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What is 'HFSS'?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.
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 exemption).
If an ad features or makes reference to an identifiable HFSS product, either alone or as one of a range of products shown, it will be treated as an ‘HFSS product advertisement’ and will be subject to the HFSS restrictions.
Marketers should also note that the use of branding in an ad, even if the product itself doesn't feature, could have the effect of promoting a specific HFSS product. The word "branding" is used in its widest possible sense and can include logos, marks, characters, colours or straplines that are directly associated with a particular product, range of products or company.
‘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.
The TfL advertising estate coveredAll the advertising estate managed by TfL is covered by HFSS. 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.
*JCDecaux has a number of local authority contracts such as Camden and Kensington & Chelsea which do not fall under TfL jurisdiction.
*Please note HFSS also applied to all panels located in Lewisham.
For more information on the TfL Ad Policy, click here.
- It will be the advertiser’s responsibility to confirm whether a product featured in an advertisement is HFSS or non-HFSS.
- It is the up to the Advertiser to have the Nutrient Profiling Model completed, & this must be done for each product.
- The onus is with the Advertiser and not the Specialist/Agency & this means JCDecaux must have it in writing from the client themselves. If emails are forwarded on from a Specialist/Agency, they must be attachments and not copy/paste.
- If there is any element of doubt, then there must be a submission of the copy and statement to TFL via the normal process
exemptionsTo 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?
A form for anyone seeking an exemption can be downloaded below. All applications and questions should be sent to: TfLHFSSQueries@tfl.gov.uk
Incidental HFSS creative – Non HFSS advertiser/product but with an image that may be considered HFSS.
- This should always be submitted to TFL via the normal process
- The Nutrient profiling model is NOT used for incidental copy
Things that will be considered when submitted:
- Is it clear what the product is
- Size of the product
- The audience the product is aimed at
- Are children present in the advert?
- Is the HFSS product used to sell the main brand?