Pursuant to the Food Act of 2004, the government has adopted a regulation that prohibits the marketing of certain types of food and drink aimed at children and young people. The aim is to prevent diet-related health problems by protecting children from the marketing of unhealthy food.

The Norwegian Food Industry's Professional Committee (MFU) already has established guidelines for the marketing of certain types of food aimed at children and young people. In this connection, the MFU has for several years had a product list that indicates which foods are covered by the scope of the guidelines. The new regulation strengthens the rules by introducing prohibition provisions that are enforced by the Directorate of Health, in addition to expanding the scope of the regulations compared to the MFU's guidelines.

The regulations raise several questions about the scope and scope of the restrictions on access to marketing. We review the main lines of the new regulation.

Which products are covered?

The product categories covered by the new regulations have been expanded and clarified compared to the MFU's product list. The regulation's product list, which is included as a separate appendix to the regulation, is based on the MFU's list, but is expanded and more detailed.

The new regulation includes chocolate and sugar confectionery, cakes, biscuits, snacks, ice cream, soft drinks and juices. A list of ten categories is included as an appendix to the regulation. For some categories, specific limits apply to the content of sweeteners, sugars and fats, which determine whether the product is covered.

Manufacturers and distributors who market food products must carefully consider which products are covered by the list and be aware of the differences from the MFU's previous guidelines.

What does it mean that marketing is specifically aimed at children?

The regulation applies to marketing "specifically aimed at" persons under the age of 18 and, as described in the purpose, is only intended to protect children. This means that general marketing of unhealthy food is still permitted, even in cases where children are part of the customer group.

Not only marketing that directly appeals to children is prohibited. The rules also prohibit marketing that occurs in such a way that adults are encouraged to buy the product for children.

The regulation provides an indication of what is meant by marketing that is particularly aimed at children. The starting point coincides with the MFU's guidelines. The following marketing is always considered to be covered by the ban:

advertising in cinemas in connection with films that are specifically aimed at children under the age of 13 and that start before 18.30
competitions with an age limit lower than 18 years
distribution of tastings and product samples to children

In other cases, the regulation provides for an overall assessment, where important criteria are whether the products in question are primarily consumed by children, and whether the way in which the marketing is presented particularly appeals to children. In this context, the time and place of the marketing will be of importance. Marketing of ice cream in connection with the recording of a TV program that is popular among the younger population will be at greater risk of being covered by the ban compared to marketing of the same product in connection with a political event.

For the overall assessment, the Ministry has assumed that it is particularly important to consider, among other things, the use of characters, games and celebrities that appeal to children. The form of presentation of the marketing in itself is not decisive, but language, colors and effects that children are attracted to will be part of the assessment. The same applies to the use of gifts, toys, coupons or similar.

Sponsorship with trademarks still allowed - several exceptions

Not all marketing of unhealthy food aimed at children will be banned. Section 6 of the new regulations includes several important practical exceptions. Packaging and wrapping can still have a design that appeals to children. The same applies to the design of the products themselves.

Another important exception concerns sponsorship and sponsors' use of names and trademarks. A sponsor can still market its brand at events aimed at children, even when the sponsor's products appeal to children. The limitation is that specific products cannot be included in the marketing.

Entry into force and transition period

The regulation entered into force on April 25, 2025, but a transition period has been introduced until October 25, 2025, which means that market participants have a few months to adapt to the regulations.

The new regulations may have significant consequences for companies that market food products aimed at children and young people. Companies should therefore review their marketing strategies, advertising campaigns and product adaptations to ensure compliance with the new rules.

As of October 25, the Norwegian Directorate of Health will carry out supervision and make decisions on rectification within a specified deadline if violations of the regulations are found. In this context, the Directorate will also have the opportunity to impose a coercive fine for violations of the rules.

Please contact us if you would like a review or advice on how your business can comply with the new regulations.

Regulations against the marketing of certain food especially aimed at children

Which products are covered?

What does it mean that marketing is specifically aimed at children?

Sponsorship with trademarks still allowed - several exceptions

Entry into force and transition period