How brands can win in the new HFSS regulatory landcape
How brands can win in the new HFSS regulatory landscape.
In January 2026, the UK introduced stricter laws around the advertising and marketing of HFSS and LHF foods, followed by updated nutrient profiling guidelines that placed more products into the Less Healthy Foods category.
In this landscape, food and drink design has become a battlefield between two opposing forces:
This creates what we call the Pleasure Paradox.
The more we restrict the mechanics of pleasure, the more intense our psychological pursuit of it becomes.
We’ve identified four key macro drivers that can help brands navigate this new landscape:

For decades, the food industry relied on “bliss point” engineering: high levels of sugar and salt designed to maximise reward. Regulation has effectively ended the era of the easy high. When you remove a buy-one-get-one-free chocolate promotion, you’re not simply removing a product, you’re removing a low-friction dopamine hit from a stressful day.
When easy pleasure disappears, consumers don’t stop wanting. They begin to hunt.
We are seeing desire migrate toward unregulated pleasure territories including premium delivery, late-night solo-treat rituals, and the rise of ingredients such as caffeine, protein and collagen that provide alternative forms of reward.

As the chemical levers of pleasure are reduced, food and drink must lean more heavily on alternative sensory signals. The industry is moving from flavour-led indulgence towards texture-led satisfaction.
When sugar is reduced, factors such as texture, viscosity, crunch and temperature contrast need to work harder. This represents a form of sensory regulation that uses the senses to satisfy consumers when traditional reward mechanisms are diminished.
At the same time, “ugly” or maximalist food design is becoming a signifier of authenticity. Imperfect and expressive products increasingly feel more pleasurable than their highly polished counterparts.

People often enjoy indulgence more when it feels earned.
A snack becomes something more when it sits within a ritual: a specific bowl, a curated playlist, or a carefully prepared beverage. Design is increasingly being used to create alibis for indulgence.
If packaging resembles an apothecary item, or preparation involves multiple steps, pleasure becomes reframed as self-care rather than self-indulgence.

The move towards clinical appetite suppressants such as GLP-1 medications, combined with cost-of-living pressures, is shrinking the quantity of food consumers want to eat.
We are entering an era where satisfaction matters more than satiety.
If consumers only want a few bites, those bites need to deliver an exceptional experience. The future may consist of highly engineered, small-format indulgences that satisfy psychological desires without triggering biological or regulatory concerns.
The four macro drivers are not simply cultural observations. They provide practical guidance for brands navigating the Pleasure Paradox.
The central provocation is simple:
The brands that win the next decade of British food and drink will not be the ones that find loopholes. They will be the ones that treat constraint as a creative material.

The 2026 advertising restrictions have created two distinct media environments: before 9pm and after 9pm. Smart brands should treat this split as an opportunity.
Daytime communications can focus on building brand worlds, identities and emotional connections without showing products directly.
Brands should ask:
Brands investing in distinctive brand assets today will have a significant advantage tomorrow.

For decades, indulgence has meant more sugar, more salt, more fat and more volume.
Regulation has effectively retired that formula and given brands a new challenge: invent a new language of pleasure.
The needs behind indulgence have always been deeper than ingredients. Consumers seek comfort, reward, escape and sensory intensity.
The challenge is to deliver those outcomes through methods that do not trigger the nutrient profiling model.
Texture: The snap, shatter and slow yield of food become increasingly important.
Temperature: Warmth, cooling sensations and thermal contrast remain underutilised sources of pleasure.
Scarcity: Limited drops and anticipation-building mechanics can create powerful emotional value.

Historically, brands focused on persuading consumers to buy more.
Today, successful brands help consumers feel good about their choices.
This is not about pretending products are healthy. It is about making indulgence feel deliberate, conscious and chosen.
Consumers are increasingly willing to pay more for products that encourage slower, more intentional enjoyment.
Portionable formats: Individual portions turn consumption into a series of conscious choices.
Deliberate friction: Small preparation rituals create a pause between impulse and enjoyment.
Time-based rituals: Linking consumption to specific moments gives indulgence cultural legitimacy and reduces guilt.

In the post-HFSS landscape, the villain is not indulgence.
The villain is dishonesty.
Consumers understand what a treat is. What they reject is misleading wellness messaging and claims that stretch credibility.
A brand that openly says, “this is a treat and it’s worth it,” can build more trust than one focused on marginal nutritional improvements.
Trust is becoming the ultimate indulgence code.
The regulatory landscape is likely to become more restrictive over time. The definition of “less healthy” will continue to expand, while opportunities for traditional product marketing will shrink.
Brands that see each new restriction as a crisis will continually retreat.
Brands that treat regulation as a design brief will discover a new creative frontier.
The Pleasure Paradox is not a problem to solve. It is a tension to design for.
HFSS = High Fat, Salt and Sugar
UPF = Ultra-Processed Food
LHF = Less Healthy Foods
A product can be HFSS without being UPF, and UPF without being HFSS. The public conversation often conflates the two.
Since 2022
Since 2025
Since January 2026
Potential future developments include:
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