Guidance

Commercial baby food and drink: voluntary industry guidelines

Published 22 August 2025

Applies to England

Introduction

The voluntary industry guidelines for commercial baby food and drink aimed at children aged up to 36 months set out:

• targets for businesses to reduce levels of sugar and salt in each product category (the targets provide figures for both salt and sodium - the word salt is used throughout the remainder of these guidelines to mean both salt and sodium)
• actions businesses should take to improve the labelling and marketing of these products to help make it easier for parents and carers to make a healthier choice

The guidelines are relevant to:

• retailers
• commercial baby food manufacturers (referred to as manufacturers in the rest of the guidelines)
• trade associations
• non-governmental healthcare organisations

Businesses have 18 months from publication of these guidelines in August 2025 to implement both the salt and sugar targets and the actions on labelling and marketing. So this means they have until the end of February 2027.

Background

Evidence

The World Health Organization (WHO) Report of the commission on ending childhood obesity stated that children’s food preferences and eating habits are formed early in life and have consequences for a range of health and developmental outcomes in later life.

The 2019 evidence review Foods and drinks aimed at infants and young children: evidence and opportunities for action demonstrated that babies and young children are eating too much sugar and salt, and energy intakes are exceeding requirements.

The consequences of over-consumption of sugar and calories are an increased risk of gaining weight and, for sugar only, tooth decay.

Data from the National Child Measurement Programme (NCMP) for England, for the school year 2023 to 2024, shows over a fifth of children aged 4 to 5 years are overweight or living with obesity. The NCMP also shows that the prevalence of obesity for children aged 4 to 5 years and 10 to 11 years in the most deprived areas is more than double that of children in the least deprived areas.

The Oral health survey of 5 year old schoolchildren 2024 showed that over a fifth of 5 year old schoolchildren in England had experience of tooth decay. Children living in the most deprived areas of the country were more than twice as likely to have experienced tooth decay as those living in the least deprived areas.

Research also shows that children who are overweight or living with obesity are more likely to be obese adults (Singh and others, 2008). Excess weight increases the risk of conditions such as heart disease, some cancers and type 2 diabetes in adulthood (Lim and others, 2012).

The 2019 evidence review also found that commercial baby foods and drinks are widely available and used in the UK, particularly for babies aged between 6 and 12 months. There has been significant growth in the types of foods and drinks marketed for babies and young children, with an estimated value of £774 million in 2023, which is nearly £70 million more than the previous year. One estimate suggested the global market was worth $53.7 billion in 2024 and is likely to grow to $84.2 billion by 2033 (Brand-Williamson and others, 2025).

The 2019 evidence review also highlighted some clear inconsistencies between government baby feeding advice and some commercial baby foods and drinks, for:

• the types of products available
• their ingredients and nutrient composition
• the labelling and marketing of products

Where these inconsistencies exist, it encourages the consumption of foods or ingredients in an amount or frequency not recommended as part of a healthy balanced diet for this age group. For example, commercial finger foods and snacks (such as sweet and savoury biscuits, crisps and puffs, and processed dried fruit products) are not the foods given as examples of healthy snacks in government feeding advice (set out in the NHS advice Your baby’s first solid foods), which include fruit, vegetable sticks, toast, bread or plain yoghurt. Some of the best-selling baby finger food products, often marketed as snacks, can be as high in sugar as standard confectionery products. Recent research is consistent with this assessment.

SACN recommendations

The Scientific Advisory Committee on Nutrition (SACN) reviewed evidence on the scientific basis of current recommendations as part of their report Feeding in the first year of life. It recommended that:

• most babies should not start solid food until around 6 months of age
• a wide range of solid foods should be introduced in an age-appropriate form from around 6 months
• dietary, flavour and texture diversification should proceed incrementally
• the only drinks offered to children between 6 and 12 months of age should be breast milk, infant formula and water

SACN also advised that, in view of high intakes of salt and free sugars in this age group, there is a need to re-emphasise the risks associated with added salt and free sugars in foods given to babies.

SACN also reviewed evidence that supports the scientific basis of current recommendations for babies and young children as part of its report Feeding young children aged 1 to 5 years. It recommended that:

• commercially manufactured foods and drinks marketed specifically for babies and young children are not needed to meet nutritional requirements
• foods (including snacks) that are energy-dense and high in saturated fat, salt or free sugars should be limited for children aged 1 to 5 years, in line with current UK dietary recommendations, while encouraging uptake of healthier snacks
• children aged 1 to 5 should not be given sugar-sweetened beverages
• dairy products, such as yoghurts and fromage frais, given to children aged 1 to 5 years should be unsweetened
• the UK dietary recommendation that free sugars intake should not exceed 5% of total dietary energy intake should now apply from 1 year old (it previously applied from the age of 2 years and up)
• salt should not be added to foods given to children aged 1 to 5 years, with the aim that, on average, young children aged 1 to 3 years should consume no more than 2 grams (g) of salt a day

Other recommendations, including those on oral health, were summarised in the 2019 evidence review.

Labelling of baby food

The 2019 evidence review highlighted that messaging and marketing associated with some commercial products conflicts with government recommendations on baby and young child feeding, and causes confusion for parents and carers. Inappropriate marketing and promotional statements that point to indirect health benefits, or that are not based on scientific evidence, suggest to parents that products are healthier than the nutrient composition indicates.

Nutrition and health claims legislation (specifically EU regulation 1924/2006 on nutrition and health claims made on food) ensures that nutrition and health claims should only be used if they have been authorised following scientific assessment of supporting evidence, and where the food meets the set conditions of use. For example, nutrients being present at the required level in the food to support the claim that the food has a beneficial impact on health.

A ‘nutrition claim’ means any claim that states, suggests or implies that a food has particular beneficial nutritional properties due to the presence, absence, increased or reduced levels of energy or of a particular nutrient or other substance. This includes claims such as ‘source of calcium’, ‘low fat’, ‘high fibre’ and ‘reduced salt’.

A ‘health claim’ means any claim that states, suggests or implies that a relationship exists between a food category, a food or one of its constituents and health. For example, ‘calcium helps maintain normal bones’ and ‘vitamin C contributes to the normal function of the immune system’.

Some marketing statements that appear on products with relatively high sugar contents may be factually accurate and do not relate to the sugar content of the product. However, using these statements on products that are high in sugar can encourage parents to overestimate the healthiness of the product. This is referred to as the ‘health halo effect’ or ‘implied health claims’.

These guidelines aim to strengthen existing regulations by giving more detail on the type of information that can and cannot be displayed on baby food and drink packaging.

Products with unclear names that do not accurately reflect the proportion of ingredients could result in babies being fed sweeter meals than intended. For example, fruit (pear) may be the main ingredient in a product, but the name (broccoli, pear and pea puree) suggests a savoury or vegetable-based flavour. Under current legislation, manufacturers must list the ingredients of a product in descending order of weight and provide the quantity of any ingredient mentioned in the name of the product or emphasised on the labelling. However, this information is generally only listed on the back of the pack and may not be reflected accurately in the name of the product.

This type of inaccurate labelling does not support parents and carers to make an informed choice at the point of purchase. It may prevent parents giving their children a varied diet and risks reinforcing babies’ innate preference for sweet tastes.

Development of the guidelines

There have been 2 phases of work to develop the baby food guidelines, first in 2019 to 2020, then in 2023 to 2024. A substantial programme of stakeholder engagement informed the guidelines over these 2 periods, including requesting informal written feedback on draft guidelines.

Other sources of information considered when setting the guidelines included:

• data on the baby food market and individual products (sales and market share, nutrition information and ingredients) as well as the technical function of ingredients and food safety considerations
• the SACN reports ‘Feeding in the first year of life’ and ‘Feeding young children aged 1 to 5 years’
• current government feeding advice for the ages of children covered by these guidelines
• existing legislation covering commercial baby food and drink (The Processed Cereal-based Foods and Baby Foods for Infants and Young Children (England) Regulations 2003)
• requirements for commercial baby food and drink set out in the WHO Nutrient and promotion profile model (NPPM)
• the Food Standards Authority of Ireland’s consultation document Draft reformulation targets for commercially available complementary foods (PDF, 1.44MB) and the subsequent guidance Reformulation targets for commercially available complementary foods
• the WHO guidance Ending inappropriate promotion of commercially available complementary foods for infants and young children between 6 and 36 months in Europe

You can find:

• further details about the development of the guidelines in annex 1
• further details of the baby food market, and the range and distribution of sugar and sodium levels in products, in annex 2
• information on the WHO Europe NPPM in annex 3

Aim and scope of the guidelines

The aim of these guidelines is to address the issues highlighted in the 2019 evidence review by reducing the sugar content and sweetness of products and limiting the salt content. Changes made by businesses to product packaging to bring them in line with the labelling guidelines will help support parents and carers make a more informed choice at the point of purchase.

Action by industry to implement these guidelines would ensure commercial baby foods and drinks:

• more closely align with government advice on introducing solid foods
• contribute to improving babies’ dietary intakes
• protect dental health

Products in scope of the guidelines are defined in the Processed Cereal-based Foods and Baby Foods for Infants and Young Children (England) Regulations 2003 as ‘processed cereal-based foods’ and ‘baby foods’.

Food and drink products that may fall outside the definition of ‘baby foods’ and ‘processed cereal-based foods’ but are marketed at, or labelled as suitable for, babies and young children under 36 months (for example, finger foods and snacks) are also within scope of these guidelines.

Infant and follow-on formula, and toddler and growing-up milks, are out of the scope of these guidelines. Government infant feeding advice (set out in the NHS advice Types of formula) states that children aged 1 to 5 years do not need formula milks including infant formula, follow-on formula and growing-up or other toddler milks. First infant formula is suitable from birth until age 1.

Data used to inform and establish the guidelines

To inform the commercial baby food and drink guidelines, we used data from Kantar Worldpanel’s take-home consumer panel. This data provides volume sales and nutrition information of products bought by a panel of 30,000 households across Great Britain (England, Scotland and Wales).

You can find further information on the development of the guidelines, and the Kantar Worldpanel data set, in annex 1.

Product categorisation

The development of the product categories, and the products included in each category, has been informed by:

• categories in the Kantar Worldpanel database
• extensive industry and other stakeholder engagement and feedback
• a review of the UK baby food market

The category definitions section sets out the categorisation for commercial baby foods and drinks, based on 3 broad product types that are each split into further sub- categories:

• baby meals
• baby finger foods and snacks
• baby drinks

The nutrition guidelines vary by product type and category. Businesses should identify which category a product is in to determine which of the guidelines apply by identifying it:

• in the overarching ‘reducing sugar’ and ‘reducing salt’ sections
• by product type (separate guidelines relating to meals, finger foods and snacks, and drinks)

Category definitions

The following is a summary of the categories included in the guidelines for commercial baby foods and drinks.

Baby meals

Baby meals includes a number of product categories, which are described below.

Fruit and vegetables

The fruit and vegetables category includes products that contain only 100% fruit and vegetables, which are usually in the form of a puree.

These products can include functional ingredients such as ascorbic acid and water. Businesses should only add the minimum amount required.

The sub-categories in the fruit and vegetables category include:

• single vegetables - for example, 100% carrot
• single fruits - for example, 100% apple
• mixed vegetables - for example, a single product including a mix of carrot, swede and potato
• mixed fruit - for example, a single product including a mix of apple, banana and pear
• mixed fruit and vegetables - for example, a single product including a mix of carrot, beetroot and apple

The fruit and vegetables category excludes products with legumes or beans, protein or starchy components, or oils.

Main meals

Main meals are composite products including protein and/or starchy components and are mainly savoury. Product examples include:

• spaghetti bolognese
• sweet potato, tomato and rice
• cheese and vegetable pasta

The main meals category excludes fruit and vegetable-only products.

Dry cereals

Dry cereals are savoury (such as vegetable flavour) and sweet (such as fruit flavour), and are intended to be reconstituted before being served. Product examples include:

• savoury meals - for example, vegetables and rice
• sweet meals - for example, fruity porridge mix

The dry cereals category excludes ready-to-eat cereals and plain starchy foods.

Desserts and breakfasts

Desserts and breakfasts are composite products, made up of combinations of fruit, dairy (or dairy alternatives) or starchy foods, and are mainly sweet. This includes:

• ambient yoghurts - for example, apple, oats and yoghurt
• desserts - for example, custard, rice pudding
• breakfasts - for example, fruity porridge (ready to eat)
• ready-to-eat cereals

The desserts and breakfasts category excludes chilled yoghurts.

Soups, stocks and cooking sauces

The soups, stocks and cooking sauces category includes:

• stock cubes - for example, chicken or vegetable flavour
• stir in pasta sauces - for example, stir-in tomato sauce, stir-in bolognese sauce

The soups, stocks and cooking sauces category excludes oils.

Other baby meals

Other baby meals includes plain starchy foods, such as pasta, rice and couscous.

Baby finger foods and snacks

Baby finger foods and snacks includes a number of product categories, which are described below.

Savoury finger foods and snacks

The savoury finger foods and snacks category includes savoury or plain products only with up to 25% fruit or vegetable-based ingredients. This includes:

• savoury puffs - for example, carrot puffs, sweetcorn rings
• breadsticks - for example, plain or cheese flavour
• rice cakes
• biscuits and crackers - for example, cheese crackers
• wafers
• grain-based snacks

Sweet finger foods and snacks

The sweet finger foods and snacks category includes only sweet products with up to 25% fruit or vegetable-based ingredients. This includes:

• puffs - for example, strawberry puffs
• rice cakes - for example, apple rice cakes
• biscuits and biscotti - for example, peach biscuits, banana biscotti
• wafers - for example, blueberry wafers
• cereal and oat bars - for example, apple oat bars

Fruit or vegetable-based finger foods and snacks

Fruit or vegetable-based finger foods and snacks includes products with more than 25% fruit or vegetable-based ingredients. This includes:

• vegetable crisps or waffles - for example, parsnip crisps
• fruit crisps - for example, apple crisps
• fruit-based bars with cereal or oats - for example, apple, banana and grain bars
• other fruit or vegetable-based products - for example, coated or flavoured and pressed or shaped dried fruit or vegetables, such as strawberry shapes

The fruit or vegetable-based finger foods and snacks category excludes 100% plain dried fruit and vegetables.

Baby drinks

Baby drinks include:

• fruit drinks and juices
• sweetened milk and milk alternatives

The baby drinks category excludes all formula milks and growing-up milks.

Nutrition guidelines: reducing sugar and salt

Reducing sugar guidelines

In the UK, dietary recommendations for sugar are based on free sugars. The SACN report ‘Feeding young children aged 1 to 5 years’ recommends, for children aged 1 and over, that average population intakes should not exceed 5% of total dietary energy intake of free sugars. Children aged 1 to 5 years should not be given sugar-sweetened beverages. Dairy products, such as yoghurts and fromage frais, given to children aged 1 to 5 years should ideally be unsweetened.

Government feeding advice for babies and young children is clear that:

• sugar should not be added to foods or drinks
• the amount and frequency of sugary foods and drinks consumed should be reduced
• sugary foods (including dried fruit) should not be provided between meals

Businesses should aim to reduce levels of free sugars wherever possible in all commercial baby food and drink products.

The definition of free sugars for the UK (Swan and others, 2018) includes all monosaccharides and disaccharides added to foods, including:

• table sugar, honey, syrups and nectars (examples include malt, fruit or corn syrup, date or coconut blossom nectar)
• lactose and galactose added as ingredients
• 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
• all sugars in drinks (except for naturally occurring sugars in dairy-based drinks)

It excludes sugars naturally present in intact fruit and vegetables (dried, stewed, canned or frozen), milk and dairy products, and cereal grains, nuts and seeds.

These guidelines restrict most types of free sugars in meals, finger foods and drinks aimed at babies aged up to 12 months (see tables 1 to 4 below).

Recognising the use of fruit and vegetables in the commercial baby food market, either alone (such as purees) or as ingredients in other products, only juices and juice concentrates are not permitted for use as a sweetening agent.

To limit the levels of free sugars, these guidelines restrict the use of fruit (but not vegetables) as an ingredient in some product categories (for example, crushed, blended, pulped, pureed, flakes, pastes, powdered, extruded or similar products in which the fruit structure has been broken down). There are also limits on total sugars in other product categories. The use of sweeteners is prohibited in all foods for infants (under 12 months old) and young children (1 to 3 years old). This includes foods specifically prepared for infants and young children (‘baby foods’).

Reducing salt guidelines

Sodium is a component of table salt (sodium chloride), but it also occurs naturally in a wide range of foods, including fruit and vegetables, cheese and many other ingredients used in commercial baby food. Some commercial baby food products contain added salt, while others contain only naturally occurring sodium.

These guidelines do not permit salt as an ingredient in any meals or finger foods and snacks, and limit the sodium (milligrams (mg) per kilocalorie (kcal)) content of products (see tables 1 to 4 below).

Since there is naturally occurring sodium in fruit and vegetables, the limit on sodium does not apply to foods that are 100% fruit and/or vegetables.

Nutrition guidelines: by product type

Guidelines for baby meals

Fruit and vegetables are recommended first foods for babies.

Government advice is to start feeding babies with single vegetables and fruits, and vegetables that are less sweet. This advice also recommends that babies aged around 6 months should move on from purees to mashed, lumpy or finger foods as soon as they can manage them. This is important both for their development and for free sugar intakes.

Businesses should ensure that their product ranges support the development of healthy eating habits in young children by not adding salt or free sugars to products.

In baby meals, fruit and/or vegetable foods have the highest average sugar content, in particular the single fruit and blended fruit products (for more information, see table 15 in annex 2). A less sweet product mix would be better for preparing babies to accept a wide range of different, less sweet tastes and to protect their dental health.

Businesses should better reflect feeding advice in the baby meal products that make up the greatest proportion of numbers of products in their portfolios, volume sales and sales spend (value). Businesses are specifically encouraged to reduce the number of pureed products and the use of fruit puree as an ingredient. This will lead to reductions in free sugar content.

Annex 4 provides more information on how to apply these guidelines. This includes example calculations of how products can be assessed against the nutrition guidelines to identify the reformulation action required to comply with the guidelines.

Table 1 below sets out how the reducing sugar and reducing salt guidelines apply to products categorised as baby meals. Some products already meet the guidelines, and reformulation of other products is feasible in most instances. Businesses should work to reduce levels of free sugar, total sugar and salt in all products that currently exceed the relevant guidelines.

Table 1: guidelines for baby meals

Product category	Added sugars guidelines (see note 1)	Sugar guidelines	Added salt guidelines	Sodium guidelines
Fruit and vegetable foods	No added sugars or sweetening agents	No total sugar guideline	No added salt	No sodium guideline
Main meals	No added sugars or sweetening agents	Less than or equal to 5% limit on fruit content by weight	No added salt	Less than 60mg sodium per 100 kcal, or less than 100mg sodium per 100 kcal if cheese is mentioned in front of pack name
Dry cereals	No added sugars or sweetening agents	Less than or equal to 10% limit on fruit content per 100g dry weight (not as prepared)	No added salt	Less than 60mg sodium per 100 kcal, or less than 100mg sodium per 100 kcal if cheese is mentioned in front of pack name
Desserts and breakfasts	No added sugars or sweetening agents	Less than 10g total sugar per 100g	No added salt	Less than 60mg sodium per 100 kcal, or less than 100mg sodium per 100 kcal if cheese is mentioned in front of pack name
Soups, stocks and cooking sauces	No added sugars or sweetening agents	No total sugar guideline	No added salt	Less than 60mg sodium per 100 kcal, or less than 100mg sodium per 100 kcal if cheese is mentioned in front of pack name
Other - for example, plain rice, pasta	No added sugars or sweetening agents	No total sugar guideline	No added salt	Less than 60mg sodium per 100 kcal, or less than 100mg sodium per 100 kcal if cheese is mentioned in front of pack name

Note 1: added sugars and sweetening agents includes sugar, honey and syrups, plus fruit and vegetable juice and juice concentrates (except small amounts of lemon or lime juice, or equivalent, as preservative), and lactose and galactose as ingredients (except lactose in whey powder in dry cereals intended for reconstitution with water).

Guidelines for baby finger foods and snacks

Baby finger foods and snacks are split into 2 separate overarching product types:

• finger foods that are aimed at babies aged up to 12 months
• finger foods and snacks that are aimed at babies aged 12 months and over

Finger food products aimed at babies aged up to 12 months are subject to more restrictions on sugar than products aimed at babies aged 12 months and over. Finger foods aimed at babies aged up to 12 months have restrictions placed on the use of free sugars and a limit on total sugar. Finger food and snack products aimed at babies aged 12 months and over have a limit on total sugar only. This approach continues to permit a range of finger foods and snacks for babies 12 months and over, but also aims to ensure that only those with lower levels of sugar are available.

Products that contain high levels of sugar, and are not able to be reformulated, should be considered more like confectionery. These are not appropriate for children aged up to 36 months.

Tables 2 and 3 below set out the sugar and salt guidelines for products categorised as baby finger foods and snacks.

Table 2: guidelines for baby finger foods aimed at babies aged up to 12 months

Product category	Added sugars guidelines (see note 1)	Sugar guidelines	Added salt guidelines	Sodium guidelines
Savoury finger foods	No added sugars or sweetening agents	Less than 10% of energy per 100g from total sugar	No added salt	Less than 60mg sodium per 100 kcal, or less than 100mg sodium per 100 kcal if cheese is mentioned in front of pack name
Sweet finger foods	No added sugars or sweetening agents	Less than 10% of energy per 100g from total sugar	No added salt	Less than 60mg sodium per 100 kcal, or less than 100mg sodium per 100 kcal if cheese is mentioned in front of pack name
Fruit and vegetable-based finger foods (containing more than 25% fruit or vegetable ingredient)	No added sugars or sweetening agents	Less than 25% of energy per 100g from total sugar	No added salt	Less than 60mg sodium per 100 kcal, or less than 100mg sodium per 100 kcal if cheese is mentioned in front of pack name

Note 1: includes sugar, honey syrups, nectars plus fruit or vegetable juice and juice concentrates (except small amounts of lemon or lime juice, or equivalent, as preservative), and lactose and galactose as ingredients (except lactose in whey powder in dry cereals intended for reconstitution with water).

Table 3: guidelines for baby finger foods and snacks aimed at babies aged 12 months and over

Product category	Sugar guidelines	Added salt guidelines	Sodium guidelines
Savoury finger foods and snacks	Less than 10% of energy per 100g from total sugar	No added salt	Less than 60mg sodium per 100 kcal, or less than 100mg sodium per 100 kcal if cheese is mentioned in front of pack name
Sweet finger foods and snacks	Less than 10% of energy per 100g from total sugar	No added salt	Less than 60mg sodium per 100 kcal, or less than 100mg sodium per 100 kcal if cheese is mentioned in front of pack name
Fruit and vegetable-based finger foods and snacks (containing more than 25% fruit or vegetable ingredient)	Less than 25% of energy per 100g from total sugar	No added salt	Less than 60mg sodium per 100 kcal, or less than 100mg sodium per 100 kcal if cheese is mentioned in front of pack name

Guidelines for baby drinks

Table 4 below sets out how the reducing sugar guidelines apply to products categorised as baby drinks. No salt guideline has been set for this category.

Table 4: guidelines for baby drinks

Product category	Sugar guidelines	Salt and sodium guidelines
Baby drinks	No added sugars or sweetening agents (see note 1)	No salt or sodium guideline

Note 1: includes sugar, honey, nectar and syrups, plus fruit or vegetable juice, and juice concentrates.

Additional considerations: nutrient content

These guidelines focus on reducing the sugar and salt content of commercial baby foods and drinks. However, there are a number of additional considerations around composition that are not covered in the guidelines but remain important.

These considerations were first included in the 2019 evidence review. They are:

• promote development of good eating habits including texture progression, development of taste preferences, dietary diversification and variety, and food recognition
• enable parents and carers to make informed choices at the point of purchase

When reviewing existing or devising new products, food producers should consider the following guidance on food composition:

• producing more vegetable and savoury foods than fruit-based and sweet foods
• using more bitter and less sweet vegetables as ingredients
• refraining from masking the flavour of vegetables
• producing more single-flavour fruit and vegetable foods
• producing fewer highly blended foods to help enable texture progression
• reducing the total sugar and free sugar contents of foods wherever possible
• appropriate portion sizes, particularly for finger foods and products aimed at children aged up to 12 months
• avoiding producing sweet desserts

Food labelling guidelines

The food labelling guidelines below are based on points originally included in the 2019 evidence review and stakeholder feedback.

As with the sugar and salt guidelines, and the additional considerations for nutrient content, the food labelling guidelines are voluntary.

Marketing and labelling guidelines

To improve the marketing and labelling of their products, we strongly encourage food producers to:

• label products in line with scientific and government advice to introduce solid foods at around 6 months of age
• provide honest labelling so that product names are not misleading and are aligned with the quantity of the primary ingredients (for more information, see ‘Labelling of baby food’ in the ‘Background’ section)
• restrict inappropriate on-pack marketing and promotional statements that make ‘implied health claims’ about health or nutritional benefits that are not based on scientific evidence
• have clear feeding instructions (for example ‘use a spoon’ or ‘do not suck’) on the front of products packaged in pouches with a nozzle
• stop labelling and marketing snacks or food products that can be eaten between meals as suitable for children aged 12 months and under

The final guideline above was added to these labelling guidelines following the informal feedback exercise with stakeholders. This is because snacks are not in line with government dietary guidelines for this age group. Babies under the age of 12 months do not need snacks.

Some responses to the informal feedback exercise suggested it was important to address the poor dietary and oral health outcomes associated with these products and practices. Adding this guideline represents best practice for businesses, and it can help ensure that their product portfolios better reflect dietary guidelines for children aged up to 36 months.

Implementing the guidelines

Action by industry to implement these guidelines will align with the government’s commitment to ensuring commercial food and drink products marketed for babies and young children are:

• age appropriate
• aligned with dietary guidelines
• supportive of healthy development

Implementing the guidelines includes ensuring parents and carers are equipped with clear, transparent and accurate product information that supports them to make healthier choices for their children.

Some businesses have already implemented some of the guidelines. However, further progress will be monitored by government to ensure that businesses are complying with legislation and are marketing and labelling baby foods and drinks in an honest and transparent way.

Legal labelling requirements

There are currently legal requirements set out in regulations relating to:

• general food labelling requirements: EU regulation 1169/2011 on the provision of food information to consumers
• labelling processed cereal-based foods and baby foods: The Processed Cereal-based Foods and Baby Foods for Infants and Young Children (England) Regulations 2003
• nutrition and health claims: EU regulation 1924/2006

The guidelines above on honest labelling and restricting inappropriate on-pack marketing will encourage businesses to ensure their practices comply with the legislation.

Timeframe for implementation of the guidelines

We expect businesses to implement both the nutrition and labelling guidelines within 18 months of publishing these guidelines, so by the end of February 2027.

This timeframe is considered to be challenging but achievable. Businesses have been aware of the actions they would need to take since 2020, and some of the changes set out in the guidelines have already been made by some businesses in some products.

Next steps

Industry’s progress towards implementing the sugar and salt guidelines will be monitored by government. A progress report is expected after February 2027. The metrics to be used to make this assessment will now be considered.

Progress by businesses towards meeting the labelling guidelines, and compliance with legislation, will also be monitored by government.

The government will consider additional or alternative measures if businesses fail to implement these guidelines.

References

Brand-Williamson J, Parrett A, Sibson V and Garcia AL. ‘Commercial baby foods: nutrition, marketing and motivations for use - a narrative review’. Maternal and Child Nutrition 2025: e70059.

Lim SS, Vos T, Flaxman AD, Danaei G, Shibuya K, Adair-Rohani H and others. ‘A comparative risk assessment of burden of disease and injury attributable to 67 risk factors and risk factor clusters in 21 regions, 1990-2010: a systematic analysis for the Global Burden of Disease Study 2010.’ The Lancet 2012: volume 380, issue 9,859, pages 2,224 to 2,260.

Singh AS, Mulder C, Twisk JW, van Mechelen W and Chinapaw MJ. ‘Tracking of childhood overweight into adulthood: a systematic review of the literature.’ Obesity Reviews 2008: volume 9, issue 5, pages 474 to 488.

Swan GE, Powell NA, Knowles BL, Bush MT and Levy LB. ‘A definition of free sugars for the UK.’ Public Health Nutrition 2018: volume 21, issue 9, pages 1,636 to 1,638.

Annex 1: development of the guidelines

Development of proposed draft guidelines

The development of proposed draft guidelines in 2020 included market analysis of the range and distribution of the salt and sugar content of commercial baby food and drink products, based on data for the year ending September 2020.

Kantar Worldpanel was commissioned to provide data for products aimed at babies and young children - in other words products in the ‘baby food’ aisle of retailers, plus some chilled or frozen products available elsewhere in stores. The Kantar data set represents purchases of products brought into the home by a panel of 30,000 households across Great Britain over a 52-week period to September 2020.

It is a comprehensive data set and provides data on both volume (kilos or litres) sales and nutrition information (per 100g or per millilitre (ml)). It also includes marketing and labelling information derived from food labels on individual products or that Kantar Worldpanel collected from third parties. The data collected is weighted to provide a representative picture of total food and drink purchasing in Great Britain.

Products in the Kantar nutrition data set were categorised into relevant food and drink categories and sub-categories.

The development of the categories, and the guidelines for each category, were informed by extensive stakeholder engagement as well as the:

• 2019 evidence review
• draft WHO Europe NPPM review
• Kantar data
• baby feeding advice

Draft proposals for voluntary guidelines were outlined in November 2020 and stakeholders were invited to provide feedback on the proposals. Comments were invited on the scope for reformulation, technical considerations, and challenges and opportunities, in relation to the draft proposals. The guidelines were then further developed taking on board this stakeholder feedback.

In October 2023, the guidelines were considered again in light of updated information obtained from stakeholders - for example, businesses and non-governmental organisations (NGOs) together. Other information considered included:

• an assessment of more recent product and market data
• information received through the previous engagement exercise in 2020
• the report from SACN on ‘Feeding young children aged 1 to 5 years’
• the requirements for commercial baby food and drink set out in the WHO Europe NPPM
• the consultation on draft reformulation targets for commercially available complementary foods published by the Food Standards Authority of Ireland

More recent Kantar data for the 52 weeks ending September 2022 provided information on the baby food market, and the range and distribution of the sugar and salt content of commercial baby food and drink products. For products where nutrition information and ingredient information was missing from the Kantar data set, data from food labels was taken from online sources during November and December 2023. The data was used to assess the impact of the guidelines as they stood after the informal written feedback exercise carried out in 2020.

This assessment showed that, overall, 75% of products met the sugar guidelines. It was therefore proposed to make the target for the desserts and breakfasts (ready to eat) category more stringent, reducing the sugar level from 12g per 100g to 10g per 100g. Several products in this category are a combination of dairy and fruit puree.

The lower sugar guideline for this category is expected to encourage a change in the balance of dairy and fruit puree, and move products to be more in line with the SACN recommendation that dairy products should be unsweetened. While the overall figure meeting the sugar guidelines may seem high, only 22% of products in the sweet finger foods and snacks category met the sugar guideline set for that category. So, there is a substantial amount of progress to be made.

The analysis against the salt guidelines showed that there was a high level of compliance, with 94% of all products meeting the salt guidelines. This is likely to be partly due to the fact that few products contained added salt. Following a review of products available in the 2022 data set, a decision was made to amend the previous proposed guideline for most products from 75mg per 100 kcal to not more than 60mg per 100 kcal.

The guideline for products where cheese is mentioned in the front of pack product name was changed from 125mg per 100 kcal to not more than 100mg per 100 kcal for this category, which brings this product category guideline in line with that suggested in the WHO Europe NPPM.

Stakeholder engagement on proposed draft guidelines

Engagement process

Between October 2023 and March 2024, OHID re-engaged with stakeholders (retailers, manufacturers, trade associations, health NGOs and academics) on the guidelines. An initial meeting was held in October 2023 with stakeholders to:

• remind them of the background to, and evidence that supports, setting the guidelines
• remind them of the draft guidelines shared with them in 2020
• inform them of the steps that would be taken over the following months to set and publish the guidelines

To help understand changes made to products and portfolios, as well as current opportunities and challenges that remain with reformulation, relevant businesses, trade bodies and NGOs were invited to attend one-to-one meetings with OHID, if they wanted to.

Draft proposals for the voluntary industry guidelines were circulated to stakeholders in February 2024 for them to provide written feedback. Stakeholders were given one month to respond.

How stakeholders engaged

The tables below lists stakeholders that attended the initial meeting in October 2023, had one-to-one meetings with OHID, or provided feedback on the draft proposed guidelines.

Retailers

Stakeholder	Attended initial meeting 24 October 2023	Attended one-to-one meeting	Provided written feedback
Boots	Yes	No	No
Morrisons	Yes	Yes	No

Manufacturers

Stakeholder	Attended initial meeting 24 October 2023	Attended one-to-one meeting	Provided written feedback
Arla	Yes	No	No
Babease	Yes	Yes	Yes
Bear (Urban Fresh Foods)	Yes	No	No
Danone	Yes	Yes	Yes
Ella’s Kitchen	Yes	Yes	Yes
Heinz/Farley’s	Yes	No	Yes
Hipp	Yes	No	No
Kiddylicious	Yes	No	Yes
Little Freddie	Yes	Yes	Yes
Nestle	Yes	Yes	Yes
Organix	Yes	Yes	Yes
Piccolo	Yes	No	No

Trade bodies

Stakeholder	Attended initial meeting 24 October 2023	Attended one-to-one meeting	Provided written feedback
British Specialist Nutrition Association	Yes	Yes	Yes
Food and Drink Federation	Yes	Yes	Yes
British Retail Consortium	Yes	No	Yes

Non-governmental healthcare organisations

Stakeholder	Attended initial meeting 24 October 2023	Attended one-to-one meeting	Provided written feedback
Action on Salt/Sugar	Yes	Yes	Yes
Baby Milk Action	No	No	Yes
British Dental Association	Yes	Yes	Yes
British Nutrition Foundation	No	No	Yes
First Steps Nutrition	Yes	No	Yes
Food Active	No	No	Yes
Food Foundation	Yes	No	Yes
Obesity Health Alliance	Yes	No	Yes
Porter Nutrition	No	No	Yes
Royal College of Paediatrics and Child Health	No	No	Yes
Sustain	No	No	Yes
University of Glasgow	No	No	Yes
World Health Organization for Nutritional Epidemiology, University of Leeds	No	No	Yes
Food Standards Agency Northern Ireland	No	No	Yes

Stakeholder feedback

OHID invited stakeholders to provide written feedback on the following 4 points of the guideline proposals:

• reducing the sugar level in the desserts and breakfasts category from 12g per 100g to 10g per 100g
• reducing the sodium guidelines from their current levels of 75mg per 100 kcal, or 125mg per 100 kcal if cheese is mentioned in the front of pack product name, to not more than 60mg per 100 kcal or 100mg per 100 kcal, respectively
• reducing the timeframe for delivery of the guidelines from 2 years to 18 months from the month the final guidelines are published
• the points included in the actions for businesses to take on food labelling intended for inclusion in the final guidelines

OHID invited stakeholders to consider the following points in relation to delivering the 3 draft proposals within the commercial baby food and drink sector and the additional considerations on food labelling:

• the scope and opportunities for reformulation
• technical considerations and challenges

A summary of the main themes and concerns raised within the feedback received from stakeholders is set out below.

Summary of stakeholder feedback

Sugar guidelines

Overall, stakeholders were supportive of the proposed sugar guideline for the desserts and breakfasts category and agreed that it was broadly achievable. Also, most stakeholders supported the no added sugar or sweetening agents guideline for finger foods for babies under 12 months.

There were mixed views about the less than 10% of energy per 100g from total sugar guideline, with NGOs being more supportive than businesses. Businesses raised some technical issues and concerns generally about the texture of products with sugar content at the levels proposed. NGOs suggested changes to bring the guidelines more in line with the WHO Europe NPPM and that the same sugar guideline should apply to all finger food and snack products, irrespective of age. Businesses suggested that the sugar guidelines should also be applied to the fruit and vegetable meals category, as there is overlap with how parents use these products and foods in the desserts and breakfasts category.

NGOs also suggested taking naturally occurring lactose into account. They compared this to the approach taken for the voluntary sugar reduction programme, even though this approach was only applied to a very limited number of categories.

Businesses requested further clarity on the definitions of free sugar, and permissible and non-permissible free sugars, including the use of fruit flakes.

Sodium guidelines

Overall, businesses were supportive of the proposed sodium guidelines and the majority agreed that they were broadly achievable.

Businesses welcomed the guideline on no added salt as an ingredient for baby food products. As with the sugar guidelines, health NGOs proposed that the sodium guidelines should be in line with the WHO Europe NPPM where this is not already the case.

Some stakeholders suggested that further consideration should be given to the inclusion or exclusion of certain food ingredients or types of products from the sodium guidelines or that some changes should be made to the guidelines for some product categories.

Timeframe for implementation of the guidelines

Although businesses agreed that most of the guidelines were achievable, they recommended that the timeframe for implementation should be extended from 18 months to 24 months. They said this would allow enough time for:

• recipe testing
• shelf-life analysis
• packaging changes

Due to product shelf-life and packaging lead times, businesses said that some non-compliant products may still be on the market after the implementation date. They also said that the government should consider the timing of products brought to market and their inclusion in the progress assessments. NGOs were supportive of the 18-month timeframe.

Categorisation and products in scope of the guidelines

Stakeholders made suggestions about or requested further clarity on:

• the products in scope of the guidelines including formula other than first formula
• the definitions or products included in some categories
• whether the guidelines apply to all products placed in the baby food aisle, including those that do not include a recommended age
• ingredients that can be added for technical reasons and specific limits on quantities of these ingredients within the baby meals category

Portion size

Stakeholders questioned the wording “consider appropriate portion sizes, particularly for finger foods and snacks, and products aimed at children aged under 12 months”. They said this was because any meaningful advice on portion sizes for products aimed at children aged under 12 months may be challenging as:

• there is a lack of consensus on appropriate portion sizes for this age group
• some types of products, such as finger foods and snacks, will be consumed in varying amounts depending on the age of the baby

Alignment with EU regulations

Businesses acknowledged that the proposed voluntary guidelines focused only on the UK market and do not reflect current UK or EU legislation. Where possible, they were keen to limit regulatory divergence and maintain regulatory alignment with the EU.

Alignment with WHO Europe NPPM

Some stakeholders said they would like to see all proposed guidance align with the relevant WHO Europe NPPM recommendations on composition, including points on:

• the fruit content of products, particularly pureed fruit, the use of fruit-based ingredients and the marketing of high-sugar dried fruit-based snacks
• producing more nutrient-dense early weaning foods (for babies aged 6 to 12 months) and not adding unnecessary water or stock to fruit or vegetable purees
• reducing the use of high-intensity flavourings

Monitoring

Businesses requested further clarity on how progress on the sugar and salt and/or sodium guidelines will be monitored and if results will be published.

Stakeholders highlighted that monitoring needs to cover all products labelled as suitable for children up to 36 months and that, after an assessment of compliance at 12 months, the government should consider additional action where insufficient progress has been made.

Other points raised

Stakeholders noted that some guidelines have different measures for them to be considered successfully implemented and requested that these should be consistent across all guidelines. For example, the guideline for finger foods and snacks is less than 10% of energy per 100g from total sugar, while the guideline for main meals is less than or equal to 5% limit on fruit content by weight.

There were requests for the additional considerations around nutrient composition to be made stronger.

Some stakeholders proposed that the guidelines should be made mandatory. Businesses did not comment on this point.

Health NGOs requested that a list of stakeholders that provided feedback on the guidelines, and the feedback responses themselves, are made public.

Summary of 2020 stakeholder feedback

Comments made by stakeholders in the feedback exercise undertaken in November 2020 were similar to those raised in the more recent feedback exercise, which are summarised above. Additional comments from the 2020 stakeholder feedback included:

• challenges around the inclusion of bitter vegetables in some products
• the limit on fruit ingredients in some categories being too strict
• clarification that ingredients that technically require salt, such as cheese, bread and ham, are permitted if sodium limits for individual categories are not exceeded
• consideration of chilled or frozen meal components - for example, pizza and breaded fish - that are targeted at young children
• extending these guidelines to any product intended for children
• plans to review the functionality and nutritional status of alternative sweetening agents to sugar

Food labelling guidelines

OHID invited stakeholders to provide written feedback on the 5 food labelling guidelines in the 2024 informal feedback exercise, which were to:

• ensure product marketing is consistent with scientific advice and NHS guidance to introduce solid foods at around 6 months of age
• ensure honest labelling so that product names are not misleading and are aligned with the primary ingredients
• restrict use of implied nutrition and health claims and health halo statements (marketing statements that appear on products with relatively high sugar contents can be encouraging parents to overestimate the healthiness of the product)
• ensure that clear feeding instructions (‘use a spoon’ or ‘do not suck’) are present on the front of products packaged in pouches with a nozzle
• ensure that products high in sugars are labelled as not being suitable for eating between meals

Summary of stakeholder feedback

Twenty-five responses were received from a mix of manufacturers, retailers and health NGOs.

Overall, most stakeholders were supportive of 3 of the 5 guidelines, which were:

• guideline 1 on product marketing
• guideline 2 on honest labelling
• guideline 4 on clear feeding instructions

One stakeholder objected to guideline 1, stating that it was contrary to legislation and the advice that parents receive from GPs and health professionals about feeding their children.

Some stakeholders emphasised that guideline 2 was already a legal requirement under assimilated EU regulation 1169/2011 on the provision of food information to consumers. For this guideline there was also a suggestion that clear guidance be provided for industry on how to comply with the legislation.

Only a few stakeholders raised objections to guideline 4 on the basis that there is limited space on the front of pack to communicate this message.

Stakeholders had differing views on guidelines 3 and 5.

On guideline 3, retailers and manufacturers indicated that nutrition and health claims are strictly regulated under assimilated EU regulation 1924/2006 on nutrition and health claims made on food and that the terms ‘implied’ and ‘health halo’ were subjective and open to misinterpretation. There was also concern that if implied nutrition and health claims and health halo statements were not restricted in other aisles for general food products, this could lead to a distortion in consumers perception of the relative healthiness of commercial baby food products and similar non-baby food products.

NGOs felt that stronger wording should be used and that the guidelines should go further to align with the WHO Europe NPPM guidance. This included:

• restricting composition statements to allergens and religious or cultural requirements only
• using descriptive words in the ingredient list only, such as ‘organic carrots’
• restricting claims that are related to emotions - such as words like ‘contentment’, ‘happiness’, ‘love’ and ‘pride’ - as these are not appropriate

It was also recommended by both manufacturers and health NGOs that clear guidance with pictorial examples be provided for retailers and manufactures to support this action.

On guideline 5, all stakeholders recommended clarification of the threshold for ‘high in sugar’. Health NGOs recommended adopting the WHO Europe NPPM sugar threshold. Manufacturers and retailers suggested that consumers may be confused if products high in sugars are labelled as not being suitable for eating between meals. This is because this wording does not align with the recommended weaning advice that there is a gradual transition to 3 meals a day by around 10 months of age so there is no concept of ‘between meals’.

Additional recommendations 

Additional proposals recommended by health NGOs for government included:

• publishing a call for evidence on front of pack labelling
• adopting in full the labelling actions included in the WHO Europe NPPM
• introducing a minimum age limit of 12 months for snack food and drinks (this aligns with public health advice)
• introducing an upper age limit of 12 months for pureed foods
• banning cross-branding of commercial baby foods with formula milk products to limit the promotion of baby formula which is not legally permitted
• banning the marketing of finger foods
• banning marketing techniques that appeal to children, such as having cartoon characters on labelling

Annex 2: market and nutrition analysis

Kantar nutrition data for the 52 weeks ending September 2022 was used to inform the baby food guidelines (see annex 1 above). The data was analysed to provide information on the product market. It was also analysed to provide data on the range and distribution of sugar and sodium levels in products in each of the product categories, which was used to inform the guideline levels set.

Market analysis

Table 5 below shows the number and proportion of products analysed by category. Baby meals make up the greatest proportion of the market in:

• number of products (71.6%)
• volume sales (77.6%)
• sales spend (54.6%)

Baby finger foods and snacks account for over a quarter of products (27.6%) and just under half of sales spend (45.1%). Baby drinks make a negligible contribution to the market across all measures.

Table 5: number and proportion of products and volume sales by category

Category	Number of products	Proportion of products (%)	Volume sales (kg, 000s)	Proportion of volume sales (%)	Sales spend (£, 000s)	Proportion of sales spend (%)
Baby meals	618	71.6	23,540	77.6	158,000	54.6
Baby finger foods and snacks	240	27.8	6,409	21.1	130,642	45.1
Baby drinks	5	0.6	385	1.3	848	0.3
Total	863	100	30,334	100	289,490	100

Table 6 below shows the number and proportion of products marketed at different age groups analysed by product category. Just over a quarter (25.6%) of baby meals are marketed at babies aged 4 months, with around 21.8% and 27.8% of baby meals marketed at babies aged 6 months and 7 months respectively. The majority of finger foods and snacks are marketed at babies aged 12 months (48.3%), with only 1.7% marketed at babies aged 4 months.

Table 6: number and proportion of products marketed at different age groups, by product category

Age	Number of all products (proportion of all products)	Number of baby meals (proportion of baby meals)	Number of baby finger foods and snacks (proportion of baby finger foods and snacks)	Number of baby drinks (proportion of baby drinks)
4 months	162 (18.8%)	158 (25.6%)	4 (1.7%)	Not available
5 months	3 (0.3%)	2 (0.3%)	Not available	1 (20%)
6 months	147 (17%)	135 (21.8%)	11 (4.6%)	1 (20%)
7 months	241 (27.9%)	172 (27.8%)	69 (28.8%)	Not available
8 months	3 (0.3%)	1 (0.2%)	2 (0.8%)	Not available
9 months	17 (2%)	3 (0.5%)	14 (5.8%)	Not available
10 months	74 (8.6%)	56 (9.1%)	18 (7.5%)	Not available
12 months	188 (21.8%)	69 (11.2%)	116 (48.3%)	3 (60%)
Over 1 year	28 (3.2%)	22 (3.6%)	6 (2.5%)	Not available
Total	863 (100%)	618 (100%)	240 (100%)	5 (100%)

Table 7 below shows the number and proportion of products with different types of packaging. The majority of the baby foods are packaged in pouch form (38.5%), followed by bag (15.9%), tray (11.7%), jar (11.5%) and box (10%).

Table 7: type of baby food packaging

Packaging	Number of all products	Proportion of all products (%)
Pouch	332	38.5
Bag	137	15.9
Tray	101	11.7
Jar	99	11.5
Box	86	10.0
Pot	39	4.5
Packet	37	4.3
Tub	13	1.5
Can	6	0.7
Bottle	5	0.6
Tin	5	0.6
Carton	3	0.3
Total	863	100

Nutrition analysis

The commercial baby food and drink guidelines have been informed by the range and distribution of the sugar and salt content of products in each of the categories. This data is shown in table 8 to table 15 below and includes the average for all products within each category, and the average for the top 10 selling products within the category.

Averages presented are simple averages which is the simple arithmetic mean where products are given equal weight.

The data used for this analysis is the 2022 data from Kantar Worldpanel’s take-home consumer panel (see annex 1 above).

Conversions from sodium to salt

Kantar Worldpanel converts the information on the salt content of food and drink (given in the back of pack nutrition information panel) into sodium content. Salt values are converted to sodium using a standard conversion figure (salt ÷ 2.5 = sodium).

Table 8: simple average energy and nutrient content for main meals and fruit and vegetable meals

Per 100g	Main meals: all 270 products	Main meals: top 10 selling products	Fruit and vegetable meals: all 137 products	Fruit and vegetable meals: top 10 selling products
Energy (kcal)	72.6	67.8	55.8	62.1
Protein (g)	3.3	2.7	0.8	0.5
Carbohydrates (g)	9.2	8.7	11.0	13.0
Sugar (g)	2.5	2.3	8.7	10.6
Fat (g)	2.1	2.1	0.4	0.3
Saturates (g)	0.8	0.7	0.1	0.1
Fibre (g)	1.7	1.5	2.0	2.2
Sodium (g)	0.0	0.0	0.0	0.0

Table 9: simple average of energy and nutrient content for dry cereals

Per 100g	Dry cereals: all 48 products (see note 1)	Dry cereals: top 10 selling products (see note 1)
Energy (kcal)	116.5	104.7
Protein (g)	3.6	3.7
Carbohydrates (g)	18.8	17.1
Sugar (g)	7.0	7.5
Fat (g)	2.8	2.4
Saturates (g)	0.9	0.8
Fibre (g)	1.6	1.0
Sodium (g)	0.0	0.0

Note 1: values shown are for products as consumed.

Table 10: simple average of energy and nutrient content for desserts and breakfasts

Per 100g	Desserts and breakfasts: all 78 products	Desserts and breakfasts: top 10 selling products
Energy (kcal)	76.6	79.6
Protein (g)	1.7	2.1
Carbohydrates (g)	12.5	13.7
Sugar (g)	8.5	9.6
Fat (g)	1.9	1.6
Saturates (g)	1.2	0.8
Fibre (g)	1.3	1.2
Sodium (g)	0.0	0.0

Table 11: simple average of energy and nutrient content for soups, stocks and cooking sauces

Per 100g	Soups, stocks and cooking sauces: all 12 products	Soups, stocks and cooking sauces: top 10 selling products
Energy (kcal)	65.2	66.8
Protein (g)	2.9	3.2
Carbohydrates (g)	6.6	6.4
Sugar (g)	3.1	2.9
Fat (g)	2.7	2.9
Saturates (g)	0.9	1.0
Fibre (g)	1.4	1.3
Sodium (g)	0.0	0.1

Table 12: simple average of energy and nutrient content for other meals, such as plain rice, pasta

Per 100g	Other meals, such as plain rice, pasta: all 11 products	Other meals, such as plain rice, pasta: top 10 selling products
Energy (kcal)	196	180
Protein (g)	5.9	5.4
Carbohydrates (g)	37.1	33.6
Sugar (g)	3.4	3.5
Fat (g)	2.2	2.2
Saturates (g)	0.7	0.7
Fibre (g)	2.3	2.2
Sodium (g)	0.0	0.0

Table 13: simple average of energy and nutrient content for baby finger foods and snacks

Per 100g	Savoury: all 76 products	Savoury: top 10 selling products	Fruit and vegetable: all 66 products	Fruit and vegetable: top 10 selling products	Sweet: all 75 products	Sweet: top 10 selling products
Energy (kcal)	426.4	461.7	363.5	399.6	413.4	403.5
Protein (g)	9.0	7.6	4.7	6.4	7.1	7.6
Carbohydrates (g)	67.1	65.2	64.7	60.4	74.4	70.7
Sugar (g)	3.9	3.6	38.6	27.6	13.6	19.9
Fat (g)	14.1	18.1	7.9	13.1	9.0	9.1
Saturates (g)	1.8	1.8	1.5	1.8	2.4	2.2
Fibre (g)	3.8	3.9	7.8	6.4	3.2	3.8
Sodium (g)	0.1	0.1	0.0	0.0	0.1	0.1

Table 14: simple average of energy and nutrient content for baby drinks

Per 100ml	Baby drinks: all 4 products	Baby drinks: top 10 selling products
Energy (kcal)	16.3	Not applicable
Protein (g)	0.1	Not applicable
Carbohydrates (g)	3.4	Not applicable
Sugar (g)	3.3	Not applicable
Fat (g)	0.1	Not applicable
Saturates (g)	0.1	Not applicable
Fibre (g)	1.4	Not applicable
Sodium (g)	0.0	Not applicable

Table 15: simple average sugar content of fruit and vegetable foods by sub-category

Product sub-category	Number of products in the sub-category	Percentage (%) of all fruit and vegetable foods in each sub-category	Sugar average (g per 100g)
Single vegetable	14	10.2	5.4
Single fruit	17	12.4	11.6
Blended vegetable	22	16.1	2.8
Blended fruit	65	47.4	11.1
Blended fruit and vegetable	19	13.9	7.3
All fruit and vegetable-based foods	137	100	8.7

Annex 3: WHO Europe recommendations

Development of the guidelines has been informed by the NPPM, which WHO Europe published in their discussion paper ‘Ending inappropriate promotion of commercially available complementary foods for infants and young children between 6 and 36 months in Europe.’

The NPPM was developed to help identify products that can and cannot be promoted for babies and young children aged up to 36 months.

The NPPM was also designed to help identify which category a product fits into, after which the nutrient specifications for that category can be evaluated. The NPPM separates the following products because of different nutritional and packaging requirements:

• dry cereals and starches
• dairy foods
• fruit and vegetable purees and smoothies and fruit desserts
• savoury meals and meal components
• snacks and finger foods
• ingredients (for cooking or adding to food in small quantities)
• confectionery (not appropriate for promotion)
• drinks (not appropriate for promotion)

The main points from the NPPM on the nutritional composition of foods include:

• confectionery and sweet snacks should not be marketed as suitable for babies and young children up to 36 months
• fruit drinks and juices and sweetened cow’s milk or milk alternatives should not be marketed as suitable for babies and young children up to 36 months
• savoury snacks and finger foods with greater than 15% energy from total sugars should not be marketed as suitable for babies and young children up to 36 months
• added sugars and other sweetening agents should not be used in foods for babies and young children up to 36 months
• the amount of processed or concentrated 100% fruit (pureed or dried) should be limited as an ingredient in meals
• the maximum permitted sodium content for commercial baby food should be reduced

Recommendations made for food producers include:

• produce more vegetable-based and savoury foods than fruit-based and sweet foods
• refrain from masking the flavour of vegetables
• produce more single-flavour blended foods
• produce fewer highly blended foods
• reduce the total sugar content of foods
• reduce the free sugar content of foods
• use no added sugars or sweetening agents
• avoid producing treats or desserts

The technical document ‘NPPM: supporting appropriate promotion of food products for infants and young children 6 to 36 months’ also sets promotional (labelling and marketing) recommendations, which include:

• minimum age recommendation of 6 months and products must not encourage early food introduction
• maximum age recommendation of 12 months for pureed foods
• front of pack indicator labels for high total sugar content: more than 30% energy in fruit or vegetable purees, desserts and dry fruit snacks and more than 40% energy in dairy foods
• product name indicates contents in descending order and does not hide sweet tastes or high fruit content
• ingredient list states proportion (%) of added water or stock, fruit content and traditional protein source
• packaging with a spout should state clearly that contents should be decanted and not directly sucked
• remove most compositional (nutritional), health and marketing claims
• include relevant statements to protect and promote breastfeeding

The guidance also notes that in order to be effective and clearly distinguish food products for babies and young children from other commercially available foods for older children, other products for older children should be clearly labelled as suitable from 3 years of age.

This particularly applies to snack foods with total energy from sugar greater than 15% or other breakfast or dessert foods with high sugar content that are likely to be given to younger children.

Annex 4: methodology and examples

Example calculations

Businesses can use the nutrition information for a product to calculate whether it is compliant with the:

• total sugars guideline for finger foods and snacks
• salt and sodium guidelines for all foods except the ‘fruit and vegetable meals’ category

Details are provided below of the calculations used.

Calculation for compliance against the total sugars guideline

To calculate whether a product complies with the total sugars guideline, use the following equation.

Percentage energy provided by sugar = 100 × (energy provided from sugar per 100g ÷ total energy content of food per 100g)

This applies to the finger foods and snacks categories with:

• less than 10% of energy from total sugar for sweet or savoury finger foods and snacks
• less than 25% of energy from total sugar for fruit and vegetable-based finger foods and snacks

Calculation for compliance against the salt guideline

To calculate whether a product complies with the salt guidelines(which applies to all foods except the ‘fruit and vegetable meals’ category), use the following equation.

Sodium content per 100 kcal = 100 × (sodium content of food (mg) per 100g ÷ total energy content of food per 100g)

This applies to food products where cheese is mentioned in the front of pack name and the sodium guideline is less than 100mg per 100 kcal. It also applies to all other products where the sodium guideline is less than 60mg per 100 kcal.

Example calculation for finger foods and snacks

The nutrition information below is for a savoury finger food or snack product.

Table 16: example nutrition information for a finger food or snack product

Nutrition information	Per 100g
Energy (kcal)	441
Protein (g)	9.2
Carbohydrates (g)	67.7
Sugar (g)	3.8
Fat (g)	14
Saturates (g)	2.2
Fibre (g)	3.6
Sodium (g)	0.14

Calculate compliance with the total sugars guideline for a finger food or snack product

The following steps outline how to calculate compliance with the total sugars guideline for a finger food or snack product.

1. Calculate the energy (kcal) provided by sugar.

2. Use that figure in the following equation: total sugar content (g) per 100g × 4 = energy provided by sugar. To note, 1g sugar provides about 4 kcal for the purpose of food labelling.

3. Using the example nutrition information above, the answer is 3.8 × 4 = 15.2 kcal.

4. Calculate the percentage of energy provided by sugar.

5. Use that figure in the following equation: 100 × (energy provided from sugar per 100g ÷ total energy content of food per 100g) = percentage energy provided by sugar.

6. Using the example nutrition information above, the answer is 100 × (15.2 ÷ 441) = 3.4% of energy content of food provided by sugar.

The example product provides less than 10% energy from sugar and complies with this guideline.

Calculate compliance with the salt guideline for a finger food or snack product

The following steps outline how to calculate compliance with the salt guideline for a finger food or snack product.

1. Calculate the sodium content per 100 kcal.

2. Use that figure in the following equation: 100 × (sodium content of food (mg) per 100g ÷ total energy content of food per 100g) = sodium content per 100 kcal.

3. Using the example nutrition information above, the answer is 100 x (140 ÷ 441) = 31.7mg sodium per 100 kcal.

The example product contains less than 60mg sodium per 100 kcal and complies with this guideline.