Citizen Petition argues toddler milks threaten children’s health and pose ‘economic harm’ to families

By Elizabeth Crawford

- Last updated on GMT

Source: Getty /  kieferpix
Source: Getty / kieferpix

Related tags toddler formula Infant formula Food for kids Childhood obesity

In a Citizen’s Petition filed today, children’s health advocates are ramping up pressure on FDA to address the labeling of so-called ‘transition formulas’ or ‘toddler milks,’ which they say offer “no unique nutritional value,” threaten the health of young children and could cause “potential economic harm to families.”

On behalf of 30 child nutrition experts representing academic, public health and advocacy organizations, the Public Health Advocacy Institute asks FDA to restrict the use of ‘infant formula’ and ‘formula’ on beverages for children older than 12 months, enforce current regulations against misbranded ‘transition formulas’ and standardize a common name and disclaimers for beverages targeting children 12-36 months.

The petition ​builds on research ​published in the Public Health Nutrition journal in February that made similar requests of US regulators after discovering that advertising spending on toddler milks increased four-fold between 2006 and 2015, sales volume increase 2.6 times from $5 million in 2006-2008 to more than $20 million in 2013-2005 and unit volume increased 158% from 47 million ounces in 2006 to 121 million ounces in 2015.

If not acted upon, the petition also could portend steadily escalating tactics to sway regulators, policy makers, health care providers and consumers, said Jennifer Harris, a senior research advisor with the UConn Rudd Center for Food Policy & Obesity.

‘These are like a gateway to chocolate milk’

Sold as ‘toddler milks,’ ‘transition formulas,’ ‘nutrition drinks’ or ‘milk drinks,’ the beverages addressed in the petition are a combination of non-fat powdered milk, natural or added sugars, such as corn syrup solids, oil and added nutrients and vitamins that are positioned as a solution for picky eaters who aren’t consuming enough fruits and vegetables in their diets.

But rather than helping children develop a healthy diet, the beverages could do the opposite – training toddlers to shun the taste of plain milk, water or whole foods in favor for products with added sugar that could contribute to obesity and other health problems, Harris said.

“If you accustom children to sweet tastes then it will make it even more difficult for them to like the taste of plain milk. So, we joke sometimes that these are like a gateway to chocolate milk,”​ Harris said, adding if parents rely on these products to fill nutrient gaps in children’s diets then “it doesn’t give kids the chance to develop healthy food preferences.”

She added that the products, which include added sugar, also directly violate recent recommendations by the USDA dietary guidelines advisory committee, which argued that children under the age of 2 years should have no added sugar in their diets because their nutrient needs are so high and their caloric needs are so low.

Similarly, Harris said, the beverages threaten children’s health by confusing parents about what to feed infants. She explained that by using the terms ‘infant’ or ‘formula’ some parents erroneously substituted toddler milks for infant formula either because they assumed they were the same thing or because they believe that the products’ nutrition is similarly regulated as infant formula when it is not.

As such, she said, the petition seeks to prohibit the use of the terms ‘infant formula’ and ‘formula’ on any beverages for children older than 12 months.

Building on this, the petition asks FDA to standardize the name for these products and require descriptors that would help parents avoid mistaking the products of infant formulas.

For example, the petition asks FDA to require disclaimers that would clarify age of use, proper nutrition for young children and clearly and prominently indicate if the product is sweetened or flavored when appropriate.

Toddler milks are little more than a marketing tool, according to petition

“There is absolutely no need for these products,”​ other than as a tool for food manufacturers to advertise infant formulas in countries where they are forbidden to do so, Harris said.

She explained that the drinks first evolved outside of US where marketing infant formulas is forbidden. But by promoting follow-on formulas or toddler milks, the makers of breast milk substitutes found a way to also raise the profile of their infant formulas.

The result is a category that also threatens the economic welfare of young families, according to the petition, which notes that the products cost four times as much as plain milk and does not provide any additional health benefits.

Next steps

While Harris said she hopes that FDA will “close the loophole in the packaging and labeling regulations”​ upon receiving the petition, she acknowledges “it might not be a slam dunk”​ given that the World Health Organization has advocated for including toddler milks under its definition of breast milk substitutes and therefore advertising for them would be prohibited, but the US delegation has strongly opposed this change.

Nonetheless, if FDA does not act in the petitioners’ favor, Harris said the group will continue to pressure the agency potentially through a Citizen’s complaint, and by working with professional groups to raise awareness of its concerns as well advocating for its inclusion in the upcoming USDA Dietary Guidelines.

The petitioners also are working to have the beverages categorized as sugary drinks so that they would be taxed at a higher rate in places that have sugar taxes and include it in public health campaigns about reducing sugary drink consumption, she said.

Finally, she said, the petitioners also might reach out to the Federal Trade Commission to have claims about the beverages labeled as misleading and deceptive.


Dr Harris will be speaking​ in the final webinar in our virtual FOOD FOR KIDS summit​ this year on November 18. Get more details HERE​.

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