IBFAN comments on agenda items 6.2.6.21,8
At the 44th session of the Codex Nutrition meeting in Germany next week (CCNFSDU44) – IBFAN will be once again fighting to protect children from harmful, sweetened, Ultra-Processed, plastic-wrapped products and probiotic additives and claims.
There are many important items on the agenda, including a Physical Working Group on Monday 30th September to discuss the Guideline on the prioritization mechanism / emerging or new work proposals:
We welcome the adoption of a process to consider when and why new work should be undertaken by Codex and whether standards can contribute to food safety, quality and nutrition while supporting the broader goals of sustainability, one health, food security and environmental protection. Here is ENCA/ IBFAN response on these broader questions.
Agenda Item 6.2 Proposals for new work and emerging issues.
NEW WORK PROPOSAL TO DEVELOP A STANDARD FOR FORMULATED COMPLEMENTARY FOODS FOR OLDER INFANTS AND YOUNG CHILDREN prepared by the United States of America
The USA proposes that the Standard for Canned Baby-Foods (CXS 73-1981) and the Standard for Processed Cereal Based Foods for Infants and Young Children (CXS 74-1981) and as well as CXG 8-1991 would be replaced by a new Standard on Formulated Complementary Foods for Older Infants and Young Children that would also cover foods for which there are no current Codex standards. Although we agree that the existing standards and guidance covering foods for children 6-26 months contain inadequate safeguards and requirements regarding added sugars, sweeteners, industrial additives, labelling and processing, IBFAN is opposing this idea for a number of reasons:
- We believe it will lead to a plethora of plastic packaged wasteful UPFs that will be sold back to families as ‘value-added’. This is likely to undermine, rather than improve access to the affordable healthy foods that children need.
- At six months infants self regulate and can eat a range of minimally processed, bio-diverse healthy foods.
- The long shelf life needed for Global trading leads to extensive processing, synthetic fortification, additives and sweeteners.
- It’s a matter of record that food industry representatives comprise 70% of non-state observers (without voting rights) and 28% of the member state delegations (with voting rights) in the Codex Committee on Nutrition.
It is no wonder that Codex decisions invariably favour political and trade interests rather than credible evidence - National governments should be free to develop regulations to control the marketing of all foods for children – taking into consideration national nutrition policies, WHO Guidelines for Complementary Feeding of Infants and Young Children 6 – 23 months, alongside the national and regional economic, cultural and the nutritional status of children.
- The canned baby food standard (CXS 73-1981) is not fit for purpose and should be revoked.
- IBFAN will, however, be calling for a limited opening up of the cereal based standard to remove added sugars and sweeteners.
Agenda Item 6.21: Proposal for Harmonized probiotic guidelines for use in foods and food supplements from the Electronic Working Group Chaired by Argentina and co-Chaired by Malaysia and China
- IBFAN is opposed to the use of microorganisms as probiotic additives for foods and food supplements for infants and young children
- The promotion of infant formulas claiming to have probiotic effect is false and misleading.
- The addition of Lactobacilli species to a product will have a negative impact on the gut microbiome and is reductionist approach that cannot replicate the complex, synergistic and uniquely specific protective microbiome of a breastfeeding infant.
- Cochrane reviews on the use of probiotics as preventive interventions note that none of the studies that meet inclusion criteria provided high-quality evidence for any outcome. Studies claiming ‘no risk’ generally did not compare results to breastfed infants.
- The FDA is warning that preterm infants who are given probiotics are at risk of invasive, potentially fatal disease caused by bacteria or fungi contained in probiotics.”
- The rationale for the proposed new work on probiotics is heavily weighted towards trade priorities and is a risk to health.
- The term Probiotics is a misleading functional claim that is being globally exploited for commercial reasons.
- A Codex guidance is highly likely to green light the global trade of yet more Ultra-processed products and take us in entirely the wrong direction, that undermines bio-diverse, traditional food cultures, harming human, animal and planetary health. We should learn from experience. The Follow-up Formula standard grew the market for totally unnecessary products. The Zilpaterol MRL is likely to do the same.Codex wasted many years discussing whether the deceptive euphemism, Bio-fortification, should accepted as a global definition. With no support from Member States it was thrown out in 2019.
IBFAN strongly supports this proposal from the European Union and Switzerland and believes this could be very helpful in reducing the sweetness of these unnecessary products
We also have several concerns about the way plant-based formulas are being pushed as the sustainable, healthy option for children, and the risk that parents may opt for these products believing that they are helping the planet. While there are valid concerns about the role of dairy products in the climate crisis, plant-based formulas are far away from real plants and the healthy alternative that the term ‘plant’ implies. We are especially concerned that there should be no health, nutrition or greenwashing claims permitted for these products.
- Codex should acknowledge the risk of children consuming fortified Ultra Processed formulas, especially when artificially flavoured, plastic wrapped, sweetened and containing synthetic additives and other risky ingredients.
- Any assumption – implicit or otherwise – that cows’ milk needs to replaced with a fortified ultra-processed formula or drink, will lead to harmful messages about optimal child health that will undermine health and appropriate child development.
- Reliance on ultra-processed drinks and pureed products risks children’s development and encourages fussiness. Children over the age of 6 months to two years and beyond can continue to be breastfed alongside minimally processed and bio-diverse family foods.
- For the 44th session of the Codex Committee on Nutrition and Foods for Special Dietary Uses (CCNFSDU44), the Chair of the Electronic Working Group (EWG) on Sweetness will propose the submission of the ISO 5495 method to the Codex Committee on Methods of Analysis and Sampling (CCMAS). The aim of this proposal is to include the method in the Recommended Methods of Analysis and Sampling (CXS 234-1999), to implement footnote 4 of Codex Standard CXS 156-1978.
IBFAN has many concerns about this Discussion paper that addresses on a number of optional ingredients such as oligosaccharides as additives to infant formulas a formulas and for special medical purposes. Industry labels its FOS additives as ‘human milk oligosaccharides’ when it is harvested from genetically modified microorganisms such as Escherichia coli.
Breastfeeding 3 The political economy of infant and young child feeding: confronting corporate power, overcoming structural barriers, and accelerating progress. Phillip Baker, Julie P Smith, Amandine Garde, Laurence M Grummer-Strawn, Benjamin Wood, Gita Sen, Gerard Hastings, Rafael Pérez-Escamilla, Chee Yoke Ling, Nigel Rollins, David McCoy, Lancet Breastfeeding Series Group
Breastfeeding 2 Marketing of commercial milk formula: a system to capture parents, communities, science, and policy. Lancet Breastfeeding Series Group*. Nigel Rollins et al, Lancet 2023; 401: 486–502 February 7, 2023 https://doi.org/10.1016/ S0140-6736(22)01931-6.
Baker, P., Russ, K., Kang, M. et al. Globalization, first-foods systems transformations and corporate power: a synthesis of literature and data on the market and political practices of the transnational baby food industry. Global Health 17, 58 (2021). https://doi.org/10.1186/s12992-021-00708-1
Compilation of IBFAN Press releases and statements on Codex over the years