Click here for the comments of IBFAN  and ENCA – please contact your government or civil society delegates to make sure they have submitted comments – hopefully in line with our concerns.  Here in Spanish: Posición IBFAN en Codex 2021

(CLICK HERE for our Press Release on the last face to face meeting on November 2019: CODEX: Exporting countries put trade before the health of the planet and children

IBFAN considers does not consider the text ready for adoption. It fails to contain sufficient safeguards to prevent the use of the ultra-processed unnecessary products.

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