EU faces urgent call for stricter young child formula regulation to ensure proper nutrition

There is a lack of clear European Union (EU) regulations for Young Child Formula (YCF) that puts the nutritional health of toddlers at risk, warn industry groups. The EU has strict rules for infant formula, but it treats YCF for children aged one to three as a general food product.

Nutrition Insight speaks to Specialised Nutrition Europe (SNE) and the European Dairy Association (EDA), which are urging the European Commission (EC) to align EU legislation with the updated Codex Standard, the minimum level of protective measures of an international benchmark for YCF composition. 

The organizations warn that without EU legislation updates on YCF, products with high sugar and low nutrients can saturate the market and harm children’s growth. Such products may cause deficiencies in iron, vitamin D, iodine, and omega-3 fatty acids.

Why does the EU have weaker rules?

SNE’s secretary general, Beat Späth, explains that the EU often takes stricter measures than the Codex Standards, but in the case of YCF, it has weaker regulations.

“For the time being, the EC does not appear to see a need to differentiate between young children’s and adults’ nutritional needs. For instance, in this age group, the legislator has recognized the need for specific protection on food safety in the EU legislation on contaminants, and specific maximum levels are set for the YCF category.”

“However, despite the aforementioned recognition of young children’s vulnerability, the EU legislation currently persists in treating young child formula as a general food. Currently, the nutritional component of these products has to apply inappropriate adult Reference Intakes (nutritional reference values), which are inappropriate for young children.”

He warns that as a result, young children may be the target of products with inappropriate compositions, such as beverages with high sugar content or insufficient nutrient levels.

Späth explains that this is why SNE is urging regulation on nutritional composition and labeling requirements for YCF to protect this young consumer group.

The EU has strict rules for infant formula, but it treats YCF for children aged one to three as a general food product.Mitigating health risks

SNE president Marie France Pagerey outlines the risks for children due to the current lack of regulation.

“In the absence of a regulatory framework for this product category [YCF], the sector is applying the Nutrient Reference Values of other regulations, such as the general framework of EU food law or Regulation (EU) 2016/127, which is more relevant given the target audience, closer to infants than adults.”

“The risks that European young children face would be related to their nutritional status. Due to their three times smaller stomachs, young children require more nutrient-dense foods throughout the day than adults.”

She cites the European Food Safety Authority’s (EFSA) conclusion that young EU children often consume too much protein and too little iodine, iron, omega-3 fatty acids, and vitamin D. 

“We need to remember that young children are neither mini adults nor maxi babies — they have their own nutritional needs. For instance, a high protein intake is not recommended since it may increase the risk of being overweight in later life,” underlines Pagerey.

“Therefore, we reiterate that YCF should be recognized as a specific product category and regulated to properly inform caregivers about the nutritional value of the products they are feeding their families.”

European Food Safety Authority finds that young EU children often consume too much protein and too little iodine, iron, omega-3 fatty acids, and vitamin D.Policy priority battles

Despite regulators facing competing policies, Späth believes YCF should be a priority, especially since the UN Food and Agriculture Organization (FAO) recently updated the Codex Alimentarius Standard for Follow-Up Formula for Older Infants and Product for Young Children.

He adds that the current lack of regulation benefits no one. “YCF is not regulated for a vulnerable population group, plus, there is no harmonization across member states, and the lack of a clear, specific EU regulatory framework for Young Child Formula could endanger the trust and popularity of the European YCF products in third countries.”

Because of the age range, Späth claims that the EU does not apply the same regulations to YCF as to infant formula.

“The EC does not differentiate between the nutritional requirements of young children and adults because it bases its rationale on an EFSA opinion2. Which states: ‘No unique role’ or ‘not a necessity to satisfy the nutritional requirements of young children.’” 

“However, EFSA, in the same opinion, is recognized as definitely ‘one of the means to increase n-3 polyunsaturated fatty acids, iron, vitamin D and iodine intakes in young children in the EU.’”

Pagerey and Späth recommend that the EC should start with the newly revised Codex Standard as a basis for discussion.Späth urges the need to realize that busy family schedules, food refusal, and fear of new foods can hinder children from getting a balanced diet. He thinks YCF can mitigate these issues.

Urgent EU leadership 

Pagerey believes the EU should continue to be a global example of food policies and regulation. 

She cites the World Health Organization to explain that healthy eating and proper health are crucial for a child’s optimal development during the first three years of life. For example, a toddler typically grows 20 cm and gains 4 kg in just two years. “During these years of life, an exponential increase in connections between nerve cells is seen and complex neural networks are built.”

“So, we should make sure that all YCF legally placed on the EU market is appropriately formulated based on internationally agreed-upon latest science as one option to help young children to reduce the inadequacies of important nutrients while also limiting excessive protein intake.”

“We recommend that the EC should start with the newly revised Codex Standard as a basis for discussion. In addition, collaboration with different stakeholders, including health authorities, medical societies, and operators, would be essential to establishing a suitable framework for the health of young children,” Pagerey concludes.