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Welcome to the December edition of our newsletter. This month we have lots of varied news items to share with you. But before we get to the news we have one important question as follows:

Can you help support FSNT?

First Steps Nutrition Trust is a registered charity and has been fortunate to be funded by a small number of generous individuals and grants over the past 13 years. As we are all aware, the world around us is changing rapidly, and to continue our work beyond next year, we need to urgently seek new sources of funding. Our principles of only accepting funding from conflict-of-interest free sources won’t be changing, but can you introduce us to any organisations, trusts and foundations, grant-makers or individuals that may be able to support our work? Please contact our Director, Vicky Sibson (vicky@firststepsnutrition.org), if you are able to make any suggestions or introductions, or if you are interested and willing to support First Steps yourself. Thank you.

News On Healthy Start:
Infant milk news
BFLG-UK news We wish you a happy Christmas and New Year and will be in touch with our first newsletter of 2024 in early February. In the meantime, feel free to be in touch.

Happy reading!

News

New FAQs: Ultra-Processed Foods

We supported colleagues at the Soil Association to produce this briefing answering frequently asked questions related to UPFs, including:
  • What is the NOVA classification?
  • How do I identify UPFs?
  • Are all UPFs equally harmful?
  • What should we do to reduce our UPF consumption? Do we need to eliminate UPFs from our diets?
  • Why, given the evidence, is the UPF concept being questioned by certain quarters?
We hope you find it useful in your work.
 
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New paper: Snacking practices from infancy to adolescence
 

This paper was published in August and reports on two investigations of food practices amongst parents across the income spectrum in England, conducted by the Centre for Food Policy at City University between 2020 and 2022. Utilising a longitudinal approach, researchers conducted three rounds of in-depth interviews over one year, providing data on how snacking practices develop over time. The first study involved 60 parents interviewed when their infants reached 6, 12 and 18 months, while the second study engaged 62 parents with children aged 2 to 18 years.

The research shows the multiple ways ultra-processed snacks often high in fat, sugar, and salt (HFSS) become normalised in children’s diets from infancy onwards, and how low-income families lack the resources to mitigate this and foster healthier habits in children.

A recurring theme in the research was the role of ultra-processed snacks as rewards and treats for families across income brackets, including commercial infant and toddler snacks misleadingly marketed as healthy and trusted by parents.

The study’s authors call for policy intervention to reduce the appeal and ubiquity of ultra-processed and HFSS snacks, and the need for strategies which generate enjoyment and availability of healthy snacks such as fruit and vegetables. These include expanding access to the Healthy Start scheme, guaranteeing a living wage that covers the cost of a healthy diet, sensory fruit and vegetable education and greater regulation of misleading front-of-pack health and nutrition claims as well as the use of colours, imagery and brand characters which appeal to children.
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Healthy Start:
New resources for frontline staff
Move More, Eat Well was launched in 2020 to support and enable those that live and work across Cardiff and the Vale of Glamorgan to move more and to eat well. They have recently launched an accessible online resource outlining Food Benefits for frontline staff to raise awareness of the food related benefits available to families on a low income.

This includes a section on Healthy Start, which presents the importance of the scheme, outlines who is eligible and explains how individuals can apply.

The online resource can be accessed free of charge here. Please note that you will need to register on the website and will be sent a password to access the information.
Also, if you are not already aware we offer an Eating Well guide to help families to get the most out of the Healthy Start scheme in England, Wales and Northern Ireland, or the Best Start Foods scheme in Scotland. The guide provides a range of healthy family recipes using ingredients that can be bought through the Healthy Start or Best Start Foods schemes and shows how these can feed the whole family. The guide can be downloaded for free here.
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New paper: Evaluation of the Healthy Start voucher scheme
The National Institute for Health and Care research published an evaluation of the Healthy Start scheme earlier this month, looking at its effectiveness on infant, child and maternal outcomes and the lived experiences of low-income beneficiary women.

Routinely collected health datasets and a nested qualitative study of low-income women were used to compare women receiving the Healthy Start voucher, with two control groups: those eligible and not claiming the Healthy Start voucher and those nearly eligible (as shown in the diagram). At the time of data collection, which began in 2015, those eligible were receiving £3.10 per week to spend on liquid milk, formula milk, fruit, and vegetables (mothers with a child aged under 1 year received £6.20). In April 2021, the scheme increased in value to £4.25 per week (or £8.50 for families with infants under 1 year of age), although it is important to note that this is a decrease in real monetary terms due to food price inflation.
Quantitative results showed that there was no difference in vitamin use between those claiming Healthy Start vouchers and those not. The effect of Healthy Start vouchers on breastfeeding were inconclusive. The authors proposed that the value of the vouchers may be insufficient to impact on wider factors that determine whether women with low incomes can offer their children a healthy diet.

Key findings from qualitative data include that:
  • Participants were not made aware of Healthy Start until their baby was born, and so did not access the scheme during pregnancy.
  • Conversations with health professionals about nutrition were infrequent or unhelpfully timed.
  • The vitamin component of the scheme was used less than the vouchers; participants were confused about the need for vitamins and/or where vitamin vouchers could be redeemed.
  • Women wanted to provide a healthy diet for their families, but living on a low income poses a range of challenges in being able to achieve this. Women had limited knowledge of the use of financial services and benefit maximisation advice and support available to them.
  • The monetary value of the scheme was described by participants as being too low to make a difference in being able to achieve a healthy diet. However, the scheme was still valued.
  • Healthy Start vouchers were not mentioned in decision-making around breastfeeding. Women’s choice to breast or formula feed was based on a range of other factors, such as support to breastfeed and assumptions and expectations of health professionals. Although, results did indicate that use of the vouchers does not discourage breastfeeding in women with low incomes.
The authors conclude that there are inherent structural limitations of Healthy Start, including access and eligibility, which limit the possible effectiveness of the scheme. They propose that these could be addressed by increasing awareness of the scheme, increasing access to vitamins during pregnancy and consideration of the increased monetary value of the allowance. The need for further research to understand the barriers to providing a healthy diet is also highlighted, including the need to understand the optimal timing for provision for nutrition advice and support, modelling to understand if an increased value of the vouchers could have more of an impact on child and maternal health outcomes and research to determine what extra support could be offered alongside the Healthy start allowance.

First Steps Nutrition Trust are members of the Healthy Start Working Group and endorse the Healthy Start Working Group Policy Positions, which include asks for: expanded eligibility, an increase in the value of the allowance, improved accessibility and the provision of information, guidance and support to beneficiaries on breastfeeding and eating diets based on minimally processed foods.
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New survey: Food access among families with No Recourse to Public Funds

In 2021, the Department of Health and Social Care agreed to temporarily extend the Healthy Start scheme to British children who would otherwise be eligible for the scheme but whose families are excluded from claiming public funds. A consultation on whether to permanently extend the scheme to households with no recourse to public funds (NRPF) was promised in 2022 but has not yet taken place. Instead, a recent parliamentary question to the under Secretary of State for Health and Social care revealed that, since the extension of the scheme, 1300 application requests have been made, but have resulted in just 110 successful applications.

Sustain conducted a survey to understand the experience of families on low incomes with NRPF in accessing nutritious food during pregnancy and for their babies and young children. Nearly 200 individuals were surveyed, including front line health service workers and representatives from community organisations, between September and October.

The survey found that families with no recourse to public funds are facing destitution, worsened mental health and multiple challenges accessing food due to the rising cost of food. Meanwhile frontline support services are unable to meet level of need. The survey, which includes personal testimonies, can be found here.

Informed by the desperate findings of this survey, First Steps Nutrition Trust have signed an open letter, alongside 147 signatories NGOs, local government institutions, charities and medical bodies to Andrea Leadsom MP, the new Parliamentary Under-Secretary for Health and Social Care, calling for children from migrant and refugee households on low incomes with no recourse to public funds (NRPF) to be given permanent access to the Healthy Start Scheme.
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Updated Eating Well Guides

We have updated our Eating well: Snacks for 1- to under-5-year-olds and Eating well: Recipes book to reflect current grocery prices, after the significant price increases experienced since these resources were first published. These guides provide practical guidance on how to meet nutrient recommendations from pregnancy to age 5, by eating affordable diets based on unprocessed and minimally processed foods.
All of our resources are free to download from here and some are available to purchase as hard copies via this link.
You may also find this infographic helpful, which outlines ways in which families may be able to cut their food costs without negatively impacting the nutritional quality of their diets.
You may also find this infographic helpful, which outlines ways in which families may be able to cut their food costs without negatively impacting the nutritional quality of their diets.
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New guidance: ‘Feeding Baby at Nursery’

In September, the Early Start Group published this new guidance for Early Years Settings to ensure they are doing what is necessary to enable and support optimal, safe and appropriate infant feeding practices for babies in their care. It covers content from current infant feeding guidelines, how to make an infant feeding policy, breastfeeding welcome posters, safer formula milk preparation, and introduction to solids.

We hope this excellent practical resource will be of use to readers working nurseries and other early years settings. 
 
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Infant milk news

First Steps response to the Competition and Markets Authority report on price inflation and competition in the infant formula market

The CMA report presents the results of an investigation in to the pricing and marketing of 10 product categories in the context of high price inflation, one of which one is infant formula. Their analysis of the infant formula market relies on our data on the cost of formula and feeding babies, which we have been gathering and reporting on since 2018. It confirms two important issues we’ve been highlighting for some time, that need to be addressed, urgently:
  • Profiteering by formula brands. Infant formula prices have risen rapidly through the cost of living crisis, from an already high base, while companies have been protecting and even increasing their already substantial profit margins (which stand at between 15 and 30%)
  • The massive range in prices of what are nutritionally comparable products; in particular between the only own-brand infant formula available (Aldi’s Mamia) and branded infant formulas
The CMA did not make any formal recommendations for addressing these issues, and instead are about to undertake a more detailed investigation in to the infant formula market, which we will feed in to: The CMA will now undertake further work to better understand consumer behaviour (including what influences choice) and barriers to entry and expansion for baby formula manufacturers and consider whether any changes to the regulatory framework could help the market work better”.

While we appreciate that this investigation may be useful to inform certain actions, our view is that the Government could and should be taking other actions NOW to ensure families can feed their babies. We are now actively promoting these 4 recommendations to Government to:

1. Establish pricing policies and practices to ensure infant formula is provided at lower prices on a long term basis, e.g. through a price cap (NB our view on the suggestion by some that weakening current legal restrictions on formula marketing would make infant formula more accessible is that this is NOT appropriate; it does not address the cause of the high prices and does not acknowledge the vital nature of infant formula as a food stuff for vulnerable babies (see more in this statement of the BFLG).

2. Run a public health messaging campaign around the nutritional equivalence of all first infant formula, to better inform parents/carers so that they may feel more comfortable to switch to cheaper products where available.

3. Better enforce existing legislation designed to prevent inappropriate marketing of formula milks which protects breastfeeding AND safe and appropriate formula feeding (AND in the medium term strengthen in line with the Code).

4. Improve Healthy Start, including through increasing the cash allowance in line with food inflation (to enable purchase of infant formula where needed, but also fruits, vegetables, milk and other healthy foods) and increasing coverage by switching to autoenrollment and extending to those with no recourse to public funds (see the full policy asks of the Healthy Start Working Group here).

You can read some of the media reports about the CMA investigation here and here, and hear our Director talk about the issue on LBC radio here (from 12 mins in).
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Update on infant milk costs
Our report ‘Costs of infant formula, follow-on formula and milks marketed as foods for special medical purposes available over the counter in the UK’ has been updated and can be accessed at infantmilkinfo.org/costs 

As ever, where babies are not breastfed or are partially breastfed, infant formula is suitable from birth and babies can drink it throughout their first year. Other types of formula milk including follow-on milks are not necessary.

In the UK, infant formula comes in different formats - powdered infant formula (PIF), powdered formula tablets and ready to feed (RTF) liquid format.  Infant formula is an expensive product that may be unaffordable for those on low incomes. The least expensive format is PIF which must be made up according to NHS guidelines as it is not sterile.
 
Since April 2023, the relentless escalation in the cost of infant formula appears to have stabilised – our latest data suggests that the average cost of (PIF) has risen by only 0.1% since April 2023 (see Graph 1 from our report “Cost of powdered infant formulas in the UK: How have they changed since January 2020?"). Although this is encouraging, infant formula remains a very expensive product and the Competition and Markets Authority investigation results (reported on above) indicate that recent price rises in branded products may be unwarranted and – in our opinion - should be reversed.
Graph 1. Unit cost of all brands cows’ milk based powdered infant formula
Key findings:

It may be surprising for some that Danone have reduced the cost of their Aptamil Advanced, Aptamil and Cow & Gate ‘starter packs’ of ready to feed infant formula by as much as 17%. Given how common brand loyalty is among parents/carers, it may be worthwhile sharing that  this reduction has not followed through to the brand equivalent PIF which, in the case of Aptamil Advanced, is the most expensive cows’ milk based PIF on the market.

The least expensive standard sized pack of PIF is Aldi Mamia at £9.39 a can (14p/100ml) but Cow & Gate infant milk powder in a 2 x 600g Big Pack format which costs £12 (13p/100ml) is generally the least expensive way to buy infant formula from high street retailers, however this requires families to pay a greater up-front cost, and these packs are not available in all retail contexts.

There can be some significant differences in cost between the same brand of infant formula or follow-on formula when bought from different high street retailers. To reflect this and to support healthcare professionals to help families struggling to afford infant formula to assess price differences between comparable products and make choices between product types and brands, we have included some new tables in our cost report. Table 7 compares the cost of the least expensive branded PIFs and Aldi's Mamia across high street and budget retailers and table 8 makes the same comparison for the least expensive branded follow-on formulas.

Across the retailers we have looked at:
  • Aldi Mamia remains the least expensive infant formula powder in a standard size format
  • Cow & Gate infant milk powder in a 2 x 600g Big Pack format is generally the least expensive way to buy infant formula
  • The price for Cow & Gate infant milk in a 2 x 600g Big Pack varies between retailers from £12.00 at Boots (13p/100ml) and £12.50 at Asda, Morrisons, Tesco and Sainsburys (14p/per 100ml)
Brand loyalty is common but unnecessary when it comes to feeding babies. It is important to re-iterate to parents that it’s OK to switch formula brands as all infant formula in the UK are safe and suitable for babies from birth and throughout the first year. It may take baby some time to adjust, and any new infant formula offered can be introduced all at once in a full feed or gradually across feeds – whichever works best for parents and their babies. 
UK legislation permits promotional offers on follow-on formula and promotions differ between retailers and are valid only for a short period of time. For these reasons, we generally report the prices for follow-on formula before any promotional offers have been applied. We have however included a new table that shows the promotional offers available in November at the time the data was collected. Table 9 shows that despite these savings, big packs of Cow & Gate follow-on milk remain the least expensive way to buy follow-on formula.

It is important to remind parents/carers that:
  • Follow-on formula marketed as suitable from 6-12 months of age offers no extra nutritional benefits for young children and is not recommended by the NHS
  • When made up, powdered follow-on formula may be marginally more expensive than same brand PIF when not bought at a promotional price (see table 6 in our updated report)
  • Transient promotional offers on follow-on formula are not a robust basis on which to base infant feeding decisions when budgets are limited
For infant milk information please visit our website www.infantmilkinfo.org. If you can’t find what you’re looking for please email Susan@firststepsnutrition.org
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Baby Feeding Law Group UK News 

New: WHO Guidance on regulatory measures aimed at restricting digital marketing of breast-milk substitutes

On 16 November 2023, the World Health Organization (WHO) published its Guidance on regulatory measures aimed at restricting digital marketing of breast-milk substitutes. The purpose of this guidance is to provide support to WHO Member States for developing and applying regulatory measures, by applying the Code to digital environments. The guidance provides 11 Recommendations that can be used by Member States as they work to develop and apply these regulatory measures. The BFLG-UK will make use of these recommendations in their advocacy with DHSC to strengthen regulations to protect infant feeding.
 
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Revised position statement in infant formula marketing legislation amidst the cost-of-living crisis

During November 2023, some revisions were made to the BFLG-UK position statement on Legal restrictions on the marketing of commercial milk formulas and the cost-of-living crisis. The edits were made to ensure that the statement reflected our updated understanding and interpretation of current matters, including the challenges regarding the accrual and redemption of loyalty points/rewards schemes for infant formula. This statement remains highly relevant given the reaction to the CMA report, which includes calls for weakening of legal restrictions on formula promotion.
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For more information about the Baby Feeding Law Group UK please visit our website Baby Feeding Law Group UK (bflg-uk.org) and sign up to our twitter account @BflgUk. You can also email katie@firststepsnutrition.org
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