How the HFSS Ad Ban Will Impact Brands and Why UGC Offers a Way Forward
Jennifer Hobson•
If you work in food and drink marketing, you’ve probably got 5 January 2026 circled in red. That’s the day new restrictions on HFSS (High Fat, Salt, Sugar) advertising officially kick in, and it’s set to change how brands show up on TV and online.
But while the headlines scream ban, the reality is more nuanced. There are still creative, compliant ways to connect with your audience. In fact, this shift might even accelerate something we’ve all seen coming: the rise of creator-led content and UGC.
The 2026 HFSS Ad Ban in a Nutshell
Here’s what’s changing:
- TV: No HFSS ads before 9pm
- Digital: A total ban on paid ads for HFSS products
- Still allowed: Brand-led advertising (think reputation, heritage, values) and non-HFSS product ads
On the surface, that sounds limiting. But it doesn’t mean brands lose their voice, it just means they need to be smarter about how they use it.
Why UGC Could Be Your Secret Weapon
1. Free from restrictions, with trust built in
The proposed rules don’t apply to organic creator activity. That means you can still work with trusted UGC creators to showcase your healthier options, talk openly about product reformulation, or share stories that resonate authentically with your audience.
And let’s be honest: consumers trust real voices more than polished ad scripts.
2. Reach at scale, without breaking the bank
As pre-9pm TV slots get more expensive, creators offer a more flexible, targeted, and cost-effective route. Want to engage parents looking for snack swaps? Fitness-focused young adults? UGC makes it possible to reach the right people without wasted spend.
3. Integrate, don’t isolate
Creator content isn’t just for social feeds. You can repurpose UGC across OOH, print, organic channels, or even as part of a bigger brand campaign. Done well, it amplifies your message without breaking any rules.
A Window of Opportunity
The ban won’t land until January 2026, which means brands have a valuable 4-month runway. This is the time to experiment, test partnerships, and build a solid UGC framework so you’re not scrambling when the rules hit.
If anything, this is less of a setback and more of a chance to rethink how you connect with your audience in a way that feels fresh, compliant, and future-proof.
Want to see what that could look like for your brand? SHOUT can help you design a UGC campaign framework tailored to HFSS challenges, complete with creative ideas and rollout plans. Book a call with us today to get started.
