Consultation on the Codex revision of the Follow-up Formula Standard. Deadline 7th April.
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.