ASA v S&E1 (Morley's Woking)
The adPaid Instagram combo-meal ad
OutcomeUpheld 8 Jul 2026, SME exemption did not apply (parent has >250 staff)
LessonCheck group headcount before relying on the SME exemption
FMCG food and drink ads are restricted on Meta and rules apply on Google. Health and Wellness (Advertising Standards): Dietary, health and weight-loss or weight-gain products must target 18+. General food, including protein products, is exempt from the age limit. Bans 'sensational language with exaggerated or extreme claims, or promises of specific outcomes within a set timeframe'. Bans cure claims for listed diseases (e.g. Diabetes, Cancer). (restricted). The phrases most likely to cause trouble include "paid online ad showing identifiable burger/fries/sweets (UK)", "licensed character", "boosts immunity".
Restricted
Sources: transparency.meta.com · facebook.com · about.fb.com · transparency.meta.com
Disapproval, warning 7 days before suspension
Sources: support.google.com · support.google.com
19 phrases that often lead to rejection, limited delivery or regulator action. High means the phrase or claim is named in a policy or ruling. Medium means it's our reading of a rule.
| Phrase | Why it's risky | Rule or source | Risk |
|---|---|---|---|
| paid online ad showing identifiable burger/fries/sweets (UK) | Paid online LHF ads banned since 5 Jan 2026 | asa.org.uk | High |
| licensed character / celebrity on HFSS ad in kids' media | Banned in UK non-broadcast children's media since 1 Jul 2017 | asa.org.uk | High |
| boosts immunity | Wording of an unauthorised health claim | asa.org.uk | High |
| secret to better digestion | Health claim that does not match authorised register wording | asa.org.uk | High |
| easier to digest (formula) | Unauthorised claim, no approved A2 claim exists | asa.org.uk | High |
| infant formula / baby formula (in ads) | Infant formula advertising is largely banned in the UK (CAP 15.10) | asa.org.uk | High |
| as good as breast milk / better than breastfeeding | Must not present formula as equivalent or superior to breastfeeding | asa.org.uk | High |
| good for the planet | Unqualified absolute green claim | asa.org.uk | High |
| healthier planet | Implied net environmental benefit not substantiated | asa.org.uk | High |
| 73% less CO2e | Comparison basis unclear (one product vs a whole category) | beveragedaily.com | High |
| cure / cures + disease | Prohibited cure claims | transparency.meta.com | High |
| miracle | Named example of an unreliable claim | support.google.com | High |
| lose X kg in Y days | Promise of an outcome within a timeframe | support.google.com | High |
| eco-friendly / green / environmentally friendly | Generic environmental claims banned in the EU from 27 Sep 2026 unless backed by recognised excellent environmental performance | coslaw.eu | High |
| carbon neutral / climate neutral (via offsets) | Offset-based product neutrality claims banned in the EU | climatepartner.com | High |
| natural / fresh / pure / original / traditional / authentic / genuine / real (India) | Restricted terms under FSSAI 2018 regulations, use in a brand name needs a disclaimer | fssai.gov.in | High |
| sustainable (absolute) | Absolute claim read as covering the full life cycle | asa.org.uk | High |
| energy drink + under-16 imagery/targeting (England) | Sale to under-16s banned from Apr 2027 (>150mg/l caffeine) | gov.uk | Medium |
| superfood | Likely read as a general health benefit that needs an authorised claim | asa.org.uk | Medium |
Before and after examples. Swap the bracketed parts for your real details.
Naturally boosts your immunity
Contains vitamin C, which contributes to the normal function of the immune system (use the exact authorised wording)
Good for the planet
Produces [X]% lower CO2e than [named comparator], per [LCA source, year]
Our formula is as gentle as breast milk
Follow-on formula for babies from 6 months. Breastfeeding is best for babies.
Lose 5kg in 2 weeks with our shake
Part of a calorie-controlled diet. Results vary.
Burger + fries meal deal £12 (UK paid social)
Brand-led creative with no identifiable less-healthy product, or feature a non-LHF item
Ofcom phase 1: HFSS ads banned around programmes for 4-9s
Ofcom phase 2: extended to programmes for 9-15s
Ofcom phase 3: all HFSS ads removed from children's channels
CAP announces a non-broadcast HFSS ban in children's media
CAP HFSS ban takes effect in under-16 media and media with >25% child audience
India FSSAI Advertising & Claims Regulations: full compliance date
England LHF location-promotion restrictions in force
UK LHF ad regulations laid, the planned Oct 2025 start was postponed
UK LHF TV ban (5:30am-9pm) and paid-online ban in force
ASA publishes its first 4 LHF rulings (Iceland and Lidl NI upheld)
England confirms under-16 energy drink sale ban from Apr 2027
EU EmpCo generic green-claim ban applies
The adPaid Instagram combo-meal ad
OutcomeUpheld 8 Jul 2026, SME exemption did not apply (parent has >250 staff)
LessonCheck group headcount before relying on the SME exemption
The ad'73% less CO2e vs. milk' and dairy/meat emissions claims
Outcome4 of 5 claims misleading (27 Jan 2022)
LessonState the comparator and the LCA basis, do not edit expert quotes
The ad'Little drinks with big dreams for a healthier planet'
OutcomeUpheld 23 Feb 2022
LessonProducts sold in plastic bottles cannot imply a net benefit to the planet
The adBaby-club podcast, A2 milk 'may be easier to digest'
OutcomeUpheld 23 Feb 2022
LessonIndirect infant formula ads and unauthorised claims are both breaches
The ad'GOOD FOR THE PLANET'
OutcomeUpheld 20 Oct 2021
LessonMake the basis of comparison clear (vs dairy, not absolute)
The ad'Naturally boosted digestion and immunity'
OutcomeUpheld 16 Aug 2017
LessonHealth claims must match authorised wording
No federal HFSS ad ban found, health and weight claims are policed through the platform policies above.
LHF paid-online and pre-9pm TV ban from 5 Jan 2026, SMEs with <250 staff exempt, infant formula ads largely banned.
FSSAI restricts 'natural', 'fresh', 'pure' and similar terms, CCPA greenwashing guidelines since 15 Oct 2024.
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This tool is a pre-launch screen, not legal advice. Meta and Google do not publish banned-word lists, so each flag is a risk signal tied to a published rule, regulator ruling or court case. Policies change often. Data last checked 5 October 2026.