UK Consultations:

The regulation of genetic technologies  Deadline: 17.3.21

DRAFT Public Health England (PHE) proposals for 2023 commercial baby food and drink guidelines.   DEADLINE 5th January 2021 BMA-response FSNT Response

Total restriction of online advertising for products high in fat, sugar and salt (HFSS) DEADLINE 22nd December 2020.

DRAFT Public Health England (PHE) proposals for 2023 commercial baby food and drink guidelines.  

DEADLINE 5th January 2021

These Draft proposed guidelines will apply to commercial foods and drinks aimed at children aged up to 3 years (36 months) but does not include formula milks and toddler milks.

Despite its narrow focus this is a good report from Public Health England (PHE) which highlights the harm caused by commercial promotion of baby foods and drinks.  While its recommendations ( referred to as ‘Opportunities for action’) could be tougher,  they are all much needed.  If you have time to respond do read the First Steps Nutrition response which we heartily endorse.

In addition to the concerns highlighted by FSNT, we will urge a specific acknowledgement of the risks of global trade of ultra-processed products, not just to health but to the environment.  Steve Wearne of the UK Food Standards Agency is currently the  Vice-Chair of the Codex Alimentarius Commission , the global food safety and quality standards setting body.

Some excerpts from the PHE report.

“…evidence….demonstrates clear inconsistencies between national recommendations on infant and young child feeding and some commercial baby foods and drinks in terms of the types of products available, their ingredient and nutrition composition and product labelling and marketing.”

“There is concern that the growth of the commercial baby finger food market (volume sales increased by nearly 11% in 2017-2018), and the way products are labelled and marketed is encouraging snacking, by suggesting to parents that these products form an expected and appropriate part of an infant’s diet, when many are biscuits or savoury snacks and others are similar nutritionally to confectionery.”

“The evidence shows that commercial practices are not consistently supporting achievement of a healthy diet”

The government’s Prevention Green Paper, published in July 2019, made a commitment to improve the nutritional content, and the marketing and labelling, of product ranges aimed at infants and young children.PHE was commissioned to develop and publish voluntary guidelines for the food industry to improve the nutritional content of commercial baby food and drinks. This document sets out the draft proposed guidelines.The aim of the guidelines is to address the nutrient composition issues highlighted in PHE’s report by reducing the sugar content and sweetness of products and limiting the salt content. This will ensure greater consistency between commercial baby food and drinks and government advice on introducing solid foods,to contribute to improving dietary intakes and protecting dental health. Baby drinks and finger foods(often marketed as snacks) are a particular focus, as these products are considered the most confusing for parents and carers and do not support them to make the best choices for babies. Separately, the Department of Health and Social Care (DHSC) will consult on proposals to improve the marketing and labelling of commercial food and drink products for infants and young children, so that parents and carers have clear and honest information that aligns with Government advice on the products they feed their babies.


First Steps Nutrition Trust is a small independent UK charity providing evidence-based information and resources to health workers about good nutrition from pre-conception to 5 years.
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Public Health England have produced some draft guidelines on how the composition of commercial baby food and drink (marketed to 3 years of age) should change to reduce intakes of salt and sugar. There is much that PHE should be commended for in these draft guidelines, but we also think they need to go further, faster, and that it makes no sense to separate out the required labelling and marketing changes from those for composition.

We have put together a response to the consultation which you can read here. This is not an online consultation and responses have to be emailed to PHE directly. If anyone hasn’t seen the draft proposals and accompanying letter and wants to do so, please email

In this draft, whilst sweetened milk drinks marketed to children under 3 years are included in the scope, so called growing up and toddler milks are not. We think this is wrong. Infant milk manufacturers have created unnecessary products for children over the age of 1 year which they cross-brand with infant formula and follow-on formula, giving the impression to many that they are a necessary part of a child’s food journey. In these products extra lactose is primarily used as the additional sweetener (sometimes with maltodextrins) and PHE considers lactose as a free sugar when it is an added ingredient.

If babies are not breastfed after 1 year of age then they can have full-fat animal milk (or a suitable milk alternative with care) as their main milk drink, and do not need a sweetened formula type drink.

Most of these products call themselves ‘stage 3’ suggesting that this is a natural progression from stages 1 and 2, but there are no compositional, labelling or marketing regulations in the UK for these products, and we believe they should be treated as sweetened milk drinks. We would like to see the use of ‘stage numbers’ banned and regulation which does not allow cross-branding of these products with infant formula.

FSNT will be publishing more information on milks marketed for children over 1 year in the new year, so if you agree do  support the call for these to be brought into scope for the PHE guidelines on the composition of commercial baby drinks .

Information on these products currently on the UK market, and their costs can be found at

Consultations: Total restriction of online advertising for products high in fat, sugar and salt (HFSS) DEADLINE 22nd December 2020. Respond online 

Public consultation on total ban of online advertising for unhealthy foods from

Consultation on restricting online marketing of foods high in fat, salt and sugar.   In line with the report by First Steps Nutrition drawing on monitoring by the Baby Feeding Law Group specifically looking at the online marketing of infant milks in the UK we urge all our supporters to push for regulatory change on the marketing and labelling of infant formula, follow on formula,  milks marketed as foods for special medical purposes and products targeting children 0-36 months – all of which are ultra processed, risky and contribute to environmental damage.

The BFLG monitoring in October and November 2020,  looked at social media, influencers and bloggers, online infant formula company websites, baby clubs, and email alerts. New methods of promotion can break or stretch the rules on the marketing of infant formula and parents are receiving communications about all manner of brands and types of infant milks.

Sustain’s  Children’s Food Campaign has also made a submission to this consultation.

Some excerpts from Baby Milk Action Response on Enforcement and liability, sanctions, scope

We appreciate the opportunity to respond to this consultation and are pleased that it is happening.   Given the difficulties ahead,  the questions should focus more on public health and  human rights to health and adequate food and to the protection from harmful marketing..  Manufacturers and advertisers of HFSS and UPFs must receive a  clear message that these products are not suitable for commercial promotion

Enforcement : On the basis of our 40 years of experience with various regulatory bodies and monitoring.  if the  proposal is to have any credibility and effect it is essential that it is a government controlled regulation. It must NOT be self-regulatory. It MUST be independent and free from any commercial influence or financing.  It must not be modelled on the Advertising Standards Authority (ASA) and the fines and sanctions for contraventions must be meaningful and effective.

Should advertisers be liable? It depends what you mean by ‘liable’ – and whether  sanctions and fines would be sufficient to fund this proposal.   The ‘benefits’ of this proposal – if it is effective – will be an improvement in public health, and less damage to the environment – or at the least a reduction in harm.

Scope The definitions of problematic products must be widened not only to infant milks but to Ultra Processed Foods (UPFs) using the NOVA definition.  UPF (the term fits  many infant milks) are often globally traded and have  long shelf lives. They invariably contain non-food ingredients to stabilize, emulsify, thicken and regulate acidity. Ultra-processing requires perishable ingredients to be removed along with many essential micronutrients. UPFs are often so highly processed that they no longer resemble their plant or animal sources.

Identification of HFSS. Manufacturers have developed many strategies to hide the risks of their products, and can and do run circles round consumers with multiple sugars, fats and other ingredients with names that noone can possibly understand.   If the UK government is serious about encouraging  healthier eating, biodiversity and environmental degradation it must look wider than merely presence of  ‘nutrients’.

FSNT recommendations:

1.Government should include infant milks marketed for children up to three years of age in any work restricting online advertising of foods and drinks that can contribute to obesity.

2.Manufacturers should follow guidance to stop the inappropriate marketing of infant milks marketed for children up to 3 years as specified in the WHO International Code of Marketing of Breastmilk Substitutesand all subsequent World Health Assembly resolutions.

3.Digital platforms should voluntarily prohibit the advertising of infant milks marketed up to 3 years of age.

4.Everyone should be made aware of how to protect themselves from unwanted marketing and public awareness increased of how to use privacy functions to block parenting related advertisementsfrom infant formula brands or use advertisement blocking software


Artificial food colours and children: Why we want to limit and label foods containing the ‘Southampton Six’ on the UK market post-Brexit.

This report summarises the evidence that links the use of some azo dye colours in the food supply to behavioural issues in children, updates the evidence base and makes recommendations to limit potential exposure of children in the UK to these additives in post-Brexit trade deals.

Artificial food colours are not necessary in the food supply chain, are associated with ultra-processed foods and can encourage children to consume foods that have limited or no nutritional value.




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