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Adapting to LHF legislation

Devising winning growth strategies in the face of HFSS restrictions

Health and wellness remain top consumer priorities, and governments are responding.

In the UK, one notable development is the Less Healthy Food (LHF) legislation, aimed at restricting the promotion of products high in fat, salt, and sugar (HFSS).

Under the rules, paid online advertising is restricted, and TV ads are banned before 9pm, but only for HFSS products in 13 defined categories, including chocolate, crisps, sugary cereals, and ice cream.

The impact of the legislation was felt early, from reformulated recipes to changes in packaging and product placement. For manufacturers, it was more than a compliance issue; it became an opportunity to rethink products, drive innovation, and stay ahead.

Reformulate, reimagine or risk falling behind

For many brands, the initial response to LHF legislation was to reformulate products to meet nutritional requirements. This shift has driven significant investment in research and development, with companies like PepsiCo and Dr Pepper leading the way by expanding their portfolios with more diet and zero options, variants that are quickly becoming the default. It’s telling that many consumers now refer to regular Coke as “full-fat”, in a reflection of shifting preferences driven by health awareness.

Reformulating indulgent foods, however, is more complex. In products like baked goods or chocolate, even small recipe changes can affect taste and texture, risks many brands can’t afford.

Still, reformulation brings new challenges. Ingredient lists often grow longer, which some consumers may perceive as over-processed or artificial. That’s why successful reformulation must go hand in hand with effective communication. Brands need to help consumers understand ingredient changes and frame them as improvements rather than compromises. In a competitive landscape, those who shape the narrative earn trust.

But it must be done carefully. Rushed changes risk alienating loyal customers and damaging brand reputation. Brands like McDonald’s have shown what strategic innovation can look like. Its McPlant burger, extensively tested before launch, proves that careful preparation can meet new expectations without sacrificing satisfaction.

Some manufacturers chose not to reformulate at all, instead keeping existing recipes and accepting limits on promotion. While this may offer short-term stability, it leaves space for more agile challengers to meet the growing demand for healthier, indulgent options.

Packaging: the silent spokesperson of your brand

LHF compliance doesn’t end with a product’s ingredients. It extends to how food is packaged and presented. Packaging design, once an afterthought, is now a key driver of both regulatory compliance and consumer trust.

Take front-of-pack traffic light labelling. Whether or not it drives purchase decisions, it clearly shapes perception. Even a small change in fat or sugar content can shift a label from red to orange, a subtle difference that may influence health-conscious shoppers.

In response, many brands are embracing simpler, more transparent packaging. Ingredient-led design, popularised by brands like Innocent Drinks, is gaining traction across the industry. M&S’s Only XX Ingredients range (as few as one ingredient in some cases) is another example, part of a broader effort to challenge perceptions of ultra-processed food. Still, authenticity matters. Today’s consumers quickly spot packaging that feels contrived or insincere.

Design is also becoming more data-driven, a necessary shift as advertising opportunities narrow. Techniques like A/B testing and programmatic design help brands refine elements like font, colour, and image placement, ensuring packaging communicates clearly and compliantly on the shelf.

Health vs indulgence: finding the sweet spot

Consumer desire for indulgence hasn’t disappeared, but it is evolving. Rather than replacing classic favourites, many brands are introducing HFSS-compliant alternatives alongside them. This approach allows legacy products to remain unchanged while broadening their appeal to health-conscious consumers.

Imagine oat bars next to chocolate, or protein-enriched ice cream beside classic vanilla. These aren’t substitutes, they’re complementary options designed for different preferences and occasions. The key is to position healthier alternatives as desirable, not lesser versions of the original.

This shift also creates opportunities for challenger brands. While legacy manufacturers must protect brand equity, newer players often have more freedom to experiment. In this evolving landscape, strong brand tracking and a clear identity are essential, especially as restrictions on traditional advertising continue to grow.

Linney – your partner in LHF strategy

Adapting to HFSS legislation doesn’t have to mean compromise.

From consultancy and menu engineering to creative reformatting and digital solutions, Linney can help you stay compliant, without losing your brand’s flavour. Talk to our experts today.

This article was originally published in Food Manufacture.