DEVELOPMENT OF A GUIDELINE FOR READY TO USE THERAPEUTIC FOODS (RUTF) (Chaired by South Africa and co-chaired by Senegal and Uganda)
IBFAN’s comments on the First Consultation Paper: IBFAN-SUBMITTERS RESPONSE_1stCONSULTATION_RUTF AMENDED-1 IBFAN Final
IACFO’s comments on the First Consultation Paper: IACFO_1st RUTF CONSULTATION 2017
Some key points in our submission:
- RUTF products should not be available, sold or promoted on the open market.
- RUTF products are for therapeutic purposes.
- Inappropriate marketing can result in unnecessary use with loss of confidence in local family foods and sustained breastfeeding.
- It is critical that these products be used in compliance with the International Code and relevant subsequent WHA resolutions and the Guidance on inappropriate marketing of foods for infants and young children.
- RUTF should not be cross promoted with Breastmilk Substitutes and should carry no promotional or idealising claims or pictures.
- IBFAN and IACFO support the use of local foods to develop culturally suitable and nutrient rich RUTFs and that national authorities are best to provide solutions to address the treatment of SAM.
- The Guidelines must state that National authorities retain the ability to provide national solutions and prevent unnecessary imports of expensive RUTF products.
- In emergency situations RUTF products may be the only available solution to feed and save children’s lives therefore no international trade standards are needed
To advocate for national positions to safeguard the appropriate use for RUTF contact your national Codex Contact Points (these can be accessed at http://www.fao.org/fao-who-codexalimentarius/members-observers/members/en/?no_cache=1) or other relevant policy makers.
Codex revision of the Follow-up Formula Standard.
IBFAN’s submission on scope and labelling relating to the revision of the Follow-up Formulas Standard is HERE
IACFO’s submission on scope and labelling relating to the revision of the Follow-up Formulas Standard is HERE
The Background paper for the consultation states: It should be noted that at CCNFSDU38, the Codex Secretariat noted that it was possible to keep the matter open on the final form and structure of the Standard. This could include one Standard in two parts (as is currently being worked on by the eWG), two separated standards, or merging with other standards.
IBFAN is proposing as the best option that all formulas 0-36 months are brought under a revised and renamed Infant Formula Standard. We believe that one over-arching standard – with 3 or 4 sections – will help regulators and policy makers bring in the safeguards on the composition, safety, labelling and marketing that are needed to prevent misleading marketing and unsafe products.
The key things we are calling for for Follow-on Formulas and milks for young children are:
- That the products should not be referred to as ‘fortified’ this term is promotional
- There should be no promotional claims, idealisation, pictures etc
- No optional ingredients (or as few as possible when justified by “Relevant convincing / generally
- accepted scientific evidence or the comparable level of evidence under the GRADE classification.”
- Mandatory declarations/labelling etc
- A clear mention that the products are not necessary (6-36m)
- That Infant formula can be used from birth until 12months and beyond.
- That the Int Code,Global Strategy and all WHA Resolutions are mentioned with key resolutions and the Guidance highlighted alongside specific key sections.
- Code of Hygienic Practice mentioned
- No cross branding
Codex Member Sates are strongly urged to support the inclusion of the WHO Guidance in standards covering these products. (Please note that only Member states and Observers who have joined the Electronic Working Group can submit comments.)
Background: At the last Codex Nutrition meeting in Hamburg in December 2016, the interests of child health came above trade for once when, in a breakthrough consensus, the Committee agreed to refer to WHO Guidelines and Resolutions in the Codex standards covering formulas for babies 6-36 months – bringing Codex a step closer towards policy coherence with WHO. In 2016 the World Health Assembly Resolution (WHA 69/9) ushered in WHO’s technical Guidance on Ending the Inappropriate Promotion of Foods for Infants and Young Children. Among other things, this Guidance clarified that all milks marketed for babies 0-36 months are breastmilk substitutes and should not be promoted. (1)
These expensive sweetened and flavored milks (called ‘follow-on milks’, ‘growing-milks’ ‘toddler milks’ etc) share branding with infant formulas from birth and are driving the formula market – a market set to rise by 55% from US$45 billion to US$70 billion by 2019. The aggressive marketing of these products is not only misleading parents, undermining national health messages and risking child health and survival, but exacerbating the obesity epidemic.(2) Infant formula can be used from birth to 12 months and beyond, so these products are not necessary and this should be clearly stated in Codex standards.
7. NAME OF STANDARD
It should be noted that at CCNFSDU38, the Codex Secretariat noted that it was possible to keep the matter open on the final form and structure of the Standard. This could include one Standard in two parts (as is currently being worked on by the eWG), two separated standards, or merging with other standards.
The Name of the Standard should be amended to reflect the approach that is determined and align with the name of the product(s) included. Until the final form and structure is determined, and the Name of Product(s) finalised, the Chairs suggest deferring a decision on the Name of the Standard.
140th WHO Executive Board Meeting (23rd January-1st February) Geneva
The WHO Executive Board Meeting continues. Two days were spent in closed meetings for the selection of the short-list of three for the post of the new Director General of WHO. CLICK HERE
IBFAN’s statements on the Agenda items will appear on the WHO website and HERE
Agenda Item 14.3 Engagement with non-State actors.
IBFAN is one of WHO’s longest-standing partners. Our work since Halfden Mahler’s time – has centred on WHA Resolutions that have saved countless infant lives.
IBFAN is anxious that WHO emerges from the FENSA process as the lead agency in public health, able to fulfill its constitutional mandate and not be relegated a limited role in a ‘multi-stake-holderised’ global health architecture. Through ill-defined terms such as ‘partnership’ ‘stake-holder’ and ‘trust’ corporations claim the right to participate in public health decision-making processes, sidelining governments, the UN and peoples’ human rights.
Despite this, FENSA was adopted – with promises of due diligence and increased transparency, and that WHO would “exercise particular caution…when engaging with private sector entities …whose policies or activities are negatively affecting human health..” The DG report further promotes this notion.
The report was presented to Member States too late for us to comment before the meeting of WHO’s Programme Budget and Administration Committee meeting (as Dr Chan called for many times). The first five applications for Official Relations are a test of its thoroughness. The Gates Foundation application is an example that has prompted a new letter to the EB from 35 organisations. That the Foundation has made substantial contributions to WHO and many health initiatives is matter of public record. That it might have an influence on WHO’s nutrition policy setting– for good or for bad – we make no judgement here – is also no secret.
Less well known are its substantial investments in food and beverage industries – investments that are merely noted in the report as: “engagements with select members of the pharmaceutical… food and beverage…health care… industries in pursuit of our public health goals.”
The FENSA process could have provided clarity on the relationship between WHO and the Foundation. This opportunity has been lost, and public trust that the process will tackle the task ahead properly has been severely damaged.
We ask that the Gates decision be delayed, ‘stakeholder’ defined and FENSA reviewed and evaluated as soon as possible and that WHO is provided with adequate, untied funding to carry on its essential.
IBFAN Statement on Agenda Item 10.1 Preparation for the third High-level Meeting of the United Nations General Assembly on the Prevention and Control of Non-communicable Diseases in 2018 (delivered Saturday, 28th January. CLICK HERE for webcast. move slider to 1.37.38 – the last of 10 NGO statements)
Now the GCM proposes an annual self-reporting mechanism for NSAs that we believe will mislead the public and policy makers alike. Although it is welcome that NSAs are ‘encouraged’ to submit only actions within their core area of business, spurious marketing strategies masquerading as health initiatives could be registered and so gain credibility from the image transfer from WHO. The baby food industry hi-jacking of World Breastfeeding Week, is just one example. The promotion of voluntary – here today, gone tomorrow – initiatives, can also undermine government resolve to bring in effective legislation.
Since WHO states that it does not have the capacity to ‘quality assure’ all activities and guarantee that they are in conformity with WHO policy, this idea should be abandoned. It is far too risky.
Last, we call on WHO to be consistent in its messaging. On the one hand WHO emphasises micronutrients – on the other, it encourages consumption of fresh fruit, vegetables and minimally processed, bio-diverse foods and of course, breastfeeding. Over-emphasis on single nutrients opens the door to idealising health and nutrition claims on less healthy processed products. The public meanwhile is unaware that high heat processing and storage can destroy essential nutrients in these products.
You could stare at a banana all day and not see the nutrients it contains. Whereas a glance at a package laden with nutrition claims immediately inspires confidence.
We are keen to continue working with WHO to address this challenge
IBFAN statement on 10.4 Commission on Ending Childhood Obesity (ECHO): Implementation Plan
IBFAN participated in the development of the ECHO Report and is pleased that many of our comments were taken on board, in particular the recognition of the importance of breastfeeding and appropriate complementary feeding in obesity prevention.
As you know, States obligations with regard to breastfeeding are defined in the 3-pillar framework ‘Protect, Promote and Support’ adopted in 2002 by the WHA. Recently, a group of UN experts, among whom the Special Rapporteur on the Right to Health and the Committee on the Rights of the Child, have reiterated that these obligations, including protection against misleading marketing, constitute an integral part of States’ human rights obligations.
Mothers themselves have no obligation to breastfeed their child. Indeed, they always remain fully sovereign over their own body. It is rather the role of States to ensure that mothers do not face obstacles to breastfeeding.
States have the obligation to provide mothers with accurate and unbiased information and counseling from the start of their pregnancy, including on the continuation of breastfeeding up to 2 years or beyond. We regret that key factor, is not mentioned in Action 4. The Baby Friendly Hospital Initiative should also be mentioned as the external audit that guarantees implementation of the Ten Steps.
To be consistent with the recommendation to exclusively breastfeed up to 6 months, States should grant working mothers with a minimum of 6 months of maternity leave.
Finally in relation to education, we are pleased that Action 5 warns of the risks of corporate sponsorship and the need for conflict of interest safeguards – corporate sponsorship of education blurs the lines between marketing and education. As highlighted by the Special Rapporteur on the Right to Education the rapid increase in the commercialization of education is a major concern
IBFAN Statement Agenda item 7.1.2 (Emergences)
IBFAN is the global network that protects breastfeeding and works for policy coherence with WHO’s Resolutions.
Our work is especially important in emergencies, where responses are often characterized by influxes of unsolicited donations of all manner of baby feeding products – donations that can often do more harm than good.
Breastfeeding is a lifeline for infants and young children in emergencies, has zero environmental impact, and States have a human rights obligation to ensure that mothers are enabled to make an informed decision on infant feeding, free of conflicts of interests. Yet, breastfeeding is often forgotten or badly managed.
Meanwhile, media reports show starving babies and rarely question why they are not breastfed. IBFAN’s World Breastfeeding Trends Initiative assessment of policies and programmes on Infant feeding during emergencies show that implementation of UN recommendations on this is dismal.
WHO – as a norm-setting, rather than implementing agency – can play a key role in reversing this situation by promoting emergency preparedness protocols that aim to improve food security in the long term. Such actions could even be opportunities for public health generally.
We know emergencies prompt philanthropy, but they are also opportunities for commercial exploitation and the Business of Malnutrition. While the speedy delivery of products can be essential in certain circumstances, emergency relief protocols must prevent over-emphasis on product-based, quick-fix approaches to the treatment of malnutrition, approaches that can undermine confidence in breastfeeding and sustainable, local, bio-diverse foods. If breastmilk substitutes are required they must be purchased, distributed and used according to the UN’s agreed strict criteria. Training is essential – to support breastfeeding, of course, but also to minimize the risks of artificial feeding for non breastfed children, whilst ensuring that breastfeeding is not undermined.
We look forward to continuing work with WHO on this important issue.
Codex REPORT OF THE MEETING (including participants list)
CODEX Press Release from the meeting
CODEX – URGENT issues to be discussed at the 38th Session of the Codex Committee on Nutrition and Foods for Special Dietary Uses in Hamburg, Germany, 3-9th December 2016.
IBFAN, IACFO, ENCA and ILCA will be attending and have sent comments to the Electronic Working Groups (EWG) on RUTF, Follow-on Formulas and Bio Fortification.
Background documents and information Click Here
1 Comments on Follow-on Formulas
The fact that Codex went against the advice of WHO demonstrates its failure to put consumer protection first and the urgent need for coherence between Codex and WHO Policy. This issue was on the agenda of the Codex Commission in July, following on from the calls at the 69th World Health Assembly in May 2016, IBFAN is calling on all Governments to call for a strengthening of Codex’ Governance and Conflicts of Interest rules.
IBFAN: ibfan-comment-review-of-the-standard-for-follow-final-1 (Codex Stan 156-1987) at Step 3
2 Ready to Use Therapeutic Foods (RUTF) draft proposal for a Guideline
Ready-to-use Therapeutic Food Market to Exceed US$ 617.4 Mn by 2024
Global Market Study on Ready-to-use Therapeutic Foods: Drinkable Therapeutic Food Segment Expected to Gain Significant Market Share
Market drivers and trends Increasing government as well as NGO focus on the treatment of malnutrition is expected to drive revenue growth of the global ready-to-use therapeutic food market over the forecast period. Increasing instances of malnutrition along with a rapidly growing population is another key market driver. Also, an increasing demand for drinkable ready-to-use therapeutic foods and rising global emergencies and disasters is expected to further fuel market growth. However, increasing consumer/local government shift towards local ingredients and inconsistencies in ready-to-use therapeutic food milk products thereby creating a risk of contamination are factors likely to restrict market growth during the forecast period.The global ready-to-use therapeutic food market offers great opportunities for market players with UNICEF encouraging the domestic production of ready-to-use therapeutic foods. ____________________
3 Definition for the term “Biofortification”
IBFAN has many concerns about this proposal that was first put forward by IFPRI. (International Food Policy Research Institute). For example:
- It obscures the fact that the term Bio-fortification includes genetically engineering; its attempts to justify the use of biofortified foods as a means to reduce malnutrition;
- it suggesting that increasing one or two nutrients in a food, such as golden rice or sweet potatoes, can alleviate malnutrition.
- It may impact negatively on biodiversity. The use of herbicides, such as glyphosate, can create super weeds and have negative health impacts. Genetically modified food production is patented and its seed use is restricted. It is not a sustainable means for food production and can increase costs to farmers.
ECHO Consultation on Draft Implementation Plan
Consultation open until 12 October 2016
The Draft Implementation Plan guiding further action on the recommendations included in the Report of the Commission on Ending Childhood Obesity is open for consultation.
The purpose of this consultation is to gather feedback on the Draft Implementation Plan for the recommendations of the Commission on Ending Childhood Obesity from Member States and other interested parties. The comments received will be taken into consideration as the document is revised prior to submission to the 140th session of the Executive Board.
Please send feedback on the Draft Implementation Plan to firstname.lastname@example.org before 12 October 2016.
Public consultation on the draft scientific and technical guidance for the preparation and presentation of a health claim application
Deadline: 12 September 2016
EFSA has launched an open consultation on its draft scientific and technical guidance for the preparation and presentation of a health claim application.
This document presents a common format for the organisation of information for the preparation of a well-structured application for authorisation of health claims which fall under Articles 13(5), 14, and 19 of Regulation (EC) No 1924/2006. This guidance outlines: the information and scientific data which must be included in the application, the hierarchy of different types of data and study designs (reflecting the relative strength of evidence which may be obtained from different types of studies) and the key issues which should be addressed in the application to substantiate the health claim.
In July 2016 the EU Commission launched a consultation with Member States asking whether health claims should be permitted on formulas and baby foods.
Here are our comments
IBFAN comments on Updated Appendix 3 of the WHO global NCD action plan 2013-2010
Consultation 25 July – 1st September 2016
WHO ACTION PLAN for the prevention and control of NCDs in the European Region
Codex Committee on Nutrition and Foods for Special Dietary Uses (CCNFSDU) Electronic Working Group (EWG)
REVIEW OF THE STANDARD FOR FOLLOW-UP FORMULA (CODEX STAN 156-1987) (Chaired by New Zealand and co-chaired by Indonesia and France) Second Consultation Paper Deadline for Comments 19th July 2016
Codex Committee on Nutrition and Foods for Special Dietary Uses (CCNFSDU) Electronic Working Group (EWG) DEVELOPMENT OF A PROPOSED DRAFT DEFINITION FOR BIOFORTIFICATION (Chaired by Zimbabwe and South Africa) Second Consultation Paper June /July 2016
Codex Committee on Nutrition and Foods for Special Dietary Uses (CCNFSDU)
Codex Guidelines for Ready to Use Therapeutic Foods (RUTF) 2nd round of comments (submitted 23rd June 2016).
page down for other comments
CODEX ALIMENTARIUS COMMISSION (CAC) 39th Session FAO Headquarters, Rome, Italy,
27 June – 1 July 2016
The Agenda is HERE
There were many important issues on the agenda of the CAC – including Antimicrobial Resistance, Lead Levels, rBST. But perhaps most importantly for IBFAN, and following on from the calls at the 69th World Health Assembly in May 2016, there was a discussion about the need for policy coherence between Codex and WHO policies. Please encourage your governments to call for a strengthening of Codex’ Governance and Conflicts of Interest rules.
RELATIONS BETWEEN FAO AND WHO POLICIES, STRATEGIES AND GUIDELINES AND CODEX WORK (Agenda Item 10)
137. The Chairperson presented the conclusions of CCEXEC7152 and noted that CCEXEC had not been in a position to discuss the item in detail due to the late availability of the document.
138. Several delegations thanked the parent organisations for initiating this discussion, acknowledging that there was a need to ensure awareness of FAO and WHO policies and guidelines at the national level when coordinating positions for Codex. It was also stressed that the mandate of Codex differed from that of FAO and WHO, meaning that issues raised by FAO and WHO would be taken into consideration when relevant to Codex work. They noted that existing mechanisms for communication generally worked well.
139. The Representative of WHO referred to the discussion at CCEXEC7153 and recalled that over the past ten years the WHA had made several requests to Codex to strengthen its work in supporting public health efforts. Simultaneously WHA had encouraged Member States to use Codex standards and guidelines to protect and promote human health, the latter being the common mandate of WHO and Codex.
140. The Representative noted that there were challenges in discussions at WHA concerning the use of Codex standards and guidelines at the national level and their reputation at the international level. These challenges were linked to the fact that Codex standards and guidelines were not always developed taking into account WHO policies, strategies and guidelines aimed at addressing the high-priority public health concerns of Member States such as obesity and diet-related noncommunicable diseases (NCDs).
141. The Representative noted further that the need for Codex to fully take into account the WHO policies, strategies and guidelines had been raised at CAC38 by Papua New Guinea as the Chair of CCNASWP54. The document recommended that Codex take action to reduce salt/sodium intake to control NCDs (as recommended by the NCD Action Plan 2013–2020 adopted by WHA in 2013), through developing maximum levels of sodium contents in selected food products. The matter could not be discussed at CAC38 due to lack of time.
142. The Representative further recalled the status of Codex as an intergovernmental body operating under the auspices of FAO and WHO. This status permitted adopted Codex standards to be published with the FAO and WHO emblems. This privileged status of Codex underscored the need for coherence between the work of Codex and WHO policies, strategies and guidelines which Codex members, as WHO Member States, had signed up to. Codex could only benefit from demonstrating to the governing bodies of WHO greater coherence of its standards with WHO policies, strategies and guidelines, which in turn would help secure ongoing financial and technical support from WHO to the work of Codex. The Representative recommended that the Commission take practical steps forward as described in paragraph 15 of CX/CAC 16/39/11.
143. The Representative of FAO thanked the members for their reflective and considered feedback and apologised for the late availability of the working document. She noted that the interventions had demonstrated a high level of awareness of the relevance of FAO and WHO policies to the work of Codex and a recognition of the importance of these policies being fully considered in carrying out the standard-setting work of Codex. She agreed with the observations made by countries that, in many cases, there was a need for better communication at national level to engage all relevant stakeholders in discussions of Codex issues. She considered, however, that the examples and analysis contained in the working document had demonstrated some scope for improving systematic and effective communication at global level as well. She underlined that while Codex existed under the umbrella of FAO and WHO, the substantive standard-setting work of Codex was member driven: it was the Commission’s decision which standards to set. She concluded by noting that administrative matters related to the Codex Secretariat were governed by the relevant FAO rules and procedures in accordance with the Codex Statutes.
144. In spite of the very late availability of the document, the Commission noted that:
(i) The main aim of the document was to raise awareness so that Codex fully consider FAO and WHO policies, strategies and guidelines when it undertakes its work;
(ii) Codex is a unique member-driven organization with a specific mandate to develop internationally harmonized food standards to protect consumer health and ensure fair practices in food trade;
(iii) FAO and WHO adopt and implement policies, strategies and guidelines, which might be relevant to the work of Codex;
(iv) There is a need to increase the dialogue and communication between FAO, WHO and Codex experts at the national, regional and global levels;
(v) Codex has always given due consideration to relevant policies, strategies and guidelines in undertaking its work being thereby enabled to make informed decisions.
145. The Commission proposed to CCEXEC to further discuss the working document at its 73rd session; noted the need to increase the visibility of Codex in WHO governing bodies, and noted the proposal by IFPRI for Codex to organize side events at WHA.
Committee on Nutrition and Foods for Special Dietary Uses (CCNFSDU) Guideline for Ready-to-Use Therapeutic Foods (RUTF)41 Paragraghs 102 – 107.
Committee on Nutrition and Foods for Special Dietary Uses (CCNFSDU)
Guideline for Ready-to-Use Therapeutic Foods (RUTF)41
102. The Commission noted the wide support for this new work especially in view of the fact that there was a need for guidance for governments and producers on RUTF used in the management of severe acute malnutrition (SAM). Delegations indicated that these products were already produced in some of their countries and/or used in the management of SAM not only in refugee populations, but also for malnourished infants and geriatrics and thus the guidance would be helpful.
103. The Delegation of India did not support the proposal due to the lack of sufficient scientific data in favour of using RUTF in the management of SAM in community settings and noted that the review from WHO on the safety and efficacy of using this product was not yet available.
104. The Representative of WHO explained that the ongoing systematic reviews, which WHO was undertaking, would not develop guidance on the nutrient composition of RUTF. WHO was more comfortable with the proposal now as it no longer included ready-to-use supplementary foods (RUSF) for which there was little evidence of their effectiveness in the treatment and prevention of moderate acute malnutrition.
105. She also noted that FAO and WHO had worked closely with UNICEF to provide this proposal for consideration to CCNFSDU and supported this new work to go ahead.
106. Noting the clarification from WHO, India expressed support for the new work.
107. The Commission approved the new work.
|Recommendation 3 of the Guidance states: Relevant Codex standards and guidelines1 should be updated and additional guidelines developed in line with WHO’s guidance to ensure that products are appropriate for infants and young children, with a particular focus on avoiding the addition of free sugars and salt|
1 Codex Guidelines for Ready to Use Therapeutic Foods (RUTF) The deadline for the 2nd round of comments on RUTF is 23rd June.
IBFAN and IACFO have submitted comments to the Codex Electronic Working Groups on Ready to Use Therapeutic Foods (RUTF) and this paper: SECOND CONSULTATION PAPER ON GUIDELINE FOR RUTF:.
This is a controversial issue. IBFAN and many developing countries maintain that a Codex Standard (or Guideline) is not needed for these products. While RUTFs can be useful in the treatment of Severe Acute Malnutrition (SAM) their use must be integrated into sustainable, local, family based solutions, that also help build health care systems. Codex instruments are designed to break down barriers to trade and boost trade. In this context there is a risk that they will encourage emphasis on single product approaches that ignore the underlying causes of malnutrition and that resources will be diverted away from training on breastfeeding and appropriate complementary feeding. It is essential that Governments strictly control the promotion, labelling, availability and safety of these products.
At the last meeting of the Codex Nutrition Committee (CCNFSDU37, Nov 2015) the decision was taken to establish an eWG, led by South Africa and co-chaired by Senegal and Uganda, to develop Guidelines for these products for babies suffering from Severe Acute Malnutrition (SAM).
Read the two page briefing used last November: RUTF Bullett FINAL
IBFAN is advocating that these products are:
- provided by the public health authorities on prescription only for therapeutic purposes,
- used only under the strict medical supervision of an independent health worker.
- not used or sold for preventative purposes
- not placed on the market
- not labelled, promoted or idealised by health or nutrition claims or other means
- that all provisions of the International Code or WHA Resolutions are included in the Guidance.
- that any decisions regarding the safety or composition of these products must be based on evidence that meets WHO’s definition of scientific substantiation: “Relevant convincing / generally accepted scientific evidence or the comparable level of evidence under the GRADE classification’ Codex baby food standards referred to a mixed bag of terms, such as ‘scientifically demonstrated’ or ‘an established history of apparently safe use’
IBFAN is attending the 69th World Health Assembly – and covering several issues.
CLICK HERE for all WHA background documents and Agenda. The open meetings are web streamed and can be viewed HERE (sorry I can’t find the link – will post when I find it!)
CLICK here for some useful background papers
All NGO statements are posted HERE
Working groups are taking place all week so there are new versions every day of the Resolution to adopt the Guidance on Ending inappropriate promotion of foods for infants and Young Children. Its so clear where the pressure to weaken the Resolution is coming from:
IBFAN is advocating the adoption of the Resolution and endorsement of the Guidance. IBFAN’s Statement that will be delivered is HERE
We are also keeping a watch on the following items:
3 A69/10 Prevention and control of noncommunicable diseases: responses to specific assignments in preparation for the third High-level Meeting of the United Nations General Assembly on the Prevention and Control of Non-communicable diseases in 2018
IBFAN NCD_GCM_statement IBFAN statement on Global Coordinating Mechanism
4 A69/8 Report of the Commission on Ending Childhood Obesity
Agenda Item 6.4 of 139th Executive Board meeting, immediately following the 69th Assembly has Health and Climate Change on the Agenda. Click on the following link for an important new report: Carbon-Footprints-Due-to-Milk-Formula GUMs – final
At the request of a Member State, the Secretariat will report on the implications of the Paris Agreement, adopted in December 2015 by the twenty-first session of the Conference of the Parties to the United Nations Framework Convention on Climate Change (Paris, 30 November−11 December 2015), and on its plans to scale up support to Member States on: health resilience to climate risks; linking climate change, air pollution, and sustainable development; and systematic measurement and reporting of country progress to global health and climate change governing bodies.
IBFAN comments on an earlier draft of the Resolution (dated 3rd May) is on the following link: IBFANCOMMENTSRESOLUTION.3.5.16
OPERATIVE PARA 2 (a) to take all necessary measures to implement the guidance on ending the inappropriate promotion of foods for infants and young children, INSERT: AS A MINIMUM REQUIREMENT while taking into account existing legislation and policies, as appropriate;
OPERATIVE PARA 2 (d) DELETE this whole para: to implement, through national legislation, the Codex Guidelines on Formulated Complementary Foods for Older Infants and Young Children and other relevant Codex standards and guidelines, and to ensure that arrangements are in place and that adequate resources are available to enact, monitor and enforce such legislation;
REPLACE WITH: Require Codex standards and guidelines to be coherent with all WHO guidelines and recommendations, including the International Code of Marketing of Breastmilk Substitutes and subsequent relevant WHA resolutions.
|Work continues on the Review of the Follow-on Formula (FUF) standard that was adopted in 1987 and has done much harm. IBFAN and WHO and several Member States have been calling for consideration to be given to whether the standard is needed at all, given that the products are not necessary, and could be brought into the Infant Formula Standard. Any the compositional differences from infant formula could easily be addressed in footnotes. The important thing is to bring the marketing in line with WHO Policy – i.e. the International Code and subsequent relevant WHA Resolutions. The baby food industry, and Member States that support the growth in this market, argue that a separate standard is necessary. The fact that CCNFSDU went against the advice of WHO demonstrates the failure of Codex to put the consumer protection first.
The Submitters response form asks for comments on the composition of FUF and formulas for babies 12-36 months. (so called Growing up milks) The eWG still is not addressing marketing.
RUTF. At CCNFSDU37, the Committee agreed to establish an eWG, led by South Africa and co-chaired by Senegal and Uganda, working in English and French, to develop the Guidelines for Ready to Use Therapeutic Food.s eWG_invitation_RUTF This is another controversial issue.The Proposed Terms of Reference and list of topics to be covered drawn up by the Electronic Working Group focuses on composition and hygiene, the General Standard for the Labelling of Pre-packaged Foods and other relevant Codex texts, but includes no reference to the much needed controls on marketing, conditions or sale, the International Code or WHA Resolutions
Biofortification deadline 7th April. Zimbabwe and South Africa are chairing the Codex eWG team that is reviewing the First Consultation Paper within the timeline: 29 March to 29 April 2016. Comments requested by the 7th of April. (Click here for IBFAN comments for the November meeting.
IBFAN is concerned that this paper will help legitimise genetic modification. We are opposed to using generic terms such as “agricultural methodologies” which hide the true means of production and mislead consumers. We are also concerned about the impact of biofortification on biodiversity which can negatively effect dietary diversity and nutrition intakes.
Public consultation on EU Commission Transparency Register
Duration 01/03/2016 – 01/06/2016
Baby Milk Action reprocess: TRansparency Register
You can contribute to the consultation via the “Your Voice in Europe” site: http://ec.europa.eu/yourvoice/consultations/index_en.htm
You can send any comments or queries on the register to the Transparency Register Joint Secretariat at http://ec.europa.eu/transparencyregister/public/staticPage/displayStaticPage.do?reference=CONTACT_US.
Transparency Register: http://ec.europa.eu/transparencyregister/public
Need to change data on your organisation?: https://webgate.ec.europa.eu/transparencyregister/restricted/ri/authenticate.do
Below is a link to our comments submitted to the UK’s Technical consultation on a draft Statutory Instrument to enforce EU Regulation 609/2013 on foods for specific groups
CLICK HERE for a link to the new Delegated Acts in all languages
Page 1-44 Directive 2006/141/EC In accordance with Article 20(4) of Regulation (EU) No 609/2013, Directive 2006/141/EC is repealed with effect from 22 February 2020.However, Directive 2006/141/EC shall continue to apply until 21 February 2021 to infant formula and follow-on formula manufactured from protein hydrolysates. References to Directive 2006/141/EC in other acts shall be construed as references to this Regulation in accordance with the scheme set out in the first paragraph. Article 14
Entry into force and application: This Regulation shall enter into force on the 20th day following that of its publication in the Official Journal of the European Union. It shall apply from 22 February 2020, except in respect of infant formula and follow-on formula manufactured from protein hydrolysates, to which it shall apply from 22 February 2021. For the purposes of the second subparagraph of Article 21(1) of Regulation (EU) No 609/2013, in respect of infant formula and follow-on formula manufactured from protein hydrolysates the later date referred to in the second paragraph of this Article shall be considered as the date of application.
This Regulation shall be binding in its entirety and directly applicable in all Member States.
Subject: Transparency Register – Public consultation
DEADLINE for submissions: 1st June 2016
Date: March 4, 2016
The European Commission has launched a public consultation concerning the Transparency Register. To access the consultation in all EU official languages please visit http://ec.europa.eu/transparency/civil_society/public_consultation_en.htm
We invite you to forward this message to any other parties which could be interested in this initiative including your members, clients or partners, if you have any.
Joint Transparency Register Secretariat
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Maternal, infant and young child nutrition WHO Secretariat Report, Draft Resolution and Guidance on ending the inappropriate promotion of foods for infants and young children Document EB138/8
IBFAN point by point suggestions for changes: CLICK HERE
A. Draft resolution
The Draft resolution and the Guidance contain some provisions that we warmly welcome as they are likely to contribute to the much needed increase in rates of optimal infant and young child feeding (Lancet 2016). One such provision is the needed clarity that formulas for older babies (up to 36 months) are covered by the International Code and WHA Resolution. However, there are some serious concerns that Member states must address before adoption of this important Resolution and its Annex at the 69th WHA in May. We highlight these below and urge Member states to present these to the WHO Secretariat so that the new draft reflects them adequately.
Codex: Draft Resolution Op2 d and Recommendation 3 of the Guidance The recommendation to implement Codex Guidelines and Standards into national law poses a serious risk to health. Codex standards and guidelines be must be brought fully in line with WHO guidelines, resolutions and recommendations before they are implemented into national legislation. As currently drafted the MIYCN Resolution and Guidance would undermine hard won, health protective norms already adopted by the WHA. Although IBFAN has achieved some strengthening of Codex standards and guidelines relating to products for babies, the lax/non existent conflict of interest rules of Codex have led to compromises. The Resolution specifically mentions the Codex Guidelines on formulated complementary foods CAC/GL 8-1991, which along with many other Codex texts does not fully reflect WHA Resolutions and Recommendations and are less health protective than many national laws. Codex is currently discussing the revision of the Follow-on Formula Standard and guidelines on Ready to Use Therapeutic Foods. The food industry is fighting hard to oppose the inclusion of important marketing safeguards. Strong guidance from the WHA is needed to inform this work and help Member States harmonize Codex texts with WHA recommendations.
B Annex: Guidance on ending the inappropriate promotion of foods for infants and young children Paragraph 3 creates a loophole that could lead to further increase of inappropriate marketing of fortified foods and supplements, rather than to the adequate oversight of their use.
Recommendation 4 opens the door to marketing by listing PROMOTIONAL strategies that MAY BE CONVEYED. This defeats the intent of WHA Resolution 65.6 that simply called on the DG: to provide clarification and guidance on the INAPPROPRIATE promotion of foods for infants and young children. There is therefore no justification for the inclusion of a shopping list of marketing strategies. If adopted such a list would undermine legislation that is in effect in many countries such as India, Kenya, Bangladesh, South Africa etc. Any reference in the Guidance that could imply that certain ‘promotions’ are endorsed by the WHA, should be replaced with terms such as “labeled” “put on sale” ‘traded ‘ etc.
Emergencies Annex: Guidance Recommendation 6 undermines previous WHA decisions. Without any explanation it provides direct access of companies to emergency relief operations and to health workers and health facilities. The two exceptions in this recommendation go directly against the WHA decisions:
- the exception on emergencies goes against the WHA 47.5 and WHA 63.23, which provide a clear guidance to member states on planning, implementing and supporting emergency relief operations in infant nutrition.
- the exception regarding ‘officially sanctioned health programmes’ introduces two problems: First the WHA 47.5 aims as ensuring no free and low cost supplies of products covered by the International Code to any part of the health care system. As the term ‘officially sanctioned health programmes’ is not defined, this exception can lead to violations of the WHA 47.5. It also introduces a loophole which could lead to indiscriminate and harmful use of products under the scope of this Guidance. Finally, this Recommendation is directed to companies who should never be direct providers of their products be it in emergencies or any other programmes. The need for any foods for infants and young children should be assessed by qualified emergency relief staff and products resourced through normal procurement channels.
World Health Organisation Executive Board Meeting
25- 30th January 2016.
CLICK HERE for FENSA speech
We are coming to the end of the WHO Executive Board meeting All the NGO statements are HERE including IBFANs on FENSA, Maternal and Child Nutrition (MCN) and NCDs
I will deliver IBFANs NCD intervention – if the NCD debate starts soon. You can catch it on the WHO website http://www.who.int/mediacentre/events/2016/webstreaming/eb138/en/
FENSA: the meeting with April will go ahead.
European Parliament to vote on Baby foods 20th January 2016
CLICK HERE for our Press Release and background to this story
CLICK HERE for the text of the Objection on processed cereal-based food and baby food (ENVI/8/04983) that will be voted on tomorrow – 20th January.
CLICK HERE for WHO commentary on sugar
IBFAN submissions to the 37th codex Committee on Nutrition and Foods for Special Dietary Uses (CCNFSDU) Bad Soden am Taunus, Germany 23-27 November 2015
- FUF_IBFAN Agenda Item 5 Review of the Standard for Follow-up Formula (FUF) – IBFAN share’s WHO’s view that FUFs and other formulas for older babies (such as the so called Growing Up and Toddler formulas that are sure to be included in the revised FUF standard) are not necessary and their marketing undermines breastfeeding (both before and after 6 months) These products can include flavoured, sweetened and fortified milk products that pose many risks to child health, including childhood obesity. We are advocating that the safety and marketing of products already on the market are dealt with under a renamed Infant formula standard.
- Agenda Item 6 Biofortification – IBFAN’s position is that the definition must clearly inform consumers that the methods used are conventional plant breeding and genetic modification. We are opposed to using generic terms such as “agricultural methodologies” which hide the true means of production and mislead consumers. We are also concerned about the impact of biofortification on biodiversity which can negatively effect dietary diversity and nutrition intakes.
- IBFAN comment on the UNICEF discussion paper on RUFs 37th CCNFSDU [final] Agenda Item 8 Ready to Use Therapeutic Foods (RUTFs) In our comments on UNICEF’s proposal for a Codex instrument for RUTFs, therapeutic products that have such a highly specific and limited function. We highlight the risk of unintended consequences of expanding the global trade of these products and the fact that the evidence for their efficacy is weak. While we understand and share UNICEF’s wish to improve the safety, quality and timely delivery of products when they are needed, we have concerns that a Codex instrument may not achieve this aim. It may also divert funds away from support for breastfeeding and the use of local complementary foods combined with nutrition education – the most sustainable way to reduce the incidence of SAM. In countries such as India and Nepal the incidence of SAM has decreased without the use of imported and expensive RUTFs. IBFAN does not support the development of a separate commodity standard or guideline and believe that WHO, FAO and UNICEF should provide guidance and support to national governments on the comprehensive treatment of SAM appropriate to national needs and cultural practices rather than single product approaches
Draft Final Report of the Commission on Ending Childhood Obesity open for comment UNTIL 13 November 2015
Open for comment: 29 September – 13 November 2015
PREVIOUS COMMENTS by IBFAN
The Draft Final Report of the Commission on Ending Childhood Obesity is now open for comment from relevant stakeholders. In addition, the Commission will hold regional consultations and hearings throughout this consultative period.
- Read the draft final report
- The work of the Commission: timeline of events
- Ending childhood obesity: a multidimensional challenge
The Commission reviewed the feedback received on their Interim Report from relevant stakeholders and through the regional consultation. This Draft Final Report proposes key policy actions to address childhood obesity.
The Commission welcomes your suggestions and feedback on the Draft Final Report and will consider these, in addition to the inputs received through further regional consultations, in the development of the final report by the end of 2015.
Childhood obesity strategy 13 October 2015 | 9:30 AM
The Health Committee is holding a short inquiry, building on the previous Committee’s work on the impact of diet and physical activity on health. This inquiry specifically considers what the Government’s policy priorities should be for addressing childhood obesity.
The Committee is not seeking formal written evidence.
20 October 2015 | 9:30 AM Witness(es):Professor Susan Jebb OBE, University of Oxford Dr Peter Scarborough, University of Oxford Dr Alison Tedstone, Director of Diet and Obesity, Public Health England Dr Emma Boyland, Institute of Psychology, University of Liverpool Professor Simon Capewell, Vice President, Faculty of Public Health, Dr Colin Michie, Chair of Nutrition Committee, Royal College of Paediatrics and Child Health
Commission consultation on health claims on foods referring to children’s development and health. Please support the IBFAN BFLG comments now and send to: nutrition email@example.com
IBFAN BFLG comments BFLG IBFAN Health Claim Comments.23.7.15
WTO Techical Barriers to Trade: Opportunity to comment on EU proposals.
CLICK here for the papers.
So far the governments of India and Afghanistan and NGOs from Hawaii, UK and Uganda have written, calling for the proposals to be stengthened and brought into line with the International Code and Resolutions. .
WHO Consultation on “Clarification and guidance on inappropriate promotion of foods for infants and young children”
Deadline: 10th August:
Here is a link to a presentation summarising our concerns: IBFAN STAG 18.8.15.pptx
WHO, led by the Department of Nutrition for Health and Development (NHD), launched an online consultation on the discussion paper to solicit comments on the draft clarification and guidance. These comments will be taken into consideration prior to informal dialogue with civil society and private sector (17 August 2015), and informal consultation with Member States (18 August 2015).
Click here: WHO STAG for background papers and online form for submissions http://www.who.int/nutrition/events/inappropriate-food-promotion-consultation/en/
Here is a LINK to a Powerpoint summary of IBFAN concerns: IBFAN STAG 18.8.15.pptx
Here are links to the List of Participants: LOP NGOs 17 august LOP private sector 17 august
CLICK HERE for the comments from everyone – including industry – recommendation by recommendation.
Follow the links below for PDFs of comments from IBFAN, WOF and WCRF
EFSA opens consultation on Health Claims Guidance
CLICK HERE Deadline September 11th
Ending Childhood Obesity – deadline for comments 5th June 2015
Baby Milk Action frequently submits comments to consultations on draft regulations and standards. These might come from the UK Government, the European Union or United Nations bodies such as Codex or WHO. Click on the Consultations tag for blog posts on this topic.
Round 2 of the Global Strategy for Women’s Children’s and Adolescent Health DEADLINE 5th June
- General comments on the zero draft of the Global Strategy as a whole:
Despite references in the Zero draft to human rights, nutrition, education, inequities, women’s empowerment and water and sanitation, there are several major flaws in this document:
- Failure to address the risks of (and promotion of) the ‘multi-stakeholder’ approaches.
- Lack of any reference to breastfeeding as a cornerstone of children’s survival, health and development and maternal health or the need for its protection and support.
- Lack of any mention of the need for governments and UN bodies to have strong Conflict of Interest safeguards in place to ensure that policy setting processes and their implementation is as free as possible from commercial influence.
- Failure to establish clearly the obligations of States and non-state actors regarding the right to health and other related rights and failure to provide strong accountability mechanisms to ensure that these rights are made enforceable
With no references to such safeguards the references to health protection, Human Rights and inequalities are totally undermined – since all are open to exploitation from commercial entities. The uncritical promotion of the involvement of commercial entities is likely to result in significant adverse implications on health and human rights.
Inequalities: The GlobalStrategy should explicitly recognise that inequalities are a political issue. Governments should be alerted to the fact that corporations are using Corporate Social Responsibility (CSR) strategies such as Breakfast Clubs, Food banks and ‘nutrition education’ to blur the boundaries with marketing and exploit the poor and vulnerable. For example: Despite the fact that the European Commission has criticised the branding used in Nestlé’s EPODE nutrition education programme the company refuses to stop it, and furthermore has renamed its programme as Epode for the promotion of Health Equity.
Towards the development of the Programme on Sustainable Food Systems.
FAO’s online consultation Towards the Development of the Programme on Sustainable Food Systems has been extended to 30th April 2015 Please share comments and suggestions on a draft concept note of the Programme and to take part in a stocktaking exercise of initiatives related to sustainable food systems. FAO and UNEP are also collecting expressions of interest to participate in the Programme and become member of its Multi-stakeholder Advisory Committee.
EU COMMISSION deliberations on the marketing of YOUNG-CHILD FORMULAE
WHO Regional Meetings.
WHO Department of Nutrition for Health and Development 2025 nutrition targets policy briefs: stakeholders’ input
Deadline: 8 October 2014
Maintaining a healthy weight and preventing excess weight gain among children and adults.6 week consultation
The National Institute for Health and Care Excellence (NICE) is developing a public health guideline on Maintaining a healthy weight and preventing excess weight gain among children and adults. This draft guideline is currently out for an 6 week consultation with stakeholders. The consultation on this draft guideline will take place between 23 September – 4 November 2014.
The link to the Draft Guideline and the Stakeholder Comments Form for the consultation can be found here http://www.nice.org.uk/guidance/indevelopment/gid-phg78/consultation.
Water and Food Security: Deadline: http://www.babymilkaction.org/archives/2432
International Conference on Nutrition 2 (ICN2)
IBFAN’s Lida Lhotska delivering an intervention on behalf of Civil Society.
10-12 October. The intergovernmental discussions on the Draft Political Declaration and Framework for Action have reopened in Rome. The proceedings can be watched on a webcast:
The discussions on the Political Declaration were put on hold as some key paragraphs could not be negotiated. The discussions on the Framework for Action go round and round in circles and IBFAN and some public interest NGOs are becoming increasingly frustrated with the process, not least the “watering down” of existing agreements and lack of attention to human rights. There has been much talk of ‘multi-stakeholder ‘ governance mechanisms. We believe that such language opens the door for entirely inappropriate influence from corporations so we are of course opposing such ideas.
An example of industry biased language that was agreed: “Recognising that efficient and effective trade is key to achieving nutrition objectives”.
However some countries are fighting on. An important intervention was made by Finland, who objected to the proposed recommendation for “the addition of essential nutrients to foods.” Finland said that fortification is only ONE way of improving food content – there are many others – including improving soil quality. Finland’s suggestion was thankfully supported and the wording changed to “improve nutrient content of foods as needed” Not wonderful but better.
Here is an excellent intervention made by IBFAN’s Lida Lhostka on behalf of Civil Society (CS)
statement 2 on day 2
HERE is another great CS intervention on the Political Declaration
The discussion and some of the comments are available on: http://www.fao.org/fsnforum/forum/discussions/ICN2-FFA CLICK HERE FOR IBFAN COMMENTS FFA_IBFAN_comments.
WABA invites YOUR Organisation to enorse and sign-on to this Statement Deadline: 7 November 2014!
- European Ombudsman public consultation concerning the composition of European Commission expert groups Deadline 31st August Baby Milk Action response 2014
- Link to old EFSA comments European Voice 2000:
- Codex consultation on REVIEW OF THE STANDARD FOR FOLLOW-UP FORMULA (CODEX STAN 156 – 1987) SECOND CONSULTATION PAPER, JULY 2014. DEADLINE 1st September 2014 responses to: Jenny.Reid@mpi.govt.nz; Alice.STENGEL@dgccrf.finances.gouv.fr; firstname.lastname@example.org
Request for information on infant and follow-on formula DEADLINE 27th August 2014 Letter from DH: Infant formula 29072014 BMA response to DH Request on IF and FUM
EU Corporate Social Responsibility policy: The Commission seeks stakeholders’ views on achievements and future challenges DEADLINE 15th August 2014 CLICK HERE or HERE CLICK HERE for Baby Milk Action’s response to this consultation EUSurvey – Survey
An FSN forum discussion on the ICN2 Framework for Action (zero) draft to implement the Rome Declaration on Nutrition, is now open for comments and inputs. DEADLINE17th August. Framework for Action. International Conference on Nutrition 2 – The discussion and all the comments so far are available on: http://www.fao.org/fsnforum/forum/discussions/ICN2-FFA CLICK HERE FOR IBFAN COMMENTS FFA_IBFAN_comments IBFAN and many other NGOs are very concerned about the involvement of the Private Sector in the International Conference on Nutrition (ICN2) and we have been taking part in many of the discussions. An FSN forum discussion on the ICN2 Framework for Action (zero) draft to implement the Rome Declaration on Nutrition, is now open for comments and inputs. DEADLINE17th August.
NICE consultation on Obesity: Prevention and Lifestyle Management in Children standard Deadline: 5pm on 7th August 2014. The draft Obesity: Prevention and Lifestyle Management in Children quality standard, along with the instructions and documents required to submit your comments, can be accessed by following this link http://www.nice.org.uk/Guidance/GID-QSD80/Consultation Baby Milk Action IBFAN comments BMAIBFAN_NICE_OBESITY2014FINAL.2
- Maternal and child nutrition guideline NICE Consultation on the review proposal to consider whether this should be updated. Completed Stakeholder Comments Form must be sent to MCN@nice.org.uk by 5pm on 31st July 2014.
- BFLG MCN response FINAL
- NICE consultation on co-sleeping DEADLINE 31st July
- Baby Milk ActionCo-Sleeping FINAL2 LLLGB NICE SIDS 2014
EFSA Public consultation on the essential composition of infant and follow-on formulae. CLICK HERE
EU: Public consultation on modalities for investment protection and ISDS in TTIP For background papers and instructions for responding click here or here
The deadline for responses to this consultation was extended to 13 July due to the level of high interest (14000 submissions).
War on Want response to the above consultation
Baby Milk Action ISDS response
- EFSA FINAL OPINION
- QUESTIONNAIRE ON YOUNG-CHILD FORMULAE EU Consultation on Article 12 of Regulation 609/2013. The UK wants comments back by 23 June in time for the EU commission deadline of 18th July Ares 1840923 Questionnaire on young-child formulae_Registered 27 05 2014
- CLICK HERE BFLG IBFAN Comments on EU Q&A
- CLICK HERE for the comments from First Steps Nutrition Trust FSN EC Questionnaire on young child formulae_June 2014
- The above consultation is part of a series of discussions that the EU Commission and Member States are having about the revision of the Baby Food legislation. CLICK HERE For the Baby Feeding Law Group comments on Foods for Special Medical Purposes
- Open EFSA meeting in PARMA 26th June