Food and Nutrition
Key points
- Health and nutrition claims must be authorised — you can’t make them up
- HFSS products face significant advertising restrictions
- Claims must be accurate for the product as sold
- Diet and weight loss claims need careful handling
What the Code says
The Code of Practice requires that we “ensure claims are truthful, accurate and can be substantiated” and “comply with all relevant advertising codes and regulations.”
Food advertising involves specific rules about health claims, nutrition claims, and restrictions on certain product types. Getting it wrong can result in ASA rulings and enforcement action.
Health and nutrition claims
Claims about health benefits or nutritional content are strictly regulated:
Nutrition claims
Claims like “low fat,” “high fibre,” or “source of protein” have defined meanings. A product must meet specific criteria to use them:
- Low fat — no more than 3g per 100g (or 1.5g per 100ml for liquids)
- Source of protein — at least 12% of energy from protein
- High fibre — at least 6g per 100g
Health claims
Claims linking food to health benefits must be from the EU Register. You can’t create new claims. Examples of authorised claims:
- “Calcium is needed for the maintenance of normal bones”
- “Vitamin C contributes to the normal function of the immune system”
Disease risk reduction claims
Very few are permitted. Claims that a food reduces disease risk require specific authorisation.
The “superfood” problem
Terms like “superfood” make implied health claims. Unless you can back them with authorised specific claims, avoid vague wellness language that could be challenged.
HFSS product restrictions
Products high in fat, salt or sugar (HFSS) face significant advertising restrictions:
Current rules
- No HFSS advertising in children’s media
- No use of licensed characters or celebrities popular with children
- No promotional offers appealing to children
New restrictions (from October 2025)
- Ban on paid-for online HFSS advertising
- 9pm watershed for TV HFSS advertising
- Some exemptions for small businesses
What counts as HFSS?
Products are scored using the Nutrient Profiling Model. The scoring considers energy, saturated fat, sugar, salt, protein, fibre, and fruit/vegetable content. Many products you might not expect score as HFSS.
Implications for copywriters
If you’re working on food advertising, check whether the product is HFSS. This affects where ads can appear and what they can include.
Weight loss and diet claims
Diet and weight loss products have specific rules:
What’s prohibited
- Claiming a specific rate of weight loss (e.g., “lose 7lbs in a week”)
- Targeting people who are underweight or vulnerable
- Using “before and after” images that exaggerate results
- Claiming products work without diet or exercise (unless true)
What’s permitted
- General claims about supporting weight management
- Factual information about calories or nutritional content
- Testimonials (if genuine and representative)
Evidence requirements
Weight loss claims need robust evidence. Consumer testimonials alone aren’t enough — you need proper studies showing the product works.
The “too good to be true” test
If a weight loss claim sounds too good to be true, it probably is — and the ASA will likely agree. Be realistic about what products can achieve.
Food advertising to children
Beyond HFSS restrictions, all food advertising to children must:
Not encourage poor diet
- Show excessive consumption
- Disparage healthy eating
- Undermine parental authority on food choices
Not exploit children’s trust
- Use direct exhortations (“tell mum to buy”)
- Exploit pester power
- Make children feel inferior for not consuming the product
Be responsible about promotional techniques
- Licensed characters and celebrities shouldn’t promote HFSS foods to children
- Competitions and promotions shouldn’t be the main appeal
Practical approach
Working on food advertising:
Before you start
- Check if the product is HFSS (ask the client for nutrient profile score)
- Identify what claims are authorised for the product
- Understand the target audience and media placement
Writing claims
- Use authorised wording for health claims
- Ensure nutrition claims are accurate for the product as sold
- Avoid implied claims that can’t be substantiated
Getting approval
- Build in time for legal/compliance review
- Be prepared to adjust claims based on feedback
- Document the evidence base for claims made
Summary
Food copywriting requires understanding the claims framework — what can be said, what must be substantiated, and what’s prohibited. HFSS restrictions add another layer of complexity.
Work closely with clients on compliance and use authorised claim wording. Avoid the temptation to make vague wellness claims that sound good but can’t be substantiated.
