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Formula Labelling in the United Kingdom: Manufacturers' Compliance With the Code, UK Law and Guidance Notes
Maiko Kamata1, Catherine Pereira-Kotze2, Marko Kerac1
1London School of Hygiene and Tropical Medicine, London, UK.
Insights
UK infant formula and follow-on formula labels show low compliance with marketing regulations. Many labels violate UK law, guidance, and the International Code of Marketing of Breastmilk Substitutes, indicating inappropriate marketing practices.
Area of Science:
- Public Health
- Nutrition Policy
- Consumer Protection
Background:
- The International Code of Marketing of Breastmilk Substitutes aims to prevent inappropriate marketing of infant formula and protect infant feeding practices.
- UK legislation partially incorporates the Code, but concerns remain regarding the marketing of infant formula (IF) and follow-on formula (FoF).
Purpose of the Study:
- To assess the compliance of UK infant formula and follow-on formula labels with the International Code of Marketing of Breastmilk Substitutes, UK law, and Department of Health and Social Care (DHSC) Guidance Notes.
- To identify specific areas of non-compliance in infant formula and follow-on formula labelling.
Main Methods:
- A systematic assessment of 57 infant formula and follow-on formula labels collected from websites, shops, and online retailers in July-August 2022.
- Development of three labelling checklists to evaluate compliance against the Code, UK law, and DHSC Guidance Notes.
- Comparison of compliance scores across different regulatory frameworks, formula types, and brands.
Main Results:
- Overall compliance was low: 50% with UK law, 32% with DHSC Guidance Notes, and 40% with the International Code.
- No labels fully complied with provisions against idealising text/images, specific nutrition/health claims, and cross-promotion.
- Significant violations were observed across all assessed regulatory frameworks, formula types, and brands.
Conclusions:
- UK infant formula and follow-on formula labels frequently violate marketing regulations, indicating inappropriate commercial influence on infant feeding.
- There is a need for stronger enforcement and enhancement of UK law to align with the International Code.
- Improved regulation is crucial to protect breastfeeding, support safe formula feeding, and reduce commercial pressures on caregivers.
Abstract:
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.
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