LHF restrictions: How TV is adapting
New restrictions banning ads for ‘less healthy foods’ online and on TV before the watershed (between 5:30 am and 9:00 pm), including on ODPS and IPTV channels regulated by Ofcom, came into force on 1 October.
The official legally enforceable date is 5 January, 2026.
A campaign titled “Countdown to October 1,” launched by the Advertising Association, Isba, the IPA and IAB UK, confirmed brand advertising remains out of the scope of the restrictions, as long as no LHF products are shown.
For LHF brands that typically rely on TV, this requires a shift in storytelling approach and a greater focus on brand in ads shown before 9pm.
The Media Leader understands that part of the reason for the harsher restrictions for TV, VOD and platforms such as YouTube is related to the way these channels target children. The incoming changes are driven by the Government’s stated aim to tackle child obesity.
Analysis: A change in course
The restrictions don’t mean there will be less advertising — but rather a shift in when and how.
David Spinner, industry director of CPG at Teads, echoed this: “LHF is driving a redistribution of weight rather than a retreat from reach.”
It will force a divvying up of activations into product-led, which will be focused on after the watershed on linear and CTV, and then activations which are brand-only for the daytime.
Whilst the implications for planners are not obsolete, with a media planner previously telling The Media Leader, the reduction in advertising space could result in a price inflation of up to 60% for TV ads for post-watershed slots.
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However, Spinner highlighted that with management, planners will be able to adapt. There will be a need for early pre-clearance approval, as well as the requirement to track performance by time of day.
More than ever, Spinner emphasised the importance of process, underlining that: “Many advertisers have moved early.”
Flexibility and re-timing of schedules, as well as making LHF “identifiable products” checks foolproof, and increasing rotation of brand-only variations were also outlined as key in adapting to the restrictions, so as Spinner states: “Plans stay compliant without sacrificing scale.”
Large and out of reach
Despite industry expectations of increased demand for post-9 pm watershed slots for those LHF brands wanting to showcase products, early indications suggest this surge in demand has not materialised.
Dylan Pritchard, head of AV at Bicycle London, said: “An early read from our partners has shown no immediate shift and therefore demand overall has remained stable.
“We believe this is due to linear advertisers typically being larger brands, those that have strong brand equity and can switch to brand-led advertising pre 9 pm.”
Pritchard caveated this by stating these are still early indicators; however, he stated, “So far we’re not seeing the influx of demand that was expected.”
However, for smaller brands, with less equity, this is not the case, and shifting to investing in brand without product is more complex, meaning they may be forced to take post-9 pm slots if they are considering linear.
Linear TV has long been regarded as the medium for effectiveness and reach; therefore, for smaller brands, the stakes are significantly higher. Pritchard put forward a solution for these brands to focus on on-demand spaces, which have “lower barriers to entry.”
An opportunity for something more
There is a creative opportunity for advertisers and potential for industry evolution from these restrictions.
Ed Palmer, managing director of St Luke’s, an independent creative agency, told Creative Salon: “They [brands] will need to elevate their messaging and focus on connecting at a deeper emotional level with their audiences, potentially delivering brand impact that will outlast the short-term impact of rational messaging and product appeal.”
Originally, the policy was intended to be implemented in early 2023, but was delayed to 2024, then 2025, and subsequently to early 2026, allowing more time for the ad industry to prepare and providing greater clarity on the policy’s scope.
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