A Shifting Landscape in Food Marketing
Imagine walking through a bustling city center, where every billboard, bus wrap, and taxi side panel screams the latest fast-food deal or sugary drink promo, capturing the eyes of children and adults alike. This vivid scene has become increasingly common as food brands pivot to out-of-home (OOH) advertising, a strategic move to sidestep tightening regulations on high fat, salt, and sugar (HFSS) promotions. In an era where public health concerns clash with corporate interests, the food industry is finding new ways to maintain visibility, exploiting spaces that remain largely unregulated. This report dives into the current state of food advertising, spotlighting a dramatic 28% surge in OOH ad spend by major brands since the UK’s 2020 ban announcement on certain HFSS ads. The focus here is not just on the numbers, but on what this shift means for vulnerable audiences and the broader battle for healthier eating habits.
The industry’s turn to OOH platforms—spanning billboards, public transport, and station displays—marks a calculated response to restrictions targeting pre-watershed TV and online spaces. Major players like McDonald’s, Unilever, KFC, PepsiCo, Coca-Cola, Mars, and Mondelez are leading the charge, with McDonald’s notably boosting its OOH budget by 71% over a recent three-year span starting from 2025. Unlike digital or broadcast media, these outdoor channels operate in a regulatory gray area, offering brands a loophole to reach consumers without the constraints of HFSS rules. This trend raises pressing questions about the effectiveness of current policies and whether they can keep pace with such adaptive marketing tactics.
Trends and Tactics in a Regulated Era
Adapting to Restrictions with Outdoor Campaigns
As regulations clamp down on traditional advertising avenues, food companies have honed in on OOH as a powerful workaround. This shift isn’t merely about plastering logos on public spaces; it’s a deliberate effort to sustain exposure among demographics most affected by policy changes, especially children. Research shows that OOH advertising ranks as the second-largest source of food ad exposure for young audiences, trailing only TV, and serves as the primary channel for HFSS product promotions. With bus stops and train stations acting as unavoidable touchpoints, brands ensure their messages are inescapable, even as TV slots before 9 p.m. and online banners face stricter oversight.
Beyond sheer visibility, the appeal of OOH lies in its unregulated nature, allowing companies to bypass the intent of HFSS bans. This pivot has proven particularly effective in maintaining brand recall among impressionable viewers who might otherwise be shielded from such marketing. The data speaks volumes: since the policy announcement, the industry-wide increase in outdoor ad spend signals not just a reaction, but a proactive strategy to exploit gaps in the system. What’s clear is that without addressing these channels, the impact of regulatory efforts risks being diluted, leaving public health goals at a disadvantage.
Digital Frontiers and Hidden Promotions
Meanwhile, the digital realm offers another frontier for subtle marketing, with food brands weaving their presence into video game livestreaming and other online content. A staggering 94% of gaming footage analyzed contains food mentions—often energy drinks or fast food—embedded seamlessly into streams watched by millions of young viewers. What’s more troubling is that 98% of these cues lack any disclosure of paid promotion, blurring the line between organic content and advertisement. This tactic, focusing on brand identity rather than specific products in 39% of cases, often falls outside the scope of upcoming HFSS rules, creating yet another regulatory blind spot.
The rise of such understated digital tactics highlights how food brands are not just reacting to restrictions but actively innovating around them. High visibility in unregulated physical spaces combined with covert online strategies paints a picture of an industry determined to maintain influence, regardless of policy intent. Looking ahead, this dual approach suggests that both physical and virtual marketing will likely grow more sophisticated, challenging regulators to adapt quickly to protect vulnerable groups from pervasive HFSS messaging.
Challenges in Closing Regulatory Gaps
Navigating the hurdles of HFSS advertising control reveals a stark reality: current policies leave significant gaps that brands are quick to exploit. OOH advertising remains exempt from the UK’s upcoming ban on TV and online HFSS ads, undermining the very purpose of curbing unhealthy food promotion. This exemption allows billboards and transit ads to target children directly, often in spaces they frequent daily, like near schools or playgrounds. The loophole is not just a minor oversight; it’s a systemic flaw that threatens to derail public health initiatives before they can gain traction.
Compounding the issue is the elusive nature of digital marketing, where subtle cues in gaming content evade traditional oversight. With nearly two-fifths of these mentions focusing on branding rather than products, enforcement becomes a near-impossible task under existing frameworks. The lack of transparency—evidenced by the overwhelming absence of paid promotion disclosures—only deepens the challenge. Addressing this requires not just broader policies but also innovative monitoring tools to track and regulate content that doesn’t fit neatly into current definitions of advertising.
Potential solutions lie in expanding policy reach to include OOH spaces and mandating stricter disclosure rules in digital platforms. Yet, implementing such measures demands coordination across national and local levels, a feat complicated by varying priorities and resources. Until these gaps are bridged, food brands will likely continue leveraging unregulated channels, highlighting the urgent need for a more cohesive regulatory approach that anticipates industry adaptability rather than merely reacting to it.
Local Initiatives and National Shortcomings
While national policies struggle to keep up, local responses offer a glimmer of hope in tackling HFSS advertising. Transport for London (TfL) stands out with its ban on such ads across the Underground, buses, and taxis, a move credited with preventing nearly 100,000 obesity cases and saving the NHS over 200 million pounds. This initiative demonstrates the tangible impact of localized action, setting a precedent for other regions to follow. Already, 14 local authorities have adopted or are planning similar restrictions, with up to 150 more in consultation across England, signaling a grassroots push for change.
However, these efforts reveal a fragmented landscape where local successes contrast sharply with national policy limitations. The UK’s forthcoming ban on HFSS ads in TV and online spaces does little to address OOH channels, leaving a significant portion of advertising exposure unchecked. This inconsistency creates a patchwork of protections, where some communities benefit from proactive measures while others remain vulnerable to unchecked marketing. Bridging this divide calls for a unified framework that empowers local actions while ensuring national policies don’t lag behind evolving industry tactics.
Looking Ahead to an Evolving Market
As the food advertising landscape transforms under regulatory pressure, the future points toward continued reliance on unregulated spaces unless comprehensive measures are enacted. Brands are likely to double down on OOH campaigns and refine digital strategies, particularly in gaming and social media, where oversight remains weak. The adaptability of marketing—seen in subtle brand cues and undisclosed promotions—suggests that new challenges will emerge faster than current policies can address them, requiring regulators to think several steps ahead.
Global health trends and rising consumer awareness could pressure the industry to shift, but economic incentives often outweigh voluntary change. Technology, while a driver of elusive marketing, also holds potential for solutions, such as AI-driven monitoring of digital content or geofencing to limit OOH ad placements near schools. Balancing these innovations with privacy concerns will be key. Ultimately, the trajectory of food advertising hinges on whether policies can evolve to match the pace of corporate creativity, ensuring public health isn’t sacrificed for profit in this ongoing tug-of-war.
Reflecting on Findings and Next Steps
Looking back, the strategic pivot by food brands to out-of-home advertising exposed critical weaknesses in regulatory frameworks, allowing unchecked exposure to unhealthy food promotions among children. Local efforts, like TfL’s impactful ban, showcased what was possible when decisive action targeted public spaces, yet national policy gaps left much of the industry’s tactics unaddressed. The rise of covert digital marketing further complicated enforcement, as brands embedded themselves in gaming content beyond the reach of existing rules.
Moving forward, the path to healthier outcomes demands systemic policy overhaul, integrating OOH and digital spaces into HFSS restrictions. Collaboration between national and local bodies must prioritize closing loopholes, while technology should be harnessed to enhance transparency and monitoring. Health experts advocate for aligning business practices with sustainability and public well-being, a shift that could redefine industry standards. The challenge now lies in sustaining momentum from grassroots initiatives and translating it into a unified, forward-thinking strategy that protects vulnerable populations for the long haul.
