IBFAN comment on revision of Codex Follow-up Formula StandardSECTION B  at Step 5.  General Comments

IBFAN considers that the text is NOT ready for adoption for the following reasons:

  • The lack of adequate safeguards to prevent inappropriate marketing of these products will lead to an increase in their needless use around the world as projected in business forecasts. WHO and other health authorities declare follow-on milks and toddler milks for young children “not necessary”. Continued breastfeeding is recommended to two years and beyond for optimal young child health, hence the use of these products, which function as breastmilk substitutes pose a risk to the health of young children during critical stages of growth and development. The current text will lead to children being fed inappropriate expensive products that do not meet their nutritional needs.
  • The current text fails to forbid the deceptive marketing strategy of cross promotion between product categories for drinks for young children, other formula and follow-up milks and products The text in Section 9.6.4 forbids only references to infant formula. Current marketing practices demonstrate that this is an insufficient safeguard. The text should clearly state that marketing of Drinks for young children should not ‘ resemble’ infant formula, FSMPs and other drinks and foods marketed for infants and young children.
  • Follow-on milks and drinks for young children must carry the warnings regarding intrinsic contamination for products in powdered form.
  • IBFAN maintains its original position that all four categories of products that FUNCTION as breastmilk substitutes – infant formulas, formulas for special medical purposes, follow-up formulas and drinks for young children – should be brought under one Codex standard that is divided into 4 parts with one overarching preamble.  It would then be clear that all products are covered by the marketing restrictions outlined in the International Code and subsequent relevant WHA Resolutions, ie – none should be promoted in any way.



IBFAN considers that the Guidelines are not ready for adoption.  IBFAN has always maintained that there is no need for a Codex Guideline for RUTF – and that the risks of having one outweigh the benefits.  If a Guideline is necessary then it should be produced by appropriate bodies such as WHO and UNICEF, whose remit is solely the pursuit of public health.

While Codex has an important role in ensuring that all foods and commodities are as safe and nutrition as possible, it is not the appropriate forum for discussions about vulnerable malnourished children. Decisions at Codex invariably encourage increased global trade and are taken on the basis on politically and commercially  influenced consensus, not on sound credible evidence.    The Guidelines risks subverting “the UN Strategy to build capacity within countries to produce RUTF where needed, while ensuring appropriate use”.

The Guidelines fail to include safeguards to prevent the marketing of RUTF products and in so doing leave the door open for commercial exploitation that increases the risk of unnecessary and inappropriate use.

The Guidelines may trigger diversion of public funds away from support for sustainable solutions such as breastfeeding and locally sourced, culturally appropriate, bio-diverse family foods.

The Codex Standard covering Formulas for Special Medical Purposes (CODEX STAN 72 –1981) is not a sufficient safeguard, because FSMPs are designed to be sold on the open market. Categorisation as an FSMP has lead to an increase in inappropriate marketing of these products.

The Codex process is not adequately safeguarded from conflicts of interest and undue influence from manufacturers and distributors of the products under discussion has subverted the public health purpose.

The Guidelines are likely to be used by manufacturers and distributors to put pressure on governments to accept imports of products that may not be needed or wanted.

CL 2020/23/OCS-CF 01/20 Proposed draft MLs for total aflatoxins in certain cereals and cereal-based products including foods for infants and young children 30/06/2020


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