Whether Santa’s coming to town or not, Scrooge has certainly arrived early this year – and he’s taking the Christmas ads with him.
Every year, major British retailers and supermarkets race against each other in the battle for the best festive season campaign, and while famous faces are not uncommon, the grub is almost always the biggest star.
Think buttery mince pies, striped candy canes, indulgent pigs in blankets, sticky toffee pudding, panettone and Yule logs, sugar-dusted tortes and tarts, and a decadent selection of chocolate and cheese that will last you until early January.
Adverts in 2025, however, will likely look devastatingly different as they are set to be stripped bare of some of these favoured treats in compliance with the Labour government’s upcoming ban on junk food advertising.
Lidl GB chief Ryan McDonnell told The Grocer: ‘There’s no doubt we’ve had to engineer our ads differently and be a lot more conservative, because there are so many products and categories that fall under HFSS regulation.’
He added that ‘there’s a lot of uncertainty around what the rules of play are’ and that it ‘remained to be seen’ what that would look like across ‘traditional media and social’.
The new rules, which aim to tackle childhood obesity, prohibit television ads airing before the 9pm watershed from showing foods that contain high levels of fat, sugar, or salt (HFSS).
While these were due to be enforced from October 1 before being delayed until January, some British supermarkets have adopted the strict ‘nanny state’ curbs under a contentious voluntary industry agreement that will put the classic Christmas ad ‘under threat’, warn consumer experts.
Whether Santa’s coming to town or not, Scrooge has certainly arrived early this year – and he’s taking the Christmas ads with him
But what does that really mean? To understand the full impact of the ban, the Daily Mail analysed the ads of Christmas past and wiped them clear of foods that could be affected by it.
The result is a dispiriting visualisation of the ‘uncertainty’ around Christmas adverts that Britain’s Lidl chief Ryan McDonnell anticipates as creative teams try to toe the line without dampening the festive spirit.
The starkest example is Marks & Spencer’s 2024 offering. While it is not clear which companies are part of the voluntary industry agreement – and which foods are covered – it could mean much of the party food on display would be taken off the table.
This includes the pork pies, spring rolls, mince pies and the Christmas Cracker Colin the Caterpillar cake – would be taken off the table.
A side-by-side comparison of Tesco’s Christmas 2024 advert with the edited version reveals an equally bleak future for these typically dazzling campaigns that are a highlight of the festive season for many.
If the promo was created in 2025, the relatives sitting at the dinner table could no longer be depicted as tucking into their rich beef wellington, red cabbage, and gingerbread house.
Instead, they would have to contend with a bowl of brussels sprouts, as the Daily Mail’s recreation showed.
‘The classic supermarket Christmas ad featuring mince pies, chocolate boxes, or full festive spreads may be under threat,’ lifestyle and branding expert Karine Laudort told this newspaper.
The table was brimming with Christmas delights in Marks and Spencer’s Christmas advert last year but, under the new regulations, there would be nearly no food left for viewers to feast their eyes on
‘The latest restrictions on advertising “less healthy” or HFSS (high fat, salt or sugar) foods – including a 9 pm TV watershed and full ban on paid-for online promotion of these products – are set to significantly change how brands plan their festive campaigns.’
Morrisons’ 2024 Christmas ad would also be similarly impacted, with the regulations wiping out the glorious sticky toffee pudding, curry party food bites, and even the smoked salmon canapes in one fell swoop – meaning just the festive bao buns would remain.
Meanwhile, the new regulations would leave the Asda employees at the Christmas do in the company’s 2023 advert with empty bellies, as all the foods in the festive spread would no longer be acceptable.
A reimagined version of Sainsbury’s campaign from the same year is equally depressing, as it lacked several components like the salmon terrine, gammon, roast potatoes, and festive Golden Forest chocolate mousse.
Against this backdrop of uncertainty, Lidl’s O’Donnell previously told The Grocer that it ‘remained to be seen’ how the new rules would play out in real time.
‘It would be an understatement to tell you that we’re obviously learning very quickly, and there’s a lot of uncertainty around what the rules of play are, and that’s across traditional media and social media.’
Mr O’Donnell added that the restrictions will ‘no doubt’ change the way adverts are made as retailers adopt a more ‘conservative’ approach to their Christmas campaigns going forward.
According to marketing consultant Estelle Keeber, these rules will force brands to ‘think outside the box’ as they drum up ways to elicit the same warmth and fuzziness that earlier adverts evoked without the heavy focus on food.
The festive treats on display in Tesco’s 2023 Christmas advert included a gingerbread house, pigs in blankets and a beef wellington
Fast forward to today, and there wouldn’t be many festive treats for the pair to enjoy on December 25
ASDA employees crowded around a table filled with Christmas-themed goodies in the company’s 2023 advert
Under the new regulations, Asda employees would no longer have the luxury of dining on delicious foods like mince pies, chocolate truffles, and shortbread biscuits
Sainsbury’s showcased its Christmas range in its 2023 Christmas advert, including a roast gammon
The advert wouldn’t stand under the new regulations – with all the festive foods failing to meet the requirements
Speaking to the Daily Mail, she predicted a rise in animated campaigns, such as Aldi’s ‘fun, memorable, and family-friendly’ Kevin the Carrot short film that won hearts last year ‘without needing to show specific products’.
‘I also think we’ll see more lifestyle-led adverts that focus on moments, values, and experiences – rather than the food itself,’ Ms Keeber shared, while highlighting a rise in the use of AI to ‘bring ideas to life faster’.
However, Ms Laudort said that while big legacy brands might eventually be able to adjust to their new reality, ‘smaller or challenger brands may struggle’.
Companies like Asda and Marks & Spencer have strong brand recognition and market equity ‘so they can lean on emotion and storytelling’ while relying on brand values to tide them over choppy waters.
‘Smaller brands that rely on product activation or cues will find the new rules much more limiting.
‘I think we should expect to see more animated adverts, more storytelling without showing the product, and fewer traditional indulgence-heavy Christmas adverts – especially for supermarkets and brands whose hero items fall into the HFSS categories,’ she concluded.
‘The rules will force creativity, and we will likely also see festive campaigns becoming more subtle, more brand-driven, and less product-centric.’
Earlier this year, M&S chair Archie Newman appeared to make a swipe at the new regulations during an industry conference, saying it would mean ‘regulating to stop people talking about mince pies.’
It was bao buns, salmon canapes, and prawn coconut curry bites galore in the Morrisons advert last year
The Morrisons spread would look a bit thinner under today’s standards, with just the bao buns left
‘You won’t be able to run an ad that includes Christmas pudding, your mince pies or sausages,’ he told the conference, according to The Sun.
The move is intended to tackle the ‘crisis’ in childhood obesity, with alarm that a third of youngsters are overweight by the end of secondary school.
Discussing the advertising ban, Health Secretary Wes Streeting said last year: ‘Obesity robs our kids of the best possible start in life, sets them up for a lifetime of health problems, and costs the NHS billions.
‘This government is taking action now to end the targeting of junk food ads at kids, across both TV and online.’
NHS data shows a trend of rising childhood obesity, with almost one in ten reception-aged children (9.2 per cent) now living with obesity and one in five by the age of five (23.7 per cent) suffering tooth decay.
Children with obesity are said to be more likely to live with the condition as adults and to be at significantly greater risk of life-limiting illnesses.
Obesity is the second biggest preventable cause of cancer, according to health experts, costs the UK health service more than £11 billion each year, and is a major contributor to ill health that prevents people from participating fully in work.
Chris Snowdon, head of lifestyle economics at the Institute of Economic Affairs, said: ‘The ban on food advertising has no global precedent so Britain is in uncharted territory, but I predict that it will not lead to a reduction in obesity. Every other anti-obesity policy has failed, including the sugar tax and mandatory calorie labelling, and I see no reason why this will be any different.
‘It is bad news for broadcasters, internet platforms and for everyone who uses them. If, in five years, obesity rates have not fallen, the ban should be repealed and serious questions should be asked of the pressure groups who pushed for it.’










