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A View on TFL’s Junk Food Ad Ban

Wednesday 5th December

Last week London mayor Sadiq Khan confirmed a new policy that shook the marketing departments of FMCG brands across the country – a ban on high fat, salt or sugar (HFSS) food or drink products being able to advertise across the whole of the Transport for London network.

Aimed at challenging the growing obesity crisis in the UK, junk food, sugary drinks and chocolate brands will be amongst those impacted by the new regulations which will include all TFL advertising formats on the London Underground, Overground, Trams and Bus Stops in a move anticipated to cost the transport company millions in lost revenue.

The news has been met with mixed reaction; whilst the policy was shown to be largely supported by Londoners, the Advertising Association have condemned the news, citing that there is no evidence that the ban will have any impact on childhood obesity and the reduction in TFLs advertising income will likely be felt by pressurised commuters through higher fares.

My own opinion on the matter is that whilst growing obesity levels amongst youngsters is obviously an important issue that must be addressed, I’m unconvinced an advertising ban of HFSS products in the capital will have an effect. Whilst advertising plays an extremely crucial role in nudging behaviour and helping to bring certain brands and products to front of mind, I feel the heavy presence of fast food outlets across London high streets and stations probably has a much larger effect.

BJ Fogg’s behavioural model elicits for a desired behaviour to occur a prompt must take place whilst motivation and ability are both high. I would suggest that whilst advertising may increase a motivation for a certain brand, surely it is much more the readily availability of fast food at hugely favourable costs in which the high ability is created. Thus by removing HFSS advertising without doing anything to address this crucial issue may be no more than papering over huge cracks.

My main problem with the ban, however, comes in the limitations of the HFSS guidelines. Whilst it restricts fizzy drinks, greasy hamburgers and sweet products, it also implicates some grocery brands which could be aimed at encouraging youngsters and families to enjoy nutritious home cooked meals or fitness related products such as protein bars, which could help encourage exercise among young people. However, apparently there will be opportunities for brands to request consideration for advertising particular products that fall into HFSS restrictions if they can demonstrate with appropriate evidence that those products do not contribute to diets high in fat, salt or sugar (HFSS) in children, but it’s currently unclear how this will work and to what degree of leniency there will be.

Like it or not, however, come February 2019 the ban will be in place and here to stay and thus now is the time for affected brands and media agencies to begin assessing how to deal with the fall out. Below is just a few examples of strategies which could be implemented:


Geo-Targeted Digital Activity

One section of the advertising world who will definitely not be disappointed with the new policy is mobile advertisers. With digital ad spend overtaking TV for the first time in 2017 and showing no sign of slowing down, advancements in geo-targeted mobile advertising in recent years certainly offers an opportunity for some FMCG brands to reach consumers in environments which they now will no longer be able to have presence via Outdoor.


Focusing on non-HFSS restricted products

All is not lost for the likes of McDonalds and co, however, as they will still be allowed to promote their healthier products such as fruit, unsalted nuts and sugar free drinks, but will not be allowed to simply promote the general brand or logo.

Thus for the larger affected brands with multiple product ranges, the option to focus on their lower fat, salt and sugar products to continue keeping the brand front of mind in TFL environments is a real possibility.

One positive effect of the new regulations is it may actually encourage some generally seen less healthy brands to fast track healthier new product developments with a view to being able to continue implementing advertising with on the underground and other TFL environments.


Other Out of Home Alternatives

Of course other out of home options and environments such as road, rail and malls remain a viable alternative. In stark contrast to expected TFL revenue loss, it’s left to be seen whether this increased demand in alternative formats will drive higher avail costs.    

One thing the ban does definitely present for us here at Total Media, the behavioural planning agency, is an exciting opportunity to really reassess how we reach and influence the behaviours of target consumers in the capital for the affected brands we work with.

Article Written by

Sean Hearson

Account Executive, Total Media

Sean is an Account Executive here at Total Media. In addition to new media and advertising innovations, he’s also a passionate about cooking and football with aspirations to host his own TV show which combines the two: Come Dine With Messi

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