Governments can influence eating habits not only through bans and restrictions, but also by shaping what consumers are exposed to in their everyday environment. The United Kingdom has taken this approach by introducing tighter restrictions on advertising foods high in fat, sugar and salt, with a particular focus on protecting children. Juras Žymančius, Senior Associate at COBALT, looks at the UK model and how it compares with the regulatory approach taken in Lithuania.
The United States has also recently revised its national dietary guidance, setting out recommendations for a balanced diet through to 2030. The familiar “plate” model, first introduced in 2011 to illustrate the main food groups and their recommended proportions, remains in place. However, the latest guidance changes how the model is interpreted in practice.
According to Juras Žymančius, the updated recommendations revise the suggested intake of certain foods, place greater emphasis on the role of protein and dairy products, and take a more detailed approach to assessing overall dietary composition.
Less exposure to unhealthy food advertising
The UK’s new advertising rules focus on products that are high in fat, sugar and salt. These products can still be legally sold and consumed; what has changed is the extent to which they can be promoted. Advertising for products such as soft drinks, sweets, pizza, ice cream and other foods high in fat, sugar and salt is restricted on television before 9 p.m., when children are more likely to be watching. Restrictions also apply to online advertising. The policy is part of a broader effort to address childhood obesity. Research cited in support of the measures shows that around one in ten children in the UK is already obese by the age of five.
“Lawmakers have opted for a preventive approach. The underlying assumption is that reducing exposure to this type of advertising can encourage healthier choices, even where consumers are not consciously aware of how advertising affects their behaviour,” says Žymančius. “The restrictions are not based on the view that such advertising is necessarily misleading or unfair. Rather, the argument is that repeated exposure itself may have harmful effects. In that sense, the approach has similarities with restrictions traditionally applied to advertising alcohol and tobacco. Instead of limiting what consumers may buy, the law changes the commercial environment in which their choices are made.”
This approach reflects a broader regulatory assumption: if consumer behaviour can be influenced by subconscious factors, intervention may be justified before the purchasing decision itself is made.
Lithuania has taken a different regulatory path
Lithuanian law does not currently treat unhealthy food as a separate category subject to broad advertising restrictions. Instead, the focus is primarily on the way products are marketed. “Lithuanian regulation is more concerned with how advertising is presented to consumers. Misleading claims, unfair commercial practices and inappropriate targeting of children are prohibited. In other words, the emphasis is less on the product itself and more on the way it is promoted,” explains Žymančius.
The Lithuanian Parliament has nevertheless considered introducing stricter rules similar to those now being applied in the UK. Proposals to restrict advertising of unhealthy food were debated several months ago but were ultimately rejected. Among the key difficulties were the question of how “unhealthy food” should be defined and concerns that broader restrictions could reduce advertising revenues for media organisations. Parliament therefore voted against introducing a general ban. “The main difference between the United Kingdom and Lithuania is not whether unhealthy diets are considered a public health issue – both countries recognise the problem,” says Žymančius.
“According to Eurostat data from 2022, Lithuania ranked fifth in the EU in terms of the share of overweight people aged 16 and over. The real difference lies in how lawmakers view the influence of advertising and where they believe responsibility should sit.” Lithuania is also using fiscal measures alongside advertising regulation. Amendments to the Law on Excise Duties introduced an excise duty on sweetened beverages from 2026, using price as another tool to influence consumer behaviour.
Two different approaches to consumer choice
The UK model is built on the idea that visibility influences behaviour: reduce exposure to unhealthy food advertising, and consumers may be more likely to make healthier choices. Lithuania currently places greater emphasis on ensuring that advertising is fair and not misleading, while leaving consumers with more responsibility for the choices they ultimately make. “The UK model seeks to influence behaviour by limiting certain commercial stimuli. Lithuania’s approach focuses more on the rules of fair communication and assumes that consumers, once protected against misleading or unfair practices, should be able to make informed choices themselves,” says Žymančius.
The broader regulatory question therefore remains open: should the law seek to influence behaviour by limiting what consumers see, or should it focus on ensuring transparent information and leave individuals to make their own decisions?
