Challenger Brands Vs. LHF Rules

Selling without showing. Advertising without appetite. That’s the new less healthy food and drink (LHF) era in a nutshell. This is now a world where the foodie ads we once knew are no more (at least, before the 9pm watershed on TV and online). For challenger brands, where consumers are often unfamiliar with their product offer, they face even more of an uphill battle when building familiarity.

For the big dog brands that already have widespread recognition, they can lean on their legacies, but what about those starting out? The ones looking to disrupt their sectors with something new? How will they promote what they sell now?

Challenger brands are all about questioning the status quo, bending the rules, and delivering surprises. The new LHF ad restrictions bring several more questions.

“A challenger launching a better-for-you crisp or craft energy drink needs to show the actual product, explain what it is, and why it's different,” explains Helen James, CEO at The Gate. “The restrictions don't hit everyone equally - they disproportionately punish the new and the small.”

The advertising playing field has shifted, and for those insurgent challengers, they have to play even smarter than before with their media buys. The rules are also infringing on the previous safe haven world of out-of-home too.

But in the face of adversity, there is always opportunity.

“These restrictions will inspire a new kind of creativity - one that brands might have once thought impossible,” counters Sophie Degraft-Johnson, social lead at Saatchi & Saatchi. 

And it leads to the question: who will become the boundary-pusher? Who will become the story-maker? Who will get left behind?

Through The Lens of Challenge

Being a disruptive brand is no easy feat in any sector. It takes a whole lot more than a good idea; it takes grit, determination, and outstanding creative thinking. 

And despite the difficult economic environment of recent years, challenger brands continue to emerge. In the last six months alone, over half of UK shoppers (51 per cent) purchased a challenger brand's product.

Surreal - the cereal company that rose to become one of the fastest-growing independent brands in Britain, is one example. It’s tactic: unique, disruptive marketing that hadn’t been seen before, from targeting users on LinkedIn to witty out-of-home billboards that can’t help but pique curiosity, to even partnering with a Viagra brand. It's secret weapon - surprise.

“Surprise is about 90 per cent of our marketing,” says co-founder Kit Gammell. “When we look at partnerships we always want it to be unexpected, but we always hope that it will also have crossover in terms of audiences.”

And Oatly - the Swedish oat milk brand that took on the task of getting populations to turn away from regular dairy milk to its alternative. A behaviour change tackling generations of consumer habits.

Over the years, it has developed a recognisable copy-led creative approach with its marketing - often through OOH - that has become eye-catching conversation starters.

One example saw it advertise real negative customer feedback (‘This tastes like sh*t!’), and even set up a WhatsApp chatbot for audiences to text their thoughts on whether it ‘works in tea’ - ideas that established dairy brands wouldn't dare to dream of.

Sometimes these stunts are not just about catching the attention of an audience, but that of industry rivals as well.

Tony’s Chocolonely, which began selling to UK consumers in 2019, is another challenger brand on the rise. It is already one of the most popular - and still growing - chocolate brands globally. This year alone, it was listed among TIME’s Most Influential Companies 2025 and ranked the most ethical large-scale chocolate company in the annual Chocolate Scorecard with a score of 91 per cent.

The Dutch company's pledge to end exploitation in the coca supply chain is a key part of its mission statement. It is even conveyed in the shape of its chocolate bars; the uneven chunks represent the inequalities in the cocoa industry, where profits aren’t shared equally between coca farmers and chocolate companies.

“Being a challenger brand means we never settle for the status quo. We don’t just sell chocolate; we use our brand as a megaphone for change,” outlines Nicola Matthews, head of marketing UK&I at Tony’s Chocolonely. “Whether it’s choosing partners who share our values, designing products and packaging that tells a story, or investing in impact-led campaigns, we challenge ourselves to be bold, uncomfortable, and uncompromising.

“Our unequally divided bars aren’t a gimmick - they’re a tool to raise awareness of inequality in the cocoa industry,” she continues. “And our outspoken tone comes from us refusing to stay quiet about injustice. This approach has made us the fourth biggest chocolate bar brand in the UK - and we’re growing at over 20 per cent globally.”

Despite being a loved brand that can be seen across a range of shelves in UK supermarkets from Waitrose to Sainsbury’s, Matthews notes that the journey wasn’t an easy one. It’s only recently that Tony’s UK turned to paid media; “We had no big budgets, no traditional media campaigns - just a loud mission, a bold bar, and a story worth sharing,” she says. “Beautiful constraints and intelligent naivety are a start-up brand’s best friend. We had to stand out to earn attention and drive word of mouth.”

Its marketing strategies place purpose-led storytelling at its forefront, which is often seen through retail media, social media - particularly Instagram and TikTok, and even eye-catching PR stunts, such as its recent pop-up in Soho.

The challenge of the new LHF/High in Fat, Sugar or Salt (HFSS) rulings, she says, is a task the brand will take on: “That DNA stands us in good stead for the changes in media options due to HFSS/LHF restrictions. We’ve never marketed to children as a principle, so we’re on board with the intent of the new legislation.” 

A start-up challenger's challenge

What about the brands who have just started its challenger journey? 

Cups Full is an up-and-coming challenger brand, looking to flip the script in the cut-throat coffee market by selling single-serve coffee bags to empower people to forget the faffing that usually comes with speciality coffee. “Like big juicy tea bags” is its self-styled offering.

Founder Katherine Willis has only just started this journey, with the vision to ensure everyone who enjoys a Cups Full coffee bag can confidently have 'a full cup moment'. 

Despite the regulations only just coming into force, Cups Full is already conscious of its communications output: “Our product is high-grade specialty coffee and is optimised and packed with potent antioxidants called polyphenols,” explains Willis. “We’ll be continuing to talk about sustainability - our bags are compostable. I have a few ideas for the future too, about making our product even more sustainable and even regenerative.”

The brand uses organic social media as its main marketing strategy, tapping into trends to grab attention, from hacks to give audiences their coffee fill while travelling to new ways to make hot drinks.

For a start-out challenger brand, she notes, the restrictions will make it harder to “cut through”.

“It will be hard enough to gain market share versus established brands that can be more aggressive and have bigger brand equity that isn’t reliant on digital channels.”

Tales Of The Unexpected

Challenger brands are clearly at a further disadvantage - in reach, in audience numbers, in budget. But arguably more than ever, they have the opportunity to flip the script of creativity like never before. 

“Why compete with people with deeper pockets? Why play by the same rules and expect to overcome their competitors? Why outspend your way to your audience? That doesn't sound like proper decision-making to me,” explains Menno Kluin, global chief creative officer at Iris. “As a result, those brands will have to become more creatively interesting. When you think about it, the government technically is forcing them to become better and more progressive marketers. Possibly making them more successful in the long run at marketing their LHF foods.” 

Some of the most loved ads from FMCG giants are inadvertently LHF compliant. Take what is often labelled as Cadbury’s most iconic ad featuring a gorilla playing along to Phil Collins on the drums, or Dominos' catchy ‘Domin-oh-hoo-hoo’ yodel.

Could the new era see the return of the unexpected that is so left-field it demands audience attention?

According to Helen James, the rulings have “handed incumbents a get-out-of-jail-free card”, and challengers will need to try and top that. 

For her, the restrictions aren’t the real problem for challenger brands to overcome: it’s the “massive disparity” in budgets - the chasm that forces them to “keep innovating”. 

“The LHF ban just makes the budget gap more visible,” she explains. “When everyone could play in the same digital sandbox, at least a challenger with a smart social strategy and some influencer partnerships could punch above their weight. Now the game includes expensive, scale-driven channels where the budget advantage of big players becomes brutally apparent.

“Will we see innovation? Absolutely. But not because of the restrictions. We'll see innovation because small budgets have always bred ingenuity. The question is whether the industry will celebrate that scrappiness or just reward the brands who can afford to dominate what's left of the available media landscape.”

Tony’s is certainly looking to continue its innovation, taking the restrictions as an “opportunity to get even more creative, bolder and try new tactics to reach more people”, according to Matthews. 

“We’re working... to turbocharge our organic social," while planning for a big 360 campaign in February, including its first TV campaign, she explains. The brand can afford to take that leap after winning free TV media spend through the Sky Zero Footprint Fund.

“It will be really interesting to see how other brands, big and small, approach the restrictions. We’ll definitely be watching with interest to see how online and TV advertising evolves in our category, but we’re not worried about our ability to continue to scale our brand and impact in the years to come,” Matthews adds.

The social sphere is another key player in this game; challengers could utilise the online space - particularly the use of creators. 

“The preclusion of the use of creators in paid advertising will hopefully move the needle away from dry ‘dead eyed influencer holds product up to camera’ in favour of either more interesting brand oriented creator partnerships, which aren’t reliant on featuring product - and could be supported with paid spend, like this Dove Recess Therapy content,” explains Degraft-Johnson.

“That’s just as true for challenger brands as it is for big hitters, and provides a jumping-off point for a different style of creator-led advertising, which is a good thing. It will open the door to more innovative creators vs those who’ll hawk myriad products without much authenticity.”

Willis agrees - believing challenger brands should utlise online content, being that “a lot of early traction” for them is online. “They might need to get more creative in getting noticed - perhaps in person experiential activations and PR stunts or working with influencers.” 

The Future of Challenger

Will the challengers of 2030 be different from those we’re used to seeing in 2025? Will the art of disruption run true, or will regulations mean core values shift in focus towards transparency, functionality, or even health claims?

The restrictions are an opportunity. A chance to stand out - not just with what’s being said, but how it’s done. 

“I genuinely think it’s easier to build a bolder brand with limited budgets and channels,” believes Matthews. “You sweat every penny and have to zig when they zag to have a hope of cutting through the chaos of messages people are bombarded with every day.”

New creative strategies will evolve - an inevitable feat for brands who are reliant on showing their products. 

“What could the ‘You’ve been Tangoed’ slap look like on TikTok in 2026?” questions Degraft-Johnson. “Or going even further back into advertising history, could this become the era of mascots once again? Where’s Tony the Tiger when you need him? 

“Alternatively, this could be where non-traditional social platforms come to the fore: Discord, Reddit, or even WhatsApp. Impossible creativity revels in restriction, so we should be leaning into this new world for the opportunities and bravery it will create.”

Not all will be rainbows and sunshine for the next generation of challengers; there will be moments of risk. James warns: “Does this regulation trigger a ‘nanny state’ backlash? When the government tells people what they can't have, suddenly, they want it more. Look at how Prime energy drink built a following, partly built on controversy and restriction. If consumers start viewing LHF restrictions as overreach rather than protection, brands could capitalise on that resentment. ‘They don't want you to see this’ becomes a positioning strategy. That's not progress, it's a perverse incentive.”

While it’s important not to forget the roots of challenging the status quo, new beginnings aren't always entirely negative. As Kluin concludes, “Change is a good thing. If you are willing to embrace it.”