The calls come one year after the Food and Agriculture Organization and World Health Organization published the revised Codex Alimentarius (Latin for ‘Food Code’), which made specific recommendations regarding the regulation of young children’s products.
At the time, SNE published a statement urging the European Commission to implement the updated standard into EU law, but its efforts have so far been fruitless.
“Since nothing has happened since last year, we are renewing the same call, this time together with our partners from the dairy industry,” said Beat Späth, SNE’s secretary general.
While progress is slower than expected, hope is not lost, according to Späth, who says EU stakeholders are starting to show “some interest” in regulating products for young children.
What is young child formula?
Young child formula, also known as toddler milk or growing-up milk, is specifically formulated to provide essential nutrients that are often insufficient in young children’s diets, such as iron, vitamin D and iodine.
It is designed to be consumed by one- to three-year-old children and differs from infant and follow-on formulas which are for children 12 months and under.
European research supports the benefits of young child formulas, with one study showing that French YCF consumers had higher intakes of ALA, iron and vitamin D, while Spanish research shows young children fed growing-up milk have 4.5 times more omega-3 fatty acids and three times more vitamin D.
However, while infant formulas are protected by stringent legislation, young child formulas are not, leaving the market open to products which lack close scrutiny.
“The role of proper nutrition for optimal development during the first three years of life cannot be overestimated,” SNE and EDA shared in a joint statement. “We strongly believe that young children would be fully protected if the composition and labelling was specifically regulated.”
The unique nutritional needs of young children
The 2024 Codex Standard contains recommendations on the nutritional compositional, quality, safety and labeling (and more) of products for young children.
While it is not legally binding, Codex Standards typically reflect the minimum level of protective measures on which the international community can agree. The EU often adopts stricter legislation, but in this case, the law is much more relaxed.
SNE and EDA say that the absence of such legal requirements is not consistent with the international framework and general principles of EU law, and this is putting young children’s health at risk.
“As long as the composition of young child formula is not regulated in the EU, products with inappropriate compositions targeting young children—such as drinks with high sugar content or inadequate levels of nutrients —may be placed on the market,” Späth said.
“Young children are not ‘mini-adults’ but a vulnerable group with specific nutritional needs. It is therefore crucial to regulate the composition of young child formula.”
Avoiding legal uncertainty
In addition to the health implications for young children, the absence of harmonized legal composition requirements for young child formula has led to a fragmentation of the EU market, Späth added.
Children’s formula product recipes and labels often have to be adapted to the different interpretations and requirements of Member States. SNE and EDA say this creates legal uncertainty and causes an unfavorable market for businesses.
The industry bodies therefore want to see tighter regulation for young child formula to facilitate easier compliance for dairy suppliers and manufacturers, reducing the complexity of meeting different standards in different regions.
“[New laws] would offer legal certainty for food business operators and clarity for national authorities regarding the free movements of goods within Member States, as well as potentially influencing other countries to look to the European Union as a model,” the bodies said.
