Formula Labelling in the United Kingdom: Manufacturers' Compliance With the Code, UK Law and Guidance Notes

The International Code of Marketing of Breastmilk Substitutes ('the Code') was established to protect babies and young children from inappropriate marketing of formula milk, bottles and teats and avoid undue commercial influence on caregiver infant feeding practices, including undermining breastfeeding and safe and appropriate formula feeding. UK law encompasses some but not all of the Code. To address persisting concerns about the marketing of infant formula (IF) and follow-on formula (FoF), we assessed labelling compliance in the UK against relevant provisions in the Code, UK law and Department of Health and Social Care (DHSC) Guidance Notes which interpret UK law. Data were collected during July and August 2022 by taking pictures of labels from company websites, in shops and online. We developed three labelling checklists to systematically assess compliance and to compare compliance scores between the regulatory frameworks, formula types and brands. We assessed 57 labels (n = 32 IF and n = 25 FoF) and found low overall compliance: 50% complied with UK law, 32% with Guidance Notes and 40% with the Code. None of the labels complied with provisions prohibiting idealising text and photographs, nutrition and health claims (where relevant) and cross-promotion between formula types. In conclusion, UK IF and FoF labels violate many of the provisions of all three regulatory frameworks. This is evidence of inappropriate marketing. The UK law should be better enforced and strengthened in line with the Code to protect breastfeeding, support safer, appropriate formula feeding and lessen commercial influence on infant feeding practices.