Nutrition Labelling for Children’s Foods and Drinks

We’re frequently asked about nutrition labelling for children’s foods and drinks, and as the labelling legislation is not clear, we thought we’d try and clarify things. 

Because in the UK and EU, there is very little reference to children in the nutrition label regulations and guidelines, the impact on nutrition labelling is minimal.

There are published EAR (Estimated Average Requirement) values for many nutrients for children¹, but these don’t form any part of labelling regulations so have no legal significance.  Also, these values have not been revised for 30 years! 

More recently, there have also been guidelines relating to the provision of school meals but again, no impact on food labels.

The Processed Cereal-based Foods and Baby Foods for Infants and Young Children Regulations 2003 ³ did give ‘Labelling Reference Values’ for 15 vitamins and minerals, but they are not included in the later general food regulations.

‘Back-of-pack’ nutrition labelling: UK and EU

The political arena has so far not changed the fact that the UK follows the EU Regulation 1169/2011^3, which controls food labelling, including nutrition labelling.  That document only mentions children in the context of products containing caffeine and a few other additives.⁴

Therefore, nutrition labelling for children’s foods has to follow adult regulations.

Of course, stated portion sizes on foods aimed at children must be appropriate for them, which then does impact upon the ‘per serving’ values, if displayed.

‘Front–of-pack’ nutrition labelling: UK

In addition to back of pack labelling, the UK has a front-of-pack traffic-light system, which is voluntary.  Although voluntary, the major retailers do require it, which effectively makes it mandatory for many manufacturers.

The Guidelines for FoP labelling⁵ state that there is no guidance for children’s reference intake values, so the percentages have to refer to the adult ones.  For this reason, FoP labelling is rarely seen on children’s products.

‘Front–of-pack’ nutrition labelling: EU

Although not yet officially adopted by the EU for front-of-pack labelling, Nutri-Score is being widely adopted by a number of EU countries and manufacturers.  Foods are labelled with a distinctive image showing A, B, C, D or E.

It’s stated in the Nutri-Score FAQs⁶ that it should NOT be used for labelling children’s foods and drinks because children’s requirements for fat are different to those of adults.  There is no version of Nutri-Score designed for children’s foods.

‘Nutrition Facts’ labelling: Canada and USA

By contrast with the EU and UK, the USA⁷ and Canada⁸ have daily nutrient value recommendations for infants up to one year old and also for children of one to four years old.  These are to be used when the food is understood to be, or is marketed for these age groups.

So, the Nutrition Facts label needs to use the children’s daily values to get the %DV values.

Foods for children of over four years old use the adult daily values.

Note however that some of the actual daily values are different between Canada and the USA.

Dr David Bartley

NutriCalc^® Ltd

References

• https://www.ncbi.nlm.nih.gov/books/NBK234929/
• https://www.legislation.gov.uk/uksi/2003/3207/schedule/8/made
• EUR-Lex – 32011R1169 – EN – EUR-Lex (europa.eu)
• For high caffeine products, the statement “not recommended for children or breastfeeding women” applies to foods or food ingredients. For foods with phytosterols, phytosterol esters, phytostanols, and phytostanol esters, the statement “the food may not be nutritionally appropriate for pregnant or breastfeeding women and children under the age of 5 years”. 
• Guide to creating a front of pack (FoP) nutrition label for pre-packed products sold through retail outlets (publishing.service.gov.uk)
• Nutri-Score (santepubliquefrance.fr)
• https://www.ecfr.gov/cgi-bin/text-idx?node=pt21.2.101&rgn=div5#se21.2.101_19
• https://laws-lois.justice.gc.ca/eng/regulations/C.R.C.,_c._870/index.html