ISBA/IAB/IPA - HFSS Joint Consultation Response

This is a joint response on behalf of our memberships to the UK Government’s consultation on introducing a total online advertising restriction for products high in fat, sugar and salt (‘HFSS’). This unprecedented joint response from the Incorporated Society of British Advertisers (‘ISBA’), the Internet Advertising Bureau UK (‘IAB UK’) and the Institute of Practitioners in Advertising (‘IPA’) reflects the potential existential impact of this proposal across the advertising industry.

For food and drink manufacturers; restaurants and takeaways; food retailers and food delivery platforms who choose to advertise in the UK; for advertising agencies (both media and creative); for the digital advertising supply chain; and for digital media owners – including news media brands – this proposal threatens investment and jobs for all and, for some, their very viability.

This proposal comes as a significant and unwelcome headwind, during a climate of economic uncertainty driven by Brexit and the impact of COVID-19. It says to the world that the UK is an unpredictable place to invest in tech, with arbitrary changes to policy and regulation out of step with the modern world. It says to the food industry, which during the pandemic has been championed for keeping the nation fed whilst tackling significant commercial challenges, that they should no longer invest in reformulation and innovation. It says to the wedding cake manufacturer, the Indian restaurant and the local café that government doesn’t care about their ability to grow their business.

It is a disproportionate and inequitable response to the sought policy outcome – to reduce children’s exposure to HFSS online advertising – built on an evidence base that is incomplete and flawed. It ignores, without justification, good practice in the market and a more proportionate and sophisticated response that builds on that good practice.

We address all these points throughout our response.

ISBA/IAB/IPA - HFSS Joint Consultation Response

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Appendix A - SLG Economics Final Report

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Appendix B - Professor Andrew Stephen, Expert Opinion

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