The Department for Health and Social Care (DHSC) has launched a consultation on applying the Nutrient Profiling Model (NPM) to advertising for less-healthy food and drink products.
The NPM is a technical tool developed by experts that determines which foods and drinks are considered “less healthy”.
The Government noted that the current model used to determine which products fall within the scope of the recently applied advertising restrictions on less healthy foods (LHF) is over 20 years old.
Since then, UK dietary recommendations have been revised. An updated NPM was consulted on and finalised in 2018, but was not applied to the recent advertising restrictions.
The new model would likely result in changes to which products are deemed within the scope of advertising restrictions.
Legislation restricting LHF advertising came into effect under voluntary compliance on 1 October last year, with the legal deadline taking effect from 5 January 2026.
LHF restrictions round-up: How each media channel is impacted
Trade bodies respond
In response to the consultation, UK advertising trade bodies have expressed exasperation.
“Given the long process that accomplished the ‘less healthy’ food restrictions, and the promise that the impact of those changes would be reviewed after five years, this proposed moving of the goalposts is disruptive at best and self-defeating at worst,” said a spokesperson for Isba, the trade body for UK advertisers.
If the new NPM were to be applied, it warned, “swathes more products which have not been considered ‘unhealthy’ – indeed, products which have been reformulated – will be barred from appearing in ads, from yoghurts to cereals.
Having spent millions of pounds on changing what goes into our food and drink, manufacturers will now be told that they cannot market them anyway. The disincentive to future reformulation is obvious.”
Richard Lindsay, director of legal and public affairs at the IPA, the trade body for advertising agencies, concurred that the action amounts to “moving the goalposts”.
He continued: “The prospect of a new nutrient profiling model is deeply frustrating, creating further disruption, added costs and yet more uncertainty for businesses that have been operating in line with the new rules.”
Both Isba and the IPA intend to “engage fully” with the Government’s consultation.
The additional measures “must be urgently reconsidered.” a spokesperson for the Advertising Association said, “It is deeply concerning that the Government has issued a consultation on a policy that would limit advertising of a vast range of products without any assessment of the impact on ad-funded media. This omission must be addressed at the earliest opportunity. “
“These additional restrictions – suggested less than three months after the less healthy food (LHF) rules were first introduced – threaten to significantly reduce advertising investment in the UK and reduce spend on ad-funded media across broadcasters, journalism, online media, and digital tools.
“That is completely at odds with the ambitions set out for the advertising and ad-funded businesses in the Government’s Creative Industries Sector Plan.”
Lindsay warned, however, that the introduction of the new NPM “will only compound the challenges already facing brands and agencies”. The Isba spokesperson likewise added that the move comes “at a time of anaemic economic growth” and thus amounts to “a fresh blow to an industry which has constructively engaged with government on matters of public health.”
Is the ban even effective?
The LHF ad ban was enacted to curb childhood obesity. Earlier this month, the innovation agency Nesta warned ministers that, following years of delays, lobbying efforts and watered-down policy, the legislation will be “mostly ineffective”.
As Nesta concluded and as advertising industry leaders had predicted, LHF producers had already planned to shift much of their advertising spend to media channels outside the scope of the ban, such as OOH.
As Nesta’s John Barber warned: “This policy was first announced eight years ago, and in that time there have been eight consultations and four delays. Partly due to pressure from the industry, these delays and adjustments mean that the restrictions intended to keep us healthy are operating at a fraction of their potential.”
Barber argued that the ban contained too many loopholes, including covering too few types of unhealthy foods, that the ban not apply to brand advertising, and that it not apply to OOH.
