What does the HFSS ad ban mean for User-generated Content?

For marketers at brands who deal with HFSS (High in Fat, Sugar or Salt) products, the upcoming ban on many forms of digital advertising represents a key strategic challenge. Here we take on one specific question: “what about User-generated Content?”

By the end of 2022, the U.K. Government has confirmed that it will implement a total ban on paid-for advertising online for certain products that are High in Fat, Sugar or Salt (HFSS). Using the predefined Nutrient Profiling Model, foods that score four or higher on the scale – e.g. soft drinks with added sugar, chocolate confectionery, pizzas, ready meals, the full list of items in scope is accessible via GOV.UK here – will be banned from appearing in advertising across most TV and digital channels.

So firstly, what’s the story?

The ban will extend to almost all paid-for online advertising: search engine marketing, display advertising, social media marketing (including influencer content), video advertising (e.g. YouTube pre-roll, mid-roll etc.), advertorial content (including sponsored placement in newsletters), in-game and in-app banners, and even sponsored listings on food delivery services.

Crucially, brand advertising or sponsorship is not in scope. So long as the advertisement does not include an identifiable HFSS product, it will be allowed under the new rules.

At first glance, the conclusion appears to be that this is much better news for brand marketers (whose KPIs are most often linked to brand awareness, recall – qualitative metrics) than it is for product marketers (who must answer to more immediately commercial goals: conversions, user acquisition, revenue – quantitative metrics). But dig deeper, and the new legislation is an invitation extended to brands to consider the importance of the quality of experience they’re offering consumers at every touchpoint.

(The IAB – the U.K.’s industry body for digital advertising – provides an exhaustive list of what’s in and out of scope.)

What effect will HFSS have on UGC? 

One of the most effective tools at the disposal of marketers – those of both the brand and product inclination included – is User-generated Content. Authentic content that transcends the bounds of studied brand-created communication has a unique capacity to surprise, delight, and normalise like no other format. At StoryStream, we connect the power of “digital word of mouth” directly to our client’s commercial aims: check out our case studies if you’d like to learn more.

As for what HFSS means for UGC, let’s go use case by use case in a quick Q&A.

I am a brand that wants to post User-generated Content on my social media feeds. 

That’s fine, carry on resharing your hard-earned UGC to your brand social media channels. Marketing in a brands’ owned spaces (e.g. websites, organic social content) are not in scope for the HFSS. Issues do arise should you want to then sponsor that content – e.g. using UGC that features an identifiable HFSS product as part of your paid social strategy – as this is considered within the scope of the new rules. Content shared organically = fine. Content sponsored = not.

I want to use UGC on my website, is that allowed? 

Yes. Marketing in your owned spaces will not be covered by the new HFSS rules. You will be free to use User-generated Content on your homepages (whether that content is sourced from social media channels, or uploaded to your site via a StoryStream direct upload functionality), inspiration pages, galleries, and product display pages in the same way that you are doing today. That’s great news for product marketers (who appreciate the effect that authentic content has on driving on-site conversion) but may mean that they need to work a little closer than usual with their colleagues in the brand team (whose messaging, because it’ll be the only style of messaging that’s permitted, will become far more prominent in user acquisition channels like paid social, search, and display).

I use User-generated Content to drive conversion on retailer sites, will I be able to continue with that? 

Yes. As mentioned by the IAB in their guidance, “​​media supporting point of sale/purchase/transactional content (i.e. buying products online, such as from a retailer)” is exempted from the ban. If you’re using StoryStream to curate User-generated Content that’s then served into non-brand owned retailer environments, you will be able to continue to do so.

What about my “Link in Bio”?

If you’re using LinkStream as part of your social selling strategy, the new HFSS rules will not stop you from continuing to do so. As an extension of your owned brand properties (and one that’s hosted by StoryStream) the “link in bio” is exempt from the ruling. Sponsored posts on social media encouraging users to visit the “link in bio” will likely become increasingly important from this perspective – just be sure those sponsored posts don’t feature any identifiable HFSS products.

I’m a B2B brand, how does the HFSS ban affect me? 

If your end-user is a business decision-maker rather than a consumer, your ads will be exempted from the ban. Similarly, small to medium enterprises (i.e. those with fewer than 250 employees) are also exempted.

What’s the timeline for the HFSS ban?

Ahead of the ban coming into effect, the U.K. Government first needs to pass legislation. The current timeline for the ban’s introduction is 1st January 2023. In the meantime, the existing restrictions on HFSS advertising continue to apply.

The HFSS ban may very well stand to change the way parts of the internet look in 2023, but the net effect on a marketer’s priorities are far less dramatic: ensuring that the experiences offered to consumers are the very best it can be, and then giving those consumers every opportunity to reward that experience through custom will remain the fundamental goal of marketing teams.

Fully harnessing the power of User-generated Content, and scaling that (compliantly) across digital presences will remain an important way for brands to optimise the full customer experience of their digital properties. If you’d like to learn more about the size of the opportunity for your brand, you can contact us here.