Re-Thinking The HFSS Debate: A Call To Arms For Context

By Ross Nicol, VP EMEA at Zefr

The imminent UK government ban on advertising products that are high in fat, sugar and salt (HFSS) is almost certainly well-intentioned. But it is also heavy-handed, especially given the positive impact of industry self-regulation, as well as the advanced technologies available to manage and control ad exposure.

During the last Queen’s Speech, it was announced that the UK will implement a 9pm watershed for HFSS TV advertising, as well as a total ban on online advertising, by the end of 2022. These changes are part of the Health and Care Bill and are intended to limit children’s exposure to HFSS advertising, theoretically helping to fight obesity. With child health a vitally important and highly emotive topic, the move understandably have strong public support, with over half of UK consumers in favour of the ban.

But in reality, there are no guarantees the ban will impact child obesity levels, while it will have a huge impact on the advertising industry, with forecasts predicting a devastating effect on revenues. The government’s own assessment indicates a total online ban on HFSS advertising will result in £4.6 billion in lost revenue for online platforms, as well as a £66 million deficit for advertising agencies. The revenue loss associated with a TV watershed is anticipated to be an additional £4.4 billion for online platforms and £63 million for advertising agencies. Media companies such as ITV are already preparing for significant revenue reduction according to its annual report.


With under 18 months to go, it’s high time to rethink the HFSS debate and look for viable alternatives.

Blunt bans are not the answer

Experience tells us blanket bans and blunt approaches to advertising regulation that are born out of a fear-based environment often do more harm than good. COVID-19 is a case in point.

When the pandemic took hold in early 2020, a huge proportion of online content naturally included words such as ‘coronavirus’ or ‘pandemic’. Antiquated brand safety tools immediately kicked in, blocking advertising from appearing alongside this content due to these controversial keywords. This meant a massive dip in revenue for the very media outlets that were providing the vital and relevant information the public demanded. It wasn’t just media companies that lost out; advertisers also missed the chance to reach highly engaged audiences consuming top-quality content that was pertinent to their immediate needs.

A far more nuanced approach is required to ensure ads are placed in appropriate environments where they are seen by suitable audiences.  In the case of HFSS products, the advertising industry is already proving other methods – which are far less draconian than blanket bans – are helping reduce the volume of ads children are exposed to.

Self-regulation is already working

The advertising industry has taken action to target HFSS ads away from children since 2017. And the strategy is working with volumes reducing significantly. Data from the Advertising Standards Authority (ASA) reveals the number of HFSS ads appearing in children’s online media fell 74% between October and December 2020. The fact that childhood obesity isn’t reducing in line with these figures serves to highlight that advertising is far from the only factor contributing to this issue.

Further steps are being taken to push self-regulation. The Committee of Advertising Practice (CAP), for instance, created an option that would meet the government’s policy goals through age-assured targeting, without the severe economic consequences of a total ban.

Tougher controls could be widely implemented and measured by expanding existing standards such as the Global Alliance of Responsible Media (GARM) charter from the World Federation of Advertisers (WFA). Current work from GARM includes a universal Brand Safety Floor and Suitability Framework, which aims to establish media placement controls online and keep advertising away from harmful content related to specific categories such as crime, terrorism, conflict or obscenity. This could also equally be used to keep a certain category of ads, such as HFSS, away from content that appeals to children.

Contextual tech supports this shift 

Technological advances can enable this shift to tighter controls, and contextual targeting – where content is scrutinised to determine what type of ads would be most suited to it – can bring the required content-level transparency. This is certainly the case for video advertising, for example, where content used to be tricky to analyse for brand suitability, but where new developments mean advertisers can now achieve a deep understanding of context and video nuance.

The key to effective contextual targeting is integrating real people into the analysis process. Combining scaled human review with machine learning is an innovative way to instantly understand what content is about, and whether it offers a suitable environment for different ad categories. Human reviewers use their innate ability to analyse the nuances of content and make suitability decisions, while machine learning algorithms use these decisions as training data, spotting patterns and applying them at scale. The result is continuous improvement in brand suitability based on human cognition.

The IAB’s CEO Jon Mew sums up the situation in a recent open letter, saying the move on HFSS ads, “ignores smarter, digital-led solutions put forward by advertising’s regulatory body that could further limit children’s exposure to digital advertising in a proportionate and targeted way”. Existing contextual targeting technologies are clearly ready to help brands be proactive about their responsible marketing initiatives without the consequences of a blanket ban.