The video lands on a Thursday evening and it is good. The creator filmed the unboxing in natural light, the texture holds on screen, the first bite is real, and the brand wants to publish on Monday. Nobody in the chain can say whether the banner « Pour votre santé, mangez au moins cinq fruits et légumes par jour » (for your health, eat at least five fruits and vegetables a day) has to appear on it, in what form, and who answers if the video goes out without it.
The question is settled before the shoot, never at publication: the answer changes the edit, and an edit gets redone.
Two health warnings, two laws
The phrase "health warning" covers two obligations that share neither their text, nor their trigger, nor their form, and confusing them costs a reshoot.
The first belongs to alcoholic drinks, carried by the loi Evin and the code de la santé publique (the French public health code). It is written one way only and accompanies every permitted advertisement, an entirely separate regime detailed in the rules for UGC on wine and spirits.
The second belongs to food, carried by article L2133-1 of the code de la santé publique and by the arrêté du 27 février 2007. It targets advertising messages and promotional operations in favour of certain foods and drinks. The alcohol warning rests on a single wording, whereas the food warning has four of them. A biscuit brand and a wine house are therefore not under the same regime, even when they brief the same creator.
Which products trigger the obligation
The obligation is not triggered by a sector, it is triggered by a composition and by a transformation. Two families are concerned.
Drinks with added sugars, salt or synthetic sweeteners, first. It is not the marketing category that decides ("soda", "sports drink", "iced tea"), it is the presence of one of those additions in the recipe.
Manufactured food products, next. A product transformed and packaged for sale enters the scope, whatever its nutritional positioning. A product that is healthy in the ordinary sense is still a manufactured product in the sense of the law.
What escapes is unprocessed raw produce: an apple, a whole fish, a loose vegetable. A campaign staging a farmer in their field has nothing to display as long as nothing manufactured is on screen.
That leaves a borderline case teams get wrong: the product under an appellation d'origine or another quality sign. The appellation protects a place, a method and a specification. It says nothing about whether the product is manufactured, and it takes nobody out of the scope of the law.
The reformulated product that changes category
A recipe with no added sugars that receives a sweetener to hold a nutritional profile enters the first family when it had left it. The change is decided in R&D, it shows on the label, and it almost never reaches the team that orders videos. If your catalogue moves during the year, the check is redone for every new reference filmed, not once and for all at the campaign launch.
The four official messages and their signature
The wordings are not written, they are copied out. The arrêté du 27 février 2007 sets four of them: « Pour votre santé, mangez au moins cinq fruits et légumes par jour », « Pour votre santé, pratiquez une activité physique régulière » (for your health, take regular physical exercise), « Pour votre santé, évitez de manger trop gras, trop sucré, trop salé » (for your health, avoid eating too much fat, sugar and salt) and « Pour votre santé, évitez de grignoter entre les repas » (for your health, avoid snacking between meals).
Two practical consequences follow. The first is that no rewording is possible: shortening « au moins cinq fruits et légumes » to « cinq fruits et légumes » is no longer the official message. The second is that nothing requires always using the same one: spreading the four sentences across the videos of a campaign is decided when the creators are allocated, not at the edit of the last one.
To that is added the signature: the address mangerbouger.fr, which points to the Programme national nutrition santé. It is the piece teams forget most often, because it is not part of the sentence and it gets lost in a recrop.
This message is an obligation of form, not to be confused with the rules governing what a food video may assert about a product's composition or its effect. The two are checked at the same moment and do not replace each other.
The medium decides the form
The arrêté does not reason by product, it reasons by medium, and for each one it describes what the message has to become on screen, in sound or on paper. Radio even has its own set of wordings, shorter, provided at its article 3.
The online channel is not a blind spot in the text. Its article 5 targets advertising messages distributed by online public communication services, attaches to them the mention of the mangerbouger.fr address, and sets a requirement that short formats neglect: the health information "appears at the same time as the advertising message and has to be accessible when the advertising message is consulted". A mention you have to go and find somewhere other than in the video being watched therefore does not satisfy the rule.
| Surface | What the surface requires | Who decides the form |
|---|---|---|
| Video published on an account | Message displayed at the same time as the video and accessible while it is watched, with the mangerbouger.fr address | The text for the principle, the brand for the placement on screen |
| Product page of an online store | Message expected as soon as the page carries a promotional argument, not on a neutral description of the reference | The brand, page by page |
| Sponsored placement at a retailer | Message required as online, within the technical templates the inventory imposes | The retailer for the template, the brand for the rest |
The message does not go in the caption
A caption folds behind a "see more" and survives neither the repost nor the download of the file. The message therefore has to live in the image itself, at a spot that neither the platform interface nor an automatic recrop covers. On a vertical format, that means avoiding the bottom band, occupied by buttons, and the top band, occupied by the account name.
The fifteen seconds
Fifteen seconds exempt nothing, they only force an early decision. The objection is real: a permanent overlay spoils a tight edit. The answer lies in the master. The creator delivers a clean version, with no burnt-in text at all, and from there the brand produces the distributed version with its mention. Asking the creator to burn it in means handing compliance to the person with the least material to judge it.
Advertising, promotional operation, or neither
The text targets advertising messages and promotional operations in favour of these products, whatever the channel. What it does not say is whether a creator's video is one of them. That, and only that, is where advertisers' practice decides.
A paid post, published on the creator's account in exchange for a consideration, is a commercial communication from the brand. It is treated as such, so it carries the message. The fact that the account belongs to someone else does not change who the advertiser is.
A video delivered white-label and distributed on the brand's channels, in paid media or on its own page, is simpler still: the brand is everywhere, and the message with it.
A spontaneous post, with no consideration and no framing, is neither. It is the only case where the question does not arise, and it is also the rarest in an organised campaign.
This reasoning is not an in-house interpretation: the ARPP Comportements alimentaires recommendation states in its scope that it targets ambassadors and influencers, whatever the audience. The sector's ethical framework therefore treats creator content as food advertising. As for the information obligation itself, it weighs on advertisers and promoters. The creator carries the video, the brand carries the obligation, and no contract clause shifts that charge.
The marketplace and retail media
A video bought for a product page or for a sponsored placement at a retailer leaves the creator's account and enters an advertising inventory. The retailer applies its own technical specifications, and it sometimes refuses overlays. That is a distribution constraint to know at the brief stage, not an exemption.
The brief that avoids the reshoot
Three lines are enough, and they are written in the framing document rather than in an exchange of messages, alongside the rest of the instructions described in our UGC brief guide.
The first asks for two deliverables per video: a master with no burnt-in text, and the subtitled version. The master is what makes it possible to produce a compliant version without calling the creator back.
The second fixes the placement of the mention and the sentence chosen for this video, picked from the set of four, with the mangerbouger.fr address.
The third names the person who checks before publication, and the moment they do it: on the final edit, not on the rushes. With no name in the brief, that check never happens, and the video goes out on Monday morning like the others.
Sources
- Code de la santé publique, article L2133-1
- Arrêté du 27 février 2007 fixant les conditions relatives aux informations à caractère sanitaire devant accompagner les messages publicitaires ou promotionnels en faveur de certains aliments et boissons
- Arcom, fiche de référence de l'arrêté du 27 février 2007
- mangerbouger.fr, le Programme national nutrition santé
- ARPP, Recommandation Comportements alimentaires v4
Checked on 19 September 2026. This guide is not legal advice. Where this guide and the official source disagree, the official source prevails.
