Young Children are not Mini-Adults: Why Young Child Formula should be regulated in the EU

Consumption of Young Child Formula remains unregulated in Europe as parents seek to improve the intake of nutrients for their children, but it is time for this to change writes Beat Späth, Secretary-General of Specialised Nutrition Europe

By Beat Späth

Beat Späth is the Secretary-General of Specialised Nutrition Europe.

04 Apr 2024

In Europe, young children may consume some nutrients in either excessive or insufficient amounts: in comparison to an adult, young children need higher amounts of several nutrients per kg of body weight (e.g., iron, vitamin D, omega-3 essential fatty acids or iodine) and more nutrient-dense foods throughout the day. In reality, these nutritional needs are unlikely to be satisfied through a regular diet alone. As recognised by the European Food Safety Authority (EFSA), consumption of Young Child Formula can be used as part of the strategy to increase the intake of nutrients that are often insufficient in young children’s diets. Unfortunately, this product composition has not yet been regulated at EU level.  

What is Young Child Formula? 

Young Child Formula – also called ‘growing-up milk’ – is tailor-made to support the nutritional needs of young children (from 1-3 years). It differs from both infant formula (for infants from 0-6 months) and follow-on formula (for infants from 6-12 months).  

For children between 1 and 3 years old, Young Child Formula is one of the most practical and available food sources to increase the intake of essential nutrients such as omega-3 essential fatty acids, vitamins and minerals. Thus, Young Child Formula, as a liquid part of a diversified diet, can play a crucial role in supporting healthy growth and development of young children.  

By way of example, the French Nutri-Bébé survey, covering more than 1000 infants and young children, revealed excessive intakes of protein and insufficient intakes of essential fatty acids, iron and vitamin D after one year. French young children consuming Young Child Formula have more adequate intakes of these essential nutrients than non-consumers.  

Similarly, in the UK, a study investigating dietary changes in young children to ensure nutritional adequacy concluded: “Increasing Young Child Formula (YCF) and supplement consumption was the shortest way to cover the EFSA nutrient requirements of U.K. children”. Today, Young Child Formula can play a role as one strategy to increase the intake of nutrients that are often insufficient in young children’s diets. 

In fact, it is recognised by medical societies and other trusted institutions in several Member States (such as Belgium, France, Ireland and Poland) and by paediatric societies (including the European Society for Paediatric Gastroenterology Hepatology and Nutrition – ESPGHAN – and the German Paediatric Association – DGKJ). 

Young Child Formula at EU level 

EU legislation currently treats Young Child Formula as a “general food”: its composition is not specifically regulated, and inappropriate adult Reference Intakes apply to these products. Consequently, 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.  

Infant and young children nutrition products are among the EU’s most valuable agri-food exports

However, it is important to remember that young children are not ‘mini-adults’, but a vulnerable group with specific nutritional needs. Consuming the right amounts of key nutrients delivered in products whose composition is in line with the latest scientific requirements during this important development period has short- and long-term benefits on the immune system, metabolism, brain development, and overall health later in life. Therefore, Specialised Nutrition Europe (SNE) would like to emphasise the importance of implementing specific regulations for the compositional requirements of Young Child Formula and appropriate References Intakes during the forthcoming EU legislative period. 

For a level playing field in the internal market and globally 

The lack of specific regulation also causes challenges in internal and global markets. The absence of harmonised legal composition requirements for Young Child Formula has led to a fragmentation of the EU internal market and creates legal uncertainty and an unfavourable environment for business food operators. Today, recipes and labels often have to be adapted to the different interpretations and requirements of Member States. Infant and young children nutrition products are among the EU’s most valuable agri-food exports. The product category “infant food and other cereals, starch or milk preparations” accounts for approximately €8bn EUR of EU exports to the rest of the world per year, making it one of the top three agri-food exports over the last five years. The quality and safety of European infant and young children nutrition products is ensured by a strict EU regulatory framework, which explains the popularity of these products in countries outside the EU. However, the lack of a clear, specific EU regulatory framework for Young Child Formula could endanger the trust in and popularity of the European Young Child Formula products in third countries.   

The lack of EU regulation is inconsistent with the international framework 

The Codex Alimentarius – which is the global United Nations body for food standards and counts inter alia all EU countries among its members – recognises the specific nutritional needs for young children and provides rules for the composition of Young Child Formula and in particular, limitations of carbohydrates and sugars. The EU’s General Food Law Regulation includes a legal obligation for the EU to duly consider Codex Alimentarius Standards. The role of proper nutrition for optimal development during the first 3 years of life cannot be underestimated. Appropriate EU regulation would allow for an appropriate level of protection for young children as well as legal certainty for food business operators in the EU.