Did the HFSS Regulations Ruin Christmas?
Announced earlier in the year and coming into effect in the autumn, the HFSS rules have shaken up the industry just in time for the busiest, most indulgent advertising season of them all. We all remember those iconic, slow-motion M&S close-ups. So, it begs the question: what does Christmas advertising look like in a post-HFSS world?
A Very HFSS Christmas: What Brands Can No Longer Do
To recap, the HFSS rules prohibit brands from:
- Promoting HFSS products to audiences under 16
- Working with influencers whose audience includes over 25% under-16s
- Getting around the rules via “organic” posts — any brand control still counts
- Gifting HFSS meals or snacks in exchange for content
- Using visuals that glamorise HFSS products (yes, even those cosy festive close-ups)
On the surface, it sounds like the ghost of Christmas past has come to take the joy out of food marketing. But actually, this could be the industry’s biggest creative unlock in years.
Why Christmas Might Be the Creative Reset We Needed
Christmas food advertising has always leaned on indulgence: the glossier, the gooier, the better. But consumers have changed and so has what they expect from brands.
Even beyond HFSS, the traditional “product first” approach just doesn’t work like it used to. With cost-of-living concerns shaping behaviour, dining out is becoming more intentional. CGA & Zonal found that 74% of diners now say the atmosphere and vibe matter just as much as food quality.
This season, people aren’t just buying the turkey, they’re buying the feeling. The company. The ritual. The festive night out. And that’s where the creative opportunity lies.
If HFSS has taken away the glossy gravy-pour shots, it’s forcing brands to ask a bigger question:
What’s your brand’s story beyond the plate?
So… What Can You Do This Christmas?
Spotlight the Non-HFSS Heroes
Plenty of brands have options that fall outside HFSS restrictions – plant-based dishes, low-sugar drinks, lighter sides. Christmas doesn’t have to mean overindulgence; there’s an entire festive table that still is allowed.
Highlight the dishes that are still rule-friendly but delicious. Lean into the idea that consumers’ attitudes have evolved, wellness and balance now have a place even in December.
Build Long-Term Creator Partnerships
One-off festive ads aren’t enough anymore. Long-term creator relationships allow for deeper storytelling that goes beyond “here’s our new menu item.”
Think campaigns centred around:
- community
- ritual
- wellness
- culture
- the role your brand plays in people’s festive routines
Creators should feel like brand ambassadors, not seasonal guest stars.
Tell Better (and More Human) Stories
The polished, perfect “ad studio Christmas” era is fading. Gen Z and younger Millennials want emotional honesty, behind-the-scenes content, chef stories, supplier spotlights, UGC – content with heart, not just hunger triggers.
Instead of the dripping mince pie shot, tell us:
- how the recipe was developed
- who made it and why
- what Christmas means within the brand
- how your suppliers prepare for festive demand
These stories build emotional connection, not just cravings.
Position Your Brand, Not Just Your Festive Specials
Christmas is a values season. Sustainability, tradition, community, ethical sourcing – they matter. And HFSS restrictions naturally push brands to spotlight these areas.
You’re not just selling food; you’re shaping traditions, culture and memories. Show the parts of your brand that can’t be regulated: your purpose, your people, your ethos.
So, Did HFSS Ruin Christmas?
Not quite, it changed it. Arguably for the better.
The HFSS regulations might have dimmed the lights on the glossy food era, but they’ve switched on something more meaningful: a smarter, more strategic, more human approach to festive storytelling.
This Christmas, the brands who win will be those who:
- lead with values
- focus on experience
- embrace creativity
- build real creator partnerships
- and tell stories with heart, not just hunger
The rules are stricter but the opportunities have never been sharper.