Background
Summary of Council decision:
Two issues were investigated, both of which were Upheld.
Ad description
An Instagram video and pre-roll ad on YouTube for Huel, seen in April and May 2026:
a. The Instagram video included the caption “Here’s how our founder uses Huel. Spoiler alert it’s not for every meal”. The post included a video of the founder of Huel, Julian Hearn, and Spencer Matthews talking into microphones in the style of a podcast.
Mr Matthew’s said, “He doesn’t eat any solid meals ever. He eats Huel and only Huel everyday.” Mr Hearn said, “I’ve met quite a few people like that. They’re just 100%. What I do is I have Huel for breakfast and lunch during the working week, go home and have a traditional meal. Weekends as well. But during the working week Huel saves time, effort and gives you everything that you do need in the most convenient format possible.” Mr Matthews said, “When I was doing the Amazon Ultra, there was a guy there called James and he only eats Huel. Literally, when he told me that I was like, he’s not going to manage the race it’s a 260 km race through the Amazon rainforest. You know it’s quite full on. He won it by miles, like literally just left us all in the dirt.” Mr Hearn said, “In an ideal world, you should have nutritionally complete whole food. If you could do that for every meal that would be the best solution for life. Most people either don’t do that or can’t have the time to do that, and therefore that’s where Huel fits in the gap.”
b. The pre-roll ad on YouTube included the same video as ad (a).
Issue
The ASA received four complaints.
- The complainants, who believed the ad implied that Huel products could be a complete replacement for all conventional food, challenged whether the ads were irresponsible.
- Two complainants challenged whether the health claims complied with the Code.
Response
1. Huel Ltd said the ads were specifically designed to address that some consumers used Huel as 100% of their diet, and to correct any misconception that was its intended use. Within the ad, Mr Hearn, Huel’s founder, unambiguously positioned Huel as part of a balanced diet for occasions when preparing whole food was not practicable. Mr Hearn was against the idea that Huel should be used as a complete replacement for conventional food. Mr Matthews referenced a competitor in the Amazon Ultra race as an anecdote of a one-off incident that was surprising and unusual. Mr Matthews’ own reaction upon learning that the competitor had consumed only Huel was of extreme scepticism and disbelief. The anecdote was recounted as a remarkable and unexpected occurrence, not as a representative outcome or a recommendation or instruction to consumers to replicate. At no point in the ads did either speaker suggest that consumers should adopt a 100% Huel diet. Mr Hearn’s immediate response to the anecdote was to advocate for nutritionally complete whole food as the ideal, with Huel filling a gap where that was not practicable.
The topic of 100% Huel usage was raised in the ads deliberately and responsibly. They believe it would have been less responsible to disregard the existence of 100% usage than to confront it openly and provide clear guidance, as the ads did.
They did not believe the ads would be damaging to younger or vulnerable audiences, rather they would be beneficial to them because they made clear, and repeated messages, that a 100% Huel diet was not the intended or recommended use of the product. If, nevertheless, a vulnerable person was to adopt a 100% Huel diet, that would not be damaging to them. Provided they consumed an appropriate amount, in line with UK and European government recommended intake guidelines, it would result in them having a nutritionally balanced diet, regardless of the fact that was not how Huel advocated its use.
Additionally, the caption on the Instagram post reinforced that Huel was not advocating a 100% Huel diet.
Google UK Ltd said Google Ireland confirmed the ad was served through Google Ads, a self-administered system. Under the terms agreed to by advertisers, it was the advertiser’s responsibility to abide by applicable law and regulations, including the CAP Code.
Meta confirmed the ad ran but they had no further comments on the case.
2. Huel did not believe the ads made a health claim that Huel products improved athletic endurance or performance. The reference to the competitor winning the Amazon Ultra race did not contain any causal language connecting Huel to their performance. Mr Matthew’s did not state or imply that the competitor won because of Huel. At most, the anecdote demonstrated that the competitor was not held back by consuming Huel. The narrative was one of surprise and scepticism. Mr Matthews expected the competitor to fail completely and recounted the outcome as remarkable, isolated and an unexpected result, not as evidence of any performance-enhancing quality of the product. The interpretation was reinforced by Mr Hearn’s reaction to the anecdote; rather than endorsing a 100% Huel diet or claiming any performance benefit, he responded by advocating nutritionally complete whole food as the ideal, with Huel filling a gap where that was not possible.
The claim “gives you everything that you do need” was not a general health claim; it did not make any claim about health or well-being. Rather it was a statement about the composition and formulation of the product, namely that Huel had been designed to contain the full range of nutrients that a person required. It was, in substance, a product composition claim.
They believed they could use language such as “nutritionally complete”, provided it was accompanied by language explaining that this referred to dietary elements such as protein, essential fats, carbohydrates, vitamins and minerals. Due to an oversight, that wording was not included in either of the ads. They said they were arranging mandatory compliance training for all members of its marketing team to ensure that the accompanying disclaimer was included consistently across all placements of ads. They were also reviewing and strengthening their internal marketing material approval process.
Assessment
1. Upheld
The CAP Code stated that marketing communications must be prepared with a sense of responsibility to consumers.
The ASA acknowledged that the caption accompanying ad (a) stated “Spoiler alert it’s not for every meal”, and that the video in both ads showed the founder of Huel (Mr Hearn) describing his own consumption of Huel as being limited to breakfast and lunch during the working week. We also acknowledged his statement that, ideally, consumers should have “nutritionally complete whole food” for every meal. We considered those elements indicated that the ads did not explicitly recommend that consumers replace all conventional food with Huel.
However, the ads also prominently discussed an individual who had only eaten Huel and had won an ultramarathon race through the Amazon rainforest by a significant lead. We considered that anecdote presented the individual's exclusive consumption of Huel in a particularly positive context. While Mr Matthews' initial reaction conveyed surprise and scepticism about the diet, the conclusion of the story directly contradicted those concerns by attributing exceptional sporting performance to an individual who was said to consume no conventional food. We considered the overall effect of the anecdote was therefore not cautionary. Rather, it presented an exclusively Huel-based diet as compatible with completing, and significantly outperforming other competitors, in an exceptionally demanding endurance event.
We further considered that the qualifications elsewhere in the ads about Mr Hearn's own use of Huel did not sufficiently counteract that impression. In particular, following the anecdote, he did not challenge the suggestion that consuming Huel exclusively was inappropriate. Instead, the discussion moved to the nutritional completeness and convenience of Huel.
We considered that consumers would therefore understand from the ads that, while consuming Huel for every meal might be unusual and was not Mr Hearn's own approach, exclusively consuming Huel in place of conventional food was nevertheless an acceptable dietary practice and one that was compatible with particularly demanding levels of physical activity and exceptional sporting performance. We considered that a diet consisting only of Huel would not provide the same variety in nutrients and other benefits associated with eating a varied diet based on whole foods. We also understood that Huel’s products provided up to 400 calories per serving. On that basis, an individual relying exclusively on Huel would need to consume multiple servings throughout the day in order to meet average daily energy requirements, rather than simply substituting one serving for each conventional meal. We considered the ads did not make that clear. Instead, by presenting exclusive consumption of Huel in that context, the ads suggested that the complete replacement of conventional food with Huel was nutritionally appropriate and presented no barrier to achieving a high level of physical performance. We considered that message encouraged or condoned irresponsible dietary habits.
Therefore, because the ads encouraged or condoned the complete replacement of conventional food with Huel, an irresponsible dietary practice, we concluded they had not been prepared with a sense of responsibility to consumers.
On that point, the ads breached CAP Code (Edition 12) rule 1.3 (Social responsibility).
2. Upheld
The CAP Code defined health claims as those that stated, suggested or implied a relationship between a food or ingredient, and health. Only specific health claims authorised on the Great Britain nutrition and health claim register (GB NHC Register) could be made in ads promoting food or drink products.
As referenced at point 1, the ads included an account of an individual who had consumed only Huel and had won an ultramarathon race through the Amazon rainforest by a significant lead.
We considered that claims relating to endurance and athletic performance were health claims for the purposes of the Code. We acknowledged that the ads did not expressly state that consuming Huel had caused the individual to win the race. However, the anecdote specifically contrasted Mr Matthews' expectation that an individual consuming only Huel would be unable to complete an exceptionally demanding endurance event with the individual's subsequent significant victory.
In that context, we considered the anecdote implied a beneficial relationship between consuming Huel and the ability to sustain exceptionally high levels of physical and endurance performance. We therefore considered that the ads made a specific health claim relating to athletic performance.
However, we had not seen any evidence which demonstrated that the claim was authorised on the GB NHC Register.
The CAP Code also stated that general health claims could be made in relation to foods only if they were accompanied by a relevant specific authorised health claim. General health claims were defined as those referring to a general benefit of a nutrient or food for overall good health or health related well-being.
The ads stated that Huel “gives you everything that you do need”. We noted that statement was made in the context of a discussion about how consumers should eat “nutritionally complete whole food” for every meal, and in which Huel was presented as an alternative to such food. In that context, we considered consumers would understand the claim to mean that Huel provided the nutritional requirements necessary for the body's general health and functioning. We therefore considered it was a general health claim because it referred to the general beneficial effect of the food supplement on health. However, it was not accompanied by a relevant specific authorised health claim.
Because the ads included a specific health claim that was not authorised on the GB NHC Register, and a general health claim that was not accompanied by a specific authorised health claim, we concluded they had breached the Code.
On that point, the ads breached CAP Code (Edition 12) rules 15.1, 15.1.1 and 15.2 (Food, food supplements and associated health or nutrition claims).
Action
The ads must not appear again in the form complained of. We told Huel Ltd to ensure that future marketing communications did not encourage or condone the exclusive consumption of Huel in place of conventional food. We also told them not to make specific health claims unless they were authorised on the GB NHC Register, and not to make general health claims unless they were accompanied by a relevant specific authorised health claim.
