certainly not affected the ads’ ability to be recognised by the public. In 2024 the supermarkets averaged an ad recognition of 33% and this has actually risen year on year to 38%6.
The stories being told actually cut through the noise and are being remembered more this year than they were last year. We also asked those that recognised the ads whether they agreed that ‘the food looked delicious’ in the ads. Here we do see a noticeable difference, with the supermarket average dropping from 51% in 2024 to 40% in 20257.
Fewer people this year have felt the food in the ads look delicious and this can have consequences for the persuasive power of the ads. It therefore becomes even more important that the ads are landing the emotional benefit of the brand over the functional benefit.
How are brands succeeding in 2025 with their Christmas food portrayals?
Food brands have worked hard in select food products to showcase that can be shown under the regulations. And of course, they can still show any products they might want to advertise after the watershed. It’s also true that until January the regulations are technically voluntary, so some of the food choices are certainly skirting the line of what may be allowed by the regulations going forward.
But, let’s have a look at some of the different strategies being deployed.
1. Focus on compliant products
A number of food brands have chosen to do this. Sainsbury’s 'The Unexpected Guest’ ad, for example, showcases a range of products being stolen by the troublesome interloper.
The focus here is on compliant products and Sainsbury’s marketing bosses have talked openly about the lengths they went to ensure the products shown were compliant. Notice too how the scenes in the ad are segmented so that if you did want to create pre and post watershed versions of the ad, it would be easy enough to slide one scene out and replace it with another showcasing a different product.
Whether that is intentional or not we’ve noticed that in a number of the ads. The M&S Food ad has the highest score in 2025 for ‘food looks delicious’ (54%) and features individual scenes where Dawn French interacts with characters who are actively calling out product names8.
No traditional Christmas sweet treats here, just savoury canopies – some party foods are currently exempt from the regulations. Black tiger prawn paella bites, pork and mushroom pate by Tom Kerridge. Small bites, sound delicious. A character even asks Dawn French if they have fondue and is roundly dismissed. A nod to the regulations?
2. You can still carve a turkey
It certainly seems that way, with the classic British centrepiece being showcased in a number of the ads. Lidl were particularly successful with the use of a Turkey this year. Their story follows a little girl discussing the value of Christmas and features very few food products. Notice when she in is in the supermarket it is the perfectly compliant fruit and veg aisle shown in the background. But the ad does have two moments where it zooms in on and dwells on a perfectly cooked Christmas Turkey. The ad was second behind M&S for ‘food looks delicious’ with 50% agreement9.
3. Food stories without the food
That’s what Morrisons tried this year. Their advert focused on the people who work year-round to bring together all the food elements that make up your perfect Christmas meal. Almost no food outside of vegetables is shown at all and food is often positioned hidden or just off camera.
The focus is on the people and their stories. Yet the food benefit is clearly communicated, we work hard all year to give you quality food at Christmas. Does this have the power to be persuasive.
The Ipsos Creative SPARK AI tool certainly thinks so. It scores the ad an impressive 154 for Creative Effect (score of 100 would be the average UK ad) suggesting it has high potential to influence short term sales where it manages to cut through10. This is because the message itself is persuasive, regardless of whether the food is shown or not.
4. Use the wider campaign to generate food stories
Not all media touchpoints are regulated by the HFSS rules. Out of Home and Radio advertising for example are not currently covered by the regulations. This provides alternative avenues for showcasing some products that can no longer be shown freely on TV.
And of course, the precious earned media. Take the example of McDonalds here. Their Grinch focused Christmas campaign could have been run in isolation. But instead, they have chosen to have the Grinch take over their in-store menu, providing Grinch meals including gherkin salted fries and a free pair of socks. They may not be able to show the Big Macs in the advert pre-watershed, but it doesn’t matter because the meals themselves are openly being discussed on social media.
Clever use of the wider campaign can help plug the gaps in what you are allowed to do through traditional media channels and ensure the campaign as a whole persuades people that your food is worth looking into.
A vision of Christmas future
We expect this to continue to be a hot topic in 2026 for food marketing teams across Britain. Expect brands to double down on festive cheer and story led advertising narratives in 2026. This year’s ads have been tugging on your heart strings, but just wait and see what brands come up with when the regulations kick in. After all, pressure makes diamonds. Or should that be, the kids are up, the family are arriving, let’s get this Christmas meal done, no matter what! Keep calm and carry on.
Sources
1 For more information on the HFSS regulations and how they affect advertising the government provided more details here - https://www.gov.uk/government/collections/less-healthy-food-or-drink-advertising-and-promotions-restrictions
2 Ipsos Fast Facts Study. December 2025, GB adults aged 18-75. (Base 1050). Question: Have you noticed any differences how food is shown in festive advertisements this year?
3 Ipsos Fast Facts Study. December 2025, GB adults aged 18-75, those who claimed to notice a difference in how food was shown in festive advertising. (Base: 269) Question: Thinking about the difference you saw in the food in the Christmas advertising this year, which of the following statements do you think applies? Scale: The food shown is less healthy than usual, The food shown is no more or less healthy than usual, The food shown is more healthy than usual, Unsure.
4 Ipsos Fast Facts Study. December 2025, GB adults aged 18-75, those who claimed to notice a difference in how food was shown in festive advertising. (Base: 269) A description of the advertising legislation was provided. Question: Before today, to what extent, if any, are you aware or not about the new policy?
5 Data from Ipsos Creative SPARK Ad Testing Database 2021-2025 Food & Beverage Ads Averages. Based on 292 independent cases.
6 Ipsos Race to Christmas Fast Facts study. 2024 & 2025 data based on comparative three-week period. Weekly Base size: 1000 GB Adults aged 18-75. Data averages primary brand adverts for 8 supermarkets (Tesco, Asda, Sainsbury’s Morrisons, Aldi, Lidl, Waitrose, M&S Food)
7 As above (6), question based on Ad Recognisers.
8 Ipsos Race to Christmas Fast Facts study 2025, details as above (6). Based on M&S Food advert Ad Recognisers Base: 378
9 Ipsos Race to Christmas Fast Facts study 2025, details as above (6). Based on Lidl advert Ad Recognisers Base: 161
10 Creative SPARK AI tool is trained to predict Human response to advertising based on the results for the Ipsos Global Ad testing database. In Nov 2025 we tested 20+ Christmas ads in Creative SPARK AI for comparison including Morrisons.
