By Charlotte Malbasa, Client Director, Capture – part of the SMG agency network
From 5 January 2026, the rules of UK food and drink advertising will change dramatically. Products classified as Less Healthy Foods (LHF), typically those high in fat, salt, or sugar (HFSS), will fall under tough new restrictions. The new rules include a 9pm watershed ban on TV and streaming, plus a complete block on paid-for online advertising, both on-site and off-site.
For brands that have relied heavily on product-led advertising: creatives featuring product visuals, pricing, promotions, or direct calls-to-action, this is a major shake-up as these formats will no longer be viable in the UK’s most visible channels.
But brand-led advertising, which focuses on people, experiences, and storytelling, without featuring the product itself, remains exempt. For example, Cadbury’s infamous drumming gorilla performing to Phill Collins, McDonald’s ‘Raise Your Arches’ or Coca-Cola’s annual Christmas ‘Holidays Are Coming’ campaigns, would all still be allowed under these new regulations.
With the clock already ticking, for many brands, there will need to be a focus on how they can implement long-term brand-building strategies rooted in emotional resonance and consumer trust, instead of relying on straight-to-the-point product-led creatives. Especially with voluntary adoption by trade bodies including the Advertising Association, ISBA, IAB and major retailers and publishers expected to adhere to these new rules as early as October 2025.
Retail media: the critical safe haven
But there is another way forward.
While many traditional and digital channels will be off-limits, retail media remains a compliant and high-impact solution. Once pigeonholed as a lower-funnel, conversion-only tactic, retail media has rapidly evolved into a full-funnel ecosystem capable of driving awareness, significant reach, consideration, and loyalty.
Additionally, digital out-of-home (DOOH) and digital audio platforms like Spotify and podcasts will also remain unrestricted, with both of these channels able to deliver reach and awareness. But with every brand eyeing the same alternatives, this will limit inventory, and competition is likely to be fierce. Retail media, by contrast, offers not just reach, but scale, salience, and contextual relevance at the point of purchase.
And with its rapidly growing brand-building capabilities, it complements DOOH and audio to drive frequency and impact across the funnel.
A MESH Experience and SMG study found in-store activations deliver a 5-6× uplift in brand awareness, precisely the metric at risk as brands lose access to TV and online advertising.
Research from Co-op and Lumen found that media in smaller, convenience retail environments deliver 2x the visibility due to greater store exploration and repeat aisle visits; 3× the attention, as shoppers engage more deeply with branded materials; and 4× the brand recall, due to higher exposure frequency in smaller formats.
What this tells us is that retail media can actually be leveraged by brand marketers as a compliant, scalable OOH platform.
Why retail media will matter more than ever
Retail media offers something few other channels can: the ability to keep product-led advertising alive within a compliant environment. At the same time, it has expanded into a powerful space for brand storytelling at scale.
The UK grocery landscape now offers thousands of digital and physical touchpoints, from in-store digital screens and radio to magazines, loyalty CRM, experiential activations, and proximity-based OOH. Supported by unified first-party data and increasingly sophisticated measurement tools, brands can now run full-funnel, omnichannel campaigns that drive awareness, conversion and loyalty, all within the retail media environment.
Retail media is becoming an avenue for true integration throughout the traditional funnel, and the real opportunity will lie with the brands willing to adapt and lead.
How to embrace the changing landscape
The shift away from traditional product-led advertising means brands now need to rethink how they use retail media across the funnel:
- For conversion: Target high-intent moments such as in-aisle media or till-point messaging where shoppers are ready to buy.
- For awareness and equity: Use rich ad formats and high-visibility placements front of store and around stores, or seasonal relevance for customers.
- For consistency: Layer channels like in-store radio with retailer’s first party data and on-site digital media to create ‘multiplier effects’ across the shopper journey.
Retailers are also innovating rapidly, digitising stores and integrating their tech capabilities into more offsite channels, traditionally reserved for brand building. These developments mean compliant creativity doesn’t have to feel limited, and if anything, the options are becoming richer.
Measuring brand impact in retail media
As advertising shifts from products to masterbrands, measurement must evolve too. Success is no longer just about immediate sales. Brands should focus on three pillars:
- First-party data gives brands confidence that their messaging is reaching the right people and driving results.
- Looking at broader metrics like brand lift, awareness, and sentiment helps to understand long-term impact.
- Measuring the ‘halo effect’ helps to understand how a brand campaign influences shopper behaviour across future missions, not just the immediate moment.
One challenge is that measurement often remains siloed within individual retailers’ ecosystems. To understand broader market-wide impact, brands will need to integrate retail media into their marketing mix models, which takes time and investment. Or use interim proxies like attention, reach, and frequency while tools mature. Encouragingly, retailers and media owners are rapidly advancing their capabilities, making long-term impact measurement more reliable.
What brands should do now
The new restrictions are not just a compliance challenge; they’re a strategic reset. To prepare, brands should:
- Shift from a product-first to a brand-first mindset, with campaigns rooted in storytelling and emotion.
- Treat retail media as a strategic brand-building channel, not just a sales driver.
- Test and learn across new formats, while revisiting ‘old-school’ tools like in-store radio with fresh perspective.
- Partner closely with retailers to co-create compliant, innovative activations.
- Update measurement frameworks to capture both immediate performance and long-term brand impact.
The upcoming LHF restrictions represent a major reset for how brands advertise in the UK. While the rules close doors on TV, streaming, and online, they open opportunities for smarter, more creative approaches.
Retail media sits at the heart of this shift. It is compliant, data-driven, and capable of delivering impact across the full funnel.
In short, the rules are changing, but so are the opportunities. Retail media isn’t just a workaround for LHF restrictions. It’s the future of smart, connected, emotionally resonant marketing. And for brands willing to embrace that shift, the rewards will be long-term, measurable, and meaningful.
