The CAP Code requires that ads for foods high in fat, sugar or salt must not be directed at people under 16 years of age through the selection of media or the context in which they appear.

The UK's Advertising Standards Authority (ASA) regularly considers complaints about ads for food products that are High in Fat, Sugar or Salt (HFSS), which highlights the importance of targeting ads for age-restricted products appropriately.   It recently ruled that a complaint about a JustEat ad for HFSS foods broke the rules.

In 2022, CAP issued guidance about age-restricted ads online.  It states that marketers should be able to demonstrate that they have taken all reasonable steps, including using all additional targeting tools available to them, to ensure that HFSS product ads are directed at an audience aged 16 and over to minimise children’s exposure to them. In addition, it says that targeting solely on the basis of age data is unlikely to satisfy the requirements of CAP’s media placement restrictions for age-restricted ads online because younger users misreport their age and because different people may use the same device.

Age-based targeting may be applied to the ad to exclude those who were registered as under-18 on Facebook from seeing the ad. But interest-based targeting factors are a crucial extra step which may help to exclude groups of people more likely to be under 16 from the target audience of the ad.  If you take the example from the JustEat ruling of a paid-for ad on Facebook with interest-based targeting measures being available for such ads, the ASA considers that those measures should be used to minimise the chances of under 16s seeing the ad.

If you advertise age-restricted products, make sure that you target the ads carefully and ensure that you have used both age- and interest-based factors, as well as any other techniques which will help divert the ad away from children.