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HFSS, AI and the secret to Christmas advertising success

Smart brands will need to plan early for festive success amid changing regulations.

Jon Evans

Chief Customer Officer System1

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The upcoming HFSS legislation has sent ripples through the Christmas advertising landscape, with some brands, including Marks & Spencer, even questioning whether they can run festive ads at all. Supermarkets are known for showcasing indulgent spreads, from pigs in blankets to golden roasties. So how can brands navigate a table without food without losing their commercial impact?

The good news is that all is not lost. Brands like McDonald’s have gone food-free with great success. Its “Raise Your Arches” campaign and its 2024 Christmas ad both performed strongly, despite no Big Mac in sight. Cadbury is another standout. While it could rely on the emotional pull of unwrapping its iconic purple packaging, it often opts for story-first creative, rarely showing the product at all.

These campaigns did not just resonate emotionally. They scored high on both long-term brand potential (Star Rating) and short-term sales impact (Spike Rating). For brands navigating foodless festivities, the lesson is clear: brand early, stay top of mind and lean into emotional storytelling. When audiences know who you are and feel something in response, the product does not need to be the hero to drive action.

Patience and consistency pay off at Christmas

Last year marked the most consistent Christmas on record, with more brands than ever leaning into familiar themes, fluent characters and repeated creative platforms. Top performers like Coca-Cola, Cadbury, Aldi, Marks & Spencer and Very all embraced consistency and reaped the commercial rewards, leading the way on emotional resonance and strength of brand.

When audiences know who you are and feel something in response, the product does not need to be the hero to drive action.

Jon Evans, Chief Customer Officer, System1

Character-led storytelling was key. From Aldi’s Kevin the Carrot to M&S’s Fairy and the return of the iconic M&M’s across the pond, fluent devices drove strong emotional engagement. Kevin the Carrot, for example, scored 3 Stars in his debut and now ranks among the top year after year at 5 Stars. According to System1’s IPA-backed research The Magic of Compound Creativity, brand characters typically start delivering their strongest returns in year three, a valuable insight for brands planning 2025 campaigns.

Channel consistency was also crucial. Cadbury successfully extended its Secret Santa Postal Service across TV and outdoor, while Waitrose made a splash with a cross-platform puzzle-led campaign that encouraged audience participation. Brands that maintain creative consistency across multiple channels see double the brand recall of those that do not.

Re-airing previous Christmas ads is another winning tactic. Brands like TUI, TK Maxx and Hershey’s tapped into the power of familiarity, reinforcing brand connections through repeated exposure. The takeaway for brands looking to succeed at Christmas: be patient, be consistent and let your creativity compound. 

Is AI the key to unlocking Christmas advertising for smaller brands?

Coca-Cola’s recent AI-generated “Holidays Are Coming” ad sparked debate in the industry, with many questioning the shift from a 29-year-old campaign. Yet, despite the noise, the ad resonated with consumers, earning top scores on System1’s Test Your Ad platform in both the UK and US.

This suggests a growing opportunity for smaller brands. AI could help lower the barrier to entry for TV advertising during the crucial Christmas period.

But success with AI depends on familiarity. Coca-Cola’s ad worked because it retained core brand elements including the trucks, the music and the polar bears. It felt new but still recognisably Coca-Cola. System1’s founder John Kearon calls this the “80:20 rule.” The most successful new concepts blend 80 percent familiarity with 20 percent novelty. Ads that strike this balance are more likely to drive positive emotional response and long-term brand growth.

For brands experimenting with AI this Christmas, the advice is simple yet important. Innovate within the framework of your brand identity to make the unfamiliar feel familiar.

Christmas creativity delivers big but brands must think beyond December

Each year, brands in the UK and US bring out their most creative work at Christmas, with November consistently delivering the highest proportion of 5-Star ads. In both markets, festive campaigns account for nearly half of all top scoring creative across the entire year.

Yet despite their impact, Christmas ads are also the most short lived. On average, these campaigns air for just 2 months, making them the most fleeting of any seasonal advertising.

To truly maximise the value of their Christmas creativity, brands must find ways to extend that momentum throughout the year. In the UK, brands like Aldi, Amazon, Very.com, Moonpig, Argos and Cadbury are leading the way. These advertisers build strong links between their festive campaigns and their everyday brand communications. Cadbury, for instance, maintains a distinctive look, feel and tone of voice year round, while others use recurring characters or fluent devices to maintain consistency and build long term memory structures.

This approach is especially important during the festive season, which is the most competitive time of the year for advertisers. October and November see more ad activity than any other months, making brand distinction and memory recall critical to campaign success.

Guest Author

Jon Evans

Chief Customer Officer System1

About

Jon Evans is an experienced commercial leader with a track record of delivering substantial growth across a large number of brands. Currently working as CMO for System1 and host of Uncensored CMO podcast. Previous experience includes a short stint as CMO for Brewdog, Marketing Director at Suntory leading some of the UK's most iconic brands, on the Board of Purity Soft Drinks, a Private Equity backed Soft Drink business and working for Britvic Soft Drinks running a 'Seed Brand Unit' in conjunction with Pepsi.

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