NUTRIENT

AND PROMOTION
PROFILE MODEL
Supporting appropriate promotion
of food products for infants and
young children 6–36 months
in the WHO European Region
 NUTRIENT
AND PROMOTION
PROFILE MODEL
Supporting appropriate promotion
of food products for infants and
young children 6–36 months
in the WHO European Region
ABSTRACT

There is growing international concern about the suitability of some commercial food products for infants
and young children (FIYC) sold across Europe. Sweet purées and snack foods dominate the market, deriving
a high proportion of energy from free sugar (including fruit juice) or because intense maceration (puréeing)
has released intrinsic sugars from within plant cell walls. Additionally, many products do not adhere to
WHO’s recommendation to introduce food at 6 months and are marketed as suitable from 4 months,
potentially displacing breast milk. Existing guidelines for FIYC fall short, resulting in the marketing and
sale of unsuitable products. Member States have therefore called for action to end the inappropriate
promotion of FIYC.

WHO will support Member States, industry, policy-makers and other stakeholders via this nutrient and
promotion profile model (NPPM) to ensure appropriate products with suitable, clear promotional materials
are available for infants and young children aged 6 months to 3 years.

The NPPM sets out nutrient and promotional requirements across different product categories. It may be
adopted in full or locally adapted to evaluate product suitability, inform product reformulation and guide
policy reform to support public health goals for optimal infant nutrition and development.

KEYWORDS
NUTRIENT PROFILE MODELLING
COMPLEMENTARY FEEDING
FOODS FOR INFANTS AND YOUNG CHILDREN
CHILDHOOD OBESITY

WHO/EURO:2022-6681-46447-67287
© World Health Organization 2022
Some rights reserved. This work is available under the Creative Commons Attribution-NonCommercial-ShareAlike 3.0 IGO licence (CC BY-NC-SA 3.0 IGO; https://creativecommons.
org/licenses/by-nc-sa/3.0/igo).
Under the terms of this licence, you may copy, redistribute and adapt the work for non-commercial purposes, provided the work is appropriately cited, as indicated below. In any
use of this work, there should be no suggestion that WHO endorses any specific organization, products or services. The use of the WHO logo is not permitted. If you adapt the work,
then you must license your work under the same or equivalent Creative Commons licence. If you create a translation of this work, you should add the following disclaimer along
with the suggested citation: “This translation was not created by the World Health Organization (WHO). WHO is not responsible for the content or accuracy of this translation. The
original English edition shall be the binding and authentic edition: Nutrient and promotion profile model: supporting appropriate promotion of food products for infants and young
children 6–36 months in the WHO European Region. Copenhagen: WHO Regional Office for Europe; 2022”.
Any mediation relating to disputes arising under the licence shall be conducted in accordance with the mediation rules of the World Intellectual Property Organization (http://www.
wipo.int/amc/en/mediation/rules/).
Suggested citation: Nutrient and promotion profile model: supporting appropriate promotion of food products for infants and young children 6–36 months in the WHO European
Region. Copenhagen: WHO Regional Office for Europe; 2022. Licence: CC BY-NC-SA 3.0 IGO.
Cataloguing-in-Publication (CIP) data. CIP data are available at http://apps.who.int/iris.
Sales, rights and licensing. To purchase WHO publications, see http://apps.who.int/bookorders. To submit requests for commercial use and queries on rights and licensing, see
http://www.who.int/about/licensing.
Third-party materials. If you wish to reuse material from this work that is attributed to a third party, such as tables, figures or images, it is your responsibility to determine whether
permission is needed for that reuse and to obtain permission from the copyright holder. The risk of claims resulting from infringement of any third-party-owned component in the
work rests solely with the user.
General disclaimers. The designations employed and the presentation of the material in this publication do not imply the expression of any opinion whatsoever on the part of WHO
concerning the legal status of any country, territory, city or area or of its authorities, or concerning the delimitation of its frontiers or boundaries. Dotted and dashed lines on maps
represent approximate border lines for which there may not yet be full agreement.
The mention of specific companies or of certain manufacturers’ products does not imply that they are endorsed or recommended by WHO in preference to others of a similar nature
that are not mentioned. Errors and omissions excepted, the names of proprietary products are distinguished by initial capital letters.
All reasonable precautions have been taken by WHO to verify the information contained in this publication. However, the published material is being distributed without warranty of any
kind, either expressed or implied. The responsibility for the interpretation and use of the material lies with the reader. In no event shall WHO be liable for damages arising from its use.
CONTENTS

ACKNOWLEDGEMENTS iv

ABBREVIATIONS iv

EXECUTIVE SUMMARY v

INTRODUCTION 1

Purpose and scope 1

Concerns with current FIYC composition and promotion 2

Outdated existing guidance and legislation for FIYC in the WHO European Region 3

Definitions of terms used in this model 4

SUMMARY OF COMPOSITION (FOOD AND NUTRIENT) REQUIREMENTS 6

SUMMARY OF PROMOTIONAL (LABELLING AND MARKETING) REQUIREMENTS 7

INDUSTRY: OPPORTUNITY FOR ACTION 8

NUTRIENT AND PROMOTION PROFILE MODEL (NPPM) 10

How to use the NPPM 10

NPPM Part A: content and front-of-pack labelling 11

NPPM Part B: promotional messages (packets, labelling and marketing) 13

NPPM further details: explanations on the NPPM requirements 15

REFERENCES 24

ANNEX 1. How the draft NPM (published in 2019) was updated into this NPPM 26

ANNEX 2. What is inappropriate promotion of foods for infants and young children? 27

ANNEX 3. Notes on where the NPPM supersedes or differs from existing CODEX and European Commission standards 28

ANNEX 4. Products outside the NPPM scope 30

ANNEX 5. Health and nutrition claims 31

ANNEX 6. Types of promotion 32

iii
ACKNOWLEDGEMENTS

This document was prepared for the WHO Regional Office for Europe by Dr Diane Threapleton, Ali Morpeth
and Professor Janet Cade (WHO Collaborating Centre for Nutritional Epidemiology, University of Leeds,
United Kingdom). Significant contributions and input were provided by Dr Holly Rippin and Dr Kremlin
Wickramasinghe (WHO European Office for the Prevention and Control of Noncommunicable Diseases).
Further thanks are owed to Dr Vicki Jenneson for input and kind review. Thanks also to colleagues that
provided feedback on the model suitability in different Member States. The nutrient and promotion profile
model (NPPM) development was funded by the WHO Regional Office for Europe.

ABBREVIATIONS

EC European Commission

EU European Union

FIYC food products for infants and young children

NPM nutrient profile model

NPPM nutrient and promotion profile model

iv
EXECUTIVE SUMMARY

There is growing international concern about the suitability of some commercial food products for infants
and young children (FIYC) sold across Europe. In particular, sweet purées and sweet snack foods dominate
the market, deriving a high proportion of their energy from free sugar (including fruit juice) or because
intense maceration (puréeing) has released intrinsic sugars from within plant cell walls. Additionally, many
products do not adhere to WHO’s recommended age of food introduction of 6 months and are marketed
as suitable from 4 months, potentially displacing intake of breast milk. Existing regulatory guidelines for
FIYC are outdated and insufficient, resulting in marketing and sale of many unsuitable products. Calls
have therefore been made by Member States at the World Health Assembly to end the inappropriate
promotion of FIYC.

WHO will support Member States, industry, local or national policy-makers and other stakeholders via
this nutrient and promotion profile model (NPPM) to ensure appropriate products, with suitable and
clear promotional materials (marketing and labelling), are available for infants and young children from
6 months up to 3 years of age.

The NPPM sets out nutrient and promotional requirements across different product categories. It may
be adopted in whole or locally adapted for the purpose of evaluating the suitability of currently available
products, to inform product reformulation and to guide policy or legislative reform to support public health
goals for optimal infant nutrition and development.

v
INTRODUCTION

Nutrient profiling is defined by WHO as “the science of classifying or ranking foods according to their
nutritional composition for reasons related to preventing disease and promoting health” (1). Nutrient
profiling enables food classification and can be used through policy to improve overall dietary quality for
the purposes of achieving public health goals. Restricting the marketing of inappropriate FIYC for health
reasons (via mandatory or voluntary policies) requires a nutrient profile model (NPM) to guide policy on
how to classify products and assess whether marketing is appropriate.

The universal belief that the health and development of infants and young children is critically important
underpins this model. Usual rules governing product composition, labelling and promotion should,
therefore, not apply to FIYC (that is, food products marketed as suitable for children under the age of
3 years). Governments should prioritize legislation to prevent commercial interests from damaging the
optimal health and development of this very young and dependent demographic in our society.

Purpose and scope

This NPPM aims to support policy changes for FIYC to ensure both high nutritional quality and appropriate
marketing, in line with internationally recognized diet and health goals for infants and young children
aged 6–36 months.

The NPPM and accompanying NPPM toolkit provide an evidence-informed, up-to-date and user-friendly
framework for governments and policy-makers to develop effective legal and policy measures to ensure
sale of appropriate FIYC in their own countries.

A discussion paper was previously published in 2019 on the appropriate marketing of FIYC, along with an
earlier draft NPM. The draft version of the NPM was validated against product data from Denmark, Spain
and the United Kingdom and was pilot-tested in a further seven WHO European Region Member States.
Details of the draft model development, literature reviews and product validation results were previously
reported in detail (2).

This report provides details of the updated nutrient and promotional (labelling and marketing) requirements
across FIYC product categories and will enable policy-makers, manufacturers and other stakeholders to
assess product suitability and support improvements in product formulation and promotional strategies.

The model was updated through consultation with users of the draft model and other stakeholders across
the WHO European Region using up-to-date published evidence (see Annex 1 for details).

Introduction 1
Concerns with current FIYC composition and promotion
A number of concerns exist about the suitability and marketing of some FIYC, including:
• high total sugar content and sweet taste profile:
⋅ frequent addition of free sugars (e.g. addition of mono and disaccharides, syrups, honey and fruit
juice or juice concentrate, etc.);
⋅ frequent high fruit content (100% fruit) resulting in high total sugar content (e.g. large proportion
of fruit purée used in breakfasts, desserts, vegetable purées, meals and snacks); and
⋅ liberation of intrinsic sugars from plant cell walls during maceration/puréeing increasing the readily
available sugar content and sweet taste;
• addition of salt or high sodium content;
• high fat content, particularly in some snack foods;
• low nutrient or energy density in purées aimed at younger ages/early weaning:
⋅ energy density is often lower than breastmilk (i.e. high natural or added water content);
⋅ s imple fruit or vegetable purées, without any protein source/dairy may have a low density of important
nutrients such as iron or iodine;
• sold as suitable from 4 months of age, contrary to WHO recommendations to exclusively breastfeed
for the first 6 months of life, potentially displacing milk intake;
• claims of “no added sugars” but a significant proportion of energy is derived from sugar (e.g. via fruit);
• frequent marketing of very smooth/puréed foods beyond 12 months of age but:
⋅ introduction of texture is important for chewing development;
⋅ most infants can accept textured foods from 12 months; and
⋅  ngoing exposure to purées, with high liberated sugar content is a concern for oral health and
o
development of sweet taste preference;
• frequently misleading product names which imply vegetable or savoury flavours, or high dairy, vegetable
or cereal content, but high fruit content and sweet taste. For example:
⋅ “peppers, broccoli and apple purée” containing 80% apple, 10% pepper and 10% broccoli;
⋅ “baby porridge with mango” containing 50% apple, 20% mango and 30% rehydrated oats; and
⋅ “apricot and banana baby rice: containing only 3% rice flour;
• proliferation of marketing messages including health and nutritional claims or other promotional
messages that:
⋅ undermine public health messages such as the age of food introduction, the importance of increasing
textures and food variety, and limiting snack food use;
⋅ undermine confidence in or displace home-prepared foods (e.g. “nutritionally balanced by experts”);
⋅ imply that features of the product are desirable or advantageous (such as “fits into little fingers”,
“no bits”, “full of goodness” and “organic”, etc.);
⋅ imply perfection or rely on the so-called “health halo” (common perception) that foods sold for
infants are inherently nutritionally superior to adult products or home-prepared foods.

Another significant issue is that products aimed at older children do not include a minimum age
recommendation of 3 years and are, therefore, likely to be given to infants and young children. Without
alignment for nutritional content regulations or requiring products for older children to carry a minimum
age recommendation on the front of packs, there is likely to be significant crossover, and inappropriate
products will be bought and given to young children. This will undermine the value of applying NPPM

2 Nutrient and promotion profile model

requirements. Furthermore, current inappropriate products aimed at young children (such as 100% dry
fruit snacks marketed for ages 12 months and over) will simply be able to remove the age guide and claim
they are targeted at older children. It is, therefore, essential that products for older children have clear
age guidance on the front of the pack to avoid undermining FIYC regulations and protect the health and
development of the youngest members of society.

Many FIYC are nutritionally adequate and already meet the NPPM requirements. However, frequent use
of, or reliance on, low-quality (e.g. low energy density and high sugar content) products may not provide
the appropriate nutritional intake for healthy growth and development. This is particularly important at the
start of weaning (from 6 months) when food intake is likely to be low and because of the relative difficulty
of compensating for the fact that up until weaning, breastmilk provides adequate nutrients (3,5). Many
FIYC (e.g. fruit purée) for first weaning are high in sugar and low in fats, proteins and other important
nutrients such as iron, and these products may not be appropriate at the start of solid food introduction.

Outdated existing guidance and legislation for FIYC in the WHO

European Region
In the WHO European Region, Codex Alimentarius guidelines and European Union (EU) directives ensure
that FIYC are safe and adhere to specified minimum or maximum nutrient thresholds (6,7). The market has
diversified and proliferated extensively since these guidelines and regulations were developed. The issues
noted above are not addressed in existing legislation or guidelines. Furthermore, existing EU labelling
requirements (7) are very brief, are outdated in terms of new food packaging (e.g. pouches with spouts),
and do not regulate highly persuasive marketing and health claims.

In 2016 the World Health Assembly approved WHO guidance on ending the inappropriate promotion of FIYC
through resolution WHA69.9. The aims of the guidance are to protect breastfeeding, prevent obesity and
chronic diseases, promote a healthy diet and ensure caregivers receive clear and accurate information
on infant and young child feeding. Resolution WHA69.9 requested that WHO provide technical support to
Member States in implementing the guidance recommendations, including the development of nutrient
profiling tools.

This work sits within the WHO European food and nutrition action plan 2015–2020 which focuses on “food
and nutrition as the leading factors in health and well-being in the European Region, with particular
attention to the associated burden of NCDs”. The plan cites the “pervasive marketing to children of foods
and drinks high in energy, saturated fats, trans fats, sugar or salt and inappropriate marketing of follow-
on foods and complementary feeding for infants and young children” as specifically within its scope (8).
In 2017 WHO published an implementation manual guide for ending inappropriate promotion of foods for
infants and young children and specified what “inappropriate promotion” means (details on inappropriate
promotion are in Annex 2) (9).

A review of existing guidelines and regulations for FIYC in 2019 (2) identified inconsistent requirements
and concluded that the regulations are generally insufficient and do not reflect the modern market, where
the range and form of products has proliferated greatly over the past few years. Updated regulations and
legislation are required to ensure product contents, promotions and labelling do not undermine important
public health recommendations.

Introduction 3
The resulting NPPM is aligned to the European Programme of Work 2020–2025 (10) and is intended to
address multiple current issues with FIYC and the NPPM requirements. It supersedes elements of existing
standards such as the Codex standard for processed cereal-based foods for infants and young children
(Codex/STAN 074-1981) (6) and the European Commission (EC) Directive 2006/125/EC on processed
cereal-based foods and baby foods for infants and young children (details provided in Annex 3) (7). New
mandatory legal regulations are recommended to ensure widespread and consistent improvements in
the content and marketing of FIYC.

The model does not make provision for micronutrient contents, so any existing local, regional or national
requirements must be followed by manufacturers. The model may be locally adapted for micronutrient
requirements according to local nutritional status, dietary habits or national policy on food fortification
or supplementation.

Definitions of terms used in this model

A food product for infants and young children (FIYC) means a manufactured food or drink other than
a breastmilk substitute which is marketed as suitable for feeding infants (less than 12 months old) and
young children (12 to 36 months old).

Note that the following are not considered to be FIYC and are not within the scope of the NPPM (see Annex 4):
• products not marketed for children under 3 years of age;
• vitamin and mineral food supplements;
• products that function as breastmilk substitutes.

FIYC are considered to be marketed as being suitable for this age group if they (9):
• are labelled with the words “baby”, “infant,” “toddler” or “young child”;
• are recommended for introduction at an age of less than 3 years;
• have a label with an image of a child who appears to be younger than 3 years of age or who is feeding
with a bottle; or
• are in any other way presented as being suitable for children under the age of 3 years.

Health claim means any representation that states, suggests or implies that a relationship exists between
a food (or a constituent of that food) and health (see Annex 5).

Nutrition claim means any representation which states, suggests or implies that a food has particular
nutritional properties, including but not limited to the energy value and the content of protein, fat and
carbohydrates, as well as the content of vitamins and minerals (see Annex 5).

Marketing is defined as product promotion, distribution, selling, advertising, product public relations and
information services.

Promotion is broadly interpreted to include the communication of messages that are designed to persuade
or encourage the purchase or consumption of a product or raise awareness of a brand. Messages may
be communicated in a variety of settings and via packaging, branding, and labelling. A detailed definition
of promotional messages and cross-promotion may be found in Annex 6 and the WHO implementation
manual for guidance on ending the inappropriate promotion of FIYC (9).

4 Nutrient and promotion profile model

Added sugar is defined as all monosaccharides and disaccharides added to foods and beverages by the
manufacturer, cook or consumer during processing or preparation.

Free sugars are defined as monosaccharides (such as glucose or fructose) and disaccharides (such
as sucrose or table sugar) added to foods by the manufacturer, cook or consumer in addition to sugars
naturally present in honey, syrups, fruit juices and fruit concentrates.

Liberated sugars are defined as those that are released or “liberated” from within plant cell walls during
processing such as heat-treatment, maceration or puréeing. Liberated sugars have the same function
as free sugars in terms of contributing to the sweet taste of foods and the speed at which sugars are
absorbed into the blood stream. For example, fruit purée is particularly high in liberated sugar. Feeding
fruit purée alone, or using it as an ingredient in other foods, means foods taste very sweet and blood sugar
levels can rise rapidly.

Banned free sugars and sweeteners are defined as:

i. all mono- and disaccharides (including sugars derived from fruits, sugarcane, palms or root vegetables,
etc.);
ii. all syrups, nectars and honey (including molasses, agave, maple, blossom nectar, malted barley syrup,
brown rice syrup, etc.);
iii. fruit juices or concentrated/powdered fruit juice, excluding lemon or lime juice (e.g. pear juice,
concentrated apple juice or powdered mango juice); and
iv. all non-sugar sweeteners (e.g. saccharin, acesulfame, aspartame, sucralose or stevia, etc.).

Total sugar includes any intrinsic sugars contained within plant cells walls, liberated sugars, free sugars
and sugars naturally present in milk (largely lactose).

Fruit juice describes fruit that is prepared with the edible pulp removed. Fruit juice is not permitted in any
FIYC product and is defined as a free sugar.

Permitted fruit includes 100% fruit, where all edible components are retained. Dehydrated 100% fruit is
only permitted in limited quantities in some product categories because of high sugar content. Tomatoes,
avocadoes and coconut are not classed as fruit and their use is unrestricted.

Introduction 5
SUMMARY OF COMPOSITION (FOOD AND
NUTRIENT) REQUIREMENTS

In general, composition requirements aim to reduce the sugar content and sweet taste profile of products.
This will be achieved through banning the addition of free sugars, limiting the total sugar content or fruit
content in certain categories and through requiring front-of-pack high-sugar labels for some products
with sugar-rich ingredients (e.g. fruit purée). Thresholds are also in place to ensure appropriate energy
density, salt, protein and fat contents across product categories.

For meaningful impact on reaching public health goals for infants and young children, these requirements
should be mandatory and written into relevant legislation.

Details of requirements across product categories can be viewed in Table 1. Further explanations and
justifications for requirements are provided in the section NPPM further details: explanations on the
NPPM requirements.

i. No addition of free sugars and sweeteners, including:

a. all mono- and disaccharides;
b. all syrups, nectars and honey;
c. fruit juices or concentrated/powdered fruit juice (excluding lemon or lime juice); and
d. non-sugar sweeteners.
ii. Confectionery should not be marketed.
iii. Flavoured or sweetened drinks should not be marketed.
iv. Maximum 15% energy from total sugar in meals and snacks.
v. Limited use of fresh and dry fruit in some food categories.
vi. Minimum energy density for dry cereals (80 kcal/100 g) and savoury meals (60 kcal/100 g).
vii. Maximum energy for snacks is 50 kcal per serving.
viii. Maximum sodium content 50 mg/100 kcal (or 100 mg if cheese is in the product name).
ix. Minimum content by weight of named traditional protein sources in meals.
x. Minimum protein content for meals, and cereals/snacks made with milk.
xi. Industrially produced trans-fatty acids are not permitted.
xii. Total fat maximum 4.5 g/100 kcal for most products, except in some meals.

6 Nutrient and promotion profile model

SUMMARY OF PROMOTIONAL (LABELLING AND
MARKETING) REQUIREMENTS

In general, promotional requirements aim to improve messaging to caregivers around product age suitability,
improve product naming, warn of high sugar content, and limit use of health, nutrient and marketing claims.

For meaningful impact on reaching public health goals for infants and young children, these requirements
should be mandatory and written into relevant legislation.

Details of requirements for age limits and front-of-pack sugar labels across product categories can be
viewed in Table 1. Details of other promotional requirements are provided in Table 2 and further explanations
and justifications for requirements are provided in the section NPPM further details: explanations on the
NPPM requirements.

i. Minimum age recommendation of 6 months and products must not encourage (either implicitly or
explicitly) early food introduction.
ii. Maximum age recommendation of 12 months for puréed foods.
iii. Front-of-pack indicator labels for high total sugar content:
a. > 30% energy in fruit or vegetable purées, desserts and dry fruit snacks
b. > 40% energy in dairy foods.
iv. Product name clarity: indicate contents in descending order and not hide sweet tastes or high fruit
content.
v. Ingredient list clarity: state proportion (%) of added water/stock, fruit content and traditional protein
source.1
vi. Packaging with a spout should state clearly that contents should be decanted and not directly sucked.
vii. Remove most compositional (nutritional), health and marketing claims.
viii. Include relevant statements to protect and promote breastfeeding.

Note that in order to be effective and to clearly distinguish FIYC from other commercially available foods
for older children, other products for older children should be clearly labelled as suitable from 3 years of
age. This particularly applies to snack foods with total energy from sugar > 15% or other breakfast/dessert
foods with high sugar content that are likely to be given to younger children.

1 Traditional protein sources include any meat, offal, poultry or fish.

Summary of promotional (labelling and marketing) requirements 7

INDUSTRY: OPPORTUNITY FOR ACTION

The NPPM provides guidance for food producers to ensure that existing products are suitable, and for
improving the content and/or promotional materials of any unsuitable products. These requirements
will help to maintain high product standards and support international goals for diet and preventing
noncommunicable diseases.

Alongside adhering to the content and promotional requirements provided in the NPPM (summarised
above), food producers should be proactive in making the following changes to support evidence-informed
dietary and health goals for infants and young children aged 6 to 36 months:

Uphold public health recommendations for food introduction from around 6 months:
→ re-label products sold as suitable from 4 months to suitable from 6 months (redefine “stage 1” foods
to be suitable from 6 months)
→ do not imply any food introduction before 6 months

Support public health goals to reduce intake of free sugars and improve product quality and support
taste development by:
→ lowering the total sugar content of products
→ lowering fruit content of products, particularly puréed fruit
→ reformulating to remove free sugars (including fruit juice and concentrated juice)
→ producing fewer sweet snacks, desserts and breakfasts with high fruit content

First weaning foods should include more vegetable and savoury flavours:
→ prepare single or mixed vegetable purées without the addition of fruit
→ refrain from masking the flavour of less sweet or bitter vegetables with sweet vegetables and fruit
→ produce more single-flavour foods (particularly vegetables) for ages 6–12 months

More early weaning foods (6-12 months) should be nutrient dense and include cereals, legumes, protein
sources and fats rather than be simple watery vegetable purées or sugar-rich fruit purées:
→ avoid the unnecessary addition of water/stock to purées (for instance to facilitate easy serving through
a spout) to maintain higher nutrient and energy density
→ focus on savoury meals (with the addition of cereals and fat and protein sources) as well as vegetable
purées for ages 6-12 months

8 Nutrient and promotion profile model

Avoid unnecessary puréeing and increase product textures to encourage chewing development and limit
the release of intrinsic sugars from fruit and vegetable cell walls during processing:
→ produce fewer highly blended foods and more foods with texture for 6–12 months and beyond
→ avoid using puréed ingredients in foods sold for young children (12–36 months) as greater textures can
be tolerated. This will also minimize exposure to liberated sugars

Go beyond minimum legal labelling requirements to provide full nutrient and ingredient information:
→ some products sold in different countries contain different nutrient data (e.g. total sugar and salt
content for the same product is not given when sold in the Eurasian Economic Union but reported for
the product when sold in the EU)

Refrain from using content, health and marketing claims on product packaging, in particular:
→ remove “no added sugar” claims, particularly on products with high total sugar content
→ remove statements about texture that imply idealism in smoother products
→ remove statements implying idealism in, or the need for, convenience foods, snacks or dessert products

Industry: Opportunity for action 9

NUTRIENT AND PROMOTION PROFILE MODEL
(NPPM)

How to use the NPPM

The NPPM is divided into two Parts. Part A details product content (nutrient) requirements by product
category along with front-of-packet age recommendation and indicator labels for high sugar contents
(Table 1), and Part B details other promotional (packet and marketing) requirements (Table 2). Both parts
are intended to guide policy-makers, industry and other stakeholders in evaluating the suitability of existing
products and making positive changes through product reformulation, packaging changes and legislation.

STEP 1: Identify the category for a product (Table 1), referring to the “details and examples” column if
necessary.

STEP 2: Cross-check nutrient data, the ingredient list and the recommended product age range against
NPPM Part A (Table 1). Note that some products may not include all relevant data to assess suitability;
in this situation use what data you have and note where gaps exist. Evaluate products as eaten, using
manufacturers’ preparation instructions for dry products, ingredients and meal components where
possible. Where preparation instructions are not given, evaluate products as sold but be aware that some
thresholds may be unmet or exceeded because of this.

i. Use the ingredient list to evaluate addition of free sugars, the proportion of fruit and proportion of
protein source (for meals).
ii. Use nutritional information to evaluate energy density and thresholds for other nutrients.
iii. Use pack information to evaluate recommended portion sizes for snacks.
iv. Determine if the recommended age is appropriate.
v. Determine if the total sugar content would require a front-of-pack indicator label.

Useful calculations
→ Convert kJ to kcal: kJ × 0.239
→ Calculate energy density (kcal/100 g): (kcal ÷ specified product or portion weight) × 100
→ Calculate nutrients per 100 kcal: (fat grams per specified product weight ÷ kcal per specified product
weight) × 100 e.g. 2.1 g fat and 110 kcal per 160 g serving: (2.1 ÷ 110) × 100 = 1.9 g per 100 kcal
→ Calculate total sugar % energy: (total sugar grams per specified product weight ÷ kcal per specified
product weight) × 400
→ Convert salt grams to sodium milligrams: (salt grams ÷ 2.5) × 1000

10 Nutrient and promotion profile model

STEP 3: Cross-check promotional materials (packaging and other associated marketing materials such
as websites) against requirements in NPPM Part B (Table 2).

i. Check for presence of compositional, nutritional, health or marketing claims.

ii. Check suitability of product name (front of pack and/or legal product name).
iii. Check that the ingredient list reports the proportions of specified foods.
iv. Check for instructions not to consume food via spout if sold with spout.
v. Check for suitable preparation instructions for dry foods, meal components or ingredients.
vi. Check for statements that protect or promote breastfeeding.

NPPM Part A: content and front-of-pack labelling

Table 1. NPPM Part A: content and front-of-pack labelling

Content and labelling requirements14

Total protein (g/100 kcal) & protein

Total fat (g/100 kcal) (no trans)2

Added free sugar or sweetener1

Front-of-pack high-sugar flag8

Energy density (kcal/100 g)

Labelling and promotional

Subcategory description

Fruit content3 (% weight)

Details and examples

Sodium (mg/ 100 kcal)

Age label (months)4

Total sugar (% E)
Product group

requirements
(% energy)
weight
Code

Dry cereals 1 Dry or powdered To be prepared with milk (or equivalent ≥ 80 ≤ 50 / None ≤ 5.5g ≤ 4.5g or ≤ 10% 6–36 ≥ 30%
and starches cereal9/starch non-sweet liquid) or water (or protein- as eaten as eaten (if contains ≤ 3.3g dry weight
to be eaten or free liquid) e.g. instant porridge, milk)12,13 (if to be
cooked with milk muesli, baby rice, dry pasta. Includes eaten
or water plain fresh pasta etc. Excludes with milk)
crackers/rusks etc. (cat. 5.2)

Dairy foods 2 Dairy-based The largest ingredient is dairy and ≥ 60 ≤ 50 / None / ≤4.5 g ≤ 5% 6–36 ≥40%
foods, desserts fruit ≤ 5% e.g. porridge, rice pudding, (100 if (max.
and cereals yogurt, fromage frais, custard. [If fruit named 2% dry)
content > 5% use cat.3.1] cheese)

Fruit & 3.1 Fruit-containing Any product containing > 5% fruit3 ≥ 60 ≤ 50 / None / ≤ 4.5 g / 6–36 ≥ 30%
vegetable product, (except dry cereals, low fruit dairy, (6–12
purées/ including or snacks) e.g. apple purée, fruit for purée)
smoothies and breakfast/dairy and yogurt, fruit custard, porridge
fruit desserts with > 5% fruit

3.2 Vegetable only Single or mixed vegetables or ≤ 25% ≤ 50 / None / ≤ 4.5 g None 6–36 ≥ 30%
product legumes e.g. spinach & pea purée, added (6–12
mashed potato & carrot. Excludes water for purée)
foods containing added starch/fat/ All requirements
dairy (cat. 4.1] apply to all
categories as
Savoury 4.1 Food WITHOUT Vegetables/legumes and/or cereals/ ≥ 60 ≤ 50 ≤ 15% None ≥ 3 g12,13 ≤ 4.5 g ≤ 5% 6–36 / detailed in
meals/meal protein5 or starches. May contain a protein (max. (6–12 NPPM Part B
components: cheese named source, dairy or fats e.g. vegetable 2% dry) for purée)
combinations rice, lasagne, pesto sauce for pasta
of starches,
vegetables, 4.2 Food WITH Cheese and no other proteins are in ≥ 60 ≤ 100 ≤ 15% None ≥ 3 g12,13 ≤6 g ≤ 5% 6–36 /
dairy and/ CHEESE named the product name e.g. cheese pasta, (max. (6–12
or traditional but no protein tomato & mozzarella pasta sauce 2% dry) for purée)
protein5,6,7
Traditional 4.3 Food with Protein source is not the first named ≥ 60 ≤ 50 (100 ≤ 15% None ≥3g ≤ 4.5 g ≤ 5% 6–36 /
protein sources protein5 source food, e.g. pea & lamb curry, tomato if named ≥ 8%12,13 (max. (6–12
include any NOT named first & beef sauce for pasta cheese) 2% dry) for purée)
meat, offal,
poultry or fish 4.4 Food with e.g. Rabbit & potato, beef soup, tasty ≥ 60 ≤ 50 (100 ≤ 15% None ≥4g ≤6g ≤ 5% 6–36 /
protein5 source chicken risotto, chicken & cheese if named ≥ 10%12,13 (max. (6–12
named FIRST pasta, beef sauce for pasta cheese) 2% dry) for purée)

4.5 Protein5 source Puréed cooked meat. May contain ≥ 60 ≤ 50 ≤ 15% None ≥ 7g ≤ 6g ≤ 5% 6–36 /
is ONLY named a small quantity of grain/starch not ≥ 40%12,13 (max. (6–12
food in product name e.g. “rabbit” or 2% dry) for purée)
“lamb” with some added rice flour
or corn starch

Nutrient and promotion profile model (NPPM) 11

 Snacks and 5.1 Fruit Fresh fruit or whole dry fruits or ≤ 50 kcal ≤ 50 / None / ≤ 4.5 g 100% 6–36 ≥ 30%
finger foods pieces e.g. plain dry apple slices or per serve (dry fruit
raisins. Excludes pulverised/puréed only)
dry fruits (cat. 7) All requirements
apply to all
5.2 Dry or semi-dry Any grain, starch, pulse/lentil ≤ 50 kcal ≤ 50 ≤ 15% None ≤ 5.5 g ≤ 4.5 g / 6–36 / categories as
snacks and or root vegetable snack such as per serve (if biscuit detailed in
finger foods cracker, bread, biscuit, pastry, cake and NPPM Part B
or pancake etc. Includes rusks, contains
crackers and biscuits to be eaten milk) 12,13
dry or pulverized with liquid

Ingredients 6 Ingredients Ingredients for cooking or adding to / ≤ 50 / None / / None 6–36 /

food in small quantities e.g. olive
oil, stock cubes

Confectionery 7 Confectionery Chocolates, sweets, liquorice, Not appropriate for promotion

marzipan, fruit chews10 etc.

Drinks 8 Drinks Fruit juice and other sweetened or Not appropriate for promotion
flavoured drinks.11 Excludes 100%
fruit/vegetable purée, breastmilk
substitutes or unsweetened milk/
milk alternatives

Footnotes to Table 1
1
Added free sugars and sweeteners include:
i. all mono- and disaccharides (including sugars derived from fruits, sugarcane, palms or root vegetables, etc.);
ii. all syrups, nectars and honey (including molasses, agave, maple, blossom nectar, malted barley syrup and brown rice syrup, etc.);
iii. fruit juices or concentrated/powdered fruit juice, excluding lemon or lime juice (e.g. pear juice, concentrated apple juice or powdered mango juice). See footnote 3 on permitted fruit use; and
iv. non-sugar sweeteners (such as saccharin, acesulfame, aspartame, sucralose or stevia, etc.).
2
No product may contain industrially produced trans-fatty acids.
3
Notes on fruit:
i. tomatoes, avocadoes and coconut are not classed as fruits for this purpose;
ii. unsweetened whole or chopped fruits and dry whole or chopped 100% fruits are permitted as per category 5.1; and
iii. blended, pulped, puréed or powdered 100% fruits (i.e. not juice) (including puréed/powdered dried fruit) are only permitted in specified quantities by weight, as they are high in liberated sugars.
4
Notes on recommended age ranges displayed on packs and all related promotional materials:
i. no product should state or imply product suitability for babies under 6 months of age, including through use of images;
ii. products that are blended/puréed should have an upper age limit of 12 months. This applies to puréed and smooth products sold for babies before they are able to chew or accept more textured foods (e.g. puréed fruit/vegetables,
processed oatmeal porridge or a blended meal). Naturally smooth and unmacerated foods such as yogurt, risotto or porridge are exempt; and
iii. a narrower age range than indicated may be displayed on packs according to product consistency (e.g. 18–36 months for crunchy snacks).
5
Note that traditional protein sources include any meat, offal, poultry or fish.
6
Note that the front-of-pack and legal product names and order of foods may differ. Follow the front-of-pack names for product categorization where possible.
7
For meal components (e.g. pasta sauce): thresholds apply to foods as eaten, where preparation details are provided.
8
A front-of-pack indicator, label or flag is required when the total energy from sugar exceeds specified thresholds [30% total energy = 7.5 g / 100 kcal; 40% total energy = 10 g / 100 kcal]. The label should conform to pre-specified
requirements, e.g. be clearly positioned and with moderate size text.
9
Minimum 25% cereal for rusks, crackers and biscuits.
10
Fruit chews include any dried and processed fruit products such as fruit gums, bars or fruit strips/leathers/roll-ups (i.e. a dense chewy food made from fruit juice or pulped and dehydrated/dried fruit).
11
Includes any drinkable product containing crushed, blended, pulped or puréed fruit/vegetable, fruit/vegetable juice and/or water, with or without added free sugar or sweetening agents. Including 100% juices, reconstituted juice
from concentrate, smoothies with added juice or water, drinks made from cordials, energy drinks, ices and soft drinks.
12
Evaluate total protein adequacy using pack nutrient information (to calculate g / 100 kcal) and the ingredient list (percent weight of protein source), where possible. Note that meal components (such as sauces) are exempt from
point iii and iv:
i. any dry cereal products (category 1) containing a high-protein food (e.g. milk or milk-equivalent) must have ≤5.5g/100kcal total protein;
ii. any biscuits or rusks etc. (category 5.2) made with the addition of a high-protein food (e.g. milk or milk-equivalent), and presented as such (e.g. in product name, or named/pictured on packet), must have ≤ 5.5 g / 100 kcal total
protein;
iii. total protein (g / 100 kcal) must be ≥ 3 g / 100 kcal for all savoury meals, or ≥ 4 g if the protein source is named first (e.g. chicken risotto), or ≥ 7 g if the product only names a protein source (e.g. rabbit purée); and
iv. total protein weight must be higher than 8%, 10% or 40% of the total product weight in product categories 4.3, 4.4 and 4.5, respectively (e.g. beef lasagne (cat. 4.4) must contain 10% beef by weight).
13
Additional mandatory protein requirements to be followed by food producers during manufacturing. Note that it is not necessary to assess these criteria using packet information while applying the NPPM. The following requirements
are as stipulated in CODEX Standard CXS 74-1981 (section 3.3) and EC Directive 2006/125/EC (Annex II, section 1):
i. any dry cereal products (category 1) made with a high-protein food (e.g. milk or milk equivalent) must have ≤ 5.5 g total protein, of which ≥ 2 g / 100 kcal may be added protein (e.g. from dairy sources);
ii. any biscuits or rusks etc. (category 5.2) made with the addition of a high-protein food (e.g. milk or milk equivalent), and presented as such (e.g. in product name, or named/pictured on packet) must have ≤ 5.5 g / 100 kcal total
protein and the added protein shall not be less than 0.36 g / 100 kJ (1.5 g / 100 kcal);
iii. each source of protein named in the front-of-pack or legal product name of meals must be ≥ 25% by weight of the total named protein weight. For example, chicken and rabbit risotto (category 4.4) must include at least 25%
chicken and 25% rabbit by weight of the total protein weight;
iv. protein from dairy must be ≥ 2.2 g / 100 kcal if cheese is mentioned in the product name; and
v. protein from the named source (meat, offal, poultry or fish) must be ≥ 2.2 g / 100 kcal in category 4.3, ≥ 4 g in category 4.4 and ≥ 7 g in category 4.5.
14
Products with vitamin, mineral and amino acid additions must adhere to existing EC requirements or other local, regional or national guidelines, where applicable.

12 Nutrient and promotion profile model

NPPM Part B: promotional messages (packets, labelling and marketing)
Table 2. NPPM Part B: promotional messages (packets, labelling and marketing)

Promotional requirement Details and examples

No compositional, No compositional, nutritional, health or marketing claims are permitted on packs or related marketing materials (promotional communications, websites,
nutritional, health or etc.). Refer to Table 3 for examples of non-permitted claims.
marketing claims Note the following composition statements are permitted:
i. statements relating to common allergens (such as containing or being “free from… [gluten, dairy/lactose, or nuts]” etc.)
ii. statements relating to religious or cultural requirements (such as “meat-free”, “vegetarian”, “contains meat”, “Kosher”, “Halal”, etc.)
iii. descriptive words may be used within the ingredient list (such as “organic carrots” and “wholegrain wheat flour”)

Product name clarity1 The front-of-pack product name and legal product name must:
i. clearly represent or name the main or largest ingredients, where appropriate, except when the largest ingredient is implied in the name (such as milk
in porridge or rice in risotto);
ii. list ingredients in an appropriate order (to indicate decreasing proportional content); and
iii. indicate when fruit or vegetables (single or in combination) comprise the majority of the product by weight. Note that fruit or vegetables are considered
to be the largest ingredient if the sum of all fruits or vegetables is the largest ingredient, and the front-of-pack name must indicate this (see example
(iii) in footnote 1)
Note that all ingredients do not need to be listed in the product name

Ingredient list clarity The ingredient list must clearly indicate the proportion (%) of:
i. the largest single ingredient (including water/stock, except when used for rehydration of legumes/grains etc.)
ii. the amount of added water/stock (except when used for rehydration of legumes/grains etc.)
iii. the total or individual proportions of fresh or dried fruit
iv. the amount of fish, poultry, meat or other traditional source of protein

Instructions not to Ready-to-eat puréed foods sold in packs with a spout must include a clear statement to discourage caregivers from allowing infants and young children
consume soft foods to suck the food directly via the spout, such as: “Infants and young children should not be allowed to suck directly from the pouch/container”
via pack spout

Suitable preparation Preparation instructions for dry cereals/starches, ingredients and meal components must state that the liquid used to reconstitute the product, or
instructions accompanying foods served, should have no added sodium or free sugar (including fruit juice)

Promotion and In relation to breast feeding:

protection of i. no cross-promotions are permitted between products that function as breastmilk substitutes, and commercially available complementary foods
breastfeeding marketed as suitable for infants and young children > 6 months;
ii. all products must include a statement on the importance of continued breastfeeding for up to two years or beyond and the importance of not introducing
complementary feeding before 6 months of age;
iii. no products should include any image, text or other representation that is likely to undermine or discourage breastfeeding, or that makes a comparison
to breastmilk or that suggests that the product is nearly equivalent or superior to breastmilk;
iv. all products must state the suitable age of introduction (≥ 6 months);
v. no products should include any image, text or other representation that might suggest use for infants under the age of 6 months (including references
to milestones and stages); and
vi. no product should convey an endorsement or anything that may be construed as an endorsement by a professional or other body, unless this has
been specifically approved by relevant national, regional, or international regulatory authorities.

Footnote to Table 2
1
Improved product name examples:
i. 30% apple, 20% sweet potato and 10% spinach:
⋅ before: “spinach and sweet potato”; after: “apple, sweet potato and spinach”
⋅ name ingredients in an appropriate order and indicate that apple is the main ingredient.
ii. 35% carrot, 30% parsnip, 20% potato and 15% chicken:
⋅ before: “chicken and vegetable meal”; after: “root vegetable and chicken dinner” or “carrot and potato mash with chicken”
⋅ Indicate that vegetables are the largest ingredient.
iii. 30% pear, 20% apple, 20% rice/oats/dairy and 10% strawberry:
⋅ before: “baby rice/porridge/yogurt with strawberry”; after: “pear and apple porridge/rice/yogurt with strawberry” or “fruity rice/porridge/yogurt”
⋅ Indicate that fruit is the largest ingredient, strawberry is not the primary fruit and rice/oats/yogurt is not the largest ingredient.

Nutrient and promotion profile model (NPPM) 13

Table 3. Examples of prohibited compositional, health and marketing claims on promotional materials (pack labels
and other marketing materials)

Composition and Statements relating to the presence or absence of ingredients generally perceived to be harmful or beneficial, for example:
nutrition claims • “no…”, “no added…”, “low in…” [sugar, salt, condiments, artificial flavour/colour, maltodextrin, modified starch, additives/preservatives, GMO,
junk, etc.]
• “contains only naturally occurring…” [sugars, salt, etc.]

Statements relating to the natural or healthful nature of ingredients, for example:

• “contributes one of your five-a-day [fruit/vegetables]”
• “contains three types of vegetables”, “contains vegetables”
• “organic food”, “natural”, “fresh”, “100% natural”, “real fruit/vegetables”

Statements implying nutritional idealism, high nutrient content or presence of nutrients generally not considered in home-prepared
foods. No product should imply that commercial foods are nutritionally superior to home-prepared foods or otherwise undermine important public
health recommendations. for example:
• “nutritionally balanced”, “perfect/unique balance of vitamins/minerals”, “ideal nutrients”, “provides good nutrition to children”
• “contains…” “a source of…” [minerals, vitamins, iron, vitamin B1, a host of nutrients, dietary fibre, omega-3, probiotics, prebiotics, protein, amino
acids, phospholipids, DHA, carbohydrate, arachidonic acid, etc.]

Health claims Statements relating to beneficial health or development resulting from the food or ingredients, for example:
• “good for…”, “supports…”, “improves…”, “…needed for…” [healthy growth, development, digestion, appetite, learning to chew, learning to hold,
constipation, defecation, bones and teeth, enteric flora, the brain, eyes, vision, skin health, thyroxine synthesis, red blood cell synthesis, preventing
iron deficiency anaemia, collagen synthesis, metabolism, cognitive development, immune system etc.]

Statements relating to the general healthful nature of ingredients or recipes, for example:
• “healthy”
• “goodness of cereals”, “extra goodness with wholegrain oats”, “infant cereal is the ideal foundation to a healthy and balanced diet”, “perfectly
balanced to support growth”
• “draws inspiration from the Mediterranean approach to health and well-being”

Marketing claims Statements relating to ideal taste, for example:

• “delight for tiny taste buds/tiny tummies”, “tasty/yummy/delicious”, “suitable for picky eaters”, “in my home the whole family loves them”, “my
flavours are a new journey for tiny taste buds”, “exotic dishes are full of variety and flavour”, “simple flavour”

Statements relating to high product quality, for example:

• “picked at the peak of ripeness”, “bursting with goodness and flavour”, “individually steam cooked”, “we use over 27 different fruits and
vegetables”, “we only use specially selected ingredients”

Statements relating to ideal food texture, for example:

• “smooth”, “no bits/chunks”, “easy-to-swallow texture that is great for helping your little one as they start to explore solid foods”, “perfectly
smooth texture has been specially developed as an ideal first weaning food”
• “I’m textured”, “yummy crispy bits will encourage your baby to begin to chew”, “ideally suited to promote exposure to textures”

Statements relating to convenience or lifestyle, for example:

• “convenient”, “great for a busy and active life”, “ideal for breakfast or meals on the go”, “simply to top up between meals”
• “great way to make fruit fun”
• “closest thing to homemade with all of the goodness and none of the guilt”
• “inspired by my favourite home-cooked recipes”

14 Nutrient and promotion profile model

 Statements conveying ideals on optimum feeding, for example:
• “making the right feeding choices for you and your baby”
• “helps to build confidence and enjoyment with food”
• “we’ve been pioneering research into infant and toddler nutrition for over 50 years to help you give your baby the best start in life”
• “carefully prepared by our baby-food experts”
• “grown by farmers we know and trust”
• “nothing unnecessary”, “no junk”, “nothing nasty”
• “encourages self-feeding”, “perfect for small hands”
• “perfect/ideal/optimum… way to feed/introduce foods”
• “breakfast is one of the most important meals of the day”
• “we guarantee our products provide the best possible start for your baby”

Statements encouraging dismissal of public health recommendations, for example:

• “the government advises that you don’t need to wean your little one until they are 6 months old. Every baby is different!”
• “the Department of Health and the World Health Organization recommend exclusive breastfeeding for the first six months. However, if you choose
to wean earlier, our ingredients are suitable from 4 months”

Statements/labels implying product or brand support from experts and trustworthy or influential individuals, groups or organizations.
No product should convey an endorsement or anything that may be construed as an endorsement by a professional or other body, unless this has
been specifically approved by relevant national, regional or international regulatory authorities. For example:
• “quality approved by Mums”
• “approved by nutrition experts/celebrities”
• “endorsed by paediatricians/national child’s association”

Statements conveying other idealistic or charitable attributes of the product or brand, for example:
• “committed to giving 10% of profits to help fund food education charities”
• B corporation certification, Hain Celestial or other corporate certification implying superior or other ethical or charitable brand attributes and
unrelated to product nutrition or content

NPPM further details: explanations on the NPPM requirements

Energy density
The existing EC directive does not contain a minimum energy requirement for meals (7) but we identified
a concern that many products have low energy density, particularly meals. A United Kingdom-based
review reported that the water content of many commercial baby foods is likely greater than homemade
foods (11) meaning that energy density is likely to be lower (12). In our pilot exercise examining products
on sale across Europe (2), we also found that many purée and meal products had lower energy density
than has previously recommended for complementary feeding (at least 0.8 kcal / g) (13) and of breast-milk
(0.69 kcal /g) (11). In our validation study, around half of all meal purées (sold as suitable from 4 or 6 months)
examined on sale in the United Kingdom and Denmark did not reach the minimum energy requirement
of 60 kcal / 100g; however, non-puréed meal products (typically sold as suitable from 12 months) tended
to meet the criteria (2).

Manufacturers should be encouraged to reduce and declare the water content of products to increase

Nutrient and promotion profile model (NPPM) 15

energy density and quality of soft foods and purées. Setting a minimum energy density of 60 kcal /100 g
for many purées will also encourage manufacturers to add less water for cooking and blending and will
therefore ensure higher quality and better value products. The restrictions on adding sugars will ensure
that this increase in energy density is not achieved through an increase in sugar content. The threshold
of 60 kcal / 100 g was set as a minimum for most categories to reflect the average puréed food energy
density observed in the pilot exercise (2). This threshold will remain under regular review and will be
increased if necessary.

No threshold was set for vegetable-only purées, so that manufacturers are not dissuaded from preparing
purées of naturally low-energy vegetables and are not encouraged to add sweet/starchy vegetables, fruit
or fats to achieve the minimum energy threshold.

NPPM requirements relating to energy density

• Dry cereals and starches must have a minimum energy density requirement of 80 kcal/ 100 g (as eaten)
to ensure foods are more energy dense than milk and to align with existing EC requirements (7);
• Most non-dry products are required to have minimum energy density of 60 kcal /100 g;
• Vegetable purées do not have a minimum energy density requirement as they often have a naturally high
water content. Different flavours and vegetables should still be offered during weaning (6 to 12 months).
A maximum added water requirement is included for vegetable purées to ensure that they are not too
low in energy.
• Snacks and finger foods must be a maximum of 50 kcal per serving in order that they do not displace
meals.

Sodium
Several national dietary recommendations in the WHO European Region advise limiting salt for infants and
young children to prevent accustoming them to a high-salt diet. Lower sodium thresholds than are currently
used in the EC 2006 directive (7) for cereal foods are proposed in the NPPM, and these apply to all food
categories. We judge this lower sodium level to be feasible and achievable during product reformulation
based on our 2019 assessment of products sold across 10 Member States (2).

NPPM requirements relating to sodium

• Most products should contain a maximum sodium content of 50 mg / 100 kcal (salt 0.125 g / 100 kcal).
• Some foods may contain 100 mg / 100 kcal sodium (salt 0.25 g / 100 kcal) if cheese is named within
the front-of-pack product name.

16 Nutrient and promotion profile model

Sugar

Existing sugar recommendations and definitions

WHO recommends that population intake of free sugar should be no more than 10% energy intake, with
an ideal recommended intake of under 5% (14). The European Society for Paediatric Gastroenterology,
Hepatology and Nutrition Committee on Nutrition recommends that intake of free sugar is even lower
than 5% below the age of 2.(15)

WHO defines free sugars as “monosaccharides and disaccharides added to foods and beverages by the
manufacturer, cook or consumer, and sugars naturally present in honey, syrups, fruit juices and fruit
juice concentrates” (14). The United Kingdom Scientific Advisory Committee on Nutrition has expanded
on the WHO definition of free sugars to stipulate exclusions for naturally-present lactose (milk sugar)
and sugars contained within the cellular structure of foods (particularly fruits and vegetables) (16). In the
United Kingdom, the definition of free sugars includes blended, pulped, puréed or extruded fruit, which is
a logical extension and interpretation of the WHO definition (17). However, liberated sugars from blended,
pulped, puréed or extruded fruit are not explicitly included in the WHO definition of free sugars. The intense
maceration (puréeing) and heat treatment used in the production of many FIYC liberates sugars from plant
cell walls (11,18). Similarly to fruit juices, fruit purées can be considered free sugars and frequent intake
may negatively affect oral health and influence taste preferences.

Why the NPPM focuses on total sugar and addition of free sugars, rather than free sugar content

Existing recommendations for sugar intake focus on free and added sugars, for which there is consistent
evidence of adverse health effects, rather than total sugars. There are arguments that intrinsic sugars
(contained within the cell walls of fruits and vegetables) are less likely to be over-consumed and contain a
range of other beneficial nutrients (15). However, this argument cannot be applied in the context of many
FIYC where products rely on intense maceration (puréeing) processes which liberate intrinsic sugars.
Similarly, products often rely on the addition of fruit purée or concentrates to sweeten foods and yet still
claim “no added sugars” on packs to give the appearance of being a healthy product.

Furthermore, assessing free sugar contents of FIYC and applying limits through the NPPM would prove
impossible at present, with only total sugar and the ingredients being required on packs in many Member
States in the WHO European Region.

The NPPM, therefore, focuses on limiting use of free sugars as an ingredient and limiting total sugars, in
addition to a range of other strategies to control fruit use, with the aim of lowering the overall sweet taste
and total sugar content of products.

In summary, the NPPM focuses on total sugar content and addition of free sugars as ingredients, rather
than free sugar content, for the following reasons:
• many countries already mandate reporting of total sugar content so this can easily be assessed;
• addition of free sugars can be identified from the ingredient list;
• total free sugar (added plus liberated sugars) content is difficult to calculate, and data are not available
on packs, presenting clear challenges in applying free sugar limits in the NPPM; and
• many FIYC are highly puréed, heat treated or use dry, pulped or powdered fruits. Such processing
liberates sugar from within plant cell walls meaning that total sugar contents will be a good indication
of free (added plus liberated) sugar content.

Nutrient and promotion profile model (NPPM) 17

FIYC and sugar concerns

A ban on all intrinsically sweet foods (including fruit) is neither feasible nor desirable. However, the addition
of free sugars including concentrated fruit juice, and the high fruit content of many foods, has resulted in
a very sweet and sugary product profile in the marketplace. For instance, our previously reported analysis
of 2634 products sold in 10 Member States showed that mean energy from total sugar in all products
ranged between 29% and 44%. Total energy from sugar was worryingly high in fruit purées, with average
sugar content in each country being greater than 70% and reaching almost 100% energy from sugar in
some blended fruit products. Furthermore, addition of free sugars was a concern, where between 21%
and 58% of baby and infant snack foods sold across Europe contained free sugars (2,19). Many FIYC also
state “no added sugar” or “contains only naturally occurring sugar” on packs, giving the appearance of
being healthy while having a high fruit content and resultant sweet taste and high sugar content.

The NPPM recommends limiting fruit content in meals and the 2019 review of products (2) identified a 5%
maximum to be feasible. The 2019 product review also provided evidence to support front-of-pack high-
sugar indicators. These thresholds were set close to the mean and median total sugar content of product
categories for United Kingdom products, so that over 40% of products did not exceed the threshold (2).
The aim was to balance optimal sugar levels for health against feasibility in product composition, as many
fruits are intrinsically rich in sugar.

Front-of-pack indicators for high sugar content

WHO recommends front-of-pack labelling to help consumers to make healthier food choices and recommends
government-led policy with input from key stakeholders through an iterative and collaborative process
(20). A recent WHO manual also provides guidance for countries on the selection and testing of evidence-
informed front-of-pack nutrition labelling systems (21). Information may be colour-coded (e.g. red, amber,
green) for different nutrients such as salt or sugar, may be presented as an overall food score (e.g. A to
E), may state high nutrient content (e.g. “high in sugar”) or may provide a health warning (e.g. “drinking
beverages with added sugar(s) contributes to obesity, diabetes and tooth decay”).

A recent comprehensive systematic review and meta-analysis of 156 studies concluded that mandatory
front-of-pack labelling policies for traffic light indicators, nutrition scores, nutrition warnings or health
warnings changes purchasing behaviour towards healthier products, and away from those less healthy
(22). The study also identified at least 31 countries where interpretive front-of-pack label systems (i.e.
those that indicate product healthfulness, rather than present simple nutrient values) had been introduced,
including six countries with mandatory warning labels on products and three countries with mandatory
colour-coded systems.(22)

18 Nutrient and promotion profile model

NPPM requirements relating to sugar and fruit content
To address concerns about sugar contents across different product categories, a range of requirements
have been set:
• no added sugars or sweetening agents are permitted in any food, including:
i. all mono- and disaccharides (including sugars derived from fruits, sugarcane, palms or root
vegetables, etc.);
ii. all syrups, nectars and honey (including molasses, agave, maple, blossom nectar, malted barley
syrup, brown rice syrup, etc.);
iii. fruit juices or concentrated/powdered fruit juice, excluding lemon or lime juice (e.g. pear juice,
concentrated apple juice or powdered mango juice; see Table 1, footnote 3 on permitted fruit use);
and
iv. non-sugar sweeteners (such as saccharin, acesulfame, aspartame, sucralose or stevia etc.);
• the total sugar content for savoury foods and non-fruit snack foods cannot exceed 15%;
• the maximum permitted fruit content for dry cereals is 10%, and for dairy foods and meals is 5% (of
which a maximum of 2% may be from dried fruit); and
• a front-of-pack indicator, label or flag is required when the total energy from sugar exceeds specified
thresholds:
i. 30% total energy (7.5 g / 100 kcal) for dry cereals and starches (category 1), fruit and vegetable
purées/ smoothies and fruit desserts (category 3) and dry fruit snacks (category 5.1); and
ii. 40% total energy (10 g / 100 kcal) dairy foods (category 2).

Protein
Existing EC guidelines (7) specify a minimum protein content in grams per 100 kcal and also as a percent
of product weight, to ensure meals that contain traditional protein sources (meat, offal, poultry and fish)
in the product name include a minimum amount of the specified protein, rather than protein from cheaper
alternative sources. These requirements have been adopted in the NPPM. Evaluation of products in the
pilot study (2) found that meals generally included enough total protein (grams per 100 kcal) but that a
substantial number of meal products (naming a traditional protein source in the name) did not meet the
minimum standard for weight of protein source. Concern remains that some FIYC containing meat, fish or
dairy have lower protein content than homemade equivalents and may not sufficiently contribute to intake
of important nutrients such as iron.

Protein requirements in the NPPM are somewhat complex and differ depending on product type and where
the protein source is listed in the product name for meals. This ensures that products naming protein first
have higher protein content than products naming another food item first in the product name. For example,
“chicken risotto” will have a higher protein and chicken content than “mushroom and chicken risotto”.

The minimum protein density (g / 100 kcal) and protein content (% of product weight) can often be checked
against reported nutrient information and the ingredient list on packs, although some countries do

Nutrient and promotion profile model (NPPM) 19

not require the proportion of protein source to be listed in the ingredients. Other protein requirements
adopted from existing EC guidelines are intended to guide manufacturers and cannot usually be checked
using packet information. These additional requirements are only provided in a footnote to the model but
manufacturers should pay close attention to meeting all requirements to ensure high product quality.

NPPM requirements relating to protein

• Any dry cereal products (category 1) containing a high-protein food (e.g. milk or milk-equivalent) must
have ≤ 5.5 g / 100 kcal total protein;
• Any biscuits or rusks etc. (category 5.2) made with the addition of a high-protein food (e.g. milk or milk
equivalent), and presented as such (e.g. in product name, or named/pictured on packet), must have
≤ 5.5 g / 100 kcal total protein;
• Total protein (g / 100 kcal) must be ≥ 3 g / 100 kcal for all savoury meals, ≥ 4 g if the protein source is
named first (e.g. chicken risotto), or ≥ 7 g if the product only names a protein source (e.g. rabbit purée).
Meal components such as sauces are exempt);
• Total protein weight must be higher than 8%, 10% or 40% of the total product weight (in product
categories 4.3, 4.4 and 4.5, respectively); e.g. beef lasagne (category 4.4) must contain 10% beef by
weight. Meal components such as sauces are exempt; and
• Additional mandatory protein requirements to be followed by food producers during manufacturing are
detailed in footnote 13 of Table 1 and are as stipulated in CODEX Standard CXS 74-1981 (section 3.3)
and EC Directive 2006/125/EC (Annex II, section 1).

Fat
Sufficient fat intake and appropriate fatty acid composition of foods is essential for healthy growth and
development. The WHO Guiding principles for complementary feeding of the breastfed child proposes that
30–45% of the energy derived from fat is “a reasonable compromise between the risks of too little intake
(such as inadequate essential fatty acids and low energy density) and excessive intake” (23).

The WHO recommend intake of total fat for adults is a maximum of 30% energy with saturated fat being a
maximum of 10%. Dietary fat recommendations from WHO for infants and young children are not specified,
although intake should be “similar” to adults (24). Fat requirements in the NPPM are set at a maximum
of 4.5 g / 100 kcal for most products and 6 g / 100 kcal for those with higher protein source (meat/fish)
content. This is equivalent to 40% or 54% energy from fat, respectively.

The model does not include saturated fatty acid limits because arguments persist around recommended
intakes of saturated fatty acids, lack of evidence for intakes in babies and whether any health effects may
depend on specific fatty acid structures and food sources rather than total intake (25). Validation work
from 2019 suggests that introducing a maximum saturated fat content in terms of 10% energy contribution
would affect most meals containing cheese, many other meals containing meat and many snack products.
However the affected snack products would no longer be suitable for sale because of high sugar contents (2).

20 Nutrient and promotion profile model

NPPM requirements relating to fat
• Most products should not exceed 4.5 g / 100kcal total fat.
• Dry cereals that are intended to be consumed with added milk should not exceed 3.3 g / 100 kcal total
fat.
• Meals containing cheese, naming a protein source first or puréed meat (intended to be eaten with other
foods) should not exceed 6 g /100 kcal total fat.

Product age range

Previous WHO calls to end the inappropriate promotion of foods for infants under 6 months of age have
been ignored by most large food manufacturers, with many products being marketed as suitable from
4 months of age. In the UK, almost half of FIYC (from the four largest manufacturers) were marketed from
4+ months (2). Continuing to permit such labels seems likely to support common perceptions about suitable
age of food introduction and encourage earlier food introduction, potentially displacing intake of milk.

Based on the evidence reviewed by WHO and summarized here, commercial products should not be
marketed as suitable for infants under 6 months old as: (i) breast-milk provides adequate nutrition for
most infants; (ii) early complementary foods are not more nutrient- or energy-dense than usual milk; and
(iii) there is insufficient evidence of clear benefits for introducing foods before 6 months of age.

There is currently no upper age limit for heavily processed (smooth and puréed) products, but with
increasing age and the development of fine and gross motor skills, infants or young children do not need
such smooth foods and can accept greater exposure to textured foods. This further develops chewing ability
and children can become accustomed to home-style and family foods. Furthermore, ongoing exposure to
highly macerated fruits and vegetables in purées increases unnecessary exposure to liberated sugars in
products, presenting issues such as blood glucose rises, oral health and the development of sweet-taste
preference. Puréeing also changes food flavour and appearance and may lead to overeating, as foods can
rapidly be swallowed without chewing (26).

NPPM requirements relating to recommended product age

• No product should state or imply product suitability for babies under 6 months of age, including images.
• Products that are blended/puréed which are typically eaten unpuréed should have an upper age limit
of 12 months. This applies to puréed and smooth products sold for babies before they are able to chew
or accept more textured foods (e.g. puréed fruit/vegetables, processed oatmeal porridge or a blended
meal). Naturally smooth and unmacerated foods such as yogurt, risotto or porridge are exempt.

Nutrient and promotion profile model (NPPM) 21

Labels and promotional messages
Health, nutrition or other pack claims should not be permitted on FIYC so that the promotion of commercial
foods does not undermine public health messages or caregivers’ confidence in home-prepared foods, or
imply that features of the product are desirable or advantageous. Product labels and names should provide
clear information on contents and not mislead consumers. For instance, front-of-pack product names are
often misleading about high quantities of cheaper, sweeter ingredients (e.g. apple or pear purée) and imply
higher content of cereal, dairy, protein (meat or fish etc.) or vegetables. This particularly applies to puréed
products and to breakfast or dairy foods such as yogurt or porridge where the main ingredient(s) is fruit.

FIYC rely on the consumer assumption that they are specifically formulated and are healthier and superior
to other commercial products for older children or adults. Many promotional messages and claims are
designed to mislead or distract consumers from undesirable qualities, for example by emphasizing use of
organic ingredients, convenience, taste or smooth texture. Unrestricted marketing places unfair burdens
and pressures upon caregivers, whereby claims imply nutritional perfection or other beneficial attributes
that could undermine confidence in providing simple home-prepared foods.

Refer to page 53–56 of Ending inappropriate promotion of commercially available complementary foods for
infants and young children between 6 and 36 months in Europe for further discussion on FIYC marketing
issues (2).

NPPM requirements relating to promotional messages and packaging

• No compositional, nutritional, health or marketing claims.
• Product name clarity.
• Ingredient list clarity.
• Instructions not to consume soft foods via pack spout.
• Suitable preparation instructions.
• Promotion and protection of breastfeeding.

Micronutrients
Micronutrients are not included in the NPPM. The bioavailability of micronutrients in foods, micronutrient
content and bioavailability in breast-milk, volume of breastmilk or formula consumed and individual
nutritional requirements across ages will differ, meaning different micronutrient requirements may be
required for different ages or products. Some regions may wish to retain existing, or establish new, product
requirements for micronutrients to ensure sufficient intake from foods (e.g. iron from protein sources)
or via fortification.

22 Nutrient and promotion profile model

Snacks and desserts
The proliferation of snack and dessert FIYCs normalises the concept of between-meal snacks and providing
sweet desserts after meals. Snacks and desserts alone are unlikely to provide essential or balanced nutrition
for development (e.g. iron) and should be used in moderation, particularly for infants (under 12 months)
when nutrient-rich rather than carbohydrate- or sugar-rich foods are required for optimal development.
The NPPM does not include specific recommendations on the use of or the labelling on snack or dessert
products. However, local adoption of NPPM requirements may consider prevalence of snacks or dessert
products and caregiver attitudes or understanding about frequency of use.

Nutrient and promotion profile model (NPPM) 23

REFERENCES

1. Nutrient profiling: Report of a WHO/IASO technical meeting, London, United Kingdom 4–6 October 2010. Geneva: World Health
Organization, 2011 (https://apps.who.int/iris/handle/10665/336447, accessed 8 October 2022).

2. Ending inappropriate promotion of commercially available complementary foods for infants and young children between 6 and 36
months in Europe: a discussion paper outlining the first steps in developing a nutrient profile model to drive changes to product
composition and labelling and promotion practices in the WHO European Region. Copenhagen: WHO Regional Office for Europe;
2019 (https://apps.who.int/iris/handle/10665/346583, accessed 8 October 2022).

3. Fewtrell M, Bronsky J, Campoy C, Domellöf M, Embleton N, Fidler Mis N et al. Complementary feeding: a position paper by
the European Society for Paediatric Gastroenterology, Hepatology, and Nutrition (ESPGHAN) Committee on Nutrition. J Pediatr
Gastroenterol Nutr. 2017;64(1):119–32. doi: 10.1097/MPG.0000000000001454.

4. EFSA Panel on Dietetic Products, Nutrition and Allergies (NDA). Scientific opinion on the appropriate age for introduction of
complementary feeding of infants. EFSA J. 2009;7(12):1423. doi: 10.2903/j.efsa.2009.1423.

5. Complementary feeding of young children in developing countries: a review of current scientific knowledge. Geneva: World Health
Organization; 1998 (https://apps.who.int/iris/handle/10665/65932, accessed 8 October 2022).

6. Codex Alimentarius standard for processed cereal-based foods for infants and young children. Rome: Food and Agriculture
Organization of the United Nations & World Health Organization; 1981 (adopted 1981, revised 2006, amended 2017: CODEX STAN
74– 1981; https://www.fao.org/fao-who-codexalimentarius/sh-proxy/es/?lnk=1&url=https%253A%252F%252Fworkspace.fao.org
%252Fsites%252Fcodex%252FStandards%252FCXS%2B74-1981%252FCXS_074e.pdf, accessed 8 October 2022).

7. Commission Directive 2006/125/EC on processed cereal-based foods and baby foods for infants and young children. Brussels:
European Commission; 2006:16–35 (https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A32006L0125, accessed
8 October 2022).

8. European Food and Nutrition Action Plan 2015–2020. In: Regional Committee for Europe 64th Session, Copenhagen, Denmark,
15–18 September 2014. Copenhagen: WHO Regional Office for Europe; 2015 (https://apps.who.int/iris/handle/10665/329405, accessed
8 October 2022).

9. Guidance on ending the inappropriate promotion of foods for infants and young children: implementation manual. Geneva: World
Health Organization, 2017 (https://apps.who.int/iris/handle/10665/260137, accessed 8 October 2022).

10. The European Programme of Work, 2020–2025: United Action for Better Health. Copenhagen: WHO Regional Office for Europe;
2021 (https://apps.who.int/iris/handle/10665/339209, accessed 8 October 2022).

11. Crawley H, Westland S. Baby foods in the UK. A review of commercially produced jars and pouches of baby foods marketed in the
UK. London: First Steps Nutrition Trust, 2017.

12. Coulthard H, Harris G, Emmett P. Delayed introduction of lumpy foods to children during the complementary feeding period affects
child’s food acceptance and feeding at 7 years of age. Matern Child Nutr. 2009;5:75–85. doi: 10.1111/j.1740-8709.2008.00153.x.

13. Dewey KG. Nutrition, growth, and complementary feeding of the breastfed infant. Pediatr Clin North Am. 2001;48(1):87–104.
doi: 10.1016/s0031-3955(05)70287-x.

14. Guideline: Sugars intake for adults and children. Geneva: World Health Organization; 2015 (https://apps.who.int/iris/handle/10665/149782,
accessed 8 October 2022).

15. Fidler Mis N, Braegger C, Bronsky J, Campoy C, Domellöf M, Embleton ND et al. Sugar in infants, children and adolescents: a
position paper of the European Society for Paediatric Gastroenterology, Hepatology and Nutrition Committee on Nutrition. J Pediatr
Gastroenterol Nutr. 2017;65(6):681–96. doi: 10.1097/MPG.0000000000001733.

16. Buttriss J. Why 5%? An explanation of the Scientific Advisory Committee on Nutrition’s recommendations about sugars and health,
in the context of current intakes of free sugars, other dietary recommendations and the changes in dietary habits needed to reduce
consumption of free sugars to 5% of dietary energy. London: Public Health England, 2015 (https://assets.publishing.service.gov.uk/
government/uploads/system/uploads/attachment_data/file/769482/Why_5__-_The_Science_Behind_SACN.pdf, accessed 8 October
2022).

17. Swan GE, Powell NA, Knowles BL, Bush MT, Levy LB. A definition of free sugars for the UK. Public health Nutr. 2018;21(9):1636–8.
doi: 10.1017/s136898001800085x.

18. Final minutes. In: Scientific Advisory Committee on Nutrition 48th meeting, 30th June 2016, Skipton House, London. London:
Scientific Advisory Committee on Nutrition; 2016.

24 Nutrient and promotion profile model

19. Hutchinson J, Rippin H, Threapleton D, Jewell J, Kanamäe H, Salupuu K et al. High sugar content of European commercial baby
foods and proposed updates to existing recommendations. Matern Child Nutr. 2021 ;17(1):e13020. doi: 10.1111/mcn.13020.

20. Guiding principles and framework manual for front-of-pack labelling for promoting healthy diet. Geneva: World Health Organization,
2019 (https://apps.who.int/nutrition/publications/policies/guidingprinciples-labelling-promoting-healthydiet/en/index.html, accessed
8 October 2022).

21. Manual to develop and implement front-of-pack nutrition labelling: guidance for countries on the selection and testing of evidence-
informed front-of-pack nutrition labelling systems in the WHO European Region. Copenhagen: WHO Regional Office for Europe;
2020 (https://apps.who.int/iris/handle/10665/336988, accessed 8 October 2022).

22. Song J, Brown MK, Tan M, MacGregor GA, Webster J, Campbell NRC et al. Impact of color-coded and warning nutrition labelling
schemes: a systematic review and network meta-analysis. PLOS Med. 2021;18(10):e1003765. doi: 10.1371/journal.pmed.1003765.

23. Guiding principles for complementary feeding of the breastfed child. Washington (DC): Pan American Health Organization and
World Health Organization; 2003 (https://www.who.int/publications/i/item/9275124604, accessed 8 October 2022).

24. Healthy diet. In: Fact sheets. Geneva: World Health Organization; 2020 (https://www.who.int/news-room/fact-sheets/detail/healthy-
diet, accessed 8 October 2022).

25. Astrup A, Bertram HC, Bonjour J-P, de Groot LC, de Oliveira Otto MC, Feeney EL et al. WHO draft guidelines on dietary saturated
and trans fatty acids: time for a new approach? BMJ. 2019;366:l4137. doi: 10.1136/bmj.l4137.

26. Koletzko B, Lehmann Hirsch N, Jewell JM, Caroli M, Da Silva Breda JR, Weber M et al. Puréed fruit pouches for babies: child health
under squeeze. J Pediatr Gastroenterol Nutr. 2018;67(5):561–3. doi: 10.1097/MPG.0000000000002061.

27. Commercial foods for infants and young children in Poland: a study of the availability, composition and marketing of baby foods
in Warsaw, Poland. Copenhagen: WHO Regional Office for Europe; 2021 (https://apps.who.int/iris/handle/10665/340443, accessed
8 October 2022).

References 25
ANNEX 1.
How the draft NPM (published in 2019) was updated into this NPPM

The draft nutrient profile model was published in 2019, developed using WHO guidelines on NPM development
(1) and informed by a literature review and a detailed validation/pilot test of 2634 products on sale across
10 European countries (2). The draft NPM has been used to evaluate appropriate promotion of FIYC on
sale in Poland (3,4).

In late summer 2021 the University of Leeds WHO Collaborating Centre in Nutritional Epidemiology re-
examined the NPM and drafted proposed model updates and simplifications. These were presented and
discussed among attendees of a WHO Expert Meeting on Nutrient Profile Models for infants and children
in September 2021.

A subsequent country consultation exercise with interviews and a questionnaire was undertaken early in
2022 to collate feedback on the draft NPM suitability and proposed model updates across WHO European
Region Member States. Invited interviewees provided context on country-level policy, readiness to implement
the NPPM and perceived barriers or facilitators to policy change. A questionnaire was more widely shared
among attendees of the expert meeting to collate feedback on local suitability of the NPPM requirements
and food categories, and perceived barriers and facilitators to implementing the model to support policy
changes. Feedback was synthesized and informed the final NPPM categories and product requirements.

References
1. Nutrient profiling: Report of a WHO/IASO technical meeting, London, United Kingdom 4–6 October 2010. Geneva: World Health
Organization, 2011 (https://apps.who.int/iris/handle/10665/336447, accessed 8 October 2022).
2. Ending inappropriate promotion of commercially available complementary foods for infants and young children between 6 and
36 months in Europe: a discussion paper outlining the first steps in developing a nutrient profile model to drive changes to
product composition and labelling and promotion practices in the WHO European Region. Copenhagen: WHO Regional Office
for Europe; 2019 (https://apps.who.int/iris/handle/10665/346583, accessed 8 October 2022).
3. Commercial foods for infants and young children in Poland: a study of the availability, composition and marketing of baby foods
in Warsaw, Poland. Copenhagen: WHO Regional Office for Europe; 2021 (https://apps.who.int/iris/handle/10665/340443, accessed
8 October 2022).
4. Mukaneeva DK, Kontsevaya AV, Antsiferova AA, Rippin H, Wickramasinghe K, Drapkina OM. Research on the labeling and
promotion of finished food products for children under 3 years of age in the Russian Federation. Profilakticheskaya Meditsina.
2022;25(1):54–62 (in Russian). doi: 10.17116/profmed20222501154.

26 Nutrient and promotion profile model

ANNEX 2.
What is inappropriate promotion of foods for infants and young children?

What is considered inappropriate promotion of foods for infants and young children (1)?

• Promotion of foods for infants and young children is considered inappropriate if it interferes with
breastfeeding, contributes to obesity and noncommunicable diseases, creates a dependency on
commercial products, or otherwise is misleading.

• Recommended breastfeeding practices can be undermined by inappropriate promotion in various ways.

These include promotion of products as being suitable for infants under 6 months, as being equivalent
or superior to breast-milk, as an effective replacement for breast-milk, or by using brands/labels/logos
that are the same or similar to those used for breast-milk substitutes.

• Promotion of products that contain high levels of sugar, salts or fats may contribute to childhood obesity
and noncommunicable diseases; such promotion should clearly be considered inappropriate.

• Promotion of foods not recommended in national food-based dietary guidelines is likewise inappropriate.
Promotion is also inappropriate if the product fails to adhere to all applicable standards for safety and
nutrient composition or discourages a diverse diet based on a wide variety of foods, including minimally
processed fruits, vegetables and animal-source foods, or if it undermines the use of suitable home-
prepared and/or local foods.

• Promotion is inappropriate if it is misleading, confusing or could lead to inappropriate use through, for
example, health and nutrition claims. Promotional claims idealize the product, imply that it is better than
family foods and mask the risks. Promotional claims put unprocessed family foods at a disadvantage.
Nutrition and health claims shall not be permitted for foods for infants and young children.

References

1. Guidance on ending the inappropriate promotion of foods for infants and young children: implementation manual. Geneva: World
Health Organization, 2017 (https://apps.who.int/iris/handle/10665/260137, accessed 8 October 2022).

Annex 2 27
ANNEX 3.
Notes on where the NPPM supersedes or differs from existing CODEX
and European Commission standards

Note that CODEX [CODEX/STAN 074-1981 REVISED 2017 ON CEREAL BASED FOODS] and EC Directive
Annex I requirements are identical in terms of nutrient requirements.

EUROPEAN COMMISSION DIRECTIVE 2006/125/EC of 5 December 2006 on processed cereal-based

foods and baby foods for infants and young children

• The NPPM differs from the directive Article 8(a) labelling requirement that products may state an age
of introduction from 4 months.

• Annex I. Essential composition of processed cereal-based foods for infants and young children
1. Cereal content definition (> 25% of final dry mix weight) is specified in the NPPM.
2. Protein and lipid content requirements for different dry cereal product categories are detailed within
the NPPM but cereal categories are not differentiated. The NPPM has one cereal category instead
of 4 [dry cereals to be eaten with milk, without milk, dry pastas etc., rusks and crackers].
3. “ Rusks, biscuits and crackers” have a maximum fat content of 3.3 g / 100 kcal, presumably because
they can be reconstituted with milk. The NPPM has adopted a higher threshold of 4.5 for all
snack foods for simplicity and because the higher fat threshold may better accommodate product
reformulation if added sugars are removed.
4. The total fat content for cereal products intended to be made up or eaten with milk (or equivalent
unsweetened liquid) is 3.3 g / 100 kcal, or 4.5 g / 100 kcal if intended to be made up or eaten with
water (or equivalent protein-free liquid). If total fat ≥ 3.3 g / 100 kcal: (i) the amount of lauric acid
shall not exceed 15% of the total lipid content; (ii) the amount of myristic acid shall not exceed
15% of the total lipid content; (iii) the amount of linoleic acid (in the form of glycerides = linoleates)
shall not be less than 70 mg / 100 kJ (300 mg / 100 kcal) and shall not exceed 285 mg / 100 kJ
(1200 mg/100 kcal). The above details were not adopted within the NPPM for simplicity, as: (i) the
fat requirements only relate to products that lie between 3.3 and 4.5 g / 100 kcal; (ii) requirements
only apply to products intended to be made up with water; and (iii) such products form only a small
part of the complementary diet.
5. Carbohydrate requirements for products with added sugar are superseded by the NPPM requirement
to disallow products with added sugars.
6. Mineral, vitamin and trace element requirements, except sodium, are not detailed in the NPPM. A
footnote is included that products must adhere to existing EC requirements or other local, regional
or national guidelines, where applicable. The sodium threshold of 100 mg/ 100 kcal was lowered to
50 mg /100 kcal in the NPPM. Note that the Codex and EC Directive requirement that sodium salts
may only be added to processed cereal-based food for technological purposes is unclear/open to
misuse and was not adopted into the NPPM.

28 Nutrient and promotion profile model

• Annex II. Essential composition of baby foods for infants and young children
1. Protein requirements for foods containing traditional protein sources named singularly or in
combination have been adopted in the NPPM. EC directive requirements for protein contents of
“meals” “sauces” and “sweet dishes” are vague and open to misuse/misinterpretation. The NPPM
now includes protein requirements for different meal categories.
2. Carbohydrate requirements have not been transferred to the NPPM:
2.1 Some requirements relate to drinks, and are now disallowed in the NPPM.
2.2 The requirement for fruit-only dishes and desserts/puddings to contain < 20 g / 100 g and
< 25 g / 100 g carbohydrate, respectively, are replaced by the focus on added sugars and front-
of-pack sugar flags in the NPPM.
2.3 The NPPM does not set maximum carbohydrate thresholds to avoid the addition of low energy
density foods (or water) to products.
3. Fat requirements have been adopted in the NPPM.
4. Mineral, vitamin and trace element requirements, except sodium, are not detailed in the draft
NPM. A footnote is included that products must adhere to existing EC requirements or other local,
regional or national guidelines, where applicable. The sodium requirements of 200 mg / 100 kcal
or 200 mg / 100 g (or 300 mg if cheese is the only named ingredient) has been lowered to 50 mg in
the NPPM (or 100 mg if cheese is listed in the product name).

• Annex III relates to amino acid composition of casein in cereal-based foods. Such details are not included
in the NPPM.

• The directive states that “only the nutritional substances listed in Annex IV may be added in the
manufacture of processed cereal-based foods and baby foods.” The NPPM does not make reference
to this.

REGULATION (EU) No 609/2013 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 12 June
2013 on food intended for infants and young children, food for special medical purposes, and total diet
replacement for weight control and repealing Council Directive 92/52/EEC, Commission Directives 96/8/
EC, 1999/21/EC, 2006/125/EC and 2006/141/EC, Directive 2009/39/EC of the European Parliament and
of the Council and Commission Regulations (EC) No 41/2009 and (EC) No 953/2009.

• Requirements were reviewed for “Processed cereal-based food and baby food” (Chapter 1, Article 1,
part b). These micronutrient requirements are not detailed with the NPPM but footnote is included
that products must adhere to existing EC requirements or other local, regional or national guidelines,
where applicable.

Annex 3 29
ANNEX 4.
Products outside the NPPM scope

Products not Products not specifically marketed for children younger than 3 years of age or
marketed for whose labels state that they are intended only for pregnant women, mothers or
babies and infants children older than 3 years

Vitamin and Vitamin and mineral food supplements, whether to be consumed as tablets/drops
mineral food or added to foods at home (such as home fortification products, micronutrient
supplements powders or lipid nutrient powders)

Products that These should not be promoted at all. These include any milks (or products that could
function as be used to replace milk, such as fortified soya milk alternatives), in either liquid or
breast-milk powdered form, that are specifically marketed for feeding infants and young children
substitutes up to the age of 3 years. This includes milk or milk-like formulations commonly
marketed for infants from 6 months of age and prepared in accordance with relevant
international or national standards. The upper age indication on the product label
varies country to country but is usually between 12 and 36 months. Any milk product
that is marketed or represented as suitable as a partial or total replacement of the
breast milk part of the young child’s diet is a breast-milk substitute and, therefore,
falls under the scope of the International Code. This product always replaces breast
milk, as breastfeeding is recommended to continue for 2 years or beyond. Follow-
up formula should therefore also not be promoted. These provisions also apply to
growing-up milk (also known as growing-up formula, toddler milk or formulated
milk), which is targeted at infants and young children from 1 year (sometimes
younger) to 3 years old. Often, the product name is similar to a company’s formula
products, with a figure “3” added on. Where growing-up milks are marketed as
suitable for feeding young children up to the age of 36 months, they fall under the
International Code definition of “breast-milk substitute” read together with WHA
resolution 58.32 from 2005, which recommends breastfeeding should continue for
up to 2 years or beyond

Other foods and beverages promoted as suitable for feeding a baby during the first
6 months of life when exclusive breastfeeding is recommended (including baby teas,
juices and waters) are also considered to be breastmilk substitutes

30 Nutrient and promotion profile model

ANNEX 5.
Health and nutrition claims

Health claim means any representation that states, suggests or implies that a relationship exists between
a food or a constituent of that food and health. A health claim includes but is not limited to the following:
i. a
 nutrient function claim that describes the physiological role of the nutrient in growth, development
and normal functions of the body;
ii. any other function claim concerning specific beneficial effects of the consumption of foods or their
constituents that relate to a positive contribution to health or to the improvement of a function or to
modifying or preserving health; or
iii. a reduction of disease risk claim relating to the consumption of a food or food constituent, in the context
of the total diet, to the reduced risk of developing a disease or health-related condition. In this context,
health means a state of complete physical, mental and social well-being and not merely the absence
of disease or infirmity.

Nutrition claim means any representation which states, suggests or implies that a food has particular
nutritional properties including but not limited to the energy value and to the content of protein, fat
and carbohydrates, as well as the content of vitamins and minerals. The following do not constitute a
nutrition claim:
a. the mention of substances in the list of ingredients;
b. the mention of nutrients as a mandatory part of nutrition labelling;
c. q
 uantitative or qualitative declaration of certain nutrients or ingredients on the label if required by
national legislation.

Annex 5 31
ANNEX 6.
Types of promotion

Promotion is broadly interpreted to include the communication of messages that are designed to persuade
or encourage the purchase or consumption of a product or raise awareness of a brand. Promotional
messages may be communicated in a variety of settings, including in-store promotions and via traditional
(such as television) and digital mass media. Marketing promotion also includes the packaging, branding
and labelling of a product. In addition to promotional techniques aimed directly at consumers, measures
to promote products to health workers or to consumers through other intermediaries are included. There
does not have to be a reference to a brand name of a product for the activity to be considered as advertising
or promotion. Cross-promotion (also called brand-crossover promotion or brand stretching) is an additional
form of marketing promotion included in this definition of marketing in which customers of one product
or service are targeted with promotion of a related product. Promotional messages and cross-promotion
that this NPPM applies to are further defined in the WHO guidance on ending the inappropriate promotion
of foods for infants and young children and implementation manual (1).

Practices commonly used to promote foods for infants and young children

1. Advertising activities and materials:

a. media advertisements (e.g. TV, radio, online, print materials); and
b. any audio-visual material meant to promote relevant products using TV/radio/print as a mean of
dissemination (e.g. TV/radio commercials, billboards, posters, newsletters, pamphlets, promotion
in books, magazines, journals or newspapers).
2. Online promotions on internet (e.g. Facebook, Twitter or other social media).
3. Non-advertising promotion activities:
a. promotion or sales inducement at the location/place where designated products are sold (e.g. special
displays/offers/sales, discount coupons and rebates, loss-leaders and tie-in sales);
b. promotion in communities and public places (e.g. banners, free product distribution/ company gifts,
discount coupons); and
c. promotion in health-care facilities and by health workers (e.g. donation or acceptance of company
equipment/services/gifts/other incentives, use of health facilities for commercial events/contests/
campaigns, distribution of any gifts or coupons to parents/caregivers/families, etc.);
4. Labelling, messaging and packaging, including health and structural claims, recommending or promoting
bottle feeding, and pictures, images and wording suggesting appropriate use of the product for infants
less than 6 months old.
5. Cross promotion of products, including through misleading labelling, and direct contact of company
representatives with mothers and other caregivers via social media.

References

1. Guidance on ending the inappropriate promotion of foods for infants and young children: implementation manual. Geneva: World
Health Organization, 2017 (https://apps.who.int/iris/handle/10665/260137, accessed 8 October 2022).

32 Nutrient and promotion profile model

The WHO Regional Office for Europe
The World Health Organization (WHO) is a specialized agency of the United Nations created in 1948 with the primary responsibility for
international health matters and public health. The WHO Regional Office for Europe is one of six regional offices throughout the world,
each with its own programme geared to the particular health conditions of the countries it serves.

Member States
Albania Greece Portugal
Andorra Hungary Republic of Moldova
Armenia Iceland Romania
Austria Ireland Russian Federation
Azerbaijan Israel San Marino
Belarus Italy Serbia
Belgium Kazakhstan Slovakia
Bosnia and Herzegovina Kyrgyzstan Slovenia
Bulgaria Latvia Spain
Croatia Lithuania Sweden
Cyprus Luxembourg Switzerland
Czechia Malta Tajikistan
Denmark Monaco Türkiye
Estonia Montenegro Turkmenistan
Finland Netherlands Ukraine
France North Macedonia United Kingdom
Georgia Norway Uzbekistan
Germany Poland

World Health Organization

Regional Office for Europe
UN City, Marmorvej 51,
DK-2100, Copenhagen Ø, Denmark
Tel.: +45 45 33 70 00
Fax: +45 45 33 70 01
Email: [email protected]
Website: www.who.int/europe

WHO/EURO:2022-6681-46447-67287