This is part of our guide to monitoring in the UK. This page explains the rules for product labelling.

You will find this information in printed form in our monitoring kit.

International Code and Resolutions

Article 9.1 on labelling includes the following for all products in the Scope:

9.1 Labels should be designed to provide the necessary information about the appropriate use of the product, and so as not to discourage breastfeeding.

Article 9.2 relates specifically to infant formula:

9.2 Manufacturers and distributors of infant formula should ensure that each container has a clear, conspicuous, and easily readable and understandable message printed on it, or on a label which cannot readily become separated from it, in an appropriate language, which includes all the following points:
     1. the words “Important Notice” or their equivalent;
     2. a statement of the superiority of breastfeeding;
     3. a statement that the product should be used only on the advice of a health worker as to the need for its use and the proper method of use;
    4. instructions for appropriate preparation, and a warning against the health hazards of inappropriate preparation.

Neither the container nor the label should have pictures of infants, nor should they have other pictures or text which may idealise the use of infant formula.

UK Regulations

The UK law (regulations 17 and 18) is similar to the International Code, although it allows approved health claims to be used on labels of infant formula if the associated requirements are met. These are given in a list annexed to the law.

In addition, regulation 19 states:

19. Infant formula and follow-on formula shall be labelled in such a way that it enables consumers to make a clear distinction between such products so as to avoid any risk of confusion between infant formula and follow on formula.

Despite this, the labels for infant formula, follow-on formula and other infant and young child feeding are almost identical as companies design them to be cross-promotional. Nestlé’s 2016 SMA range is shown below.

smarangeuk010916

The companies ignore specific requirements intended to make the type of products clear. The Guidance Notes state:

51. … the specific terms ‘infant formula’ and ‘follow-on formula’ should be clearly featured on the packaging, in a font size no smaller than the brand name.

Again, companies ignore this.

The Guidance Notes require warnings on powdered formula that it is not sterile and instructions on how to reduce risks of possible contamination. As with the Code and Resolutions, idealising text and images on labels are prohibited.

The Guidance Notes state:

30 & 31… infant formula shall not include…. any other picture or text which may idealise the use of the product… Pictures of infants, young children or carers (e.g. mothers or fathers)…. Graphics that represent nursing mothers and pregnant women…. Baby or child related subjects (e.g. toys, cots or young animals) and anthropomorphic characters, pictures and logos.

Again, companies disregard the official interpretation of the law. Nestlé’s SMA logo, above, incorporates a stylised breastfeeding woman and heart.

Danone uses a shield on Aptamil, a heart on Cow & Gate and young animal figures on both.

aptamiluk0215 cowandgatelabel200116

Please report any practices that concern you to mikebrady@babymilkaction.org

Guide to UK formula rules: