Inappropriate marketing of baby foods – new consultation round to start soon
Following the last meeting of Member States in early April, we understand that some changes have been made to the Guidance and we hope that our remaining concerns will soon be addressed. We are especially pleased that the Guidance includes a clear statement that formulas for children 0-36 months are covered by marketing restrictions the International Code..
We know that some Member States do not wish to ban the promotion of baby foods. However it is important that Member States who want to do so are not undermined. The International Code was adopted as a Minimum Requirement in 1981 and has been an empowering tool for many Member States who have translated it and the subsequent relevant WHA Resolutions) into legislation that is protecting child health. (1) IBFAN is calling for the inclusion of text that safeguards Member States right to bring legislation they consider necessary.
In order to ensure that international trade does not take precedence over a Child’s right to health, Codex standards and guidelines must follow the norms and policies set by WHO – not the other way round.
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.____________________________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.)_____________________________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