One black octagon on the front of the pack is enough. You do not need three, the product does not have to be ultra processed, and nobody has to consider it unhealthy: with at least one (1) warning seal, article 10 of Law 27.642 already changes what that video is allowed to do.
It is worth saying up front what the law does not do, because it is the most expensive misunderstanding in the trade: it does not regulate food advertising in general. It regulates advertising of packaged foods and non alcoholic drinks that carry at least one seal. A product without seals falls outside this article, and a food brand can have both kinds in the same catalogue.
The question that settles everything: does this product carry a seal?
The Warning System is black octagons with a white border and white capital letters, and article 5 sets that each seal may not occupy less than five per cent of the main face of the pack. They are visible at a glance, and that is the good news: nothing has to be interpreted, you look at the front of the package.
What you look at is the exact product to be filmed, not the brand. The same company can have one line with seals and another without, and the sugar free version of a product may not carry the same ones as the original.
If it carries at least one, two layers of rules come in at once: a total prohibition when the piece is specially directed at children, and a list of restrictions for all other advertising.
The prohibition that admits no nuance
Article 10 prohibits every form of advertising, promotion and sponsorship of those products that is specially directed at children and adolescents.
It is not a recommendation or a best practice: it is a prohibition, and it is not solved by a note in the description or by an age restriction on the platform.
The hard part is deciding when a piece is specially directed at children, because it almost never says so. You read it as a whole: who appears, what language it uses, what music, what format, where it is published and who it will be shown to with paid media.
Who appears, and how they speak
A child on screen is the most obvious signal, but not the only one and not the most frequent. Language, tone, editing rhythm and the visual codes of a platform can direct a piece at adolescents without a single minor appearing.
The test that works is uncomfortable and fast: show the video to somebody who does not know the brand and ask who it seems made for. If the answer is "for kids", it does not matter what the brief says.
Where it is published, and who it is shown to
The same piece changes nature depending on where it lives. Published on an adult account it is one thing; bought with targeting towards the youngest brackets, or placed in a format whose real audience is teenagers, it is another.
That decision is almost never the creator's, which is why it has to be asked before filming rather than read afterwards in a campaign report.
School settings, which are a separate rule
Article 12 goes further than advertising: products carrying at least one seal may not be offered, sold, advertised, promoted or sponsored in educational establishments.
For a shoot that translates into something very concrete: a school is not an available location for this kind of product, not even as a background, not even if the video addresses parents. The same goes for an event taking place inside an educational establishment.
What a video cannot do when there is a seal
For all other advertising, the law lists concrete restrictions. Translated into what actually happens on a shoot:
| Usual device | Why it is out | What works instead |
|---|---|---|
| Child character, drawing or animation | the law names them expressly | the product in real use, without personification |
| Celebrity or athlete | the law names them expressly | a non famous person showing their routine |
| Brand mascot | the law names it expressly | the pack exactly as it is |
| Highlighting a nutritional quality | complementary claims may not be emphasised | talking about taste, use, convenience |
| Gift, prize or draw for buying | free promotion is prohibited | showing the product without conditioning the purchase |
| Covering the front of the pack with a hand | all seals must be fully visible | holding it by the side or the back |
By contrast with an ordinary campaign, where these devices are exactly what gets commissioned, here each one is a line removed from the script before filming rather than a fix in the edit.
The pack on camera
This is the restriction most often broken without bad intent. Every time the pack appears on screen, the seals that belong to it must be fully visible or stated.
In practice that means three things decided on set and not afterwards. The hand holding the product cannot cover the front. The shot showing the pack has to last long enough for the octagons to be read, not be a half second flash. And if the product appears from behind or cropped, the audio has to say what the image does not show.
None of this is fixed in the edit. A shot where a thumb sits on the octagon is not saved by a zoom.
What you can still show
More is left than it seems, and that is the part nobody explains.
You can show the product being used, cooked, shared. You can talk about taste, texture, price, where to find it, how far it goes. You can tell a personal experience without turning it into a nutritional property of the product. And you can film with adults, without famous faces, in an ordinary kitchen.
What the law removes is an aesthetic, not the product. The campaign that collapses is the one that depended on a character, a gift or a health promise; the one built on real use survives whole.
Before accepting the campaign
- Ask for a photo of the front of the pack, of the exact product, not the line. Two minutes, and it defines everything else.
- Ask where it will be bought as media, and to which audience. A correct piece can become an infringement through targeting, and that decision is not the creator's.
- Check the script against the list of prohibited devices, one by one, before writing the shooting plan.
- Agree how the pack is shown, in what shot and for how long, and write it into the brief.
Point two prevents the most trouble. A creator can shoot a flawless piece and find out afterwards that the brand ran it with targeting towards adolescents, which is exactly what article 10 prohibits. Asking beforehand is not distrust, it is the only way to know what you are taking part in.
Sources
- Law 27.642 on the Promotion of Healthy Eating, full text
- Ley simple: front of pack labelling
- Decree DNU 274/2019, Lealtad Comercial
Checked on 12 September 2026. This guide is not legal advice. Where this guide and the official source disagree, the source prevails.
