HFSS food and drinks advertising

Vodafone London Underground Campaign - Exterion Media

You will probably have read about the Mayor’s recent announcement to restrict the advertising of food and non-alcoholic drink that is high in fat, sugar and salt (‘HFSS’ products) across Transport for London’s advertising estate. The mayor is introducing this policy to reduce exposure to these advertisements among children as part of his response to the challenge of child obesity. The restrictions will come into effect from Monday 25 February 2019. The Out-of-Home market therefore must quickly put in place an efficient process to manage the changes. Below is an introductory briefing about the impending ruling; further dialogue will follow early in January 2019. 

The TfL Advertising estate covered: 

All the advertising estate managed by TfL is covered by this new ruling. This includes the London Rail estate (Underground, Overground, DLR, Trams), London Buses, London Bus Shelters, London Black Cabs, and any roadside large formats sited on TfL land. 
 
HFSS explained: 

HFSS is the classification for all food and non-alcoholic drink which is high in fat, salt, and/or sugar according to the Nutrient Profiling Model, managed by Public Health of England. Alcoholic drinks are not included in the ruling as they are governed under their own rules.  

For more information on nutrient profiling, visit the Department of Health website



It is the advertiser's responsibility to confirm whether a product featured in an advertisement is HFSS or non-HFSS. 
  

The new ruling requirements: 

1. All advertisers: 

  • Any advertisers wishing to feature food and/or non-alcoholic drinks in their creative copy must ensure that any products featured are ‘HFSS’ compliant (unless they have received an exception, see later)

    - ‘Incidental’ food and drink: The above includes HFSS food & non-alcoholic drinks which feature ‘incidentally’ in creative copy, so even if it is not an ad for food or drink. All such copy will need to be reviewed. 

2. Food or non-alcoholic drink brands, services companies (e.g. supermarkets, restaurants), or ordering services:

  • These advertisers must always feature a healthy option (non-HFSS) in their advertisement as the basis of their copy 

The TfL advertising guidelines have been amended to incorporate these new restrictions. HFSS is added as clause 2.3 (p) in the policy HERE


Exceptions: 

To ensure that the policy does not have any unintended consequence, there is the opportunity for food and drink brands to request consideration for advertising particular products (which are otherwise scored as HFSS) if they can demonstrate, with appropriate evidence, that those products do not contribute to HFSS diets in children. Consideration will be based on the following 4 factors: 

1. Is there a healthier version of the product available? 
2. Is the product on the PHE’s sugar or calorie reduction list?  
3. Is the product generally consumed by children? 
4. Does the presentation of the product appeal to children?  

The form to use to seek an exception can be downloaded HERE. All applications and questions should be sent to TfLHFSSQueries@tfl.gov.uk

If you would like an opinion on any creative please contact our copy approval team at !Copy.Approval@exterionmedia.co.uk

For any additional information or if you would like to speak to the HFSS team, please email us at HFSS@exterionmedia.co.uk



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