Norway’s ban on marketing unhealthy food to children

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Dario Dongo
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Food Times_Norway_junk food_marketing to kids ban

On 25 April 2025, Norway established itself as a global pioneer in public health policy by implementing a comprehensive regulation prohibiting the marketing of unhealthy food and beverages specifically targeted at children under 18 years of age.

This legislative initiative, formally known as ‘Forskrift om forbud mot markedsføring av visse næringsmidler særlig rettet mot barn‘ (Regulation on the prohibition of marketing certain food products particularly directed at children), represents a significant advancement in preventive health measures aimed at addressing diet-related health challenges in the Norwegian population.

The regulation, which comes with a six-month transitional period ending on 25 October 2025, marks Norway as potentially the first nation worldwide to introduce such extensive protective legislation for all children up to 18 years of age.

Background and context

Historical development

The journey toward this regulatory framework began years earlier when Norway established a self-regulatory scheme managed by the food industry called ‘Matbransjens Faglige Utvalg’ (MFU). However, evaluations revealed significant limitations in this self-regulatory approach, particularly regarding its scope (only protecting children up to 13 years) and lack of effective enforcement mechanisms.

In line with recommendations from the World Health Organization (WHO) and responding to concerning health data showing approximately 24% of boys and 22% of girls in primary school experiencing overweight or obesity, the Norwegian government determined more robust protective measures were necessary.

A pilot study conducted by Oslo Metropolitan University (OsloMet) provided compelling evidence that 8 out of 10 food and drink advertisements aimed at children in Norway violated WHO guidelines by promoting unhealthy nutrition.

Policy development process

The path to regulation included several key milestones:

  • in 2023, the Norwegian Directorate of Health developed a nutrient profile model for identifying foods subject to marketing restrictions;
  • in March 2024, this proposal was submitted to authorities; in August 2024, the government released a public consultation document proposing the marketing ban;
  • on 25 April 2025, the final regulation was enacted.

The regulation evolved through extensive stakeholder engagement, including consultation with the sports community and other interested parties, resulting in certain adjustments such as exemptions for trademark use in sponsorship contexts.

Key provisions of the regulation

Scope and applicability

The regulation applies to anyone who produces, processes and distributes, including sells or markets, food products. Importantly, this includes foreign entities marketing products in Norway, though certain information service providers, video-sharing platforms, and editorially controlled media are still exempted. The regulation’s territorial scope encompasses all of Norway, including Svalbard.

Definition of ‘children’ and ‘unhealthy foods’

A notable aspect of the regulation is its broad definition of ‘children‘ as individuals under 18 years of age, without differentiation between younger children and teenagers. This aligns with WHO recommendations but exceeds the previous self-regulatory framework that only protected children up to 13 years.

The regulation categorizes food products based on nutrient profiles, with specific products covered by the prohibition detailed in an appendix based on ‘healthiness‘, including factors such as:

  • sugar content (both natural and added sugars);
  • fat content;
  • salt levels;
  • use of sweeteners.

Typical unhealthy products such as candy, soft drinks, chocolate, snacks, ice cream, and cakes cannot be marketed to children. For other products like milk, cereals, yoghurt, and fast food, nutrient thresholds determine inclusion.

The Norwegian nutrient profiling model

Norway has adopted a distinctive approach to nutrient profiling that, while technically refined, diverges from the growing European consensus. Instead of aligning with Nutri-Score – a front-of-pack nutrition labelling scheme officially adopted by seven countries (France, Belgium, Germany, Spain, Luxembourg, the Netherlands, and Switzerland) and under consideration as the EU-wide standard – Norway has developed its own model for regulating food marketing (Øvrebø et al., 2023).

This national system uses a category-based methodology, dividing foods into ten groups, each with specific threshold values for limiting nutrients such as energy, saturated fat, total sugars, and sodium. In contrast, Nutri-Score employs a continuous scoring algorithm that weighs both negative nutrients and positive elements like protein, fibre, and fruit and vegetable content.

Despite this divergence, research by the Norwegian Institute of Public Health concluded that ‘the updated Nutri-Score could be a useful tool in guiding consumers towards healthier food choices in Norway’, even though it noted some minor inconsistencies with national dietary guidelines (Øvrebø et al., 2023).

From the author’s standpoint, Norway’s decision not to implement the scientifically validated Nutri-Score in favour of a separate model risks undermining efforts to establish a coherent, evidence-based labelling framework across Europe. Such fragmentation may ultimately weaken the effectiveness of public health strategies aimed at improving nutrition at the population level.

Prohibited marketing practices

The regulation prohibits the marketing of listed products that are particularly targeted at children. Under Section 4, a comprehensive case-by-case assessment is required to determine whether a given marketing strategy is considered ‘particularly aimed at children‘. Certain practices are automatically considered to target children, including:

  • competitions with an age limit under 18 years;
  • distribution of taste and product samples to persons under 18 years;
  • placement of products near toys or items particularly appealing to children;
  • promotional activities encouraging adults to purchase such products for children.

Exemptions and implementation timeline

The regulation includes certain exemptions to balance commercial interests with health objectives. Particularly notable is an exemption for the use of trademarks in connection with sponsorship, provided it is not a trademark for specific products covered by the product list.

Sponsorship of charitable purposes is permitted if the contribution does not consist of products in the restricted categories.

While the regulation entered into force on 25 April 2025, it includes a six-month transitional period until 25 October 2025, giving the industry adequate time to adapt to the new requirements.

Enforcement and compliance

The Norwegian Directorate of Health (Helsedirektoratet) has been designated as the supervisory authority responsible for monitoring compliance with the regulation. This marks a shift from the industry-led self-regulatory approach to a more robust government-controlled enforcement mechanism:

  • unlike the previous self-regulatory scheme, the new regulation introduces clear sanction mechanisms for non-compliance, with violations subject to infringement fees, though the specific penalty structure is not fully detailed in available information;
  • to facilitate implementation, the Directorate of Health has been commissioned to prepare comprehensive guidance to address potential ambiguities in interpretation and application, particularly given criticism that some aspects of the regulation may be difficult to understand.

Historical precedence: the UK model

Norway’s regulatory approach requires important contextual qualification, as the United Kingdom established significant precedents in restricting food marketing to children nearly two decades earlier:

  • in 2007, the UK’s Office of Communications (Ofcom) implemented comprehensive restrictions on television advertising of high fat, salt, and sugar (HFSS) products during children’s programming, using the Food Standards Agency’s nutrient profiling model to distinguish between healthier and less healthy foods eligible for advertising (Ofcom, 2008);
  • these regulations, introduced in three phases between April 2007 and January 2009, banned HFSS advertising during programmes specifically designed for children aged 4-15 and eventually prohibited all such advertising on dedicated children’s channels;
  • the effectiveness of these early restrictions proved mixed. Ofcom’s evaluation found that children’s exposure to HFSS advertising decreased by 37%, though independent assessments suggested that overall exposure remained largely unchanged due to increased advertising during family viewing times (Whalen et al., 2019). This experience highlighted the enforcement challenges inherent in regulating children’s media exposure in an evolving broadcasting landscape.

The UK has continued to evolve its regulatory framework, with new legislation effective October 2025 introducing a 9pm watershed for junk food advertising and comprehensive online advertising bans (UK Government, 2024). This progression demonstrates the ongoing refinement of policy approaches as governments grapple with changing media consumption patterns and the persistent challenge of childhood obesity.

Front-of-Pack Nutrition Labelling (FOPNL): the Nordic Keyhole system

The marketing restrictions introduced by Norway complement the Nordic Keyhole front-of-pack nutrition labelling (FOPNL) system that this country – along with Denmark, Iceland, Lithuania, and North Macedonia – has adopted to inform consumers. The Nordic Keyhole, developed by the Swedish Food Agency in 1989, functions as a positive endorsement label for healthier food options within 32 specific product categories, based on the Nordic Nutrition Recommendations (Helsenorge, 2025).

This voluntary labelling scheme requires that products so marked meet stringent criteria regarding fat content, saturated and trans fatty acids, sugar levels, salt content, and minimum fibre requirements. Certain product categories such as soft drinks, confectionery, chocolate, cakes, and biscuits are categorically excluded from its use. The Norwegian Directorate of Health and the Norwegian Food Safety Authority jointly oversee the implementation of this evidence-based system, which enjoys high consumer recognition with 97% awareness levels amongst Nordic populations and demonstrates high compatibility (81%) with the Nutri-Score system when applied to comparable food databases (Amberntsson et al., 2023).

This regional approach risks, however, creating market fragmentation, even whilst the European Commission continues – at least in theory – to pursue harmonised EU-wide front-of-pack nutrition labelling (FOPNL) under its Farm to Fork Strategy. The Nordic countries have collectively maintained that their established systems should inform any future harmonised European FOPNL, emphasising that successful labelling schemes must be government-led, scientifically grounded, and built upon demonstrated consumer trust rather than commercial interests (Nordic Council of Ministers, 2022).

The European Union’s regulatory gap: a call for comprehensive action

Norway’s approach highlights the significant regulatory gap at European Union level, where the Audiovisual Media Services Directive (AVMSD) has demonstrably failed to protect children from aggressive junk food marketing across Member States:

  • the European Commission’s own 2021 report acknowledged that the AVMSD’s implementation produced ‘unsatisfactory results‘, with at least half of member states failing to apply any meaningful co-regulation or self-regulation schemes for food marketing to children;
  • this regulatory vacuum has persisted despite mounting evidence from UNICEF and WHO Europe since 2020 identifying aggressive marketing of high fat, salt, and sugar (HFSS) foods as a primary driver of childhood obesity and diet-related non-communicable diseases across the European region;
  • the 2015-2018 revision of the AVMSD represented a ‘once in a decade opportunity‘ to establish comprehensive protections, yet the final directive relied predominantly on voluntary industry self-regulation rather than mandatory restrictions, effectively perpetuating the policy failure that continues to expose European children to predatory marketing practices;
  • the European Parliament’s recognition of this failure, demonstrated through parliamentary question E-001798/2022, has prompted calls for the European Commission to fulfil its commitments under the Farm to Fork Strategy and Europe’s Beating Cancer Plan.

However, the persistence of fragmented national approaches – exemplified by recent initiatives in the UK and Norway – underscores the urgent need for harmonised EU-wide legislation. The European Public Health Alliance, supported by over 20 NGOs and research institutions, has therefore called for a comprehensive directive establishing mandatory restrictions on junk food marketing to children across all audiovisual media, including video-sharing platforms and social media services, with uniform nutritional criteria and robust enforcement mechanisms to ensure genuine protection of children’s health throughout the European single market.

Expected outcomes and future Implications

The primary objective of this regulation is to promote population health by preventing diet-related diseases and protecting children from harmful marketing influences. Minister of Health and Care Services Jan Christian Vestre emphasized this goal, stating, ‘We are committed to ensure good health for children and youth and that it should be easy to make good choices in everyday life‘.

Specific anticipated benefits include decreased consumption of unhealthy food and beverages among children, reduction in childhood obesity rates, prevention of tooth erosion, caries, and other oral health issues, and long-term reduction in diet-related non-communicable diseases (NCDs). The regulation’s effectiveness will ultimately be measured by its impact on children’s dietary habits and health outcomes, providing valuable insights for other nations considering similar approaches to safeguarding children’s health in an increasingly marketing-saturated environment.

However, the Norwegian nutrient profiles system’s emphasis on absolute thresholds rather than relative scoring reflects a more regulatory-focused approach, designed specifically for enforcement purposes rather than consumer guidance, and it may ultimately contribute to market fragmentation and reduced consumer understanding compared to the internationally harmonised Nutri-Score model.

Conclusion

Norway’s regulation prohibiting the marketing of unhealthy food and beverages to children represents a significant advancement in preventive health policy and positions the country as a global leader in protecting children from potentially harmful marketing influences.

By moving from industry self-regulation to a comprehensive government-enforced framework, Norway has taken a decisive step toward addressing diet-related health challenges.

Whilst Norway’s initiative builds upon decades of international precedent rather than representing entirely novel policy territory, its comprehensive scope and rigorous enforcement mechanisms offer valuable lessons for other jurisdictions grappling with childhood obesity and diet-related health challenges.

Dario Dongo

References

Dario Dongo
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Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.

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