A ‘major breakthrough’, yet potentially ‘entirely ineffective’? Experts’ opinions about the ‘total ban’ on unhealthy food marketing online in the UK’s Health and Care Act (2022)

The UK's Health and Care Act (2022; paused until 2025) includes a globally novel ban on paid-for online advertising of food and beverage products high in saturated fat, salt and sugar (HFSS), to address growing concerns about the scale of digital marketing and its impact in particular on children's food and beverage preferences, purchases and consumption. This study aimed to understand the potential impact of the novel ban (as proposed in 2020) on specified forms of online HFSS advertising, through the lens of interdisciplinary expertise. We conducted semi-structured interviews via videoconference with eight purposively selected UK and global digital marketing, food and privacy experts. We identified deductive and inductive themes addressing the policy's scope, design, implementation, monitoring and enforcement through iterative, consensual thematic analyses. Experts felt this novel 'breakthrough' policy has potential to substantially impact global marketing by establishing the principle of no HFSS advertising online to consumers of all ages, but they also identified substantive limitations that could potentially render it 'entirely ineffective', for example, the exclusion of common forms of digital marketing, especially brand marketing and marketing integrated within entertainment content; virtual/augmented reality, and 'advertainment' as particularly likely spaces for rapid growth of digital food marketing; and technical digital media issues that raise significant barriers to effective monitoring and compliance. Experts recommended well-defined regulations with strong enforcement mechanisms. These findings contribute insights for effective design and implementation of global initiatives to limit online HFSS food marketing, including the need for government regulations in place of voluntary industry restrictions.