Authorities not too long ago confirmed in Parliament that pure model promoting, i.e. that doesn’t function identifiable much less wholesome merchandise, might be exempt from the brand new 9pm/internet advertising restrictions. Caroline Cerny, Deputy Chief Government, Motion on Smoking and Well being (ASH), discusses the implications for future coverage improvement;
In October 2025, new restrictions on excessive in fats, salt and/or sugar (HFSS) meals promoting will lastly come into power with a ban on adverts for much less wholesome merchandise on TV earlier than 9pm and paid-for adverts on-line at any time. It’s a giant win for baby well being, marking the tip of a decade-long marketing campaign with many twists and turns alongside the way in which. However at the same time as we rejoice, consideration should shift to the following problem: pure model promoting.
Entrepreneurs are specialists at adaptation. Limiting one path to potential clients solely drives innovation and funding in one other. Cue the most recent tactic: model promoting that doesn’t function particular merchandise. After a lot lobbying from business (together with festive hand-wringing over mince pies), the federal government not too long ago confirmed in Parliament that pure model promoting, i.e. that doesn’t function identifiable HFSS merchandise, might be exempt from the brand new guidelines.
However are you able to promote an unhealthy meals product with out exhibiting it? The reply is sure – and powerfully so. McDonald’s “Increase Your Arches” marketing campaign didn’t function a single burger, but it drove huge will increase in gross sales and model loyalty. That is model advertising in a nutshell, and it poses a severe coverage drawback.
The usage of pure model promoting to bypass product advertising restrictions isn’t new. As a baby rising up within the nineties I used to be enchanted by the billboard adverts exhibiting opulent ripples of purple. Little shock then that after I began to experiment with cigarettes in my late teenagers, Silk Lower was my model of selection.
Simply as 90s tobacco adverts relied on glossy imagery and coded visuals, immediately’s meals giants are rebranding unhealthy decisions with way of life messaging, occasion sponsorships, and emotional cues. Like McDonald’s, different giant manufacturers, together with KFC and Cadbury, have been investing in pure model promoting, typically with minimal or no merchandise proven and entrepreneurs brazenly discussing it as a method to safeguard gross sales in mild of the incoming restrictions. And it’s not simply restricted to junk meals. Large alcohol manufacturers are following Coca Cola’s model sharing lead and closely selling their zero alcohol manufacturers that use the identical branding because the hero alcohol product.
Analysis exhibits that this kind of promoting can have an effect on our brains, form social norms and affect habits even when no particular product is proven. A latest systematic review and meta-analysis discovered proof that model advertising for meals and alcohol can have an effect on shopper preferences, decisions, and buy intentions (although research had been restricted and of various high quality).
As model advertising seems more and more prone to be the way in which meals giants proceed to market to kids, we have to ask: how can coverage sustain?
Final yr Bite Back labored with Professor Emma Boyland on the College of Liverpool to convey collectively a spread of coverage and educational specialists to discover key questions:
- How will we outline and determine an unhealthy model?
- What can we be taught from alcohol and tobacco regulation?
- What coverage instruments can be found?
4 potential fashions had been mentioned:
- Gross sales-based: Manufacturers are judged on the healthiness of the merchandise they promote. That is prone to encourage reformulation however depends on clear gross sales or quantity information – which is presently missing, until the brand new Meals Technique is ready to revive the Meals Knowledge Transparency Partnership, and – crucially – give it some actual tooth.
- Class-based: Manufacturers in high-risk meals classes (like confectionery or sugary drinks) are restricted outright. It’s a easy however blunt strategy, however prone to convey some political challenges, because it doesn’t present the identical incentive for reformulation.
- More healthy product-led: Adverts can solely run in the event that they function product/s assembly well being standards , as with Transport for London’s mannequin, which has been efficient however dangers merely driving want for unhealthy merchandise that share branding options or are extra related to the model.
- Synonymous branding: Restrictions on branding that mimics or displays unhealthy merchandise. This displays the Promoting Requirements Authority’s(ASA) present strategy, which has by no means been efficiently utilized as a result of its extremely subjective nature.
Learn extra in regards to the choices and discussions in our joint briefing here.
Because the meals business and advertisers evolve their ways, coverage should evolve too. If rules are going to be efficient in defending kids from unhealthy meals advertising, we have to shut the model loophole earlier than it turns into the primary path to promoting but extra illness.
