A Welcome Step, But More To Be Done

By Ali Morpeth + Diane Threapleton

Today, the government published Commercial Baby Food and Drink Guidelines for children up to 36 months. Baby and toddler food manufacturers have been given 18 months to reduce sugar and salt levels in foods and drinks aimed at children under three years and introduce clearer labelling.

The government has set this in context of its 10 Year Plan to support children’s health, including tackling obesity rates which have doubled since the 1990s. The consequences of overconsumption of sugar and calories are an increased risk of gaining weight. The National Child Measurement Programme For England showed over a fifth of children, aged four to five are overweight or living with obesity.

These new guidelines are a step in addressing foods manufactured and marketed for young children which fall short of public health standards. We wrote extensively about this in our report, Commercial Baby Foods in Crisis, which analysed 600+ products and surveyed over 1,000 parents. You can find it here, and discussed in the BBC Panorama documentary.

The findings we published this year, built on evidence showing products are often high in sugar, labels cause confusion and the marketplace is not suitable for protecting the health of young children. Our report called for updates to the seriously outdated current babyfoods regulations, a call supported across the sector.

These guidelines are therefore a step forward. They signal recognition that stronger standards are needed. But while they improve on the status quo, they fail to take decisive action on what we know to be a real problem.

The government’s Commercial Food and Drink voluntary industry guidelines outline measures across nutrition, marketing, and product design. While some nutritional recommendations are clearly outlined, the guidance fails to adequately address other key concerns - such as the reliance on overly smooth product textures and misleading marketing practices - which lack meaningful resolution.

Nutritional guidelines

The guidelines aim to reduce sugar content and sweetness of products and limit salt content.

Action by industry on these areas is advised to ensure commercial foods align with public health guidance, contribute to improved dietary intakes and protect dental health. Some of the key areas outlined in the *Commercial Baby Food and Drink Guidelines* include:

**Dietary recommendation:** SACN advises that, from age one, average intakes of *free sugars* should not exceed 5% of total dietary energy. Children aged 1–5 years should not be given sugar-sweetened drinks, and dairy products (such as yoghurt) should ideally be unsweetened.
**Free sugars in products:** The guidelines prohibit the addition of free sugars (including sugar, honey, syrups), with only small amounts of lemon or lime juice permitted as a preservative.
***Businesses are explicitly asked to reduce levels of free sugars wherever possible.***
**Fruit ingredients & purées:** To limit free sugars, fruit (unlike vegetables) is restricted in some product categories. The document describes the UK free sugar definition as including ‘all sugars naturally present in fruit and vegetable juices, smoothies, purees, powders, pastes, extruded products and similar products in which the structure of the fruit or vegetable has been broken down’.
**Fruit content:** Capped at ≤5% of ingredients by weight in main meals and ≤10% in dry cereals, in line with the WHO NPPM (international standards for baby food composition from the World Health Organization). The new guidelines also state that fruit and vegetables should not be used as sweetening agents.
***Businesses are asked to reduce the amount of puréed products and limit fruit purée as an ingredient.***
**Our** **analysis** of products found just one in 20 meals and one in 10 cereals exceeded the fruit content limits, and only by a small margin. However, fruit powders and purees are used extensively in the snacks category - something that's not fully addressed in the guidelines.

Sugar limits are applied across categories, including:

Desserts and breakfasts: capped at 10g/100g.
Sweet and savoury finger foods and snacks, marketed up to 36 months: no more than 10% energy from sugar (plus no added sugars or sweetening agents - including juice - if marketed up to 12 months).
Fruit and vegetable-based finger foods, marketed up to 36 months: no more than 25% energy from sugar (plus no added sugars or sweetening agents - including juice- if marketed up to 12 months).
Our product analysis found that a third of baby snacks derived more than 15% of their energy from sugar.
Confectionery as a descriptor: Products with high sugar content that are unable to comply with sugar limits through reformulation should be described more like confectionery (not finger foods) and are not appropriate for children under three years old.

Our study found 21 confectionery products got 67% of their calories from sugar on average - making them wholly unsuitable for young children.

Below / Above 12 month sugar thresholds: Despite the guidelines acknowledging sugary foods (including dried fruit) should not be provided between meals, the guidance for children over 12 months states those products with at least 25% fruit content should have no more than 25% energy from sugar. This is a much higher sugar threshold that the 15% applied to this product category in World Health Organisation guidance.

Our study found a large proportion of baby snacks are overly sweet. For example, one third derive more than 15% of their energy from sugar.

Salt: Salt should not be added to any baby foods.

Marketing guidelines

The guidelines include some recommendations on packaging and marketing “to help support parents and carers make a more informed choice at the point of purchase” but don’t cover the breadth of issues identified in our report.

Age suitability: Clearly label products as only suitable from six months of age. This is in line with scientific and government advice to introduce solid foods around six months of age.
Our study found many products were marketed as suitable for infants younger than six months. For example, 33% of fruit products had age suitability labels of “4 months +”.
Honest naming: Product names should be honest and not misleading, and aligned with the quantity of the primary ingredient. For example, pear might be the main ingredient in a product, but the name “broccoli, pear and pea puree” suggests a vegetable based flavour. Currently, although manufacturers list ingredients in descending order of weight on the back of pack, this may not be reflected in the product name as it appears to customers.
Our study found that nearly one in five products had front-of-pack names that didn’t match their main ingredients, misleading parents.
Health-implying claims: Restrict marketing or promotional statements that imply health benefits or about nutritional benefits which are not based on scientific evidence.
Our research shows widespread healthwashing, greenwashing and causewashing are used to convince consumers about sustainability or charity claims while downplaying excessive sugar levels.
Feeding instructions: Provide clear feeding advice (e.g., “do not suck”). This should be on the front of products, rather than hidden in small print on the back of pack, or not communicated on pack at all.
Our research showed over half (51%) of spouted products failed to clearly include a back of pack warning not to drink via the spout.
Between-meal positioning: Stop labelling and marketing snacks or products promoted for eating between meals as suitable for children under 12 months.

Product development recommendations

The guidelines cover three product types (baby meals, baby finger foods and drinks, baby snacks) which are split into further sub categories. The guidelines encourage manufacturers to rethink the types of products they bring to market. Specifically, they should:

Focus on **vegetable-based and savoury** foods rather than fruit-based sweet products.
Use a wider range of vegetables, including **bitter and less-sweet varieties**.
**Avoid masking** the flavour of vegetables.
**Avoid single-flavour** fruit and vegetable products.
Produce **fewer highly blended** foods to support babies’ **texture progression**.
**Reduce total sugar and free sugar content wherever possible.**
Ensure **appropriate portion sizes**, particularly for snacks and products aimed at children under 12 months.
**Avoid producing and promoting sweet desserts.**

Many of these recommendations are the same as those outlined in the World Health Organisation Nutrient Promotion Profile Model. Without better, clearer and measurable targets for each recommendation, it is unclear how these changes will be monitored or measured.

What else could be done

The published guidelines are voluntary, meaning there is no legal requirement for manufacturers, or the wider industry to follow them. However, the government has clearly stipulated that manufacturers have 18 months to reduce sugar and salt levels in baby foods aimed at children under three and introduce clearer labelling.

To strengthen the marketplace further, and in line with the success of other health policies including high fat salt sugar (HFSS) legislation government should:

Commit to mandatory guidelines: Set strong, mandatory compositional and marketing standards for commercial infant foods, with robust monitoring and enforcement.
Set nutritional recommendations against the World Health Organisation Europe Nutrient and Promotion Profile Model (NPPM): to classify foods for infants and toddlers. This ready-made tool will ensure regulation is based on appropriate standards, addressing the shortcomings of the current UK marketplace and go beyond the sugar and salt concerns addressed here.
Recognise young children as a vulnerable population: Ensure that these policies are included in wider public health policy such as the Government Food Strategy.
Go further on ensuring that high sugar products are restricted: via introducing mandatory guidelines that reflect the wishes of parents:

Our survey of over 1,000 parents found 7 in 10 support front of pack warning labels on high-sugar baby foods.

2 in 3 parents said they feel misled by product claims and labelling.

WHO guidance already prohibits any main meal or snack product with more than 15% of energy from total sugar. The UK could implement a warning label for products exceeding this threshold (e.g. purées, desserts, dried fruit).

A moment of opportunity

The government’s voluntary guidelines are a welcome acknowledgement that the baby food market is not working in the interests of young children and families. But to succeed in re-orientating the marketplace, industry will either need to act quickly and decisively to meet the recommendations or government will need to strengthen them via moving from voluntary to mandatory guidance.

Government Launch of Commercial Baby Food Guidelines