Coupons: The Key Loophole in 2026’s HFSS Advertising Restrictions

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As of January 5, 2026, the long-awaited Less Healthy Food (LHF) advertising restrictions have come into full effect, dramatically reshaping the landscape of food and beverage marketing. Under these new rules, the UK government has banned product-led advertising for HFSS (high in fat, salt, or sugar) products across paid digital media, as well as on TV and streaming platforms before 9 pm.

While these measures aim to curb the promotion of HFSS products to younger and more vulnerable populations, one key exception remains: coupons. Unlike other promotional tools, coupons are currently unrestricted by the new laws, creating a loophole that brands can use to continue offering LHF products directly to consumers.

Why Coupons Are Still Compliant: The Distinction from Volume-Based Promotions

The decision to exclude coupons from the HFSS restrictions is not an oversight; it’s a deliberate distinction. While the restrictions focus on volume-based price promotions (e.g., multi-buy offers or ‘buy one, get one free’ promotions), coupons operate differently. Coupons offer discounts on single purchases, rather than incentivizing consumers to buy more. Because of this, they are not seen as volume-driven promotions and remain outside the scope of the new laws.

These discount vouchers allow brands to reduce the price of a product without encouraging increased quantity or frequency of purchases, which is the primary concern of the restrictions. As a result, coupons have become one of the few fully compliant ways for brands to market LHF products directly in 2026.

The Evolution of Couponing in a Digital World

For brands looking to adapt to the new regulatory landscape, the role of coupons will evolve. Traditionally seen as a promotional tool, coupons are now becoming a core communications channel. In the digital age, mobile coupons and digitally distributed vouchers can be strategically targeted to relevant audiences, enabling brands to deliver real-time promotions at the right moment.

Research by Savi Shopper OnePoll (November 2025) revealed that 70% of consumers would be willing to try a new product if offered a coupon. Among younger consumers, this figure jumps to 85% for those aged 25-34. The ability to offer targeted promotions via smartphones gives brands a competitive edge, making coupons not just a tool for discounts but also a sophisticated media channel in their own right.

The Power of Coupons: Driving Conversion and Building Brand Reach

For brands navigating HFSS advertising restrictions, the opportunity lies in integrating couponing into their broader media strategy. While channels like TV and digital advertising are now restricted, coupons can help brands maintain product visibility, drive conversions, and continue reaching targeted consumers.

For example, a well-known brand like Cadbury could reimagine its iconic Gorilla ad by integrating a QR code that links to a mobile coupon, driving both purchase and interaction. By layering coupons with other compliant channels, such as organic social media, CRM communications, and in-store placements, brands can continue to engage with their audience and capture first-party data.

Maximizing ROI with Compliant Channels

The brands most likely to succeed in the post-HFSS era will be those that embrace coupons early and integrate them seamlessly into their media planning. The following channels are particularly effective in this context:

  • Organic social media and owned websites
  • In-app placements and mobile ads
  • CRM and direct communications
  • DOOH (Digital Out of Home)
  • In-store POS (within regulatory limits)

These channels, when combined with mobile coupons or vouchers, provide an opportunity to boost awareness, drive trial, and measure consumer engagement in a compliant manner, all while ensuring that brands can still remain competitive in a regulated environment.

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