Response to CMA report

The Competition and Markets Authority (CMA) report offers comprehensive analysis around the unaffordable prices of infant formula

14 February 2025

The Competition and Markets Authority (CMA) have published their final report in their infant formula and follow on formula market study, setting out findings and recommendations to the UK Government to deliver better outcomes for families who depend on infant formula to feed their babies. The report confirms that infant formula prices have soared and that robust interventions are needed to enforce existing regulations and to better support informed choice for families in infant feeding.

We are pleased to see the report shine a light on the unaffordable prices of infant formula and its impact on families. Findings reveal how high prices and misleading marketing tactics of the infant formula industry add financial strain on family budgets and obscure the impartial information provided by the NHS which families rely on when navigating important decisions around infant feeding.

Findings further inform critical recommendations by the CMA, including to standardise infant formula packaging, enhance information for families on the nutritional equivalence of all infant formula, extend the advertising ban to include follow on formula and strengthen regulatory enforcement.

Whilst the proposed recommendations are a positive step, we would like to see the recommendations go even further to include a price cap which would provide a robust and sustainable solution for families struggling to afford infant formula and provide equitable, effective and long-term relief.

In response to the CMA recommendations to Government, the UK Committee for UNICEF (UNICEF UK) Baby Friendly Initiative has the following comments:

1. Standardised labelling and enhancing information for parents and caregivers in healthcare settings

The CMA’s recommendations around standardised, non-branded packaging in healthcare settings and enhancing communication to parents and primary caregivers around timely, clear, accurate and impartial information on the nutritional sufficiency of all infant formula products are commendable. Clear and verifiable information on products will empower parents and primary caregivers to make informed choices, reducing the influence of misleading marketing.

2. Equipping families with clear and prominent information when they are shopping

We welcome recommendations to Government that support the provision of clear, prominent and accurate information around the nutritional sufficiency of all infant formula to families in health and retail settings. The recommendation to display all brands of infant formula together on shelves and separately from other types and brands of formula milks in order to prevent the pervasive cross-promotion of products is also welcome. These are critical steps to ensure that parents and primary caregivers have the clear information they require to make informed purchasing decisions free from misleading marketing.

3. Extending the advertising ban to include follow on formula

Extending the ban on advertising to include follow on formula is a crucial step. This action addresses the promotion of unnecessary follow on formula products. We would like this to go further to cover unregulated toddler and growing up milks aimed at children 1-3 years of age. Cows’ milk can be introduced as a main drink for children at 1 year old and is a lower-cost alternative to these products.

4. Implementing effective enforcement

The CMA’s attention to the tactics employed by infant formula companies, such as cross-promotion to circumvent UK law, is vital. We support recommendations that strengthen enforcement and introduce a competent and independent authority to pre-approve all products and labels before they enter the market, which will go a long way to enhance transparency and prevent inaccurate and misleading information.

5. Implementing effective price regulation

We call for recommendations to go further than the use of loyalty points. To earn loyalty points, families are first required to spend money which is not a viable solution for many families. We reiterate our calls for a price cap which would provide a robust and sustainable solution for all families struggling to afford infant formula and provide equitable, effective and long-term relief.

Other significant areas

1. Healthy Start

We consider an important recommendation to Government to be addressing the inadequacy of the Healthy Start scheme in England by widening its eligibility and access and increasing its value.

2. Review by the Scientific Advisory Committee for Nutrition (SACN)

In light of the WHO revised recommendations and the current cost of living crisis, we would also like to see the Scientific Advisory Committee for Nutrition (SACN) be requested by Government to review the rationale for follow on formula and whether it has a role in infant and young child feeding in the UK. A review to incorporate this WHO international policy into UK health policy could present considerable savings for families.

In summary, CMA recommendations to Government represent a comprehensive analysis with clear recommendations around the unaffordable prices of infant formula and the impact this has on parents and primary caregivers and their babies. We see this as a positive development and we urge the Government to respond quickly and thoroughly to these recommendations, and to go further to include a price cap to ensure that all families have access to affordable and nutritionally adequate infant formula.

 

Commenting on this topic, UNICEF UK Baby Friendly Initiative Programme Director Shereen Fisher said:

“No family should have to struggle to afford the formula their baby needs. At a time when the cost-of-living crisis has left many families struggling to make ends meet, parents deserve clear, honest, information and fair pricing, not confusion and unnecessary costs.

“Today’s CMA report provides comprehensive analysis and clear recommendations around the unaffordable prices of infant formula and the impact this has on parents and their babies.

“We commend the proposed recommendations to Government to standardise infant formula packaging, enhance information for parents on the nutritional equivalence of all infant formula, as well as the extension of the advertising ban to include follow on formula.

“To help protect the most vulnerable babies, we would like to see the recommendations to Government go even further to include a price cap on infant formula which we believe is essential to protect families in the long term from unjustified price increases. This action would provide a robust and sustainable solution for families struggling to afford infant formula and provide equitable, effective and long-term relief.