IBFAN Comments:

NEW SUGGESTION:
OPERATIVE PARA 2  (a) to take all necessary measures to implement the guidance  on ending the inappropriate promotion of foods for infants and young children, INSERT:  AS A MINIMUM REQUIREMENT  while taking into account existing legislation and policies, as appropriate;  

POINT ONE:  Comment on the DRAFT RESOLUTION.  Op Para 2 (d)  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.     

 

It is risky to  urge Member States to adopt Codex standards as they are as law.  Codex has weak ineffectual Conflict of Interest Rules. Often 40% of the delegates at the Nutrition meetings are from the food industry.  As a consequence compromises are made and few Codex texts fully reflect WHO norms, recommendations and Resolutions. For example no Codex standards refer to Resolutions after 2001,  the baby food standard allows high sugar levels.   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 “   Not only that, Codex is –  right now – in the middle of two highly controversial discussions – a review of the follow-on formula  standard and Guidance on Ready to Use Therapeutic foods.  

What IBFAN  suggests:  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. 

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POINT TWO:   Comments on the Guidance:

• Inappropriate promotion; World Health Assembly Resolution 65.6 requested  the Director-General:  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;  The guidance is not confined to inappropriate promotion and include weak wording relating to sponsorship, advertising etc that  will almost certainly be exploited. 
• Promotional Claims:  The Guidance fails to include the clear reference in WHA Resolution 63.23 (2010)  that “nutrition and health claims shall not be permitted for foods for infants and young children, except where specifically provided for, in relevant Codex Alimentarius standards or national legislation..”  This is an important safeguard that doesn’t ban all claims but would  ensure that governments are in control.  Parents of young children are disproportionately targets by claims. (Click Here)
• Vitamin supplements:  Scope Para 3 of the Guidance:  should  apply to  vitamin and mineral food supplements and home-fortification products such as micronutrient powders and small-quantity lipid-based nutrient supplements.  IBFAN is not arguing that these products  are not  useful in the right circumstances – but decisions about their use,  need and how they are distributed  should be made by public health authorities  and based on sound evidence of need – not left to the market place.  These products are being promoted with idealising health claims and imagery  already.   CLICK HERE   for an example from Uganda.

What we suggest:    Recommendations 3 and 4 should ONLY  refer to INAPPROPRIATE PROMOTION and should include the qualified ban on claims.  If the Guidance can’t be changed on these points – at the very least it must specifically state that Member States  have the right to go further (and prohibit all promotion of such products if they believe this is necessary for the protection of child health.) 

 

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Notes:  

 

(1) The majority of MS  have adopted measures that implement  the International Code to some degree.  40 countries have strong legislation that bans promotion of all baby foods:  Asia:   Afghanistan, Bangladesh 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 4 on Page 2  is incomplete – there  are dozens of Codex Standards and Guidelines  that need to be improved and brought in line with WHO policy