Costcutter's Cadbury Easter page breached the new HFSS ad rules

For Easter, Costcutter ran a 'Spin to Win' promotion in partnership with Mondelez, owner of Cadbury. The campaign paired a paid Instagram ad inviting shoppers to 'Spin to Win Cadbury Treats' with a linked landing page hosted on Bestway Retail's website.

The campaign group Bite Back complained. The landing page prominently displayed pack shots of identifiable Cadbury Easter products classified as less healthy — including Creme Eggs, Mini Eggs and Biscoff Filled Eggs. The ASA found the page was part of a paid promotional package purchased by Mondelez, and that it constituted a paid online ad for identifiable high fat, salt and sugar (HFSS) products.

The watchdog upheld the complaint against the landing page, finding it breached CAP Code rule 15.19, the ban on paid online advertising for less healthy food and drink that took effect on 5 January 2026. Because the page advertised specific identifiable HFSS products rather than the brand, it was not eligible for the brand advertising exemption.

The ASA dismissed a separate complaint against the paid Instagram ad, concluding it promoted the Cadbury Easter range as a brand and therefore qualified for the brand advertising exemption. The landing page must not appear again in its complained-about form, and Costcutter and Mondelez were told to keep future paid online ads clear of identifiable less healthy products.

The ASA ruled the page was a paid ad for specific HFSS products, not exempt brand advertising, so it breached the January 2026 ban and must not appear again.

The new HFSS rule draws a line between brand advertising and product advertising: promote the range and you are exempt, name the packs and you are breaking the law

Payment decides the case: because Mondelez paid for the landing page as part of the promotional package, it was an ad, whatever the degree of control

A promotion that funnels shoppers toward identifiable less-healthy packs is exactly the paid placement the January 2026 ban was written to stop

Under the UK's January 2026 HFSS rules, a paid landing page selling specific less-healthy packs is advertising, not a promotion. Brand is exempt; bags of Creme Eggs get the page pulled.

The ASA upheld the complaint against the landing page on 5 August 2026 and ordered it not to appear again. The Instagram ad was cleared under the brand advertising exemption. The ruling was one of the first to test the new CAP 15.19 paid online HFSS rules.