Member States will meet TOMORROW (8th April) to discuss a Draft Resolution and a Revised Guidance on Inappropriate Promotion of baby Food (with call-in capability for those not in Geneva)
Please share IBFAN’s suggestions for changes with your government. We think that they will be fairly easy to ‘do’ and hopefully will not cause the whole initiative to be delayed. We are very keen to support WHO in having a Resolution on this subject.
IBFAN position:
Although we warmly welcome certain aspects of the Resolution and guidance – especially the clear statement that milks targeted for children under 36 months are covered by the International Code of Marketing of Breastmilk Substitutes and subsequent relevant WHA Resolutions) and the call for nutrient profiles that should help define which foods contribute to childhood obesity. But we still have several important concerns that we would like Member States to address before adoption..
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POINT ONE: The Guidance should focus on what is INappropriate not what IS Appropriate
World Health Assembly Resolution 65.6 requested the Director-General: (1) to provide clarification and guidance on the INAPPROPRIATE promotion of foods for infants and young children cited in resolution WHA63.23, taking into consideration the ongoing work of the Codex Alimentarius Commission;
While some Member States might not wish to implement a ban of all promotion of baby foods marketed for infants and young children, it is important that Member States who want to do so are not undermined by this guidance. We know that the companies are complaining about regulatory obstacles. 39 countries have banned commercial promotion of baby foods to varying ages. These laws are protecting breastfeeding and saving lives. (1)
WHAT NEEDS TO BE DONE:
Recommendations 3 and 4 should only refer to INAPPROPRIATE PROMOTION. If the Guidance can’t be changed on this point – it must at the very least specifically state that Member States have the right to go further and prohibit all kinds of promotion of such products.
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POINT TWO: The references to Codex
Op Para 2 (d) of the draft Resolution contains a serious fault. It calls for Member States 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.
This is risky. The Formulated Complementary Foods guidance disproportionately promotes fortified products and urges Member Stated to adopt Codex standards as law. Codex has weak ineffectual Conflict of Interest Rules and its nutrition meeting are dominated by industry (often 40% of the delegates) So serious compromises are made and few Codex texts fully reflect WHO norms, recommendations and Resolutions. No Codex standards refer to Resolutions after 2001, the baby food standard allows high sugar levels and Codex is in the middle of a review of the follow-on formula standard. 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 ”
WHAT NEEDS TO BE DONE:
The draft Resolution needs to call for Codex standards to be coherent with all WHO guidelines and recommendations, including the International Code of Marketing of Breastmilk Substitutes and subsequent relevant WHA resolutions. (2)
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PPOIT 3
Scope Para 3 of the Guidance: This should apply to vitamin and mineral food supplements and home-fortification products such as micronutrient powders and small-quantity lipid-based nutrient supplements. These products are being promoted with idealising health claims and imagery already. See social media promotion in Uganda. February 2016.
Notes:
(1) 39 countries ban promotion of all baby foods: Asia: Afghanistan, India, Maldives, Nepal, Pakistan, Sri Lanka, Viet Nam Africa: Benin, Botswana, Cameroon, Cape Verde, Gabon, Gambia, Ghana, Kenya, Madagascar, Mozambique, South Africa, Tanzania, Uganda, Zimbabwe M. East & N. Africa: Bahrain, Kuwait, Lebanon, Yemen Europe: Albania, Armenia, Georgia, Kosovo, Americas: Bolivia, Brazil, Dominican Republic, Guatemala, Panama, Peru, Venezuela Oceania: Fiji, Palau
(2) The list given in the footnote of the Guidance is incomplete – there are numerous Codex Standards and Guidelines that need to be improved and brought in line with WHO policy