The ARPP’s “Comportements alimentaires” Recommendation: what has changed between V3 and V4?
Version 4 of the ARPP’s (French advertising self-regulatory organisation) “Comportements alimentaires” (Eating Behaviour) Recommendation came into force on 15 June 2026.
In a previous article, we discussed its entry into force and the main rules governing the depiction of eating behaviour in advertising. We noted in particular that this code of practice, now well established in the advertising landscape, has a particularly high compliance rate, while remaining the subject of constant scrutiny by the ARPP.
The new version does not overhaul the overall structure of the text. The core principles remain unchanged: promoting a balanced diet, prohibiting the encouragement of excessive consumption, regulating snacking, protecting children and prohibiting scenes of eating in front of a screen at home.
V4 nonetheless introduces several notable changes which advertisers, agencies, influencers and content creators would be well advised to build into their approval processes.
A broader concept of physical activity
The first change appears in the preamble itself.
Whereas the previous version merely promoted “daily physical activity”, V4 now specifies that this notion must be understood broadly as “moving” or “being active”.
The text mentions, among other things, walking, cycling, taking the stairs, active breaks at work and, perhaps more surprisingly, gardening.
This clarification brings the Recommendation more closely into line with the current guidelines of the Programme national nutrition santé (PNNS, French national nutrition and health programme), which promote physical activity in all its forms.
A new rule on the Nutri-Score and nutritional benchmarks
V4 introduces a specific provision concerning nutritional benchmarks.
From now on, where nutritional benchmarks, in particular the Nutri-Score, are mentioned in an advertisement, they must comply with the legibility rules laid down in the ARPP’s “Mentions et renvois” (Disclaimers and Footnotes) Recommendation.
This requirement applies wherever the benchmark appears in the advertisement, including where it appears only on the packaging shown.
This new rule reflects a desire to improve the visibility and understanding of the nutritional information made available to consumers.
Regulation of slimming diets
V4 also creates a new provision on slimming diets.
The text now provides that advertisements promoting such diets must refer to supervision by a healthcare professional.
This requirement did not exist in the previous version.
It forms part of a wider trend of vigilance towards communications liable to trivialise restrictive practices or excessive promises relating to weight loss.
Stricter assessment of excessive consumption
The principle remains unchanged: advertising must not encourage excessive consumption.
V4 does, however, provide several interesting clarifications.
First, whether consumption is excessive must now be assessed in the light of the PNNS recommendations.
Second, the text establishes an explicit link with the notion of food waste, specifying that the quantity depicted must also be assessed with regard to that issue.
This change makes the self-regulatory review of advertising campaigns more objective.
The emergence of sustainable food
One of the main innovations in V4 is the introduction of a section devoted to sustainable food.
The Recommendation now provides that advertising must not discredit certain criteria associated with sustainable food, such as the seasonality of products or methods of production that respect biodiversity.
This provision illustrates the gradual extension of the ARPP’s concerns to environmental issues relating to food.
Particular attention paid to environmental labels
Following on from this new theme, V4 also provides that labels, including environmental labels, must comply with the legibility rules of the “Mentions et renvois” Recommendation when they are highlighted in an advertisement.
This requirement comes against a background of heightened scrutiny of environmental claims and the risks of greenwashing.
A strengthened rule on diversity
Finally, the wording of the provision on diversity has changed slightly but significantly.
Whereas V3 stated that advertising should “avoid any form of stigmatisation”, V4 now provides that it “must not stigmatise” people on grounds including their height, size, thinness or dietary choices.
This change in wording reflects a higher standard expected by the ARPP.
Key takeaways
V4 does not alter the foundations of the “Comportements alimentaires” Recommendation. It is more a matter of consolidating and updating the existing framework.
Three strong trends nonetheless emerge:
greater attention to the legibility of nutritional information;
the inclusion of new concerns relating to slimming diets;
the emergence of issues relating to sustainable food and environmental communication.
These changes confirm the gradual broadening of the self-regulatory review of food advertising, which now sits at the crossroads of public health, consumer information and sustainability.
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