On 3 December, The Food Foundation published its State of the Nation’s Food Industry report – and its headline message is hard to ignore: when government regulation starts to close in, marketing budgets don’t disappear, they move.
The report highlights that outdoor advertising spend by food companies rose 28% between 2021 and 2024, in the years after the Government signalled tougher restrictions on junk-food advertising on TV and online.
From screens to streets: the spend that “shifted”, not shrank
The backdrop is the UK’s forthcoming HFSS (high fat, salt and sugar) advertising restrictions, due to be implemented in January 2026, which will ban HFSS adverts online and on TV before 9pm.
But the report argues that a critical weakness remains: outdoor advertising is exempt – creating an obvious escape route.
Outdoor formats aren’t niche either. They include billboards, buses, bus shelters, stations, retail and leisure sites, and taxis – the kind of media you can’t scroll past or switch off. The report notes that 98% of the UK population sees at least one outdoor advert each week, and that outdoor advertising is a major source of children’s exposure to food advertising.
McDonald’s: the biggest jump, the biggest presence
Among the companies analysed, McDonald’s stands out most sharply. The Food Foundation reports that McDonald’s outdoor advertising spend increased by 71% between 2021 and 2024 – the largest rise of any business surveyed.
It also notes McDonald’s spent £86 million on outdoor advertising in 2024 alone.
The significance isn’t just the number – it’s what it represents. If the most visible brands can pivot quickly into channels not covered by legislation, the public-health intent of the rules risks being diluted before they even begin.
The wider list of heavy hitters
McDonald’s wasn’t the only major spender identified. The report points to other companies with high outdoor advertising spend, including Unilever, PepsiCo, Coca-Cola, Mars and Mondelez.
In other words: this isn’t a one-brand story. It’s a sector-wide signal that when one door closes, many firms will look for the next open window – especially in high-reach media that remains largely unregulated in the same way as TV and online.
Gaming and live streaming: “always-on” marketing in plain sight
The report also highlights a second channel where marketing is reaching young audiences at scale: video game live streaming platforms.
It found that over two-thirds (71%) of food marketing cues observed were for unhealthy HFSS food and drink, with 77% of branded cues linked to energy drinks and soft drinks, and 20% linked to the fast-food sector.
One of the sharpest details is how often this marketing can evade typical definitions of “an advert”. The Food Foundation notes that a significant share of cues can be brand-led rather than product-specific, and therefore risk sitting outside the scope of certain restrictions.
“The market won’t fix this”: calls for bolder action
The tone of the report is not simply observational – it’s urging intervention.
The Head of Food Business Transformation at The Food Foundation, warns against relying on voluntary progress, arguing that it’s simply not working, and calling for bold and urgent action from business and government to reset the incentives that shape what is produced, promoted and sold.
This is the crux of the argument: if healthier outcomes are optional, and unhealthy products remain the easiest to promote at scale, the commercial default settings will keep pulling in the same direction.
Corporate influence and the slow pace of policy
Beyond advertising spend, the report also raises concerns about corporate lobbying and the transparency of policymaking.
It states that, in the period July 2024 to June 2025, meetings between the food industry and ministers outnumbered NGO meetings by 10 to one, with limited clarity on what was discussed.
The report warns that such imbalance can slow public-health regulation – pointing to the fact that the advertising restrictions took five years to come into effect.
Separately, reporting has also linked the timetable and design of the HFSS ad restrictions to industry pressure, including debate over whether brand-only advertising should be exempt.
The “brand-only” loophole — and why it matters
The Executive Director of the Obesity Health Alliance, argues the findings show companies can change behaviour quickly when regulation is announced – but that speed becomes a problem when the rules leave gaps.
They point to outdoor advertising exploding as spend shifts to unregulated spaces, and warn that future policies must be comprehensive, cover all channels, and close the brand-only loophole that can leave substantial advertising out of scope.
In plain terms: if the rules focus narrowly on where ads appear (TV/online) or what appears (specific HFSS products), but leave room for brand-heavy campaigns elsewhere, the outcome can be the same exposure – just delivered through different routes.
Conclusion: the ads didn’t go away — they just went outside
The Food Foundation’s report paints a consistent picture: the moment government signalled tougher junk-food advertising rules, a sizable slice of marketing effort was repositioned into places the rules don’t fully cover – particularly outdoor media and livestreaming environments.
With outdoor food advertising spend up 28% and McDonald’s up 71% between 2021 and 2024, the report argues the United Kingdom risks entering 2026 with tighter legislation on paper, but familiar marketing pressure in everyday life.
The warning from both The Food Foundation and the Obesity Health Alliance is that policy can only protect children’s health if it is designed for how advertising actually works in the real world: multi-channel, brand-led, and fast to adapt.
The choice now, as the restrictions approach, is whether the government responds with a patchwork of partial limits – or a joined-up approach that closes the gaps before the billboards fill them.
