New voluntary industry guidelines on commercial baby food and drink products

On 22 August 2025, the Office for Health Improvement and Disparities published its updated voluntary industry guidelines for commercial baby food and drink products aimed at children up to 36 months. The guidance sets out salt and sugar content targets and labelling expectations intended to align products more closely with government infant feeding advice and improve babies’ dietary intakes.

Who do the guidelines apply to?

It is not just manufacturers of commercial baby food who will need to consider these guidelines. They will also be relevant to retailers, trade associations and non-governmental healthcare organisations.

What products are in scope?

Although baby food is generally out of scope of other advertising restrictions relating to products high in fat, salt and sugar because it is covered by a separate regulatory regime, the new guidelines capture all “processed cereal-based foods” and “baby foods” as defined in the  Processed Cereal-based Foods and Baby Foods for Infants and Young Children (England) Regulations 2003. Any food and drink products marketed at, or labelled as suitable for babies and young children under 36 months (such as finger foods and snacks) are also within scope. However, infant and follow-on formula, and toddler and growing-up milks are out of scope the guidelines.

Salt & sugar targets

The guidelines introduce targets for businesses to reduce the salt and sugar content of their commercial baby food and drink products. These nutrition guidelines are split into 3 product categories:

1. Baby meals
2. Finger food and snacks
3. Baby drinks

Product labelling and marketing

The guidelines also set out clear expectations for product labelling and marketing with the aim of encouraging greater transparency and ensuring that parents and carers are able to make more informed decisions when it comes to making purchases. For example, businesses should:

1. provide honest labelling so that product names are not misleading and are instead aligned with the quantity of the primary ingredients;
2. restrict inappropriate on-pack marketing and promotional statements that make ‘implied health claims’ about health or nutritional benefits that are not based on scientific evidence; and
3. stop labelling and marketing snacks or food products that can be eaten between meals as suitable for children aged 12 months and under.

Voluntary but with teeth?

Despite the guidelines being labelled as voluntary, the Government has made its position clear that it expects businesses to implement the guidelines within 18 months (by the end of February 2027). The Government has stated that it will be monitoring progress and will consider additional or alternative measures if it determines that businesses are failing to implement these guidelines.

Conclusion

The new guidelines represent a significant step in addressing nutritional concerns in early childhood and aim to support healthier dietary habits through reformulation and clearer labelling. Although many businesses have already made the changes to their products as set out in the guidelines, it will be beneficial for others to review their products/labelling and decide what changes they will need to make. This may be an opportunity for businesses to not only comply, but to gain a competitive edge in a market increasingly driven by informed, health-conscious consumers.

If you have any questions or would otherwise like to discuss any of the issues raised in this article, please contact Richard Hugo, Amanda Leiu, or another member of our Commercial & Technology team.

This article was written by Fraser Campbell and Amanda Leiu.