Background
On 5 January 2026, new rules in the CAP and BCAP Codes on the advertising of “less healthy” food and drink products came into force.
The rules were supported by additional guidance, “Advertising of less healthy food and drink products”, which set out various tests and exemptions relevant to the ASA’s approach to assessing individual ads under the relevant Code rules.
The rules and guidance reflected the requirements of the Communications Act 2003, The Advertising (Less Healthy Food Definitions and Exemptions) Regulations 2024, and The Advertising (Less Healthy Food and Drink) (Brand Advertising Exemption) Regulations 2025.
Ad description
Two paid-for social media ads for Domino’s pizza:
a. A paid-for ad, seen on YouTube on 7 January 2026, showed three pizzas sliced into portions with large text that stated “PIZZA FROM £10”, small text that stated “Visit advertiser”, and the Domino’s logo. Underneath the image, text stated “Price Slice on all pizza from just £10”.
b. A paid-for ad, seen on Facebook on 12 January 2026, showed a pizza in a box, with one slice missing and the text “Domino’s” across the image. Next to the image, text stated “Price Slice is a bargain whichever way you slice it”.
Issue
Two complainants challenged whether ads (a) and (b) were paid ads for an identifiable less healthy food product placed on the internet.
Response
Domino’s Pizza UK & Ireland Ltd t/a Domino’s said that the pizza featured in ad (a) was the “Vegi Supreme” pizza with a classic crust, shown as a small, medium and large pizza. The pizza depicted in ad (b) was also the Vegi Supreme classic crust pizza in a medium size.
They said that the Vegi Supreme pizza was distinctive from all other flavour variants of pizza sold, in that it had tomatoes, green and red peppers, mushrooms, red onions and sweetcorn as toppings and that all sizes of the Vegi Supreme classic crust pizza were not high in fat, salt or sugar (HFSS).
Domino’s said that the Vegi Supreme was also available with other crusts; namely, the stuffed crust, Italian style crust and the thin & crispy crust and that those crusts were available in most sizes of pizza. They said that the variations of crust bases were visually different to the classic crust, which was moderately thick with a raised edge and a thickness to the base. The stuffed crust had a wider and thicker outer crust with a cheese filling that made it appear rounded. The Italian style crust was thinner than a classic crust with a flat appearance and a crispier edge. The thin & crispy crust was thinner and flatter than the classic crust, with the toppings spread closer to the pizza edge. Domino’s said that the medium stuffed crust Vegi Supreme and the medium thin & crispy Vegi Supreme were HFSS products.
They said that all Domino’s brand advertising featured pizzas with the classic crust, which was the most popular crust chosen by customers. They explained that if any other crust were featured then it would be highlighted in an ad.
They also confirmed that the Vegi Supreme could be bought as a plant-based variant, in a medium and large size, and additionally as a gluten-free variant, in a small size only. The plant-based variants were only available with a thin & crispy crust. Domino’s provided information to confirm that both the medium and large size of that pizza were HFSS. The gluten-free Vegi Supreme was non-HFSS. They stated that if the plant-based Vegi Supreme was advertised, it would be clearly labelled as plant-based. They said that the gluten-free and plant-based variants of their pizzas were specialist products which a consumer would expect to be labelled as such in advertising.
Assessment
Not upheld
The CAP Code required that persons must not pay for ads for an identifiable less healthy food or drink product to be placed on the internet.
The ASA firstly noted that Domino’s had paid for the ads to be placed on the internet.
The test determining whether an ad was covered by the restrictions was set out in law, as reflected in Code rule 15.19. A less healthy product was “identifiable”, in relation to ads, if persons in the UK could reasonably be expected to be able to identify the ad as being for that product.
Ad (a) featured photographic imagery of three of the same sliced pizza, and ad (b) showed a photographic image of a sliced pizza in an open box. Both ads included the Domino’s logo and name. Ad (a) referenced “PIZZA FROM £10” and “Price Slice on all pizza from just £10”. Ad (b) included the wording “Price Slice is a bargain whichever way you slice it”. In those contexts, we considered consumers could reasonably be expected to identify that both ads were for a promotion across the range of Domino’s pizzas in all sizes and flavours, including the specific pizzas depicted in the ad and including pizzas in the range that were less healthy foods.
We noted that brand advertisements (those that promoted a brand, including the brand of a range of products), were exempt from the restrictions in rule 15.19, subject to certain provisions. For example, an ad that depicted a specific less healthy product was not a brand advertisement. An ad that included a realistic image of a food or drink itself, out of packaging, where that food or drink was visually indistinguishable from a specific less healthy food or drink product, was also not a brand advertisement. A “specific” product was a product that was differentiated from other products, unless it was only differentiated by pack size or packaging format.
The ASA must therefore consider which of the following scenarios applied to ads (a) and (b):
1. An ad which depicted a specific “less healthy” pizza from the Domino’s range would be in breach of the “less healthy” food rule.
2. An ad which depicted a specific non “less healthy” pizza from the Domino’s range, by clearly identifying it as that specific non “less healthy” pizza (for example, by stating its name), would not be in breach of the “less healthy” food rule.
3. If an ad featured a realistic image of a Domino’s pizza, but did not identify which specific pizza it was, we must assess whether the pizza shown in the ad was visually indistinguishable from any specific “less healthy” pizza in the Domino’s range. That was the case whether the realistic image in the ad was of a “less healthy” pizza, or a non “less healthy” pizza. If it was visually indistinguishable from a “less healthy” pizza, the ad would be in breach of the “less healthy” food rule.
A food or drink was “less healthy” if it met two tests, set out in the rule. Firstly, it must be classified as HFSS according to the Department of Health and Social Care’s Nutrient Profiling Technical Guidance. Secondly, it must also fall within a food or drink category set out in law.
Pizzas fell within the “less healthy” food Category 11, described in law as “Pizza (except plain bases)”. While the ads did not state which flavour variant was shown in the ads, we understood it was the classic crust Vegi Supreme pizza. We understood that all sizes of Vegi Supreme with the classic crust were non-HFSS. The images in the ads were therefore of a pizza that was not classified as “less healthy”; the ads did not depict a specific less healthy product. Scenario 1, as referenced above, therefore did not apply. Additionally, the ads did not identify the pizzas shown, so scenario 2 also did not apply.
We must therefore assess whether the pizza shown in the ads was visually indistinguishable from any specific less healthy pizza sold by Domino’s, as referenced at scenario 3.
The pizza shown in ads (a) and (b) consisted of tomatoes, onions, sweetcorn, mushrooms and green and red peppers on top of cheese and a base of tomato sauce. The vegetables were visible in the ads’ imagery, as was melted cheese and an outline of tomato sauce at the edge of the pizzas. The pizza crusts in both ads were shown sliced, and in ad (a) they were evenly brown in colour with an edge that appeared to be thick and rounded. The pizza crust in ad (b) appeared slightly paler and thicker than those in ad (a). We noted there would be some natural variation between individual pizzas of the same type, which was illustrated by the slight variation in the crusts, and the placement of the toppings, on the pizzas in ad (a) compared to ad (b). We considered it was reasonable for us to take those natural variations into account when assessing whether the pizza shown in the ads was visually indistinguishable from pizzas sold by Domino’s.
We compared the images of the pizzas shown in the ads with images of the range of Domino’s pizzas shown on Domino’s website. We considered the pizzas as shown in the ads were visually indistinguishable from an image of the classic crust Vegi Supreme pizza on Domino’s website.
The majority of the pizzas included meat toppings, such as pepperoni, bacon, chicken, sausage, ham, ground beef or meatballs. Those meat elements meant the pizzas were distinguishable from the pizzas in the ads, even where the meat was placed in combination with some of the same toppings that were on the pizzas in the ads. Some pizzas were shown with a sauce drizzled over the toppings. Because meat toppings or a sauce were visible on those pizzas and were not present on the pizzas in the ad, we concluded that those pizzas were visually distinguishable from the pizzas in the ads.
We then compared the images in the ads with images of the Tuna Supreme pizza and two vegetarian pizzas – the Vegi Volcano and the Cheese & Tomato. We considered the Tuna Supreme was visually distinguishable, because while the website image showed sweetcorn and onion, no tomatoes, peppers or mushrooms were shown as toppings. We noted that the Vegi Volcano images showed green jalapeno peppers as a topping, and the Cheese & Tomato pizzas shown on the website showed melted cheese on top of a tomato sauce, but no vegetable or tomato pieces on top of the pizza. We therefore concluded that those pizzas were visually distinguishable from the pizzas in the ads.
We then considered the crust variations available for the Vegi Supreme. We understood that the crusts depicted in both ads were the classic crusts, but that the Vegi Supreme could alternatively be ordered with an Italian style, thin & crispy or stuffed crust. We compared the website images of the crusts on the Vegi Supreme with the crusts shown in both ads. Both the Italian style and thin & crispy crust showed a thinner, flatter base, with no rounding. We considered the Vegi Supreme with those crust variants was visually distinguishable from the pizzas shown in the ads. While the website image showed that the stuffed crust was thick and rounded, similar to the classic crust, the stuffed crust contained a cheese filling that was visible when the pizza was sliced. Both ads pictured sliced pizzas, with gaps showing between each slice and with no cheese or other filling visible. We considered that the pizzas in the ads’ imagery were therefore visually distinguishable from the stuffed crust variant of a Vegi Supreme.
We finally considered the gluten-free and plant-based variants of the Vegi Supreme.
The website image of the gluten-free Vegi Supreme, which had only one crust type, showed slices of red onions, mushrooms, red and green peppers, as well as pieces of sweetcorn and tomato, along with melted cheese and an indication of a tomato sauce base. Taking natural variations in placement into account, we considered the toppings were visually indistinguishable when compared to the toppings on the pizzas shown in both ads. However, we considered that the crust of the gluten-free variant appeared both less risen and less rounded, and therefore flatter than the crusts shown in the ads. We therefore concluded that, overall, the gluten-free variant was visually distinguishable from the pizzas in the ads.
The plant-based Vegi Supreme was available in medium and large sizes and was only available with the thin & crispy crust. The website image of that pizza showed visible slices of onions, peppers and mushrooms along with sweetcorn and tomato pieces, a melted cheese topping and tomato sauce visible along the edge. Taking natural variations in placement into account, we considered the toppings were visually indistinguishable when comparing the website image with the images of the pizzas in the ads. However, as with the gluten-free variant, when comparing the crust on the plant-based variant with the crusts on the pizzas in both ads, we considered that the plant-based crust was thinner and less rounded. We therefore considered the plant-based variant was also visually distinguishable from the images of the pizzas in both ads (a) and (b).
Because the realistic images of the pizzas in ads (a) and (b) were not visually indistinguishable from any specific less healthy food, we concluded the ads were brand advertisements. We concluded the ads were therefore out of scope of the rule and did not breach the Code.
We investigated ads (a) and (b) under CAP Code (Edition 12) rule 15.19 (Place of less healthy food and drink product advertisements online), but did not find them in breach.
Action
No further action necessary.
