HFSS Regulations: Promotions You Can Still Run

Yes, the rules have changed. But that doesn’t mean game over for prize promotions. It just means playing smarter.

The HFSS (High Fat, Salt, Sugar) restrictions are officially in force, and if you’re a brand manager working in the category, you’re probably feeling the squeeze. Gone are the days of multi-buys, deep discounting, and carefree on-pack giveaways. The UK government’s crackdown on HFSS marketing now bans paid advertising of these products online and restricts TV advertising before the 9pm watershed. It also limits where and how HFSS products can be promoted in-store.

It’s a big shift. But it doesn’t mean promotions are off the table. In fact, there’s still a lot you can do. You just need to do it carefully, creatively, and compliantly.

That’s where we come in.

At SPARK, we’ve helped HFSS brands navigate regulation changes before. We know how to design promotions that deliver results without falling foul of the ASA, CAP Code, or Trading Standards.

Here’s what you need to know, and how we can help.

The Short Version: You Can Still Run Prize Promotions. Just Not Like You Used To.

Despite the new rules, prize promotions and on-pack activations are still allowed for HFSS products, but with some important caveats:

❌ You can’t:

• Target or appeal to children under 16
• Use characters, cartoons, or nostalgia that appeal to children
• Run paid social or paid search ads promoting your HFSS product or associated promotion
• Require multiple purchases of HFSS products to enter
• Run in-store promotions at aisle ends, checkouts, or front-of-store

✅ You can:

• Use on-pack promotions (e.g., instant win, QR code entries) that are clearly not aimed at under-16s
• Run online competitions or prize draws via your brand’s own channels (website, organic social, email) with age-gating in place
• Offer value-add incentives like cinema tickets, experiences, or brand partnerships that reward responsible purchase behaviour
• Build first-party data through prize promotions that drive engagement, sign-ups, and long-term brand affinity

Why Prize Promotions Still Work

Let’s be honest, slapping “£1 off” on a pack isn’t going to cut it in today’s compliance landscape. But promotions that tap into emotions, aspirations, and entertainment still have real pulling power.

Done right, a tactical prize promotion can:

• Drive trial for NPDs or new variants
• Increase basket spend without relying on price
• Build loyalty and repeat purchase
• Capture GDPR-compliant first-party data for remarketing
• Create a story worth sharing organically, even when paid ads are off-limits

How SPARK Helps HFSS Brands Stay Compliant (and Still Win)

We’re experts at navigating the legal and logistical hoops of sales promotions. From campaign ideation to execution, we build activations that work hard and stay within the lines.

Our approach:

1. Review your brand and objectives – including HFSS classification and target audience
2. Propose compliant mechanic options – like age-gated prize draws, QR-code instant wins, or reward activations
3. Handle the heavy lifting – from legal T&Cs and data compliance to sourcing prizes and fulfilling winners
4. Deliver on time, on budget – so you can get results fast, without the stress

Whether you’re looking to grow share, support a new launch, or just keep momentum going in a restricted media landscape, we’ve got tactical answers.

The Bottom Line

Regulations may have changed, but the need to drive engagement, build loyalty, and grow your brand hasn’t.

With SPARK, HFSS brands don’t need to go quiet. You just need to go smarter.

Want to explore your options?
Let’s chat. We’ll help you find a compliant, creative route to results.