IBFAN has submitted the attached comments to the Codex Alimentarius electronic Working Group for the revision of the Standard for Follow-up Formula.

IBFAN 2nd CP Submitters response FINAL   These are supported by IACFO.

ENCA2015 eWG Consultation 2_ENCA Comments

Please forward the IBFAN comments to Codex Contact Point persons   http://www.fao.org/docrep/005/Y2200E/y2200e0l.htm  within your government to ensure that good infant and young child practices of exclusive and sustained breastfeeding and complementary foods based on local culturally appropriate family foods starting after six months are protected in all countries as the baby milks industries are attempting to increase their markets with various formulations of baby milks.

 

WHA resolution 39.28 categorically states that follow-up milks are not necessary and hence they should not be marketed as such. The Codex meetings are heavily influenced by the foods, drinks and formula industries and the chair’s bias is to favour industry positions as they work to avoid any requirement of Code provisions in the standards and any statements that follow-up formulas are not necessary. IBFAN is also asserting that these milks are breastmilk substitutes and therefore come under the scope of the International Code and subsequent WHA resolutions.

 

We are pleased that at the last Codex meeting in Bali Indonesia, November 2014 WHO took a very positive position on these milks.

The Representative of WHO stated that continuing the work on this Standard risked creating policy conflict. Member States had adopted resolutions at the World Health Assembly on infant nutrition and breastfeeding and, more recently at ICN2 in Rome, the role of Codex in promoting healthy diets had explicitly been mentioned.  And that WHA resolutions…should therefore guide and inform the work undertaken by Codex Committees, including CCNFSDU, so as to ensure policy coherence across various intergovernmental bodies.  And if the work does progress, WHO would request the Committee to include clear language as to the need for strong regulatory measures to avoid inappropriate marketing of FUF, not only through necessary labelling requirements, but in line with the marketing restrictions on breast-milk substitutes, as reflected in the International Code.

IBFAN’s submission supports:

Is FUF necessary?

1. IBFAN supports the WHO Statement on follow-up-formula “Information concerning the use and marketing of follow-up-formula” that these products fall under the scope of the International Code.” (released July 17, 2013).
2. The WHA resolution 39.28 (1986) states that “the practice being introduced in some countries of providing infants with specially formulated milks(so called follow-up milks) is not necessary.”

Marketing risks

1. IBFAN notes that the marketing of follow-up-formulas is misleading, undermines breastfeeding and promotes artificial feeding, putting infant and young child health at risk.
2. As these products may be marketed at a lower cost than routine formulas, they risk being fed at too early an age, increasing the risks of formula feeding and compromising infant health.
3. If marketed to the age of 36 months, they risk being bottle fed for this duration and seriously damaging oral development, normal growth and other negative health impacts.

Amendment to the Standard for Infant Formula

1. IBFAN is of the opinion that a separate standard is redundant since fortified milk products are not necessary. It is our position that the Standard for Infant Formula is sufficient to take care of any artificial milks that may be required for non-breastfed children up to the age of 12 months. If milks are consumed then routine cow’s or other mammalian milks can be used as part of the liquid component of the complementary feeding diet of family foods for young children

 

IBFAN, ENCA and IACFO’s  submissions on the latest round of discussions about  the global standards for Follow on Formulas are here.