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What is HFSS? And How Will it Affect Food and Drink Photoshoots?

May 15, 2026

Roughly a 2 minute read by Carly Hendren-Smith

When a client recently approached me about managing a photoshoot that needed to take into consideration the new HFSS legislation, I’ll admit that I didn’t know a whole lot on the subject.

I’d heard of the new guidelines but as I imagine a lot of people in the hospitality industry felt/still feel, I couldn’t picture what this would look like in practice.

To strip it right back:

• HFSS = High Fat, Salt and Sugar
• A HFSS product is either a food or soft drink that has high fat, salt or sugar content

What are the rules around HFSS?

• HFSS legislation only affects paid media/ads, organic content isn’t affected
• It also affects TV shown between 5.30am – 9:00pm and on-demand services too
• Advertising must not show non-compliant products on the above restricted channels
• Organisations can be fined if they don’t comply

And what does this look like for food & drink photoshoots?

• Only photography that will be used on the restricted channels will be affected by the legislation
• For products that are compliant, brands don’t need to worry about how these are shot (unless they are aimed at kids, and then this is a whole other can of worms we had to look into!)
• For products that are non-compliant, brands could:
  • Not push this photography on the restricted channels
  • Adopt a more ‘lifestyle’ focused approach, where the products aren’t centre stage
  • Look at an 80/20 balance, where the products only make up 20% of the image, so aren’t the main focus
  • Shift the focus to the brand/atmosphere rather than on the products themselves

As brands become more comfortable with the legislation I’ll be intrigued to see how they approach advertising and marketing of non-compliant HFSS products

Watch this space!