Ongoing consultations:

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UK-US trade relations inquiry launched  Deadline 17th November.

Baby Milk Action submission

BMA_UK_US_Submission_17.11.17(2)

First Steps Nutrition submission:

FSNT Submission to the Select Committee on UK

The deadline for written submissions is Friday 17 November 2017. Written evidence should be submitted via the UK-US trade relations inquiry page.

16 October 2017

The International Trade Committee launches an inquiry into UK-US trade relations. This will pick up on the previous Committee’s work, brought to an end by the 2017 election, examining the opportunities and challenges in negotiating a free trade agreement and increasing trade between the two countries.

Terms of Reference

Interested organisations or individuals are invited to submit written evidence to the Committee. The Committee is particularly interested in the following:

  • what the UK’s priorities and objectives should be in negotiating any such agreement;
  • the possible impacts (positive and negative) on specific sectors of the UK economy from such an agreement;
  • the extent to which any agreement could and should open up markets in services, including public services;
  • the extent to which any agreement could and should open up markets in public procurement;
  • how any agreement should approach regulation, including regulatory harmonisation;
  • what dispute-resolution mechanism should form part of any such agreement; and
  • what involvement, if any, the UK should seek to have in the North American Free Trade Area or any future regional free trade agreement involving the USA.

The Committee encourages those who did not send submissions to the previous inquiry to submit evidence to this one.

Individuals and organisations that did submit evidence to the previous Committee’s inquiry do not need to re-send their submissions, as that evidence can continue to be considered in this inquiry. This Committee would, however, welcome additional evidence from these stakeholders if they would like to submit an updated view.

The deadline for written submissions is Friday 17 November 2017. Written evidence should be submitted via the UK-US trade relations inquiry page.

Written evidence submitted should:

  • Have a one-page summary at the front   Be no longer than 3,000 words

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Codex Trade consultations

CLICK HERE for the Background Papers for the 39th Codex Committee on Nutrition and Foods for Special Dietary Uses,  4th – 8th December 2017  | Berlin, Germany

Below are IBFAN briefings on the  Agenda  items we are following:

1  The revision of the Follow-up Standard (Codex Stan 156-1987);

Codex paper  

IBFAN Follow-up Formula Briefing

IBFAN’s point by point comments on Follow-up Formula  CLICK HERE

IACFO’s comments are the same as IBFAN’s  CLICK HERE

 IBFAN’s Codex Working Group has prepared a briefing paper to highlight our recommendations for the revision of the Codex Follow-up Formula  standard (Codex Stan 156-1987) at the 39th Codex nutrition meeting to be held in Berlin, 4-8th December.

The briefing highlights the need:

  •  to safeguard the health of older infants and young children;
  •  to ensure policy coherence between Member State decisions at WHA and FAO (the Codex parent UN agencies) and Codex standards and guidelines;
  • to highlight our concerns that the proliferation of standards risks increased trade and marketing of unnecessary and risky products.
  • to ensure that formulas targeting babies 6-36months are noted as being unnecessary, that all are Breastmilk Substitutes and all come under the scope of the International Code and subsequent relevant WHA resolutions and should not be promoted.

2     The Proposed draft guideline for Ready To Use Therapeutic Food (RUTF);

CLICK HERE  for IBFAN Briefing on RUTF 

CLICK HERE for IBFAN comment on the Proposed draft RUTF guidelines

CLICK HERE for IACFO comment on the RUTF Guidelines

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3     The Proposed draft Definition for Biofortification.

CLICK HERE for the  IBFAN comment of the draft  Definition of Biofortification

CLICK HERE for the IACFO comment

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COMPLETED CONSULTATIONS

WHO Consultation on the thirteenth General Programme of Work (GPW13)  New Deadline 23rd November 2017

The new draft of the 13th Programme of Work (see links below) will be discussed at a special Executive Board Meeting at WHO HQ on 22-23rd November.

2.11.17.EBSS4_2-en 2019-23_Strat_Map Agenda Nov GPW GPW13_-impact-framework-draft

 

Draft concept note towards WHO’s 13th General Programme of Work 2019–2023   English pdf, 653kb 

CLICK HERE  for IBFAN’s comment

Despite its laudable aims, IBFAN has many concerns about this plan, and we hope the consultation will lead to its improvement.   In seeking to align WHO more closely with the Sustainable Development Goals (SDGs) and become more ‘ operational’ there is no mention the harm caused by marketing, Conflicts of Interest,  the need to protect WHO’s integrity  independence and credibility, or how inappropriate funding can distort and influence outcomes and impact.  There is no mention of the  difference between the objectives and duties of WHO and its Member States and those of the Private Sector (including Transnational Corporations, who have a duty to maximise profits).  The only safeguard offered seems to be the deeply flawed FENSA which is presented as an ‘enabler of responsible partnerships‘. The section Providing the world’s Governance Platform for Health is particularly worrying and seems to promote the idea that private sector entities and philanthropic foundations could actually be involved in governance: “At the same time, it is recognized that global governance has evolved from intergovernmental governance alone, and WHO is also an emerging platform for multi-stakeholder (i.e. government, nongovernmental organizations, private sector entities, philanthropic foundations and academic institutions) governance” (p8 Para 3).  You may find other problems related to your field of expertise/activism.

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WHO draft Conflicts of Interest in Nutrition Tools

Of relevant to this consultation are  the comments on WHO’s proposals for  Conflicts of Interest in Nutrition  Tools.  Only some of the comments have been posted on WHO’s website HERE.  Several other important comments from CoI experts have not been posted:

For example this  comment from Judith Richter

JRichter Comments_Safeguarding_against_CoI_in_nutrition_programmes_draft_approach_2017

Here is a selection of some of the comments on the WHO website:

GIFA comments+refs ibfan

IBFAN_WHO_COI_Nutrition_24_9_17

namibia

oecd

world_public_health_nutrition_association

the_cochrane_collaboration_united_kingdom

brazil

centre_for_health_science_and_law

WHO Consultation on Conflicts of Interest in nutrition

WHO has  published some of the comments  received  HERE   There are several other important ones from individuals that have not been posted

Here is the comment from IBFAN.

IBFAN_WHO_COI_Nutrition_24_9_17

Here is the comment from the Geneva Infant Feeding Association

GIFA comments+refs

Here is a comment from Judith Richter

JRichter Comments_Safeguarding_against_CoI_in_nutrition_programmes_draft_approach_2017

Here is the comment from Bill Jeffery, LLB, Executive Director
Centre for Health Science and Law (CHSL)  Canada

http://healthscienceandlaw.ca/wp-content/uploads/2017/09/CHSL.WHO-NutritionConflicts-of-Interest.Sept25-2017.pdf

http://www.who.int/nutrition/consultation-doi/en/ or in Nutrition webpage http://www.who.int/nutrition/en/ .

some useful articles:  

Valente, F. (2016). “Nutrition and food – how government for and by the people became government for and by the TNCs.” TNI.

https://www.tni.org/en/article/nutrition-and-food-how-government-for-and-of-the-people-became-government-for-and-by-the

Richter, J. (2014). “Time to turn the tide: WHO’s engagement with non-State actors & the politics of stakeholder-governance and conflicts of interest.” Rapid response to BMJ online letter by Nigel Hawkes, ‘Irrelevant’ WHO outpaced by younger rivals d5012 (Title of Hawkes’s BMJ print feature article: Will WHO reforms open the doors to private donors? http://www.bmj.com/content/348/bmj.g3351/rapid-responses

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August 2017: Consultation on WHO Guidance on Ending the Inappropriate Promotion of Foods for Infants and Young Children

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Codex Consultations:

The 40th  CODEX ALIMENTARIUS COMMISSION (CAC)  will start tomorrow in  Geneva.  The Global Food Standards set by Codex are important because they are used as bench marks in the event a Trade Dispute.   IBFAN and IACFO have been attending Codex meetings for over 20 years with the aim of achieving Policy Coherence between WHO and Codex: it is helpful to governments who want to protect child health if Codex Standards are in line with WHO Policy and the Resolutions adopted the World Health Assembly.

WHO has been raising the need for Policy Coherence many times at  Codex Commission meetings.  (see Paras 137-145 of the 2016 Report of CAC39 and Paras 161-170 of Report of the 73rd Session of the Executive Committee meeting.)

IBFAN continues to be concerned about  the  weak Codex  safeguards on Conflict of Interest that leave the Codex process wide open to undue commercial influence. The food and related industries and their front groups –  often constitute 40% of  Codex nutrition meetings, funding dinners and receptions for participants, promoting the findings from industry-funded research. This can affect the evidence base that is used to decide on the safety of ingredients, additives etc. Ill-defined terms, often used by industry, such as ‘generally accepted’ ‘History of safe use ‘ ‘science­‐based’ ‘scientifically demonstrated’ are used rather than the terms recommended by WHO: “Relevant convincing / generally accepted scientific evidence or the comparable level of evidence under the GRADE classification ”   

The industry argument that a ‘History of Safe Use‘ is sufficient was challenged  by the European Food Safety Authority (EFSA) in May in  its final guidance  on the assessment needed for  food for babies under the age of 16 weeks.  Following a consultation EFSA maintains the requirement for an extended one generation reproductive toxicity study for substances added intentionally to infant formula.

Other issues:  CLICK HERE for the background paper: Matters arising jointly from FAO and WHO: 2 The UN Decade of Action on Nutrition 2016-2025 3.2.2 Climate change and water scarcity 3.2.6 Antimicrobial Resistance (AMR)  and 4.2 Antimicrobial Resistance, 4.3 WHO Framework of Engagement with Non-State Actors (FENSA) 4.8 Development of nutrient profile models for regulating marketing of food and non-alcoholic beverages to children 

The discussion Panel on Wednesday 19th July.18.00 is entitled NGOs and Codex: what we expect and what we can contribute.   CLICK HERE   It is worth noting, that apart from IBFAN, nearly all the other panellists are funded by or representing the interests of industry of one kind or another:

AOAC International (Erik Konings, Past President) Association of American Feed Control Officials (Richard Ten Eyck, Ingredient Definitions Chair) European Association of Polyol Producers (Anders Liljegren, President) European Food Law Association (Nicole Coutrelis, Vice-President) Grocery Manufacturers Association (Richard D. White, Director, Codex and International Standards Policy) International Association for Cereal Science and Technology (Amine Jbeil, Technical Director) International Baby Food Action Network (Patti Rundall, IBFAN Codex Team) International Grain Trade Coalition (Katy Lee, Secretariat) National Health Federation (Scott Tips, Board Member) United States Pharmacopeial Convention (Kristie Laurvick, Acting Director, Science – Foods Program Unit) World Sugar Research Organisation (Roberta Re, Director General) 

Another issue to watch out for in April I highlighted on my Blog  a new US Trade briefing that was  published in April:  2017 National Trade Estimate Report on FOREIGN TRADE BARRIERS  This seemed to identify many health protective policies, including those designed to protect breastfeeding, as “trade barriers” that should be eliminated:  CLICK HERE

Codex revision of the Follow-up Formula Standard. 

2nd Consultation on scope and labelling:  In the last consultation the majority of Member States and NGOs called for the WHO Guidance on Inappropriate marketing of Foods for infants and young children/the International Code or subsequent relevant WHA Resolutions to be included in the revised Codex standard of Follow-on Formulas.   CODEX CHART April 2017   Click Here

2017 2 CP Older Infants Scope and Labelling SUBMITTERS RESPONSE FORM IBFAN -final 1

CLICK HERE  2017 2 CP Young Children Scope and Labelling SUBMITTERS RESPONSE FORM IBFAN – final 1

IACFO submitted a response that mirrors that of IBFAN

IBFAN’s submission on  scope and labelling relating to the revision of the Follow-up Formulas Standard submitted in April is HERE

IACFO’s submission on scope and labelling relating to the revision of the Follow-up Formulas Standard submitted in April is HERE

The Background paper for the consultation statesIt 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.

1 WHO’s Guidance on Ending the Inappropriate Promotion of Foods for Infants and Young Children states:  “A breast-milk substitute should be understood to include any milks (or products that could be used to replace milk, such as fortified soy milk), in either liquid or powdered form, that are specifically marketed for feeding infants and children up to the age of 3 years (including follow-up formula and growing-up milks). It should be clear that the International Code of Marketing of Breast-milk”
 
For example, Nestlé’s promotion to health professionals in Botswana of its “First acidified ‘growing-up milk’ in Southern Africa”  Pelargon 3  – uses unsubstantiated claims that it: reduces the risk of infection from: Dirty water; Child Minding/Day care; Exposure when travelling and Exposure in warm, wet seasons. 

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 second consultation submitted June 2017.

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:

  1. RUTF products should not be available, sold or promoted on the open market.
  2. RUTF products are for therapeutic purposes.
  3. Inappropriate marketing can result in unnecessary use with loss of confidence in local family foods and sustained breastfeeding.
  4. 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.
  5. RUTF should not be cross promoted with Breastmilk Substitutes and should carry no promotional or idealising claims or pictures.
  6. 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.
  7. The Guidelines must state that National authorities retain the ability to provide national solutions and prevent unnecessary imports of expensive RUTF products.
  8. 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.

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.

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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

 THIS is the LINK to the EB140   WEBCAST  TIMETABLE   STATEMENTS

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)

IBFAN appreciates the difficulties facing WHO and Member States in  tackling NCDs. However, we have watched with growing alarm as the Global Coordinating Mechanism – before and after the adoption of FENSA – has given disproportionate access and promotion to a wide range of corporations and public private partnerships. The GCM shows no sign of heeding WHO’s FENSA requirement to “exercise particular caution…when engaging with private sector entities …whose policies or activities are negatively affecting human health..”

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)

Emergencies:  breastfeeding –  a lifeline in emergencies

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.[1]

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.

Thank you

[1]  http://worldbreastfeedingtrends.org/84-country

 http://worldbreastfeedingtrends.org/WBTi-84Country/84-country-report-Indicator9.pdf

 

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Codex REPORT OF THE MEETING (including participants list)

CODEX Press Release from the meeting

Ongoing consultations

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

Lack of Policy Coherence between WHO and Codex IBFAN is concerned that Codex’ weak Conflict of Interest safeguards leaves it wide open to undue commercial influences from the food and related industries and their front groups – who often constitute 40% of  Codex nutrition meetings, funding dinners and receptions for participants, promoting the findings from industry-funded research. When deciding on the safety of ingredients, additives etc. Codex often refers to ill defined terms such as ‘generally accepted’ ‘History of safe use ‘ ‘science­‐based’ ‘scientifically demonstrated’ rather than the terms recommended by WHO: “Relevant convincing / generally accepted scientific evidence or the comparable level of evidence under the GRADE classification ”   this is the underlying factor behind the struggle we have at Codex. We are pleased that the need for Policy Coherence was discussed at the Codex Commission in July,  following on from the calls at the 69th World Health Assembly in May 2016.

1  Comments on Follow-on Formulas

The 1987 Follow-on Formula (FUF) standard established a market for these unnecessary and potentially risky products. WHO has clarified that all formulas for children 12-36 months function as breastmilk substitutes so are covered by the International Code and WHA Resolutions and should not be promoted.  IBFAN and WHO and many developing countries have called for these products to be included into the infant formula  standard – the baby food industry, and the producer Member States wants separate standards.

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.

CLICK HERE for a report on the Carbon Footprint for formulas: Carbon-Footprints-Due-to-Milk-Formula

Click Here  for a paper showing examples of promotion of so called “gums-new-2016

IBFAN: ibfan-comment-review-of-the-standard-for-follow-final-1 (Codex Stan 156-1987) at Step 3

HKI: hki_whabrief_v2

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2   Ready to Use Therapeutic Foods (RUTF)  draft proposal for a Guideline

IBFAN: ibfan-comment-proposed-draft-guideline-rutfs-ccnfsdu-2016-3

IACFO iacfo-comment-proposed-draft-guideline-rutfs-ccnfsdu-2016-v2

Ready to Use Therapeutic Foods (RUTFS); IBFAN does not see the need for a separate Codex instrument for RUTFs – products that should be made available under strict conditions for those who need them.    CLICK HERE and below  to see the media articles showing how marketeers are looking forward to the expansion of the global market. This illustrates the urgent need for very strict controls how these products are supplied, and funds to be allocated for training to support breastfeeding and Kangaroo Mother Care:   http://inkmc.net

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 comment: ibfan-comment-proposed-draft-definition-for-biofortification-ccnfsdu-2016-2

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.

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ECHO Consultation on Draft Implementation Plan

Consultation open until 12 October 2016

A group of children pose for a photograph.

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 echo@who.int before 12 October 2016.
http://www.who.int/end-childhood-obesity/implementation-plan/en/

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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. 

DH BULLETIN – Follow-up questions to the Commission Working Group on hea…

Here are our comments

Baby Milk Action_Health Claims_29.7.16

HealthClaims_July2016_HCrawley

 

_______________________FINAL_BMA_IBFAN_Health Claims_29.7.16

WHO Consultation

IBFAN comments on Updated Appendix 3 of the WHO global NCD action plan 2013-2010 

Consultation 25 July – 1st September 2016

2IBFAN comments on Updated Appendix 3 of the WHO global NCD action plan 2013 version 1

WHO ACTION PLAN for the prevention and control of NCDs in the European Region

WHONCDActionPlan_2016

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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

IACFO_Submitters response form-final

ENCA201606_Submitters response form_ENCA

FINAL IBFAN 201606_Submitters response form-final HKI201606_

SOUTH AFRICA SECOND CONSULTATION PAPER ON FUF JULY 2016

EU_FUF_comments eWG FUF_22072016

Canada201606July 19

ISDI CP2 submitters response form 2016 07 19 final

USA_Submitters 19JUL2016.

FinalSubmitters response form HKI 18July 2016

Morroco_201606_

Submitters response form RUSSIA 

Norway_FUF second response July 2016

ICAAS_2ndConsultation

IDF _FuF 2016-07-14

NL_20160618072016

China FUF–response form-CHINAF

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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

IBFAN comment Biofortification definition July 13, 2016

IBFANSECOND CONSULTATION PAPER ON BIOFORTIFICATION IBFAN Response

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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).  

SECOND CONSULTATION PAPER ON GUIDELINE FOR RUTF:.

IACFO-2nd RUTF consultation

IBFAN-2nd SUBMITTERS RUTFs

page down for other comments

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CODEX ALIMENTARIUS COMMISSION (CAC)   39th Session  FAO Headquarters, Rome, Italy,

27 June – 1 July 2016  

The report of the meeting is Report   The preceedings are webcast CLICK HERE 

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)    

Paragraphs 137-145

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.

Conclusion 

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.

Conclusion 

107. The Commission approved the new work.

 

 

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The failure of Codex to include and implement adequate and effective Conflict of Interest safeguards means that its norm setting procedures (and its guidelines for National Codex Committees and National Codex Contact Points) are wide open to undue commercial influences from industry and its front groups.  Often 40% of delegates at Codex nutrition meetings are from the food or related industries. These companies regularly create situations that give rise to conflicts of interest by funding dinners and receptions for participants, promoting the findings from industry-funded research and contributing to secretarial services – a conflict of interest in itself.   When deciding on the safety of contaminants, ingredient, additives etc. Codex refers to ill defined terms such as ‘generally accepted’ ‘History of safe use ‘ ‘science­‐based’ ‘scientifically demonstrated’ rather than the terms recommended by WHO: “Relevant convincing / generally accepted scientific evidence or the comparable level of evidence under the GRADE classification ”  Electronic Working Groups arrive at decisions on the basis of consensus rather than evidence.
 
WHA Resolution (69/9) states:  ‘Recognizing that the Codex Alimentarius Commission is an intergovernmental body which is the principal organ of the joint FAO/WHO food standards programme and that it is the appropriate body for establishing international standards on food products, and that reviews of Codex standards and guidelines should give full consideration to WHO guidelines and recommendations, including the International Code of Marketing of Breast-milk Substitutes and relevant Health Assembly resolutions’ 
 
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

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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:.

IACFO-2nd RUTF consultation

IBFAN-2nd SUBMITTERS RUTFs

France RUTF 2nd CONSULTATION PAPER – France contribution

Brazil_RUTF

EU comments 2nd Consulation RUTF_20062016 FINAL

IDF RUTF 2nd CONSULTATION PAPER FOR 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

RUTFbriefing

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’

How the IMS Act has helped India

Baker et al_2016_Global trends and patterns of formula sales – is an IYCF transition underway

 

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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

1  Maternal, infant and young child nutrition A69/7  A69/7 Add.1   A69/7 Add.2

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:

25.May.2016.A69-A-CONF-7_25May16

May 24_A69_ACONF7 draft as shown on the screen at 21 hr

20 May 2016 -Draft resolution – Nutrition.

IBFAN is advocating the adoption of the Resolution and endorsement of the Guidance.   IBFAN’s Statement that will be delivered is HERE

See also useful new papersGUMs – final   Statement on sugar in fortified milks_May2016  Carbon-Footprints-Due-to-Milk-Formula

Framework of engagement with non-State actors A69/6  and  A69/60 Framework of engagement with non-State actors

CLICK here for Press Release and Statement

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

A69/8 Report of the Commission on Ending Childhood Obesity

A69/24  A69/24 Add.1 Global action plan on antimicrobial resistance

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. 

 

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CODEX consultations

Review  of the Follow on Formula Standard Deadline 3rd April 2016:   First consultation paper on the review of FUF (2016)  201602_First Consultation Paper 201603_Submitters response form

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.

FIRST CONSULTATION PAPER ON BIOFORTIFICATION   eWG_invitation_biofortificationSUMMAryCODEX BIOFORTIFICATION DEFINITION by eWG led by Zimba

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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

BFLG_Comment_FINAL_UKLawconsultation_Feb2016

Technical consultation – SI on Foods for Specific Groups

The EU delegated regulations on Infant Formula, Follow on Formula and Foods for Special Medical Purposes were published on 2.2. 2016

CLICK HERE for a link to the new Delegated Acts in all languages

http://eur-lex.europa.eu/legal-content/FR/TXT/?uri=OJ:L:2016:025:TOC

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.

http://eur-lex.europa.eu/legal-content/FR/TXT/?uri=OJ:L:2016:025:TOC

_________________

From: SG-TRANSREG-NOREPLY@ec.europa.eu

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
+’ Contact the register
Web: http://ec.europa.eu/transparencyregister

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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   

IBFAN statement during the WHO ExecutiveBoard Meeting  29th January 2016

 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:

  1. 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.
  2. 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.

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World Health Organisation Executive Board Meeting

25- 30th January  2016.

IBFAN Statement on Maternal Child Nutrition 6.1.

WHO proposals for a Resolution and Guidance on ending inappropriate foods for Infants and Young children

FINAL IBFAN NCD statement 6.3

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.

The Maternal Child Nutrition   documents will be open for comments in the next 4 weeks.
By coincidence The Lancet is today publishing a series of important  articles on Breastfeeding.  CLICK HERE

 

 

 

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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

For UK MEPshttps://www.writetothem.com

For other MEPshttp://www.europarl.europa.eu

 

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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

 RUTFbriefingHere are our submissions on three agenda items and a quick summary of our  concerns .
RUTF Bullett FINAL  for new paper on RUTF proposal
CLICK HERE for the Codex Background papers
  1. 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.
  2. Biofortification_IBFAN
  3. 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.
  4. 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  

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Draft Final Report of the Commission on Ending Childhood Obesity open for comment UNTIL 13 November 2015

 ECHO DRAFT FINAL REPORT

Baby Milk ActionIBFAN_ECHO_Nov2015

Open for comment: 29 September – 13 November 2015

PREVIOUS COMMENTS by IBFAN

IBFAN-comment-on-ECHO

IBFAN to ECHO 16.12.14(3)

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.

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.

 

Health Select Committee

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.

13th October 9.30:  Witness(es):Dr Paul Darragh, Board of Science, British Medical Association Professor Graham MacGregor, Chairman, Action on Sugar Malcolm Clark, Co-ordinator, Children’s Food Campaign Andrew Opie, Director of Food and Sustainability, British Retail Consortium Ian Wright, Director General, Food and Drink Federation Chris Snowdon, Director of Lifestyle Economics, Institute for Economic Affairs
19 October 2015 | 4:10 PM   Witness(es):Jamie Oliver MBE
Room 8, Palace of Westminster

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 legislation@dh.gsi.gov.uk

DH BULLETIN – Commission Working Group on health claims 8 June 2015_sent to IPS 19 June   Item A3.1 10472-EN Item A4.1 10891 – EN_ANNEX Item A4.1 10891 – EN3 (4)

IBFAN BFLG comments   BFLG IBFAN Health Claim Comments.23.7.15

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WTO Techical Barriers to Trade:  Opportunity to comment on EU proposals.

CLICK here for the papers.

Member States and others who share our concerns can write to the European Union, Internal Market, Industry, Entrepreneurship and SMEs Directorate-General: GROW-EU-TBT@ec.europa.eu
 The proposals will go to the European Parliament in September.

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. .

http://ec.europa.eu/growth/tools-databases/tbt/en/search/

http://ec.europa.eu/growth/tools-databases/tbt/en/search/?tbtaction=search.results

 

_________________________________

WHO  Consultation  on “Clarification and guidance on inappropriate promotion of foods for infants and young children”

Deadline:  10th August:

I attended the informal hearing with NGOs in Official Relations on 17th 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
Baby Mlk Action IBFAN on STAGLOGO

ICDCGIFA STAGFINAL

INFACT Canada comment on the Draft Inappropriate marketing

ENCA STAG Comments

WOF-WCRF response to infant foods consultation for upload

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EFSA opens consultation on Health Claims Guidance

CLICK HERE   Deadline September 11th

Closed consultations

Ending Childhood Obesity  – deadline for comments 5th June 2015

IBFAN comment on ECHO

http://www.who.int/end-childhood-obesity/interim-report-for-comment/en/

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

CLICK HERE  BMAonGSWCAH2   for Baby Milk Action’s comments

  1. 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.[1] 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.  

CLICK HERE for the document  and CLICK HERE 

 

Committee on Food Security

CLICK HERE (word)  or  HERE (PDF)  for Baby Milk Action Submission Committee on Food Security

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  

IBFANBFLG BMA SCOFCAH FINAL

Working document_WG_Advisory group_YCF (2)

IBFAN_NutritionActionPlan_

IBFAN_Reform_ Framework NSA

    • EUR/RC64/16 
      WHO reform: progress and implications for the European Region
    • EUR/RC64/22
      Framework of engagement with non-State actors: report
      by the Secretariat to the regional committees
    • EUR/RC64/21
      Framework of engagement with non-State actors
      (same document as for WHA67)

 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

Click Here

International Conference on Nutrition 2  (ICN2)

IBFAN’s Lida Lhotska delivering an intervention on behalf of Civil Society.

Lida small 00110-12 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

CSO on Pol Dec.11.10.14

 

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. 

CSO Statement OEWG – Final Version – 21 Sep 14

OEWG intervention

 

WABA invites YOUR Organisation to enorse and sign-on to this Statement    Deadline:  7 November 2014!

CLICK HERE 

  • 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

EFSA Public consultation on the essential composition of infant and follow-on formulae.  CLICK HERE