Following the consultation last summer (in to which we fed this response), the Scientific Advisory Committee on Nutrition (SACN) published their long awaited guidance on Feeding young children aged 1-5 years earlier this month. It complements Feeding in the First Year of Life, published in 2018 and includes a much-needed evaluation of the available evidence on young children’s diets, albeit limited to systematic reviews. It provides a wide range of recommendations for research, policy and to a lesser extent, practice.

In our view, some of the recommendations in the report are not easily translated into clear practical advice (e.g., ’give this’, ‘avoid this’) and to provide this we will need to wait for clarification from SACN and/or the interpretation of the Department of Health and Social Care (DHSC) when they update public health guidance on the NHS webpages. These include the recommendations which state that formula milks are “not required” by children aged 1 to 5 years and that commercially manufactured foods and drinks marketed specifically for infants and young children are “not needed” to meet nutritional requirements. The key question for practice arising from these recommendations is whether these products should or should not be used in young children’s diets? 

In the meantime, below are some of the unequivocal recommendations which can inform your practice now [with our commentary in square brackets].

Between 1 to 2 years of age, children’s diets should continue to be gradually diversified in relation to foods, dietary flavours and textures. A flexible approach is recommended to the timing and extent of dietary diversification, taking into account the variability between young children in developmental attainment and the need to satisfy their individual nutritional requirements.

For children from around the age of 2 years, the dietary recommendations in the Eatwell Guide apply [noting that the images for the main food groups show mainly unprocessed and minimally processed foods], with the following exceptions: 

•    Milk or water, in addition to breast milk, should constitute the majority of drinks given to children aged 1 to 5 years [we read this to mean, avoid artificially sweetened drinks as well as sugar sweetened drinks, as listed below].

•    Pasteurised whole and semi-skimmed cows’ milk can be given as a main drink from age 1 year, as can goats’ and sheep’s milks [noting that the recommendation to use semi-skimmed milk is new, though practical guidance on when semi-skimmed would be preferable to whole milk would be useful].

•    Pasteurised skimmed and 1% cows’ milk should not be given as a main drink until 5 years of age. These lower-fat milks can be used in cooking.

•    Children aged 1 to 5 years should not be given rice drinks as they may contain too much arsenic.

•    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. 

•    Foods (including snacks) that are energy dense and high in saturated fat, salt or free sugars should be limited in children aged 1 to 5 years in line with current UK dietary recommendations.

•    Salt should not be added to foods given to children aged 1 to 5 years. 

Children aged 1 to 5 years should be presented with unfamiliar vegetables on multiple occasions (as many as 8 to 10 times or more for each vegetable) to help develop and support their regular consumption.

Deliberate exclusion of peanut or hen’s egg (and foods containing these) beyond 12 months of age may increase the risk of allergy to the same foods. Importantly, once introduced, these foods should continue to be consumed as part of the child’s usual diet in order to minimise the risk of allergy to peanut or hen’s egg developing after initial exposure.

Children aged 1 to 5 years should continue to be offered a wide range of foods that are good sources of iron. They do not require iron supplements unless advised by a health professional.

Children aged 1 to 5 years should be given a daily supplement of 10μg (400 IU) vitamin D and 233μg vitamin A unless, contrary to recommendations, they are consuming more than 500ml of formula milk a day (Vitamin C supplements are not necessary for the general population. However, there is no evidence that taking vitamin C supplements at the current recommended level of supplementation has any adverse effects).

In addition, it is pertinent to note that the guidelines recommend that: government considers a range of strategies and actions to support and promote continuation of breastfeeding into the second year of life.

And among the recommendations for monitoring: intakes of low and non-caloric sweeteners among children aged 1 to 5 years.

Once we are clear on how to interpret all the recommendations in the report, we will be updating our Eating Well guides to ensure they align with the latest public health guidance. We will keep you informed in future newsletters. 

NEW SACN STATEMENT: processed foods and health 

In the Autumn of 2022, the UK government requested SACN to examine the most recent research findings regarding the relationship between food processing and health. This request was made in response to a growing body of evidence that indicates a higher intake of Ultra-Processed Foods (UPF) is associated with adverse health effects, as outlined in our recent report. 

SACN issued a position statement on food processing and health on 11th July 2023. This position applies to the general population and so excludes infants and young children who have unique nutritional needs. We think this is a missed opportunity as what children eat in their first years of life sets the trajectory for lifelong health. 

Unsurprisingly, SACN found that “most systematic reviews reported that increased consumption of processed food (specifically UPF) was associated with an increased risk of the adverse health outcomes considered.” In our view, this overwhelming evidence base, which points towards the potential harmful effects of high levels of ultra-processed foods in the diets of infants and young children warrants a public health response. However, this is not SACN’s view. They state that “the evidence needs to be treated with caution” because of perceived limitations in the NOVA classification system, the potential for confounding and the possibility that the observed adverse associations with ultra-processed foods are covered by existing UK dietary recommendations. 

In order to establish a higher degree of certainty in evidence, SACN recommend gathering further evidence before updating public health guidance, missing the opportunity to take a precautionary approach in order to safeguard child health.

We are concerned that industry affiliations prevalent among the members of SACN might have unduly influenced the conclusions of this position (you can see more on this in the Soil Association’s blog post) and we plan to provide feedback on the report to SACN, which we will share in due course.

In the meantime our Eating Well Resources already address food processing, and show how it is possible to eat well in pregnancy, infancy and the early years by consuming diets based on nutrient-dense unprocessed and minimally processed foods, avoiding commercial baby and toddler foods. This approach aligns well with the images used on the Better Health Start for Life webpages around feeding babies and toddlers and with those in the EatWell guide which is applicable to children from the age of 2 and up, with some exceptions (see above, on SACN’s new guidance for feeding children aged 1-5 years). It is also consistent with SACN’s new recommendation that “commercially manufactured foods and drinks marketed specifically for infants and young children are not needed to meet nutritional requirements.”

The images below show minimally processed meals and foods suitable for infants and toddlers from:

FSNT Eating Well resources:

Better Health Start for Life (NHS) webpages:

NEW SACN RESPONSE: to WHO guidance on non-sugar sweeteners

Following the release of WHO guidance on the use of non-sugar sweeteners (NSS), SACN undertook a horizon scanning meeting in June 2022 and have proposed actions based on their interpretation of the evidence that “swapping sugar for sweeteners, alongside other positive changes to diet, is likely to be beneficial overall.” This means that SACN do not endorse the WHO guidance that NSS should not be used as a means of achieving weight control or reducing the risk of non-communicable diseases) (see more in our May newsletter).

We believe the actions proposed by SACN are not sufficiently precautionary, and do not support the promotion of optimal feeding practices during pregnancy and in the early years the following reasons:

-    The WHO systematic review and meta-analysis on the health effects of the use of non-sugar sweeteners suggest possible unfavourable effects of NSS consumption on birthweight and adiposity in offspring later in life.
-    Acceptable Daily Intakes for NSS by infants and young children are based on old and limited population data not including the UK.
-    Public health messaging around NSS and diets in pregnancy and the early years is not sufficiently clear or consistent. 
-    Initiatives like the NHS Food Scanner App actively promote products containing NSS, without any safeguards for parents or carers purchasing foods for infants and young children.
-    NDNS (National Diet and Nutrition Survey) data reveals potentially high levels of NSS intake among young children. Data from 2008-15 (pre-dating the Soft Drinks Industry Levy) shows that 65% of children aged 18 months to three years old drank a low-calorie (artificially sweetened) soft drink during the four-day recall period (and mean consumption was 330g/day, which is equivalent to one whole can of soft drink).
-    The focus on reducing intakes of high fat, salt, sugar (HFSS) foods and drinks may be leading to increased intake of NSS as products are reformulated. SACN note that “Evidence indicates that the Soft Drinks Industry Levy has resulted in significant sugar reduction in the UK soft drinks market.  However, this appears to reflect replacement of sugar with NSS, rather than development of new, unsweetened, drinks.”

We welcome SACN’s recommendation to the Food Standards Agency (FSA) to monitor UK population exposure to non-sugar sweeteners (noting, as above, that a recommendation in the new guidance for feeding 1–5-year-olds includes monitoring of intakes among this age group) and view this as overdue and urgent. 

Aspartame

This month the International Agency for Research on Cancer (IARC) and the WHO and FAO Joint Expert Committee on Food Additives (JECFA) classified the sweetener aspartame as “possibly carcinogenic to humans”, but Acceptable Daily Intakes remain unchanged. The approach to foods and drinks containing aspartame with respect to the early years should be as for other sweeteners, as outlined below. 

In terms of implications for practice, infants up to 12 months of age should be given only breastmilk/infant formula, and from 6 months, water. For children aged 1-5 years, milk or water, in addition to breast milk, should constitute the majority of drinks given. As above, we read this to mean, avoid artificially sweetened drinks as well as sugar sweetened drinks. Commercial infant and toddler foods are not permitted to include artificial sweeteners. Public health advice on the use of foods containing artificial sweeteners for infants and young children is unclear (and we are seeking clarity). However, such foods would be ultra-processed, so in our view should not feature prominently in diets which are based on unprocessed and minimally processed foods.   

More information on sweeteners relevant to the early years can be found in our 2019 report on sweeteners in the diets of young children in the UK.

Lay Member role with the Scientific Advisory Committee on Nutrition

SACN is a UK-wide advisory committee set up to provide advice to the UK government on nutrition related matters. The committee is made up of specialists from a range of relevant disciplines and includes lay members, who are expected to contribute robust views representing the interests of the wider public. The role involves a time commitment of up to approximately 10 days per year, including three meetings per year.

SACN are currently looking for a lay member and are looking for applications from members of the public. Applications for the role can be found here: Working for DHSC - Department of Health and Social Care - GOV.UK . The closing date for applications is midday on 8 September 2023.

NEW PODCAST: Ultra-processed diets in the early years

At the end of June, our Director, Dr Vicky Sibson and Nutritionist, Rachel Childs, were interviewed for the Food Active podcast. You can listen to the (28 minute) recording through Spotify on Ultra processed diets in the early years – unpacking the concerns. Some of the key findings and recommendations from our recent report on Ultra-Processed Foods marketed for infants and young children in the UK were described and discussed. 

NEW WHO and UNICEF PROGRAMME guidance

Taking action to protect children from the harmful impact of food marketing: A child rights-based approach was published by WHO and UNICEF on 7 July 2023, and provides a practical guide for governments and partners with steps to introduce legal measures to restrict food marketing that are fit for purpose. It is intended to complement the WHO’s recent Guideline on Policies to protect children from the harmful impact of food marketing (see below) as well as UNICEF’s 2018 A child rights-based approach to food marketing: a guide for policy makers. This new document provides an evidence update, a framing of food marketing as a child rights concern and a 4-stage process for the policy cycle involved in restricting food marketing using a child rights-based approach. 

The WHO Nutrition Guidance Expert Advisory Group Subgroup on Policy Actions launched Policies to protect children from the harmful impact of food marketing on 3 July 2023. This builds on the 2010 WHO Set of recommendations on the marketing of foods and non-alcoholic beverages to children. This new guideline includes a comprehensive review of latest evidence on the extent of, practices used in and effects of food marketing to children. A WHO good practice statement is made that “Children of all ages should be protected from marketing of foods that are high in saturated fatty acids, trans-fatty acids, free sugars and/or salt” through the implementation of policies to restrict the marketing of unhealthy foods (classified using appropriate nutrient profiling models) to children. 

Infant Milk News

One manufacturer promises a price freeze on infant milk value packs for this year

As the rising cost of commercial milk formula gains attention, manufacturers are finding ways to tackle the issue while staying competitive in the market. Danone have responded to rising costs by increasing the prices of the majority of their products whilst also introducing value packs of their Aptamil and Cow & Gate brands. The value packs use the same formulation as the standard packs but in larger unit volumes, using different, and presumably less expensive bag in a box packaging. This helps them to maintain their market share by offering parents a more ‘wallet-friendly’ price point for some existing formulations. Cow & Gate value packs (1200g) of infant formula currently cost £12.00, equivalent to 13p/100ml made up formula whilst the standard packs (800g) cost £10.50, equivalent to 17p/100ml made up formula. Danone have also committed to freezing the price of their value packs until the end of the year. We regularly monitor the price of infant milks in the UK, you can read our latest April 2023 cost report here. We expect to publish an update in August. 

We are continuing our advocacy to ensure those families who need it can access infant formula as per the asks in our cost of living briefing. 

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

Baby Feeding Law Group UK news

Retained EU Law (REUL) Act published 

Following months of deliberation and considerations from the Houses of Lords and Commons respectively, the Retained EU Law (Revocation and Reform) Bill (REUL Bill) has been given Royal Assent and was passed into an Act, the Retained EU Law (Revocation and Reform) Act 2023 on 29 June 2023. One purpose of this Act is to revoke certain retained EU law through the sunsetting of legislation. All legislation to be “sunsetted” (revoked) is listed in Schedule 1 of the Act, but of note, none of the relevant legislation relating to the composition, labelling, and marketing of foods for infants and young children is included in this list. This means that all legislation relating to foods for infants and young children will be retained. Government departments will now create secondary legislation where necessary to effect changes and these will be consulted on in due course. 

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

Forthcoming

Webinar series: Breastfeeding not on the agenda 

The Breastfeeding webinar series has started, with 3 webinars having taken place already (recordings available here and also on a YouTube channel) and 6 webinars still to come (see here for the lineup). This forms part of the launch of a social media call to action, including the screening of a documentary, Breastfeeding: Not on the Agenda and a petition (which can be signed here) to Embed Breastfeeding in the curriculum, family-friendly rights and the Net Zero 2050 Target. 

Breastival

Breastival 2023 is taking place in person on Saturday 5th August and online from 1st-7th August 2023. Breastival is a unique, award-winning festival which aims to support, normalise and celebrate breastfeeding as part of everyday life in Northern Ireland and across Ireland. You can register for tickets here.

Reminder: World Breastfeeding Week: 1-7 August 2023

World Breastfeeding Week (WBW) takes place annually from 1-7 August and this year’s theme is “Enabling Breastfeeding: Making a difference for working parents”. The comprehensive (28-page) Action Folder is now available.

The Global Breastfeeding Collective is hosting a webinar, Let’s Make Breastfeeding Work on Thursday 3 August, from 13:00-14:30 UK time. The purpose of the webinar is to:

• Hear from mothers about experiences combining work and breastfeeding

• Get new ideas from countries who have used evidence-based policies to make breastfeeding work

• Learn about updated maternity leave recommendations 

• Find resources to support advocacy

You can register for the webinar here.