Regulatory packages that combine front-of-pack nutrition labeling (FoPNL) with advertising restrictions are widely recommended to reduce population exposure to unhealthy foods and to support healthier dietary choices. Nutrient Profile Models (NPM) are used to standardize which products should be targeted by such measures. Brazil currently implements FoPNL via RDC No. 429/2020 and IN No. 75/2020 (hereafter RDC 429), but advertising restrictions and FoPNL are regulated separately. This study applied RDC 429 and the PAHO NPM to ultra-processed food advertising on Brazilian social media platforms commonly used by children and adolescents to identify foods that would be subject to advertising restrictions under each model.
Brand and product selection followed the WHO/Europe CLICK framework. Researchers screened a database of branded products from major São Paulo retailers for child-targeted marketing elements and retained products classified as ultra-processed per the NOVA system, producing a list of 724 products/brands. Official brand pages on Instagram, TikTok, and YouTube were identified; 604 had active accounts and, after exclusions, 33 unique brand pages remained.
From each brand page, 20 posts published in 2023 were randomly sampled in line with CLICK guidance. The final advertising sample included 994 posts: 623 Instagram, 257 TikTok, and 114 YouTube.
All industrialized foods shown in selected advertisements were identified and nutrition information was collected from labels, brand, or retailer websites between August and October 2024. Foods lacking nutrition data at collection were excluded (n = 56). When multiple foods appeared, items representative of the advertised brand were considered; when all foods represented the brand, all were included. The analytical dataset comprised 1,498 foods.
Foods were categorized per CLICK recommendations into groups such as candies and chewing gum, breads/cakes/cookies, snacks, dairy/chocolate beverages, sweets/chocolates, juices/soft drinks, breakfast cereals, ultra-processed cheeses, and ready-to-eat meals.
Two NPM were applied: the Brazilian FoPNL parameters consolidated in RDC 429 and the PAHO nutrient profile model. The PAHO model requires data on free sugars, but because Brazilian labeling reports added sugars rather than free sugars, the analysis applied PAHO using added sugars as the comparable parameter where necessary. Foods were classified as non-compliant if they exceeded at least one criterion in each model.
Absolute and relative frequencies described adequacy under both models. Classification occurred at the food-item level (each food) and at the advertisement level, where a post was considered non-compliant if it featured at least one food exceeding model thresholds. Brand-only advertisements with no foods were treated as permitted (n = 216). Analyses used 95% confidence intervals with significance inferred by non-overlapping intervals; Stata v14.0 was used.
Applying RDC 429, 61.28% of foods advertised exceeded at least one model parameter. Platform-specific food-level non-compliance under RDC 429 was highest on TikTok (72.63%), followed by Instagram (59.88%) and YouTube (49.06%). Under PAHO, 93.86% of foods exceeded at least one critical nutrient threshold, with TikTok at 100% and YouTube at 98.50%.
Across both models, added sugars were the nutrient with the highest prevalence of non-compliance. Under RDC 429, 45.99% of foods exceeded the added sugars cut-off (TikTok 56.01%, Instagram 44.64%, YouTube 35.58%). Under PAHO, 62.62% of foods exceeded the added-sugars threshold (Instagram 60.0%; TikTok 71.87%; YouTube 57.30%).
Under RDC 429, several categories showed particularly high non-compliance: ultra-processed cheeses reached 100%, breakfast cereals 90.32%, breads/cakes/cookies 88.29%, sweets/chocolates 77.27%, and candies/chewing gum 67.57%. Platform stratification showed similar patterns, with TikTok often exhibiting the highest proportions (several categories reaching 100% non-compliance on TikTok).
Under PAHO, non-compliance rates were higher across categories: most categories exceeded 85%, and several reached or approached 100%—for example, pre-prepared meals, ultra-processed cheeses, and dairy/chocolate beverages all reached 100% in the pooled analysis. On TikTok, all analyzed categories reached 100% non-compliance under PAHO.
At the advertisement level (a post considered restricted if it contained at least one non-compliant food), 49.53% of posts would be restricted under RDC 429, while 74.13% would be restricted under PAHO. By platform, YouTube showed the highest proportion of restricted advertisements under RDC 429 (62.16%) and nearly all YouTube ads were restricted under PAHO (99.10%).
The analysis demonstrates operational feasibility of applying both the national RDC 429 and the PAHO NPM to digital advertising content aimed at children and adolescents. The PAHO model identifies a substantially larger share of advertised foods as subject to restriction, offering a stricter basis for coordinated regulation. RDC 429, already implemented in Brazil for FoPNL, could function as a pragmatic starting point to align advertising restrictions with existing labeling rules, although its thresholds are less stringent and were not validated prior to implementation.
The results highlight elevated exposure to ultra-processed product advertising on social media platforms popular with youth, and the prominent role of added sugars in driving non-compliance. The findings underscore the potential for integrated policy packages—combining FoPNL and advertising restrictions using a common NPM—to strengthen Brazil’s regulatory response to unhealthy food marketing targeted at children and adolescents.
This study provides a descriptive assessment and does not evaluate the effectiveness of FoPNL or advertising restrictions. The PAHO application used added sugars as a proxy because free-sugar labeling was not available in Brazil. Data were restricted to institutional brand content publicly available during the sampling period. The authors conclude both NPM are feasible for regulating digital food advertising, with PAHO offering a more comprehensive standard and RDC 429 representing a strategic, currently implemented entry point for Brazil.