2021

IBFAN comments on a WHO Private Sector interactions. IBFAN NCD Tool FINAL

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WHO Executive Board and World Health Assembly

See webcasts of inter-sessional meetings. on Maternal Infant and Young Child Nutrition, Food Safety, NCDs, WHO Funding and Emergencies

For IBFAN comments and interventions at the WHO Executive Board in January 2022: HERE and HERE

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November 2021

Baby food industry lobbies to weaken Codex standards on sweetness and flavouring

See Policy Blog for what happened at the lest meetings:  http://www.babymilkaction.org/archives/31632

IBFAN Comments: IBFAN FUF scope etc   IBFAN RUTF UNICEF FUF

IBFAN, ENCA, ILCA and partner NGOs attend  the Codex Nutrition meeting (CCNFSDU) (19thNovember – 1st December) where the Proposed Draft revised standard for Follow-up Formula  and the Guidelines on Ready to Use Therapeutic Foods were discussed.

1  IBFAN COMMENT ON PROPOSED DRAFT GUIDELINES FOR READY TO USE THERAPEUTIC FOODS (RUTF)  IBFAN RUTF

Summary: Children affected by severe acute malnutrition (SAM)  need  efficacious and timely treatment and RUTF is ONE of the options for the dietary treatment of children with uncomplicated SAM. However, it is critical that it’s use is appropriate and  does not undermine support for continued breastfeeding or re-lactation, since this is the most important requirement for the rehabilitation of children suffering from malnutrition.

It is also critically important to protect against commercial exploitation. The claim that they are helping feeding malnourished children is the perfect cover for the baby  industry’s predatory marketing tactics, and Codex Guidelines or Standards are used to fuel the opening up of global markets.

The current draft guidelines contain some good provisions, but on the question of promotion they rely on the weak safeguards contained in the Standard for Foods for Special Medical Purposes (FSMPs) –  products that are on general sale. The FSMP standard does contain a ban on ‘advertising’  –  but this  far from adequate.  Above-the-line ‘advertising’ is the crudest form of commercial promotion and the Guidelines should clearly recommend prohibition of all commercial promotion,  including claims, (health, nutrition, convenience, etc) cross-promotion with infant formula, sponsorship and the myriad other forms of marketing currently used to maintain and expand the FSMP market.  Also the Guidelines fail to specifically ban promotional claims. Claims are MARKETING TOOLS that are not appropriate for therapeutic foods and are forbidden for foods for infants and young children by WHA Resolution 63.23.

Codex is proposing a very short Preamble to the Guidelines. IBFAN disagrees and believes that a well-defined preamble is essential.  It must  highlight the appropriate use of RUTFs and the safeguards and recommendations of WHO, UNICEF and WFP in order to stop the use of RUTF undermining  breastfeeding and sustainable,  culturally appropriate family-food based feeding of young children and local economies.   It is essential that the Preamble highlights the importance of breastfeeding and re-lactation support as the first option to promote optimal rehabilitation of children with uncomplicated SAM.

All these safeguards should be stated in the preamble, along with a clear prohibition for general sale,  to alert  all involved in the production, distribution, and implementation of care programs.

While accepting the caution regarding long lists of documents, it is surely most important to include the reference to the International Code of Marketing of Breastmilk Substitutes and subsequent relevant WHA Resolutions, especially as this is specifically mentioned in Article 4.4 of the  Codex Code of Ethics for International Trade in Food, that states: “National authorities should be aware of their obligations under the International Health Regulations (2005) with regard to food safety events, including notification, reporting or verification of events to the World Health Organisation (WHO). They should also make sure that the international code of marketing of breast milk substitutes and relevant resolutions of the World Health Assembly (WHA) setting forth principles for the protection and promotion of breastfeeding be observed”

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The FSMP safeguards are not a sufficient safeguard.  The Guidelines should contain a full Preamble, forbidding general sale and all forms of  marketing.

The labelling of RUTF for children from 6 to 59 months with SAM must be in accordance – NOT ONLY with the Standard for the Labelling of and Claims for Foods for Special Medical Purposes (CXS 180-1991), the General Standard for the Labelling of and Claims for Pre-packaged Foods for Special Dietary Uses (CXS 146-1985), and Guidelines on Nutrition Labelling (CXG 2-1985) BUT ALSO  the  Guidelines for Use of Nutrition and Health Claims (CXG 23-1997) that include a prohibition  on the use of nutrition and health claims for foods for infants and young children.

In addition to the proposed safeguards, the labelling of RUTF should include the following prominent additional safeguards and WARNINGS:

There should be no promotional claims

The products should not be flavoured

The product must only be used for the therapeutic treatment of Severe Acute Malnutrition,  strictly under medical supervision

Potable  drinking water must be available for children receiving RUTF treatment.

The labelling of the product shall not  refer to, resemble or cross-promote infant formula, follow-up formula for older infants, or formula for special medical purposes intended for infants, including numbers,  text, statements, or images of these products. 

These products must only be used for the treatment of SAM and strictly under medical supervision.

Potable drinking water must be available for children receiving RUTF treatment 

Products are not to be sold on the open market

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2    IBFAN COMMENT ON REVISION OF FOLLOW FORMULA STANDARD  IBFAN FUF scope etc

General Comments

IBFAN considers that the text is NOT ready for adoption for the following reasons:

• The lack of adequate safeguards to prevent inappropriate marketing of these products will lead to an increase of their needless use around the world as projected in business forecasts. WHO and other health authorities declare follow-on milks and toddler milks for young children “not necessary”. Continued breastfeeding is recommended for up to two years and beyond for optimal young child health, hence the use of these products, which function as breastmilk substitutes pose a risk to the health of young children during critical stages of growth and development. The current text will lead to children being fed inappropriate, expensive, highly processed products that pose health risks and do not meet their nutritional needs.

The global trade of these products will add an unnecessary burden to the environment. Dr. Julie Smith, Honorary Associate Professor,  Australian Centre for Economic Research on Health:  “The most alarming finding in our research is a very large proportion of greenhouse gas emission impact is associated with the so-called growing up milks or toddler formula …  In China, nearly half of the sales of milk formula is toddler formula.  For the UK alone, carbon emission savings gained by supporting mothers to breastfeed would equate to taking between 50,000 and 77,500 cars off the road each year.

• The current text fails to forbid the deceptive marketing strategy of cross promotion between product categories for drinks for young children, other formula and follow-up milks and products. The text in Section 9.6.5 forbids only references TO infant formula. Current marketing practices demonstrate that this is an insufficient safeguard. The text should clearly state that marketing of Drinks for Young Children should not ‘resemble’ share branding or cross promote infant formula, FSMPs and other drinks and foods marketed for infants and young children. Since the debate on this issue in the 41^st CCNFSDU in November 2019 was brought to an early close through lack of time and since numerous Member States have stated that they would have preferred stronger language, the issue of cross promotion should be reopened at CCFSND42.
• 9.6.5 The labelling of the product as defined in Section 2.1 shall not refer to,  RESEMBLE or Cross Promote infant formula, follow-up formula for older infants, or formula  for special medical purposes intended for infants, including numbers,  text, statements, or images of these products. 
• On the issue of product definition, the overwhelming majority of countries and observers (28 plus 27 EU members (and more in CRDs)were in favour of the deletion of text that implies that these products may have added value for child nutrition. The EU cited the European Food Safety Authority (EFSA) scientific advice on young child formulae in 2013, that these products have “no unique role” and “cannot be considered as a necessity to satisfy the nutritional requirements of young children” when compared to other foods that may be included in their normal diet.  Only 14 countries proposed retaining the promotional text.
• Drinks for young children are not necessary therefore it is critical that the ban on health and nutrition claims be mandatory. Claims will be deceptive and mislead parents and care givers into believing that the use of these products provide benefits that cannot be derived from breastmilk, animal milks, other drinks or complementary family foods.
• Follow-on milks and drinks for young children must carry the warnings regarding intrinsic contamination for products in powdered form.
• IBFAN maintains its original position that all four categories of products that FUNCTION as breastmilk substitutes – infant formulas, formulas for special medical purposes, follow-up formulas and drinks for young children – should be brought under one Codex standard that is divided into 4 parts with one overarching preamble.  It would then be clear that all products are covered by the marketing restrictions outlined in the International Code and subsequent relevant WHA Resolutions, ie – they should not be promoted in any way.

 

Useful links:

RUTF: WHO RUTF  Meeting 19 MARCH 2019.  IBFAN-Codex-RUTF31.10.17-

previous IBFAN FUF comment  IBFAN COMMENT FOPN

Exporting countries put trade before the health of the planet and children. IBFAN Press release,  Nov 2019 

WHO/UNICEF INFORMATION NOTE – Cross–promotion of infant formula and toddler milks, WHO, 2018).

Worldwide Baby Food Drink Market In-depth Research Report 2021, Forecast to 2026, expects 7.7% growth from $68bn in 2020 to 91bn by 2026 – more than 30% in 5 years!

Codex Paper What You Don’t Know About the Codex Can Hurt You: How Trade Policy Trumps Global Health Governance in Infant and Young Child Nutrition.http://ijhpm.com. Int J Health Policy Manag 2021, x(x), 1–15. Katheryn Russ1*ID, Phillip Baker2ID, Michaela Byrd3, Manho Kang3ID, Rizki Nauli Siregar3ID, Hammad Zahid3, David McCoy4ID

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CODEX COMMITTEE ON FOOD LABELLING (CCFL)

Front of Pack Nutrition Labelling

IBFAN COMMENT FOPN

Posición-IBFAN Spanish

46th Codex Committee on Food Labelling cl21_19e.  CLICK HERE for report CX/FL 21/46/6
27 September–1 October and 7 October 2021

Please share IBFAN’s comments on both these items  your government delegations in the hopes that they can take our concerns into account.

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CODEX COMMITTEE ON FOOD LABELLING. 46th Session
Virtual – cl21_19e.   27 September–1Octoberand 7 October 2021

CLICK HERE for report CX/FL 21/46/6

PLEASE SHARE WITH YOUR GOVERNMENT DELEGATES

IBFAN COMMENT FOPNL Sept 1, 2021

IBFAN COMMENT PROPOSED DRAFT GUIDELINES ON FRONT-OF-PACK NUTRITION LABELLING at Step 3 – submitted 1^st September 2021

General Comments

Front of Pack Nutrition Labeling (FOPNL) can be a means to provide additional information to those who purchase pre-packaged foods and provide a system for making decisions about food products available in the market-place. Moreover it has the potential of reducing consumption of food ingredients and products that contribute to unhealthy diets.

A number of underlying principles are essential for the effective implementation of FOPNL policies.

• For FOPNL to be effective IBFAN considers a mandatory system of WARNINGS to be much preferred. Research of countries where FOPNL has been voluntary shows limited uptake by the food products industries and hence the ability for product comparisons is compromised and the expected health benefits are under realized.
• Processed complementary food products and formulas for infants and young children should not have FOPNL as this will be promotional of certain products over other products and contrary to the provisions of the International Code of Marketing of Breastmilk Substitutes and subsequent WHA resolutions. To effectively safeguard infant and young child health, it is preferable to have warnings on these products.
• Codex must address the environmental impact of the global trade in unnecessary food products. The United Nations Intergovernmental Panel on Climate Change (IPCC) estimates that 21–37% of total greenhouse gas (GHG) emissions are attributable to the food system and that climate change will have important negative impacts on food security. Green lighting the ultra-processed, excessively packaged with plastic/styrofoam products may reduce the consumption of a few harmful food ingredients yet will continue contributing to increasingly alarming levels of environmental degradation.
• In view of the need to safeguard policy setting from commercial influence, IBFAN believes that the business term ‘stakeholder’ is removed from all Codex texts. Advocating for public health goals/objectives is very different from seeking commercial/profit ones. It is misleading to group all constituents under this term.
• Specific CommentsIt is critical that the implementation and policy setting for FOPNL be led by national governments who are accountable and responsible for the overall health and nutrition of their citizens. To fulfill their obligations governments must ensure that policy development is free of commercial influence while ensuring adequate participation from civil society, independent academics, health associations, and other relevant constituencies.We see no need for a Codex text to list collaboration or consultation with specific interested parties since this is likely to open the door to abuse and legitimise corporate lobbying – placing the businesses on the same level as all other actors.  Governments have a duty to protect citizens and ensure appropriate consultations.Principle 4.3.1 The text should. read:FOPNL should be government led and developed in collaboration with all interested parties including  government, consumers, academia, public health associations, private sector among others,by ensuring robust safeguards against conflict of interest.Section 2.2 Exclusion for foods and products intended for infants and / or young children Commercial foods and products intended for infants and young children should not be included in the guidelines for FOPNL. The International Code of Marketing of Breastmilk Substitutes and subsequent resolutions of the World Health Assembly govern the labeling and marketing of a number of these products. These include infant formulas, formulas for special medical purposes, follow-up formulas and drinks for young children. A number of Code provisions also cover complementary foods for older infants and young children. Claims are not permitted by Codex Guidelines on Nutrition and Health Claims or WHA Resolution 63.23 that urges Member States “To end inappropriate promotion of foods for infants and young children and to ensure that claims not be permitted for foods for infants and young children”  The FOPNL would be contrary to provisions in the International Code as they are promotional in essence by preferring one product to another.  This may lead parents and care givers to perceive these products as being endorsed by government authorities and thus have a negative impact on breastfeeding decision-making. In effect FOPNL on formulas for infants and children will have a negative impact on infant and young child health.Similarly complementary food products should not be included. These products are highly processed and their consumption should be discouraged. Older infants and young children fed processed complementary foods risk dental caries, obesity and develop preferences for bland “white” foods. Ultra-processed products invariably contain chemical additives to stabilize, emulsify, thicken, regulate acidity, and act as anti-oxidants etc.  Many ingredients are  “permitted” by Codex Alimentarius standards, some at regulated levels and others according to “good manufacturing practices”, with their safety declared not by independent and convincing science but on the basis of political consensus and claims of “history of safe use”.Public health nutrition policy promotes the consumption of healthy nutritious foods for optimal health and development as well as the development of life long preferences for healthy foods.  FOPNL in these situations can act as a marketing tool for the consumption of inappropriate ultra-processed food products at a vulnerable stage of growth and development.

DRAFT REVISED STANDARD FOR FOLLOW-UP FORMULA(CXS 156-1987) SECTION B: DRINK/PRODUCT FOR YOUNG CHILDREN WITH ADDED NUTRIENTS OR DRINK FOR YOUNG CHILDREN

IBFAN Step 7 FUF

ENCA- Codex FUM section B

Here in Spanish: Posición IBFAN en Codex 2021

(CLICK HERE for our Press Release on the last face to face meeting on November 2019: CODEX: Exporting countries put trade before the health of the planet and children

CL 2021/03-NFSDU (REST OF THE TEXT ONLY) Revision of the Standard for Follow-Formula: Section B”

DRAFT REVISED STANDARD FOR FOLLOW-UP FORMULA(CXS 156-1987) SECTION B: DRINK/PRODUCT FOR YOUNG CHILDREN WITH ADDED NUTRIENTS OR DRINK FOR YOUNG CHILDREN

IBFAN considers does not consider the text ready for adoption. It fails to contain sufficient safeguards to prevent the use of the ultra-processed unnecessary products.

• The lack of adequate safeguards to prevent inappropriate marketing of these products will lead to an increase in their needless use around the world as projected in business forecasts. WHO and other health authorities declare follow-on milks and toddler milks for young children “not necessary”. Continued breastfeeding is recommended to two years and beyond for optimal young child health, hence the use of these products, which function as breastmilk substitutes pose a risk to the health of young children during critical stages of growth and development. The current text will lead to children being fed inappropriate expensive products that do not meet their nutritional needs.
• Drinks for young children are not necessary therefore it is critical that the ban on health and nutrition claims be mandatory. Claims will be deceptive and mislead parents and care givers into believing that the use of these products provide benefits that cannot be derived from breastmilk, animal milks, other drinks or complementary family foods.
• The current text fails to forbid the deceptive marketing strategy of cross promotion between product categories for drinks for young children, other formula and follow-up milks and products The text in Section 9.6.4 forbids only references to infant formula. Current marketing practices demonstrate that this is an insufficient safeguard. The text should clearly state that marketing of Drinks for young children should not ‘ resemble’ infant formula, FSMPs and other drinks and foods marketed for infants and young children.
• Follow-on milks and drinks for young children must carry the warnings regarding intrinsic contamination for products in powdered form.
• IBFAN maintains its original position that all four categories of products that FUNCTION as breastmilk substitutes – infant formulas, formulas for special medical purposes, follow-up formulas and drinks for young children – should be brought under one Codex standard that is divided into 4 parts with one overarching preamble.  It would then be clear that all products are covered by the marketing restrictions outlined in the International Code and subsequent relevant WHA Resolutions, ie – none should be promoted in any way.

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Codex Draft Guidance for the Management of Biological Foodborne Outbreaks.

Biologicaloutbreaks (step 6)

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IBFAN Drinks YC Description.March 2021

Codex Consultation 2021

DRINK/PRODUCT FOR YOUNG CHILDREN WITH ADDED NUTRIENTS OR DRINK FOR YOUNG CHILDREN

Request for comments at Step 6 on the draft revision of the Standard for Follow-Formula: Section B: scope, definition and labelling

IBFAN Comment

DRAFT REVISED STANDARD FOR FOLLOW-UP FORMULA (CXS 156-1987)

SECTION B: DRINK/PRODUCT FOR YOUNG CHILDREN WITH ADDED NUTRIENTS OR DRINK FOR YOUNG CHILDREN

At Step 6  Section 2 Description

2.1.1.

The proposed text should be replaced with Para 59 of the Report  (that received ‘considerable’  support):

• “Drink for Young Children means a product manufactured for use as a liquid part of the diversified diet of young children that functions as a substitute for either breastmilk or other milks and is not nutritionally adequate to meet the requirements of young children”.

The following footnote should be added:

• In many countries these products are regulated as breastmilk substitutes.

IBFAN comment:

The term “with added nutrients” is a claim which gives parents and care givers the impression that the product has added nutritional value and may be a necessary nutritional requirement for young child growth. Such a product name is misleading and deceptive and bears an intrinsic nutrient content claim. The use of follow-up products has been declared “not necessary” by the World Health Organization and these products are  not needed as a part of the diversified diet for young children.

IBFAN recommends that the name of the product should be “drink for young children”. This will eliminate confusion and deception for parents and care givers as to the use and lack of need and potential risks of  these Ultra Processed products.

 

In order to assist in the development of national responses, comments should be submitted for Section 2.1.1  to national Codex Contact points.  by March 17, 2021 and for The rest of the text by June 16, 2021

CCNFSDU – Session 42 -CL 2020/03/OCS-NFSDU – Request for comments at Step 6 on the draft revision of the Standard for. Follow-Formula_En-Fr    Here is the link to the documentation for the 42nd Session of CCNFSDU  CL 2020/03/OCS-NFSDU –
http://www.fao.org/fao-who-codexalimentarius/sh-proxy/pt/?lnk=1&url=https%253A%252F%252Fworkspace.fao.org%252Fsites%252Fcodex%252FCircular%252520Letters%252FCL%2525202021-03-OCS%252Fcl21_03e.pdf

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BPNI website with EVIDENCE regarding the risks to Health and the Planet

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UK Consultations:

The regulation of genetic technologies  Deadline: 17.3.21

DRAFT Public Health England (PHE) proposals for 2023 commercial baby food and drink guidelines.   DEADLINE 5th January 2021 BMA-Response FSNT response

Total restriction of online advertising for products high in fat, sugar and salt (HFSS) DEADLINE 22nd December 2020.

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Latest IBFAN Comments Codex  Consultation on Review of Follow-up Formula (CXS156 – 1987)  

Deadline 10th June 2020.  

IBFAN-2020-Comment

Subject under discussion: Definition, linkages between definition and name of product, and the JEMNU report on nitrogen to protein conversion factor.

IBFAN response to 2 of the  6 Questions:

Question 1 What is the purpose of a definition?

Summary of IBFAN response: A definition is a regulatory tool that must describe the product as clearly as possible and contain no unnecessary, idealising, promotional or deceptive wording which will mask the real lack of nutritional necessity of these drinks. The products that are industrially produced and  function as breastmilk substitutes. Their marketing poses serious risks to child health and survival, including the health risks of consuming industrially produced, non-food based nutrients, possibly in excessive amounts. The marketing and labelling of these products must be strictly controlled, at the very least to the same level on infant formula, if the standard is to meet the Codex mandate of protecting consumer health. The mandatory addition of certain nutrients can in no way match the nutritional composition of breastmilk. The products were invented by the baby food industry in an effort to circumvent the International Code of Marketing of Breastmilk Substitutes and subsequent relevant WHA Resolutions, and are recognized to be unnecessary. CCNFSDU has failed to allow sufficient discussion and consideration of the positions of all member states regarding cross promotion, marketing and labelling of these products. The products are highly likely to be confused with infant formula and their global trade risks the replacement of breastfeeding and the undermining of child health. The name should only be Drink for young children’

 

Question 2.  Select one of the 3 options provided:   ‘Drink/Product for young children with added nutrients’ and ‘Drink for young children’ and provide justification for your response. Summary of IBFAN comment:  If these products are to be included in  a  standard  at  all  –  and  IBFAN  strongly  recommends  that they are not -­‐  they should be absorbed into one revised infant formula standard. IBFAN considers Option 2 to be the least risky option and strongly opposes Options 1 and 3.  Option 3 is especially problematic in that it ascribes an unsubstantiated idealising, wholly risk free value to the product, that will be used by marketeers to undermine confidence in breastfeeding and suggest that unprocessed, locally available, bio­‐diverse, more sustainable, culturally appropriate and invariably healthier alternatives are somehow lacking in nutrients. There is no commonality or consensus in what might be ‘lacking’. IBFAN strongly objects to the inclusion of the text “with added nutrients” in all three options since this is a nutrient content claim and does not belong in the name. Nutrition information is labelled in the Nutrient Content table.

Codex  Consultation on Review of Follow-up Formula (CXS156 – 1987)   Deadline 10th June 2020.  

IBFAN-2020-Comment

Subject under discussion: Definition, linkages between definition and name of product, and the JEMNU report on nitrogen to protein conversion factor.

 

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See Codex Circular letters with other deadlines  here

Letter from Codex Secretary to CCPs May_2020.  This letter outlines the plans for continuing codex work in COVID context

CL 2019/114/OCS-NFSDU

12/19

Request for comments at Step 5 on the proposed draft Guidelines for ready to use therapeutic foods

30/04/2020

IBFAN comment on revision of Codex Follow-up Formula Standard.  SECTION B  at Step 5.  General Comments

IBFAN considers that the text is NOT ready for adoption for the following reasons:

• The lack of adequate safeguards to prevent inappropriate marketing of these products will lead to an increase in their needless use around the world as projected in business forecasts. WHO and other health authorities declare follow-on milks and toddler milks for young children “not necessary”. Continued breastfeeding is recommended to two years and beyond for optimal young child health, hence the use of these products, which function as breastmilk substitutes pose a risk to the health of young children during critical stages of growth and development. The current text will lead to children being fed inappropriate expensive products that do not meet their nutritional needs.
• The current text fails to forbid the deceptive marketing strategy of cross promotion between product categories for drinks for young children, other formula and follow-up milks and products The text in Section 9.6.4 forbids only references to infant formula. Current marketing practices demonstrate that this is an insufficient safeguard. The text should clearly state that marketing of Drinks for young children should not ‘ resemble’ infant formula, FSMPs and other drinks and foods marketed for infants and young children.
• Follow-on milks and drinks for young children must carry the warnings regarding intrinsic contamination for products in powdered form.
• IBFAN maintains its original position that all four categories of products that FUNCTION as breastmilk substitutes – infant formulas, formulas for special medical purposes, follow-up formulas and drinks for young children – should be brought under one Codex standard that is divided into 4 parts with one overarching preamble.  It would then be clear that all products are covered by the marketing restrictions outlined in the International Code and subsequent relevant WHA Resolutions, ie – none should be promoted in any way.

IBFAN COMMENT ON PROPOSED DRAFT GUIDELINES FOR READY TO USE THERAPEUTIC FOODS (RUTF). (at Step 5).

IBFAN Comment RUTF March 2020 IBFAN POLICY BRIEF ON RUTF

IBFAN considers that the Guidelines are not ready for adoption.  IBFAN has always maintained that there is no need for a Codex Guideline for RUTF – and that the risks of having one outweigh the benefits.  If a Guideline is necessary then it should be produced by appropriate bodies such as WHO and UNICEF, whose remit is solely the pursuit of public health.

While Codex has an important role in ensuring that all foods and commodities are as safe and nutrition as possible, it is not the appropriate forum for discussions about vulnerable malnourished children. Decisions at Codex invariably encourage increased global trade and are taken on the basis on politically and commercially  influenced consensus, not on sound credible evidence.    The Guidelines risks subverting “the UN Strategy to build capacity within countries to produce RUTF where needed, while ensuring appropriate use”.

The Guidelines fail to include safeguards to prevent the marketing of RUTF products and in so doing leave the door open for commercial exploitation that increases the risk of unnecessary and inappropriate use.

The Guidelines may trigger diversion of public funds away from support for sustainable solutions such as breastfeeding and locally sourced, culturally appropriate, bio-diverse family foods.

The Codex Standard covering Formulas for Special Medical Purposes (CODEX STAN 72 –1981) is not a sufficient safeguard, because FSMPs are designed to be sold on the open market. Categorisation as an FSMP has lead to an increase in inappropriate marketing of these products.

The Codex process is not adequately safeguarded from conflicts of interest and undue influence from manufacturers and distributors of the products under discussion has subverted the public health purpose.

The Guidelines are likely to be used by manufacturers and distributors to put pressure on governments to accept imports of products that may not be needed or wanted.

CL 2020/23/OCS-CF

01/20

Proposed draft MLs for total aflatoxins in certain cereals and cereal-based products including foods for infants and young children

30/06/2020

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See Codex Circular letters with other deadlines  here

Letter from Codex Secretary to CCPs May_2020.  This letter outlines the plans for continuing codex work in the context of COVID

IBFAN comment on revision of Codex Follow-up Formula Standard.  SECTION B  at Step 5.  General Comments

IBFAN considers that the text is NOT ready for adoption for the following reasons:

• The lack of adequate safeguards to prevent inappropriate marketing of these products will lead to an increase in their needless use around the world as projected in business forecasts. WHO and other health authorities declare follow-on milks and toddler milks for young children “not necessary”. Continued breastfeeding is recommended to two years and beyond for optimal young child health, hence the use of these products, which function as breastmilk substitutes pose a risk to the health of young children during critical stages of growth and development. The current text will lead to children being fed inappropriate expensive products that do not meet their nutritional needs.
• The current text fails to forbid the deceptive marketing strategy of cross promotion between product categories for drinks for young children, other formula and follow-up milks and products The text in Section 9.6.4 forbids only references to infant formula. Current marketing practices demonstrate that this is an insufficient safeguard. The text should clearly state that marketing of Drinks for young children should not ‘ resemble’ infant formula, FSMPs and other drinks and foods marketed for infants and young children.
• Follow-on milks and drinks for young children must carry the warnings regarding intrinsic contamination for products in powdered form.
• IBFAN maintains its original position that all four categories of products that FUNCTION as breastmilk substitutes – infant formulas, formulas for special medical purposes, follow-up formulas and drinks for young children – should be brought under one Codex standard that is divided into 4 parts with one overarching preamble.  It would then be clear that all products are covered by the marketing restrictions outlined in the International Code and subsequent relevant WHA Resolutions, ie – none should be promoted in any way.

IBFAN COMMENT ON PROPOSED DRAFT GUIDELINES FOR READY TO USE THERAPEUTIC FOODS (RUTF). (at Step 5).

IBFAN Comment RUTF March 2020 IBFAN POLICY BRIEF ON RUTF

IBFAN considers that the Guidelines are not ready for adoption.  IBFAN has always maintained that there is no need for a Codex Guideline for RUTF – and that the risks of having one outweigh the benefits.  If a Guideline is necessary then it should be produced by appropriate bodies such as WHO and UNICEF, whose remit is solely the pursuit of public health.

While Codex has an important role in ensuring that all foods and commodities are as safe and nutrition as p

IBFAN comment on revision of Follow-up Formula Standard Section B

IBFAN  Step 5 Section B Review FUF Standard

IBFAN considers that the text is NOT ready for adoption for the following reasons:

• The lack of adequate safeguards to prevent inappropriate marketing of these products will lead to an increase in their needless use around the world as projected in business forecasts. WHO and other health authorities declare follow-on milks and toddler milks for young children “not necessary”. Continued breastfeeding is recommended to two years and beyond for optimal young child health, hence the use of these products, which function as breastmilk substitutes pose a risk to the health of young children during critical stages of growth and development. The current text will lead to children being fed inappropriate expensive products that do not meet their nutritional needs.
• The current text fails to forbid the deceptive marketing strategy of cross promotion between product categories for drinks for young children, other formula and follow-up milks and products The text in Section 9.6.4 forbids only references to infant formula. Current marketing practices demonstrate that this is an insufficient safeguard. The text should clearly state that marketing of Drinks for young children should not ‘ resemble’ infant formula, FSMPs and other drinks and foods marketed for infants and young children.
• Drinks for young children are not necessary therefore it is critical that there is a ban on health and nutrition claims. Claims will be deceptive and mislead parents and care givers into believing that the use of these products provide benefits that cannot be derived from breastmilk or animal milks other drinks or complementary food or family food.
• Follow-on milks and drinks for young children must carry the warnings regarding intrinsic contamination for products in powdered form.

IBFAN maintains its original position that all four categories of products that FUNCTION as breastmilk substitutes – infant formulas, formulas for special medical purposes, follow-up formulas and drinks for young children – should be brought under one Codex standard that is divided into 4 parts with one overarching preamble.  It would then be clear that all products are covered by the marketing restrictions outlined in the International Code and subsequent relevant WHA Resolutions, ie – none should be promoted in any way.

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BFAN COMMENT ON PROPOSED DRAFT GUIDELINES FOR READY TO USE THERAPEUTIC FOODS (RUTF). (at Step 5)

IBFAN Comment RUTF Guidelines Step 5

IBFAN POLICY BRIEF ON RUTF

IBFAN considers that the Guidelines are not ready for adoption.

IBFAN has always maintained that there is no need for a Codex Guideline for RUTF – and that the risks of having one outweigh the benefits.  If a Guideline is necessary then it should be produced by appropriate bodies such as WHO and UNICEF, whose remit is solely the pursuit of public health.

While Codex has an important role in ensuring that all foods and commodities are as safe and nutrition as possible, it is not the appropriate forum for discussions about vulnerable malnourished children. Decisions at Codex invariably encourage increased global trade and are taken on the basis on politically and commercially  influenced consensus, not on sound credible evidence.    The Guidelines risks subverting “the UN Strategy to build capacity within countries to produce RUTF where needed, while ensuring appropriate use”.

The Guidelines fail to include safeguards to prevent the marketing of RUTF products and in so doing leave the door open for commercial exploitation that increases the risk of unnecessary and inappropriate use.

The Guidelines may trigger diversion of public funds away from support for sustainable solutions such as breastfeeding and locally sourced, culturally appropriate, bio-diverse family foods.

The Codex Standard covering Formulas for Special Medical Purposes (CODEX STAN 72 –1981) is not a sufficient safeguard, because FSMPs are designed to be sold on the open market. Categorisation as an FSMP has lead to an increase in inappropriate marketing of these products.

The Codex process is not adequately safeguarded from conflicts of interest and undue influence from manufacturers and distributors of the products under discussion has subverted the public health purpose.

The Guidelines are likely to be used by manufacturers and distributors to put pressure on governments to accept imports of products that may not be needed or wanted.

see PDF for specific comments

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146th Session of the WHO Executive Board

When: 3 February 2020 – 8 February 2020

Where: WHO Headquarters

Contact: Event website

“The WHO Executive Board is composed of 34 members technically qualified in the field of health. Members are elected for three-year terms. The main Board meeting, at which the agenda for the forthcoming Health Assembly is agreed upon and resolutions for forwarding to the Health Assembly are adopted, is held in January, with a second shorter meeting in May, immediately after the Health Assembly, for more administrative matters. The main functions of the Board are to give effect to the decisions and policies of the Health Assembly, to advise it and generally to facilitate its work.” (quoted from WHO website)

• The draft provisional agenda of EB 146 and an  annotated agenda are now available on the WHO website.
• EB 146 documentation
• EB members

Maternal, Infant and Young Child Health will be on the agenda again this year and I will be joining the small IBFAN team, Alison Linnecar (Convenor of our Climate Change and Contaminants Working Group), and Dr Marina Rea of IBFAN Brazil to raise awareness of our concerns.  The DG report the report of the Director General (EB146/24) focuses on the Comprehensive implementation plan on maternal, infant and young child nutrition: biennial report

We will also be covering issues related to Governance,  WHO interactions with Non State Actors, emergencies and NCDs

I am planning  to speak on Saturday 1st February in the session on WHO and Global health Governance  at the civil society events organised by  G2H2.

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16th December 2019 – joining by WEBEX

WHO information session on NSA consultation and secretariat proposals:  IBFAN Questions/Comments

Upcoming Codex nutrition (CCNFSDU) meeting  –  23 – 29th November 2019

CLICK HERE for background papers   Dusseldorf, Germany

IBFAN will be attending the next  meeting in Germany where the struggle to protect child rights to health and planetary health will continue.  Because Codex Standards are used by the World Trade Organisation (WTO) as bench marks in trade disputes,  IBFAN has been working since 1995 to ensure that they incorporate the Resolutions and Guidance passed at the World Health Assembly.  Strong Codex standards support governments sovereign rights (and duties) to adopt laws that safeguard citizens and control the marketing of products that pose a risk to health.

While infant formulas are legitimate products for babies who are not breastfed, formulas targeting babies over six months are unnecessary and often pose a risk to health in terms of obesity, diabetes, dental caries and other non-communicable diseases.  Another important factor is the impact these products have on climate change in terms of production, distribution and when  marketed in single use/single portion plastic containers. The global trade of these unnecessary products certainly  increase greenhouse gases and other effects harmful to the environment.  CLICK here for IBFAN’s Greenfeeding papers.

PROPOSED DRAFT REVISED STANDARD FOR FOLLOW-UP FORMULA (CXS 156-1987)

SECTION B. (held at Step 4)

The key issues  at stake:

1. Preamble and scope  of the standards for formulas for for older infants (follow-up formula) and for young children. IBFAN will call for the inclusion of the following text:
1.4 The application of this section of the Standard shall conform to the recommendations made in the International Code of Marketing of Breast-milk Substitutes (1981), relevant WHO guidelines and policies as well as relevant World Health Assembly (WHA) resolutions, including the WHA resolution 69.9 (2016) and its accompanying WHO Guidance on Ending the Inappropriate Marketing of Foods for Infants and Young Children the Global Strategy for Infant and Young Child Feeding and
World Health Assembly resolution WHA54.2 (2001).

2. Definition of the products as breastmilk substitutes. Regardless of the unsuitability of their composition, follow-on and other formulas for older infants and young child FUNCTION as breastmilk substitutes and their promotion undermines optimal feeding. WHO’s 2016 Guidance clear calls for no promotion of these products up to the age of 36 months.

3. Cross-promotion/branding in the labelling section of both the follow-up formula and the products for young children.

IBFAN is proposing to keep the last sentence in  Para 9.6.4 and remove the word ‘label’. (retaining the much wider and safer term ‘labelling’ )

The baby food industry is extending its use of cross promotion not only to follow-up formulas and toddlers milks – but also to products well beyond the age of 36 months  (sometimes redefining as nutritional milks). IBFAN, supported by many countries, believes that the  last part of the ban on cross promotion is very important to retain along with a reference to  Codex labelling of pre-packaged foods which contains useful safeguards.

Codex General Standard for Pre Packaged foods:CODEX STAN 1-1985

3. GENERAL PRINCIPLES.  3.1 Prepackaged food shall not be described or presented on any label or in any labelling in a manner that is false, misleading or deceptive or is likely to create an erroneous impression regarding its character in any respect.1. 3.2 Prepackaged food shall not be described or presented on any label or in any labelling by words, pictorial or other devices which refer to or are suggestive either directly or indirectly, of any other product with which such food might be confused, or in such a manner as to lead the purchaser or consumer to suppose that the food is connected with such other product.

Here are some other resources.

IBFAN Comment FUF for young children Part B (held at step 4)

Final IBFAN Comment Step 3 on the Review of the Standard for follow MA

IBFAN comment on PREAMBLE to Sections A and B FUF standard – final

WHO paper on cross promotion

Other topics on the agenda that we are following:

Ready to Use Therapeutic Foods for malnourished children IBFAN Codex RUTF

Report of a WHO meeting on RUTF   WHO-NMH-NHD-19.1-eng

Updated Indian position statements on RUTF and SAM Management: https://journals.plos.org/plosmedicine/article?id=10.1371/journal.pmed.1002934

Additives – there was a long discussion about Additives in Liquid milk at the Codex Commission meeting in July.  See NOTES HERE and webcast HERE   

The definition for Bio-fortification – proposed by IFPRI and Harvest Plus. We hope that work on the definition will be dropped.  It is highly promotional and misleading and as proposed  refers to all forms of agriculture, including Genetic Modification. In the EU the term Bio means ‘Organic’, so the definition would not be not legal if used in the EU.

At the Codex Labelling Committee (CCFL) in Canada, May 2019 (1) many countries reiterated their concerns about the term and the EU, India, Russia, Chile, Mexico, New Zealand, Panama, Nigeria, and even the US, all agreed that the work should be stopped. However IFPRI seems determined to press ahead and keep the issue on the agenda and its Committee Room Document (2) proposes three different definitions, Agronomic Fortification, Fortification using conventional breeding techniques and Fortification using the techniques of modernbiotechnology.

(1) 45^th Session of CCFL, May 2019, Ottawa Canada. (Report forthcoming).

(2) IFPRI CRD 5 PROPOSED DRAFT DEFINITION FOR BIOFORTIFICATION.

IBFAN statement on Biofortification

CAC42.IBFAN.CRD_34x

FINAL-IBFAN CRD CCAFRICA23 Agenda Items 1+15

National Health Federation statement on Biofortification

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Consultation on the Sustainable Development Goals (SDGs). Deadline 8th September

See my Policy BLOG  for more and our statements on the agenda items.

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Proposed draft definition for biofortification, Comments at Step 3  Deadline 25th October 2018. IBFAN 2018 BIO COMMENT.

Review of the Standard for Follow-Up Formula.  IBFAN 2018 FUF COMMENT

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144th WHO Executive Board meeting

24th January – 1st February

All the documents and live webcasts are available from this link

IBFAN  intervention on Universal Health Care:  EB 144 UHC IBFAN 2019

Call for public health best practices  Deadline 31st January

https://webgate.ec.europa.eu/dyna/bp-portal/EUSurvey – Final

DG SANTE and the Commission’s Joint Research Centre are seeking to select public health best practices i.e. practical interventions that have shown to work at local, regional or national level, that can be transferred between Member States or scaled-up and are conducive to reaching Sustainable Development Goal 3.4.

Stakeholders are invited to submit evaluated practices through the best practice portal until 31 January 2019. All practices submitted by this date will be assessed in spring 2019. The owners of the practices selected as “best” would be invited to a “marketplace” workshop with Member States representatives to present their practice (planned for June 2019). It is foreseen that all practices selected as “best” receive a certificate of recognition and are published on the best practice portal.

Perception survey on EC public consultations

Deadline January11th

Baby Milk Action Response.  EUSurvey – Final

To participate in the survey, click on the link below:
https://ec.europa.eu/eusurvey/runner/AUDITPUBLICPARTICIPATION/867e603b-c2ba-4447-86a6-2858502d7a91

The European Court of Auditors, the EU’s independent auditor, is reviewing how the European Commission services, the auditee, consult stakeholders and the Commissions framework for public consultations. They are examining a sample of the Commissions public consultations.

In this context, the European Court of Auditors would like to know how citizens perceive public consultations as well as their opinions and suggestions for improvement. For this reason, the auditors have prepared a survey, which will be technically handled by the European Commission.

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DHSC EU Exit consultation 14.12.18Ongoing consultations:

UK Brexit Consultation

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EU,WHO,Codex

NHS article on Biofortification

CODEX ALIMENTARIUS CONSULTATION  – Please share with your country delegation:

FINAL REPORT of the meeting

REVIEW OF THE STANDARD FOR FOLLOW-UP FORMULA (CODEX STAN 156-1987) (Agenda Item 4b)7, 8

1. The Chair introduced the item and proposed to order the discussion as follows:

• Section A: follow-up formula for older infants: scope, product definition and
• Section B [Product] for young children: scope, product definition and
• Options for the structure of the Standard and the

2. New Zealand, the Chair of the electronic working group (EWG), speaking also on behalf of the co-Chairs France and Indonesia, introduced each of the recommendations in the order of the discussion
3. The Committee considered the recommendations of the EWG and in addition to editorial amendments, made the following decisions and

9. Labelling

1. The Committee agreed to reinsert the last sentence in this section relating to the prohibition on the use of nutrition and health It was noted that even though prohibitions on the use of nutrition and health claims were covered in section 1.4 of the Guidelines for Use of Nutrition and Health Claims (CXG 23 – 1997), it was necessary to emphasize the prohibitions for follow-up formula for older infants, which was also consistent with the Standard for Infant Formula and Formulas for Special Medical Purposes Intended for Infants (CXS 72 – 1981).

9.6 Additional labelling requirements

2. The Committee noted that this section was largely based on Article 9 of the WHO International Code of Marketing of Breastmilk Substitutes, and Recommendation 4 of the WHO Guidance on Ending the Inappropriate Promotion of Foods for Infants and Young Children (specifically provision 9.6.2); and in some cases the provision used the wording as contained within the
3. One observer called for the inclusion of the word “independent” in 9.6.1 (c).
4. There was discussion regarding 6.1(d) with the resultant agreed text referring to “not leading to cessation of continued breastfeeding” rather than referring to “not replacing breastmilk” as this concept was considered in conflict with the definition.
5. Regarding 9.6.2 the decision was taken to include young children in the list of prohibited pictures on the label of follow-up formula for older
6. The Committee made further amendments, to align with the WHO guidance, to section 9.6.2.4 to emphasize that the product was not similar to breastmilk; and to section 9.6.4 to indicate that the product should be distinctly labelled to ensure that consumers could distinguish between infant formula, follow-up formula for older infants and [product] for young children, and foods for special dietary uses. In addition, a statement that cross-promotion was not allowed on the label was also introduced. Some delegations were not in favour of a provision on cross-promotion and raised concerns on whether it included advertising and marketing and that it went beyond the mandate of this Committee. The Chair confirmed that any reference to cross-promotion should be in relation to the label of the A suggestion was made to refer to cross-promotion on labelling rather than label. A question was then asked whether the term labelling extended to marketing and advertising.
7. Attention was drawn to the Codex definition of labelling in the General Standard for Labelling of Pre-Packaged Food (CXS 1-1981) that included “any written, printed or graphic matter that is present on the label, accompanies the food, or is displayed near the food including that for the purpose of promoting its sale or disposal”. The Representative of WHO clarified that the intent of the provision on cross-promotion was to avoid messages on labels that a product for a particular age group was also suitable for another age group or that reference was made to a similar product for another age group. Based on the clarification on the meaning of cross-promotion, the Committee agreed that the wording in the last section of 9.6.4 should refer to label/labelling and that “label/labelling” should remain in square

The Codex Committee on Nutrition and Foods for Special Dietary met in Berlin from 24th -30th November.

CLICK HERE for a  report on what happened last year. 

IBFAN and partner NGOs focused on the issues that relate to infant and young child feeding – thee key isses.

CLICK HERE for the agenda and Codex background papers.  There are three main items:

Review of the Standard for Follow-Up Formula

IBFAN 2018 FUF COMMENT

WHO INFORMATION NOTE – Clarification on the classification of follow-up formulas for children 6-36 months as breastmilk substitutes.  This is an important paper that provides the rationale for WHO’s position that breastmilk substitutes  include any milks of products that could be used to replace milk that are specifically marketed for feeding infants and young children up to the age of 3 years.

SUMMARY OF MEMBER STATES POSITIONS prepared by the Chairs of the Working Group

Comments at Step 3 on Scope, Product Definition, Labelling. Comments at Step 6 on Essential Composition.

Formulas for babies  6-36 months are big business and there was global media coverage following the position taken by the United States at the 71st World Health Assembly this  May.  At the Codex Commission meeting in Rome in July there was yet more evidence of the hard line being taken by the US to protect corporate interests and the routine use of antibiotics and growth hormones in livestock. These issues  affect the health of us all, but are especially important for children.

The promotion of formulas for older babies  is fuelling  global formula sales (set to rise to $70bn by 2019) and exacerbating the obesity epidemic – while undermining breastfeeding  –  a lifeline for so many children and undermining the health safeguards that exist in many countries.

The key consideration will be the definition. WHO, IBFAN and all our partners are clear that these products function as breastmilk substitutes and their labelling and marketing must properly controlled in line with the International Code and all subsequent relevant WHA Resolutions and that specific reference is made to the 2016 Resolution (WHA 69/9) and the Guidelines on Ending the inappropriate Promotion of Foods for infants and Young Children.

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Proposed draft Guidelines for Ready-to-Use Therapeutic Foods.

IBFAN 2018 RUTF COMMENT

RUTFcl18_64e.    RUTF Paper.  IBFAN 2017 Briefing on RUTF 

Commission Notice on the classification of Food for Special Medical Purposes (FSMP) (2017/C 401/01)  CLICK HERE

IBFAN Comment

IBFAN is concerned that this  issue was brought to Codex where commercial interests are so dominant.  We will be working to ensure that these products are not marketed and pushed as THE solution to malnutrition, and that support for more culturally appropriate and sustainable family foods and continued breastfeeding is not undermined. There are many unresolved problems with the products related to safety, composition (RUTF currently contain 25% sugar), production, transportation, distribution  and of course marketing. There will be a Physical Working Group to discuss the Preamble of this Guidelines on Saturday 24th November 2018.

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Proposed draft definition for biofortification, Comments at Step 3  Deadline 25th October 2018. IBFAN 2018 BIO COMMENT.

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Paper prepared for Codex Meeting in Berlin:

MATTERS OF INTEREST ARISING FROM FAO AND WHO (Prepared by FAO and WHO)

Marketing of breast-milk substitutes: national implementation of the international code: status report 2018
This biennial update on the legal status of the International Code of Marketing of Breast-milk Substitutes was published in May 2018 (http://www.who.int/nutrition/publications/infantfeeding/code_report2018/en/). The report documents that 136 out of 194 countries had some form of legal measure in place covering all, many or few provisions of the Code. Three countries enacted new Code-related legislation, three adopted additional legal measures to strengthen their legislative frameworks, and two took retrogressive steps by repealing laws or specific provisions of laws. The report also provides information on the provisions about marketing of complementary foods among the 59 countries that cover complementary foods as part of their Code law. Of those, 29 require messages and labels for complementary foods to include a statement on the importance of continued breastfeeding for up to 2 years or beyond, while 23 require mention of the importance of not introducing complementary feeding before 6 months of age. Thirty-seven of the countries prohibit manufacturers and distributors from sponsoring meetings of health professionals and scientific meetings, but in only 14 countries are manufacturers and distributors prohibited from using health facilities to host events, contests or campaigns.

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EU Delegated Regulation 2016/128 on Foods for Special Medical Purposes

Informal Consultation on a draft amended Statutory Instrument provisions to enforce the legislation in England

1. Foods for Special Medical Purposes (FSMP) are specialist foods intended for the exclusive or partial feeding of people whose nutritional requirements cannot be met by normal foods.
2. The Department of Health and Social Care is seeking views on plans to introduce domestic legislation, in the form of an amending Statutory Instrument (SI), so that EU Regulation 2016/128 on food for special medical purposes can be enforced in England. We are asking for stakeholders’ views on the appropriateness of the proposed approach to enforcement, which is based on Improvement Notices.
3. The SI to be amended for England is the Food for Specific Groups (Information and Compositional Requirements) (England) Regulations 2016, SI 2016 No. 688.
4. This is a limited technical consultation; the list of consultees is at Annex A.
   

Timing

5. The informal consultation will start 20^th September 2018 and end 18^th October 2018. Responses should be submitted to nutritionlegislation@dh.gsi.gov.uk by 5pm on 18^th October 2018.

EU Consultation: “healthy and sustainable food systems”.  Deadline 31st August

IBFAN Follow-up Formula Briefing

IBFAN’s point by point comments on Follow-up Formula  CLICK HERE

https://www.ohchr.org/EN/Issues/Poverty/Pages/CallforinputUK.aspx

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Public consultation on the draft protocol for the Scientific Opinion on free sugars from all dietary sources

Deadline: 4 March 2018

Document (1.51 MB)

Privacy statement (299.78 KB)

EFSA has launched an open consultation on its draft protocol for the Scientific Opinion on free sugars from all dietary sources.

This draft protocol describes the methodology that the EFSA Panel on Nutrition, Dietetic Products and Allergies (NDA Panel) will apply to address the request to define a science-based cut-off value for a daily exposure to free sugars from all dietary sources that is not associated with adverse health effects. This mandate was received from the national food authorities of five European countries (Denmark, Finland, Iceland, Norway, and Sweden), and it is expected to be finalised by February 2020 with the publication of the EFSA Scientific Opinion on free sugars from all dietary sources.

IBFAN is in Official Relations with WHO and will have a team at the forthcoming Executive Board Meeting   CLICK HERE for some key submissions IBFAN has made about WHO’s Framework of Engagement with Non State Actors and the redefining of Conflicts of Interest.

142nd session of the WHO Executive Board: 22–27 January 2018

CLICK HERE for more and for  IBFAN interventions

The Executive Board is composed of 34 members technically qualified in the field of health. Members are elected for three-year terms. The main functions of the Board are to give effect to the decisions and policies of the World Health Assembly, to advise it and generally to facilitate its work.

• Provisional agenda

• All documentation
• Click here to watch the live webcast for 142nd WHO Executive Board

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WHO Consultation on the DRAFT thirteenth General Programme of Work (GPW13)

New Deadline 29th November 2017

IBFAN SUBMISSIONS:   (CLICK HERE for Policy Blog)

Baby Milk Action IBFAN GWP

IBFAN_GIFA_2017_GPW13

Page down on this Link to make a new submission

The draft of the 13th Programme of Work was discussed at a special Executive Board Meeting at WHO HQ on 22-23rd November.

CLICK here for reports from this meeting   Click here for other NGO comments. (these are cut down to less than 300 words.)

2.11.17.EBSS4_2-en 2019-23_Strat_Map Agenda Nov GPW GPW13_-impact-framework-draft

IBFAN oral statement: IBFAN Statement GWP

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CLICK HERE for the Background Papers for the 39th Codex Committee on Nutrition and Foods for Special Dietary Uses,  4th – 8th December 2017  | Berlin, Germany

Below are IBFAN briefings on the  Agenda  items we are following:

1  The revision of the Follow-up Standard (Codex Stan 156-1987);

Codex paper  

IBFAN Follow-up Formula Briefing

IBFAN’s point by point comments on Follow-up Formula  CLICK HERE

IACFO’s comments are the same as IBFAN’s  CLICK HERE

 IBFAN’s Codex Working Group has prepared a briefing paper to highlight our recommendations for the revision of the Codex Follow-up Formula  standard (Codex Stan 156-1987) at the 39th Codex nutrition meeting to be held in Berlin, 4-8th December.

The briefing highlights the need:

•  to safeguard the health of older infants and young children;
•  to ensure policy coherence between Member State decisions at WHA and FAO (the Codex parent UN agencies) and Codex standards and guidelines;
• to highlight our concerns that the proliferation of standards risks increased trade and marketing of unnecessary and risky products.
• to ensure that formulas targeting babies 6-36months are noted as being unnecessary, that all are Breastmilk Substitutes and all come under the scope of the International Code and subsequent relevant WHA resolutions and should not be promoted.

2     The Proposed draft guideline for Ready To Use Therapeutic Food (RUTF);

CLICK HERE  for IBFAN Briefing on RUTF 

CLICK HERE for IBFAN comment on the Proposed draft RUTF guidelines

CLICK HERE for IACFO comment on the RUTF Guidelines

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3     The Proposed draft Definition for Biofortification.

CLICK HERE for the  IBFAN comment of the draft  Definition of Biofortification

CLICK HERE for the IACFO comment

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COMPLETED CONSULTATIONS

WHO Consultation on the thirteenth General Programme of Work (GPW13)  New Deadline 29th November 2017

Draft concept note towards WHO’s 13th General Programme of Work 2019–2023   English pdf, 653kb 

CLICK HERE  for IBFAN’s comment

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WHO draft Conflicts of Interest in Nutrition Tools

Of relevance to this consultation are  the comments on WHO’s proposals for Conflicts of Interest in Nutrition  Tools.  Only some of the comments have been posted on WHO’s website HERE.  Several other important comments from CoI experts have not been posted:

For example this  comment from Judith Richter

JRichter Comments_Safeguarding_against_CoI_in_nutrition_programmes_draft_approach_2017

Here is a selection of some of the comments on the WHO website:

GIFA comments+refs ibfan

IBFAN_WHO_COI_Nutrition_24_9_17

namibia

oecd

world_public_health_nutrition_association

the_cochrane_collaboration_united_kingdom

brazil

centre_for_health_science_and_law

WHO Consultation on Conflicts of Interest in nutrition

WHO has  published some of the comments  received  HERE   There are several other important ones from individuals that have not been posted

Here is the comment from IBFAN.

IBFAN_WHO_COI_Nutrition_24_9_17

Here is the comment from the Geneva Infant Feeding Association

GIFA comments+refs

Here is a comment from Judith Richter

JRichter Comments_Safeguarding_against_CoI_in_nutrition_programmes_draft_approach_2017

Here is the comment from Bill Jeffery, LLB, Executive Director
Centre for Health Science and Law (CHSL)  Canada

http://healthscienceandlaw.ca/wp-content/uploads/2017/09/CHSL.WHO-NutritionConflicts-of-Interest.Sept25-2017.pdf

http://www.who.int/nutrition/consultation-doi/en/ or in Nutrition webpage http://www.who.int/nutrition/en/ .

some useful articles:  

Valente, F. (2016). “Nutrition and food – how government for and by the people became government for and by the TNCs.” TNI.

https://www.tni.org/en/article/nutrition-and-food-how-government-for-and-of-the-people-became-government-for-and-by-the

Richter, J. (2014). “Time to turn the tide: WHO’s engagement with non-State actors & the politics of stakeholder-governance and conflicts of interest.” Rapid response to BMJ online letter by Nigel Hawkes, ‘Irrelevant’ WHO outpaced by younger rivals d5012 (Title of Hawkes’s BMJ print feature article: Will WHO reforms open the doors to private donors? http://www.bmj.com/content/348/bmj.g3351/rapid-responses

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August 2017: Consultation on WHO Guidance on Ending the Inappropriate Promotion of Foods for Infants and Young Children

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Codex Consultations:

The 40th  CODEX ALIMENTARIUS COMMISSION (CAC)  will start tomorrow in  Geneva.  The Global Food Standards set by Codex are important because they are used as bench marks in the event a Trade Dispute.   IBFAN and IACFO have been attending Codex meetings for over 20 years with the aim of achieving Policy Coherence between WHO and Codex: it is helpful to governments who want to protect child health if Codex Standards are in line with WHO Policy and the Resolutions adopted the World Health Assembly.

WHO has been raising the need for Policy Coherence many times at  Codex Commission meetings.  (see Paras 137-145 of the 2016 Report of CAC39 and Paras 161-170 of Report of the 73rd Session of the Executive Committee meeting.)

IBFAN continues to be concerned about  the  weak Codex  safeguards on Conflict of Interest that leave the Codex process wide open to undue commercial influence. The food and related industries and their front groups –  often constitute 40% of  Codex nutrition meetings, funding dinners and receptions for participants, promoting the findings from industry-funded research. This can affect the evidence base that is used to decide on the safety of ingredients, additives etc. Ill-defined terms, often used by industry, such as ‘generally accepted’ ‘History of safe use ‘ ‘science­‐based’ ‘scientifically demonstrated’ are used rather than the terms recommended by WHO: “Relevant convincing / generally accepted scientific evidence or the comparable level of evidence under the GRADE classification ”   

The industry argument that a ‘History of Safe Use‘ is sufficient was challenged  by the European Food Safety Authority (EFSA) in May in  its final guidance  on the assessment needed for  food for babies under the age of 16 weeks.  Following a consultation EFSA maintains the requirement for an extended one generation reproductive toxicity study for substances added intentionally to infant formula.

Other issues:  CLICK HERE for the background paper: Matters arising jointly from FAO and WHO: 2 The UN Decade of Action on Nutrition 2016-2025 3.2.2 Climate change and water scarcity 3.2.6 Antimicrobial Resistance (AMR)  and 4.2 Antimicrobial Resistance, 4.3 WHO Framework of Engagement with Non-State Actors (FENSA) 4.8 Development of nutrient profile models for regulating marketing of food and non-alcoholic beverages to children 

The discussion Panel on Wednesday 19th July.18.00 is entitled NGOs and Codex: what we expect and what we can contribute.   CLICK HERE   It is worth noting, that apart from IBFAN, nearly all the other panellists are funded by or representing the interests of industry of one kind or another:

AOAC International (Erik Konings, Past President) • Association of American Feed Control Officials (Richard Ten Eyck, Ingredient Definitions Chair) • European Association of Polyol Producers (Anders Liljegren, President) • European Food Law Association (Nicole Coutrelis, Vice-President) • Grocery Manufacturers Association (Richard D. White, Director, Codex and International Standards Policy) • International Association for Cereal Science and Technology (Amine Jbeil, Technical Director) • International Baby Food Action Network (Patti Rundall, IBFAN Codex Team) • International Grain Trade Coalition (Katy Lee, Secretariat) • National Health Federation (Scott Tips, Board Member) • United States Pharmacopeial Convention (Kristie Laurvick, Acting Director, Science – Foods Program Unit) • World Sugar Research Organisation (Roberta Re, Director General) 

Another issue to watch out for in April I highlighted on my Blog  a new US Trade briefing that was  published in April:  2017 National Trade Estimate Report on FOREIGN TRADE BARRIERS  This seemed to identify many health protective policies, including those designed to protect breastfeeding, as “trade barriers” that should be eliminated:  CLICK HERE

Codex revision of the Follow-up Formula Standard. 

2nd Consultation on scope and labelling:  In the last consultation the majority of Member States and NGOs called for the WHO Guidance on Inappropriate marketing of Foods for infants and young children/the International Code or subsequent relevant WHA Resolutions to be included in the revised Codex standard of Follow-on Formulas.   CODEX CHART April 2017   Click Here

2017 2 CP Older Infants Scope and Labelling SUBMITTERS RESPONSE FORM IBFAN -final 1

CLICK HERE  2017 2 CP Young Children Scope and Labelling SUBMITTERS RESPONSE FORM IBFAN – final 1

IACFO submitted a response that mirrors that of IBFAN

IBFAN’s submission on  scope and labelling relating to the revision of the Follow-up Formulas Standard submitted in April is HERE

IACFO’s submission on scope and labelling relating to the revision of the Follow-up Formulas Standard submitted in April is HERE

The Background paper for the consultation states: It should be noted that at CCNFSDU38, the Codex Secretariat noted that it was possible to keep the matter open on the final form and structure of the Standard.  This could include one Standard in two parts (as is currently being worked on by the eWG), two separated standards, or merging with other standards.

IBFAN is proposing as the best option that all formulas 0-36 months are brought under a revised and renamed Infant Formula Standard. We believe that one over-arching standard – with 3 or 4 sections – will help regulators and policy makers bring in the safeguards on the composition, safety, labelling and marketing that are needed to prevent misleading marketing and unsafe products.

The key things we are calling for for Follow-on Formulas and milks for young children are:

• That the products should not be referred to as  ‘fortified’  this term is  promotional
• There should be no promotional claims, idealisation, pictures etc
• No optional ingredients (or as few as possible when justified by “Relevant convincing / generally
• accepted scientific evidence or the comparable level of evidence under the GRADE classification.”
• Mandatory declarations/labelling etc
• A clear mention that the products are not necessary (6-36m)
• That Infant formula can be used from birth until  12months and beyond.
• That the Int Code,Global Strategy and all WHA Resolutions are mentioned with key resolutions and the Guidance highlighted alongside specific key sections.
• Code of Hygienic Practice mentioned
• No cross branding

Codex Member Sates are strongly urged to support the inclusion of the WHO Guidance in standards covering these products. (Please note that only Member states and Observers who have joined the Electronic Working  Group can submit comments.)

Background: At the last Codex Nutrition meeting in Hamburg in December 2016, the interests of child health came above trade for once when, in a breakthrough consensus, the  Committee agreed to refer to WHO Guidelines and Resolutions in the Codex standards covering formulas for babies 6-36 months –  bringing Codex a step closer towards policy coherence with WHO.  In 2016 the World Health Assembly Resolution (WHA 69/9) ushered in WHO’s technical Guidance on Ending the Inappropriate Promotion of Foods for Infants and Young Children. Among other things, this Guidance clarified that all milks marketed for babies 0-36 months are breastmilk substitutes and should not be promoted. (1)

These expensive sweetened and flavored milks (called ‘follow-on milks’, ‘growing-milks’ ‘toddler milks’ etc)  share branding with infant formulas from birth and are driving the formula market – a market set to rise by 55% from US$45 billion to US$70 billion by 2019. The aggressive marketing of these products is not only misleading parents, undermining national health messages and risking child health and survival, but exacerbating the obesity epidemic.(2) Infant formula can be used from birth to 12 months and beyond, so these products are not necessary and this should be clearly stated in Codex standards.

DEVELOPMENT OF A GUIDELINE FOR READY TO USE THERAPEUTIC FOODS (RUTF) (Chaired by South Africa and co-chaired by Senegal and Uganda)

IBFAN’s comments on the second consultation submitted June 2017.

IBFAN’s comments on the First Consultation Paper:       IBFAN-SUBMITTERS RESPONSE_1stCONSULTATION_RUTF AMENDED-1 IBFAN Final

IACFO’s comments on the First Consultation Paper:  IACFO_1st RUTF CONSULTATION 2017

Some key points in our submission:

7.         NAME OF STANDARD

It should be noted that at CCNFSDU38, the Codex Secretariat noted that it was possible to keep the matter open on the final form and structure of the Standard.  This could include one Standard in two parts (as is currently being worked on by the eWG), two separated standards, or merging with other standards.

The Name of the Standard should be amended to reflect the approach that is determined and align with the name of the product(s) included. Until the final form and structure is determined, and the Name of Product(s) finalised, the Chairs suggest deferring a decision on the Name of the Standard.

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140th WHO Executive Board Meeting  (23rd January-1st February) Geneva

The WHO Executive Board Meeting continues.  Two days were spent in closed meetings for the selection of the short-list of three for the post of the new Director General of WHO.  CLICK HERE

IBFAN’s statements on the Agenda items will appear on the WHO website and HERE

Codex REPORT OF THE MEETING (including participants list)

CODEX Press Release from the meeting

Ongoing consultations

Ready-to-use Therapeutic Food Market to Exceed US$ 617.4 Mn by 2024
Global Market Study on Ready-to-use Therapeutic Foods: Drinkable Therapeutic Food Segment Expected to Gain Significant Market Share
Market drivers and trends Increasing government as well as NGO focus on the treatment of malnutrition is expected to drive revenue growth of the global ready-to-use therapeutic food market over the forecast period. Increasing instances of malnutrition along with a rapidly growing population is another key market driver. Also, an increasing demand for drinkable ready-to-use therapeutic foods and rising global emergencies and disasters is expected to further fuel market growth. However, increasing consumer/local government shift towards local ingredients and inconsistencies in ready-to-use therapeutic food milk products thereby creating a risk of contamination are factors likely to restrict market growth during the forecast period.The global ready-to-use therapeutic food market offers great opportunities for market players with UNICEF encouraging the domestic production of ready-to-use therapeutic foods. ____________________

3  Definition for the term “Biofortification”

IBFAN comment: ibfan-comment-proposed-draft-definition-for-biofortification-ccnfsdu-2016-2

IBFAN has many concerns about this proposal that was first put forward by IFPRI. (International Food Policy Research Institute). For example:

• It obscures the fact that the term Bio-fortification includes genetically engineering;  its attempts to justify the use of biofortified foods as a means to reduce malnutrition;
• it suggesting that increasing one or two nutrients in a food, such as golden rice or sweet potatoes, can alleviate malnutrition.
• It may impact negatively on biodiversity. The use of herbicides, such as  glyphosate, can create super weeds and have negative health impacts. Genetically modified food production is patented and its seed use is restricted.  It is  not a sustainable means for food production and can increase costs to  farmers.

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ECHO Consultation on Draft Implementation Plan

Consultation open until 12 October 2016

The Draft Implementation Plan  guiding further action on the recommendations included in the Report of the Commission on Ending Childhood Obesity is open for consultation.

The purpose of this consultation is to gather feedback on the Draft Implementation Plan for the recommendations of the Commission on Ending Childhood Obesity from Member States and other interested parties. The comments received will be taken into consideration as the document is revised prior to submission to the 140th session of the Executive Board.

• Read the Draft Implementation Plan
  pdf, 1.73Mb

Please send feedback on the Draft Implementation Plan to echo@who.int before 12 October 2016.
http://www.who.int/end-childhood-obesity/implementation-plan/en/

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Document (812.27 KB)

IBFAN EFSA Health Claims Sept 2016

EFSA has launched an open consultation on its draft scientific and technical guidance for the preparation and presentation of a health claim application.

This document presents a common format for the organisation of information for the preparation of a well-structured application for authorisation of health claims which fall under Articles 13(5), 14, and 19 of Regulation (EC) No 1924/2006. This guidance outlines: the information and scientific data which must be included in the application, the hierarchy of different types of data and study designs (reflecting the relative strength of evidence which may be obtained from different types of studies) and the key issues which should be addressed in the application to substantiate the health claim.

 

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In July 2016  the EU Commission  launched a  consultation with Member States asking whether health claims should be permitted on formulas and baby foods. 

DH BULLETIN – Follow-up questions to the Commission Working Group on hea…

Here are our comments

Baby Milk Action_Health Claims_29.7.16

HealthClaims_July2016_HCrawley

_______________________FINAL_BMA_IBFAN_Health Claims_29.7.16

WHO Consultation

IBFAN comments on Updated Appendix 3 of the WHO global NCD action plan 2013-2010 

Consultation 25 July – 1st September 2016

2IBFAN comments on Updated Appendix 3 of the WHO global NCD action plan 2013 version 1

WHO ACTION PLAN for the prevention and control of NCDs in the European Region

WHONCDActionPlan_2016

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Codex Committee on Nutrition and Foods for Special Dietary Uses (CCNFSDU) Electronic Working Group (EWG)

REVIEW OF THE STANDARD FOR FOLLOW-UP FORMULA (CODEX STAN 156-1987) (Chaired by New Zealand and co-chaired by Indonesia and France)  Second Consultation Paper   Deadline for Comments  19th July 2016

IACFO_Submitters response form-final

ENCA201606_Submitters response form_ENCA

FINAL IBFAN 201606_Submitters response form-final HKI201606_

SOUTH AFRICA SECOND CONSULTATION PAPER ON FUF JULY 2016

EU_FUF_comments eWG FUF_22072016

Canada201606July 19

ISDI CP2 submitters response form 2016 07 19 final

USA_Submitters 19JUL2016.

FinalSubmitters response form HKI 18July 2016

Morroco_201606_

Submitters response form RUSSIA 

Norway_FUF second response July 2016

ICAAS_2ndConsultation

IDF _FuF 2016-07-14

NL_20160618072016

China FUF–response form-CHINAF

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Codex Committee on Nutrition and Foods for Special Dietary Uses (CCNFSDU) Electronic Working Group (EWG) DEVELOPMENT OF A PROPOSED DRAFT DEFINITION FOR BIOFORTIFICATION (Chaired by Zimbabwe and South Africa) Second Consultation Paper June /July 2016

IBFAN comment Biofortification definition July 13, 2016

IBFANSECOND CONSULTATION PAPER ON BIOFORTIFICATION IBFAN Response

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Codex Committee on Nutrition and Foods for Special Dietary Uses (CCNFSDU)

Codex Guidelines for Ready to Use Therapeutic Foods (RUTF)  2nd round of comments (submitted 23rd June 2016).  

SECOND CONSULTATION PAPER ON GUIDELINE FOR RUTF:.

IACFO-2nd RUTF consultation

IBFAN-2nd SUBMITTERS RUTFs

page down for other comments

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CODEX ALIMENTARIUS COMMISSION (CAC)   39th Session  FAO Headquarters, Rome, Italy,

27 June – 1 July 2016  

The report of the meeting is Report   The preceedings are webcast CLICK HERE 

The Agenda is HERE

There were many important issues on the agenda of the CAC – including Antimicrobial Resistance, Lead Levels, rBST. But perhaps most importantly for IBFAN, and  following on from the calls at the 69th World Health Assembly in May 2016, there was a discussion about the need for policy coherence  between  Codex and WHO policies.  Please encourage your governments to call for a strengthening of  Codex’ Governance and Conflicts of Interest rules.

RELATIONS BETWEEN FAO AND WHO POLICIES, STRATEGIES AND GUIDELINES AND CODEX WORK (Agenda Item 10)    

Paragraphs 137-145

137. The Chairperson presented the conclusions of CCEXEC7152 and noted that CCEXEC had not been in a position to discuss the item in detail due to the late availability of the document.

138. Several delegations thanked the parent organisations for initiating this discussion, acknowledging that there was a need to ensure awareness of FAO and WHO policies and guidelines at the national level when coordinating positions for Codex. It was also stressed that the mandate of Codex differed from that of FAO and WHO, meaning that issues raised by FAO and WHO would be taken into consideration when relevant to Codex work. They noted that existing mechanisms for communication generally worked well.

139. The Representative of WHO referred to the discussion at CCEXEC7153 and recalled that over the past ten years the WHA had made several requests to Codex to strengthen its work in supporting public health efforts. Simultaneously WHA had encouraged Member States to use Codex standards and guidelines to protect and promote human health, the latter being the common mandate of WHO and Codex.

140. The Representative noted that there were challenges in discussions at WHA concerning the use of Codex standards and guidelines at the national level and their reputation at the international level. These challenges were linked to the fact that Codex standards and guidelines were not always developed taking into account WHO policies, strategies and guidelines aimed at addressing the high-priority public health concerns of Member States such as obesity and diet-related noncommunicable diseases (NCDs).

141. The Representative noted further that the need for Codex to fully take into account the WHO policies, strategies and guidelines had been raised at CAC38 by Papua New Guinea as the Chair of CCNASWP54. The document recommended that Codex take action to reduce salt/sodium intake to control NCDs (as recommended by the NCD Action Plan 2013–2020 adopted by WHA in 2013), through developing maximum levels of sodium contents in selected food products. The matter could not be discussed at CAC38 due to lack of time.

142. The Representative further recalled the status of Codex as an intergovernmental body operating under the auspices of FAO and WHO. This status permitted adopted Codex standards to be published with the FAO and WHO emblems. This privileged status of Codex underscored the need for coherence between the work of Codex and WHO policies, strategies and guidelines which Codex members, as WHO Member States, had signed up to. Codex could only benefit from demonstrating to the governing bodies of WHO greater coherence of its standards with WHO policies, strategies and guidelines, which in turn would help secure ongoing financial and technical support from WHO to the work of Codex. The Representative recommended that the Commission take practical steps forward as described in paragraph 15 of CX/CAC 16/39/11.

143. The Representative of FAO thanked the members for their reflective and considered feedback and apologised for the late availability of the working document. She noted that the interventions had demonstrated a high level of awareness of the relevance of FAO and WHO policies to the work of Codex and a recognition of the importance of these policies being fully considered in carrying out the standard-setting work of Codex. She agreed with the observations made by countries that, in many cases, there was a need for better communication at national level to engage all relevant stakeholders in discussions of Codex issues. She considered, however, that the examples and analysis contained in the working document had demonstrated some scope for improving systematic and effective communication at global level as well. She underlined that while Codex existed under the umbrella of FAO and WHO, the substantive standard-setting work of Codex was member driven: it was the Commission’s decision which standards to set. She concluded by noting that administrative matters related to the Codex Secretariat were governed by the relevant FAO rules and procedures in accordance with the Codex Statutes.

Conclusion 

144. In spite of the very late availability of the document, the Commission noted that:

(i) The main aim of the document was to raise awareness so that Codex fully consider FAO and WHO policies, strategies and guidelines when it undertakes its work;

(ii) Codex is a unique member-driven organization with a specific mandate to develop internationally harmonized food standards to protect consumer health and ensure fair practices in food trade;

(iii) FAO and WHO adopt and implement policies, strategies and guidelines, which might be relevant to the work of Codex;

(iv) There is a need to increase the dialogue and communication between FAO, WHO and Codex experts at the national, regional and global levels;

(v) Codex has always given due consideration to relevant policies, strategies and guidelines in undertaking its work being thereby enabled to make informed decisions.

145. The Commission proposed to CCEXEC to further discuss the working document at its 73rd session; noted the need to increase the visibility of Codex in WHO governing bodies, and noted the proposal by IFPRI for Codex to organize side events at WHA.

Committee on Nutrition and Foods for Special Dietary Uses (CCNFSDU) Guideline for Ready-to-Use Therapeutic Foods (RUTF)41  Paragraghs 102 – 107.  

Committee on Nutrition and Foods for Special Dietary Uses (CCNFSDU) 

Guideline for Ready-to-Use Therapeutic Foods (RUTF)41 

102. The Commission noted the wide support for this new work especially in view of the fact that there was a need for guidance for governments and producers on RUTF used in the management of severe acute malnutrition (SAM). Delegations indicated that these products were already produced in some of their countries and/or used in the management of SAM not only in refugee populations, but also for malnourished infants and geriatrics and thus the guidance would be helpful.

103. The Delegation of India did not support the proposal due to the lack of sufficient scientific data in favour of using RUTF in the management of SAM in community settings and noted that the review from WHO on the safety and efficacy of using this product was not yet available.

104. The Representative of WHO explained that the ongoing systematic reviews, which WHO was undertaking, would not develop guidance on the nutrient composition of RUTF. WHO was more comfortable with the proposal now as it no longer included ready-to-use supplementary foods (RUSF) for which there was little evidence of their effectiveness in the treatment and prevention of moderate acute malnutrition.

105. She also noted that FAO and WHO had worked closely with UNICEF to provide this proposal for consideration to CCNFSDU and supported this new work to go ahead.

106. Noting the clarification from WHO, India expressed support for the new work.

Conclusion 

107. The Commission approved the new work.

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1   Codex Guidelines for Ready to Use Therapeutic Foods (RUTF) The deadline for the 2nd round of comments on RUTF  is 23rd June.  

 IBFAN and IACFO  have submitted comments to the  Codex Electronic Working Groups on  Ready to Use Therapeutic Foods (RUTF)  and this paper: SECOND CONSULTATION PAPER ON GUIDELINE FOR RUTF:.

IACFO-2nd RUTF consultation

IBFAN-2nd SUBMITTERS RUTFs

France RUTF 2nd CONSULTATION PAPER – France contribution

Brazil_RUTF

EU comments 2nd Consulation RUTF_20062016 FINAL

IDF RUTF 2nd CONSULTATION PAPER FOR FOR RUTF

This is a controversial issue.  IBFAN and many developing countries maintain that a Codex Standard (or Guideline) is not needed for these products. While  RUTFs can be useful in the treatment of  Severe Acute Malnutrition (SAM) their use  must be integrated into sustainable, local, family based solutions, that also help  build health care systems. Codex instruments are designed to break down barriers to trade and boost trade. In this context  there is a risk that they will encourage emphasis  on single product approaches that ignore the  underlying causes of malnutrition and that resources will be diverted away from training on breastfeeding and appropriate complementary feeding.   It is essential that Governments strictly control the promotion, labelling, availability and safety of these products.

At the last meeting of the Codex Nutrition Committee (CCNFSDU37,  Nov 2015) the decision was taken  to establish an eWG, led by South Africa and co-chaired by Senegal and Uganda, to develop Guidelines for these products for babies suffering from Severe Acute Malnutrition (SAM).

Read the two page briefing used last November: RUTF Bullett FINAL

IBFAN is  advocating that these products  are:

• provided by the public health authorities on prescription only for therapeutic purposes,
• used only under the strict medical supervision of an independent health worker.
• not used or sold for preventative purposes
• not placed on the market
• not labelled,  promoted or idealised by health or nutrition claims or other means
• that all provisions of the International Code or WHA Resolutions are included in the Guidance.
• that any decisions regarding the safety or composition of these products must  be based on evidence that meets WHO’s definition of scientific substantiation: “Relevant convincing / generally accepted scientific evidence or the comparable level of evidence under the GRADE classification’   Codex baby food standards referred to a mixed bag of  terms, such as  ‘scientifically demonstrated’  or ‘an established history of apparently safe use’

How the IMS Act has helped India

Baker et al_2016_Global trends and patterns of formula sales – is an IYCF transition underway

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IBFAN is attending the 69th World Health Assembly –  and covering several issues.

CLICK HERE for all  WHA background documents and Agenda.    The open meetings are web streamed and can be viewed HERE (sorry I can’t find the link – will post when I find it!)

CLICK here for some useful background papers

All NGO statements are posted HERE

1  Maternal, infant and young child nutrition A69/7  A69/7 Add.1   A69/7 Add.2

Working groups are taking place all week so there are new versions every day of the Resolution to adopt the Guidance on Ending inappropriate promotion of foods for infants and Young Children.   Its so clear where the pressure to weaken the Resolution is coming from:

25.May.2016.A69-A-CONF-7_25May16

May 24_A69_ACONF7 draft as shown on the screen at 21 hr

20 May 2016 -Draft resolution – Nutrition.

IBFAN is advocating the adoption of the Resolution and endorsement of the Guidance.   IBFAN’s Statement that will be delivered is HERE

See also useful new papers: GUMs – final   Statement on sugar in fortified milks_May2016  Carbon-Footprints-Due-to-Milk-Formula

2 Framework of engagement with non-State actors A69/6  and  A69/60 Framework of engagement with non-State actors

CLICK here for Press Release and Statement

We are also keeping a watch on the following items:

3  A69/10  Prevention and control of noncommunicable diseases: responses to specific assignments in preparation for the third High-level Meeting of the United Nations General Assembly on the Prevention and Control of Non-communicable diseases in 2018

IBFAN NCD_GCM_statement   IBFAN statement on Global Coordinating Mechanism

4 A69/8 Report of the Commission on Ending Childhood Obesity

5 A69/24  A69/24 Add.1 Global action plan on antimicrobial resistance

Agenda Item 6.4 of 139th  Executive Board meeting,  immediately following the 69th Assembly has Health and Climate Change on the Agenda.  Click on the following link for an important new report:  Carbon-Footprints-Due-to-Milk-Formula GUMs – final

At the request of a Member State, the Secretariat will report on the implications of the Paris Agreement, adopted in December 2015 by the twenty-first session of the Conference of the Parties to the United Nations Framework Convention on Climate Change (Paris, 30 November−11 December 2015), and on its plans to scale up support to Member States on: health resilience to climate risks; linking climate change, air pollution, and sustainable development; and systematic measurement and reporting of country progress to global health and climate change governing bodies.

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IBFAN  comments on an earlier draft of the Resolution (dated 3rd May)  is on the following link: IBFANCOMMENTSRESOLUTION.3.5.16 

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;

OPERATIVE PARA 2  (d)  DELETE this whole para:   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, and to ensure that arrangements are in place and that adequate resources are available to enact, monitor and enforce such legislation;  

REPLACE WITH:   Require Codex standards and guidelines  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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CODEX consultations

Review  of the Follow on Formula Standard Deadline 3rd April 2016:   First consultation paper on the review of FUF (2016)  201602_First Consultation Paper 201603_Submitters response form

RUTF.  At CCNFSDU37, the Committee agreed to establish an eWG, led by South Africa and co-chaired by Senegal and Uganda, working in English and French, to develop the Guidelines for Ready to Use Therapeutic Food.s eWG_invitation_RUTF  This is another controversial issue.The Proposed Terms of Reference and list of topics to be covered drawn up by the Electronic Working Group focuses on composition and hygiene, the General Standard for the Labelling of Pre-packaged Foods and other relevant Codex texts, but includes no reference to the much needed controls on marketing, conditions or sale, the International Code or WHA Resolutions

Biofortification deadline 7th April.  Zimbabwe and South Africa are chairing the Codex eWG team that is reviewing  the First Consultation Paper within the timeline: 29 March to 29 April 2016.  Comments requested  by the 7th of April.  (Click here for  IBFAN comments for the November meeting.

IBFAN is concerned that this paper will help legitimise genetic modification. We are opposed to using  generic terms such as “agricultural methodologies” which hide the true means of production and mislead consumers. We are also concerned about the impact of biofortification on biodiversity which can negatively effect dietary diversity and nutrition intakes.

FIRST CONSULTATION PAPER ON BIOFORTIFICATION   eWG_invitation_biofortification) SUMMAryCODEX BIOFORTIFICATION DEFINITION by eWG led by Zimba

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Public consultation on EU Commission Transparency Register

Duration  01/03/2016 – 01/06/2016

Baby Milk Action reprocess:  TRansparency Register

You can contribute to the consultation via the “Your Voice in Europe” site: http://ec.europa.eu/yourvoice/consultations/index_en.htm

You can send any comments or queries on the register to the Transparency Register Joint Secretariat at http://ec.europa.eu/transparencyregister/public/staticPage/displayStaticPage.do?reference=CONTACT_US.

Transparency Register: http://ec.europa.eu/transparencyregister/public
Need to change data on your organisation?: https://webgate.ec.europa.eu/transparencyregister/restricted/ri/authenticate.do

Below is a link to our comments submitted to the UK’s  Technical consultation on a draft Statutory Instrument to enforce EU Regulation 609/2013 on foods for specific groups

BFLG_Comment_FINAL_UKLawconsultation_Feb2016

Technical consultation – SI on Foods for Specific Groups

The EU delegated regulations on Infant Formula, Follow on Formula and Foods for Special Medical Purposes were published on 2.2. 2016

CLICK HERE for a link to the new Delegated Acts in all languages

http://eur-lex.europa.eu/legal-content/FR/TXT/?uri=OJ:L:2016:025:TOC

Page 1-44  Directive 2006/141/EC In accordance with Article 20(4) of Regulation (EU) No 609/2013, Directive 2006/141/EC is repealed with effect from 22 February 2020.However, Directive 2006/141/EC shall continue to apply until 21 February 2021 to infant formula and follow-on formula manufactured from protein hydrolysates. References to Directive 2006/141/EC in other acts shall be construed as references to this Regulation in accordance with the scheme set out in the first paragraph. Article 14 

Entry into force and application:   This Regulation shall enter into force on the 20th day following that of its publication in the Official Journal of the European Union. It shall apply from 22 February 2020, except in respect of infant formula and follow-on formula manufactured from protein hydrolysates, to which it shall apply from 22 February 2021. For the purposes of the second subparagraph of Article 21(1) of Regulation (EU) No 609/2013, in respect of infant formula and follow-on formula manufactured from protein hydrolysates the later date referred to in the second paragraph of this Article shall be considered as the date of application.

This Regulation shall be binding in its entirety and directly applicable in all Member States.

http://eur-lex.europa.eu/legal-content/FR/TXT/?uri=OJ:L:2016:025:TOC

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From: SG-TRANSREG-NOREPLY@ec.europa.eu

Subject: Transparency Register – Public consultation

DEADLINE for submissions:  1st June  2016

Date: March 4, 2016

The European Commission has launched a public consultation concerning the Transparency Register. To access the consultation in all EU official languages please visit http://ec.europa.eu/transparency/civil_society/public_consultation_en.htm

We invite you to forward this message to any other parties which could be interested in this initiative including your members, clients or partners, if you have any. 
Joint Transparency Register Secretariat
+’ Contact the register
Web: http://ec.europa.eu/transparencyregister

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Maternal, infant and young child nutrition  WHO Secretariat Report, Draft Resolution and Guidance on ending the inappropriate promotion of foods for infants and young children  Document EB138/8   

IBFAN point by point suggestions for changes: CLICK HERE   

IBFAN statement during the WHO ExecutiveBoard Meeting  29th January 2016

 A.  Draft resolution

The Draft resolution and the Guidance contain some provisions that we warmly welcome as they are likely to contribute to the much needed increase in rates of optimal infant and young child feeding (Lancet 2016). One such provision is the needed clarity that formulas for older babies (up to 36 months) are covered by the International Code and WHA Resolution. However, there are some serious concerns that Member states must address before adoption of this important Resolution and its Annex at the 69th WHA in May. We highlight these below and urge Member states to present these to the WHO Secretariat so that the new draft reflects them adequately.

Codex: Draft Resolution Op2 d and Recommendation 3 of the Guidance  The recommendation to implement Codex Guidelines and Standards into national law poses a serious risk to health. Codex standards and guidelines be must be brought fully in line with WHO guidelines, resolutions and recommendations before they are implemented into national legislation. As currently drafted the MIYCN Resolution and Guidance would undermine hard won, health protective norms already adopted by the WHA. Although IBFAN has achieved some strengthening of Codex standards and guidelines relating to products for babies,  the lax/non existent conflict of interest rules of Codex have led to compromises.  The Resolution specifically  mentions the Codex  Guidelines on  formulated complementary foods CAC/GL 8-1991, which along with many other Codex texts does not fully reflect WHA Resolutions and Recommendations and are less health protective than many national laws. Codex is currently discussing the revision of the Follow-on Formula Standard and guidelines on Ready to Use Therapeutic Foods. The food industry is fighting hard to oppose the inclusion of important marketing safeguards. Strong guidance from the WHA is needed to inform this work and help Member States harmonize Codex texts with WHA recommendations.

B Annex: Guidance on ending the inappropriate promotion of foods for infants and young children  Paragraph 3 creates a loophole that could lead to further increase of inappropriate marketing of fortified foods and supplements, rather than to the adequate oversight of their use.

Recommendation 4 opens the door to marketing by listing PROMOTIONAL strategies that MAY BE CONVEYED. This defeats the intent of WHA Resolution 65.6  that simply called on the DG: to provide clarification and guidance on the INAPPROPRIATE promotion of foods for infants and young children. There is therefore no justification for the inclusion of a shopping list of marketing strategies.  If adopted such a list would undermine legislation that is in effect in many countries such as India, Kenya, Bangladesh, South Africa etc. Any reference in the Guidance that could imply that certain ‘promotions’ are endorsed by the WHA, should be replaced with terms such as  “labeled” “put on sale”  ‘traded ‘ etc.

 Emergencies Annex: Guidance Recommendation 6 undermines previous WHA decisions. Without any explanation it provides direct access of companies to emergency relief operations and to health workers and health facilities. The two exceptions in this recommendation go directly against the WHA decisions:

1. the exception on emergencies goes against the WHA 47.5 and WHA 63.23, which provide a clear guidance to member states on  planning, implementing and supporting emergency relief operations in infant nutrition.
2. the exception regarding  ‘officially sanctioned health programmes’  introduces two problems: First the WHA 47.5 aims as ensuring no free and low cost supplies of products covered by the International Code to any part of the health care system. As the term ‘officially sanctioned health programmes’  is not defined, this exception can lead to violations of the WHA 47.5. It also introduces a loophole  which could lead to indiscriminate and harmful use of products under the scope of this Guidance.   Finally, this Recommendation is directed to companies who should never be direct providers of their products be it in emergencies or any other programmes. The need for any foods for infants and young children should be assessed by qualified emergency relief staff and products resourced through normal procurement channels.

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World Health Organisation Executive Board Meeting

25- 30th January  2016.

IBFAN Statement on Maternal Child Nutrition 6.1.

WHO proposals for a Resolution and Guidance on ending inappropriate foods for Infants and Young children

FINAL IBFAN NCD statement 6.3

CLICK HERE for FENSA speech

We are  coming to the end of the WHO Executive Board meeting   All the NGO statements are HERE   including IBFANs  on FENSA, Maternal and Child Nutrition (MCN)  and  NCDs

I will deliver IBFANs NCD  intervention – if the  NCD debate starts soon. You can catch it on the WHO website    http://www.who.int/mediacentre/events/2016/webstreaming/eb138/en/

FENSA:  the meeting with April will go ahead.

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European Parliament to vote on Baby foods  20th January 2016

CLICK HERE for our Press Release and background to this story

CLICK HERE  for the text of the Objection on processed cereal-based food and baby food (ENVI/8/04983) that will be voted on tomorrow – 20th January.

CLICK HERE  for WHO commentary on sugar

For UK MEPs: https://www.writetothem.com

For other MEPs: http://www.europarl.europa.eu

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IBFAN submissions to the 37th codex Committee on Nutrition and Foods for Special Dietary Uses (CCNFSDU)  Bad Soden am Taunus, Germany 23-27 November 2015

 Here are our submissions on three agenda items and a quick summary of our  concerns .

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Draft Final Report of the Commission on Ending Childhood Obesity open for comment UNTIL 13 November 2015

 ECHO DRAFT FINAL REPORT

Baby Milk ActionIBFAN_ECHO_Nov2015

Open for comment: 29 September – 13 November 2015

PREVIOUS COMMENTS by IBFAN

IBFAN-comment-on-ECHO

IBFAN to ECHO 16.12.14(3)

The Draft Final Report of the Commission on Ending Childhood Obesity is now open for comment from relevant stakeholders. In addition, the Commission will hold regional consultations and hearings throughout this consultative period.

• Read the draft final report
  pdf, 1.58Mb
• The work of the Commission: timeline of events
• Ending childhood obesity: a multidimensional challenge 
  Commentary from “The Lancet”.

The Commission reviewed the feedback received on their Interim Report from relevant stakeholders and through the regional consultation. This Draft Final Report proposes key policy actions to address childhood obesity.

The Commission welcomes your suggestions and feedback on the Draft Final Report and will consider these, in addition to the inputs received through further regional consultations, in the development of the final report by the end of 2015.

Health Select Committee

The  Committee is not seeking formal written evidence.

20 October 2015 | 9:30 AM  Witness(es):Professor Susan Jebb OBE, University of Oxford Dr Peter Scarborough, University of Oxford Dr Alison Tedstone, Director of Diet and Obesity, Public Health England Dr Emma Boyland, Institute of Psychology, University of Liverpool Professor Simon Capewell, Vice President, Faculty of Public Health, Dr Colin Michie, Chair of Nutrition Committee, Royal College of Paediatrics and Child Health

Commission consultation on health claims on foods referring to children’s development and health.  Please support the IBFAN BFLG comments  now and send to:  nutrition legislation@dh.gsi.gov.uk

DH BULLETIN – Commission Working Group on health claims 8 June 2015_sent to IPS 19 June   Item A3.1 10472-EN Item A4.1 10891 – EN_ANNEX Item A4.1 10891 – EN3 (4)

IBFAN BFLG comments   BFLG IBFAN Health Claim Comments.23.7.15

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WTO Techical Barriers to Trade:  Opportunity to comment on EU proposals.

CLICK here for the papers.

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WHO  Consultation  on “Clarification and guidance on inappropriate promotion of foods for infants and young children”

Deadline:  10th August:

I attended the informal hearing with NGOs in Official Relations on 17th August.

Here is a link to a presentation summarising our concerns:  IBFAN STAG 18.8.15.pptx

WHO, led by the Department of Nutrition for Health and Development (NHD), launched an online consultation on the discussion paper to  solicit comments on the draft clarification and guidance. These comments will be taken into consideration prior to informal dialogue with civil society and private sector (17 August 2015), and informal consultation with Member States (18 August 2015).

Click here:  WHO STAG for background papers and online form for submissions http://www.who.int/nutrition/events/inappropriate-food-promotion-consultation/en/

Here is a LINK to a Powerpoint summary of IBFAN concerns:    IBFAN STAG 18.8.15.pptx

Here are links to the List of Participants:  LOP NGOs 17 august LOP private sector 17 august

CLICK HERE for the comments from everyone – including industry – recommendation by recommendation.

Follow the links below for PDFs of comments from  IBFAN, WOF and WCRF

Baby Mlk Action IBFAN on STAGLOGO

ICDCGIFA STAGFINAL

INFACT Canada comment on the Draft Inappropriate marketing

ENCA STAG Comments

WOF-WCRF response to infant foods consultation for upload

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EFSA opens consultation on Health Claims Guidance

CLICK HERE   Deadline September 11th

Closed consultations

Ending Childhood Obesity  – deadline for comments 5th June 2015

IBFAN comment on ECHO

http://www.who.int/end-childhood-obesity/interim-report-for-comment/en/

Baby Milk Action frequently submits comments to consultations on draft regulations and standards. These might come from the UK Government, the European Union or United Nations bodies such as Codex or WHO. Click on the Consultations tag for blog posts on this topic.

Round 2 of the Global Strategy for Women’s Children’s and Adolescent Health   DEADLINE 5th June

CLICK HERE  BMAonGSWCAH2   for Baby Milk Action’s comments

1. General comments on the zero draft of the Global Strategy as a whole:

Despite references in the Zero draft to human rights, nutrition, education, inequities, women’s empowerment and water and sanitation, there are several major flaws in this document:

• Failure to address the risks of (and promotion of) the ‘multi-stakeholder’ approaches.

• Lack of any reference to breastfeeding as a cornerstone of children’s survival, health and development and maternal health or the need for its protection and support.

• Lack of any mention of the need for governments and UN bodies to have strong Conflict of Interest safeguards in place to ensure that policy setting processes and their implementation is as free as possible from commercial influence.

• Failure to establish clearly the obligations of States and non-state actors regarding the right to health and other related rights and failure to provide strong accountability mechanisms to ensure that these rights are made enforceable

With no references to such safeguards the references to health protection, Human Rights and inequalities are totally undermined – since all are open to exploitation from commercial entities. The uncritical promotion of the involvement of commercial entities is likely to result in significant adverse implications on health and human rights.

Inequalities: The GlobalStrategy should explicitly recognise that inequalities are a political issue. Governments should be alerted to the fact that corporations are using Corporate Social Responsibility (CSR) strategies such as Breakfast Clubs, Food banks and ‘nutrition education’ to blur the boundaries with marketing and exploit the poor and vulnerable.^[1] For example: Despite the fact that the European Commission has criticised the branding used in Nestlé’s EPODE nutrition education programme the company refuses to stop it, and furthermore has renamed its programme as Epode for the promotion of Health Equity.  

Committee on Food Security

CLICK HERE (word)  or  HERE (PDF)  for Baby Milk Action Submission Committee on Food Security

Towards the development of the Programme on Sustainable Food Systems. 

FAO’s online consultation Towards the Development of the Programme on Sustainable Food Systems has been extended to  30th April 2015   Please share comments and suggestions on a draft concept note of the Programme and to take part in a stocktaking exercise of initiatives related to sustainable food systems. FAO and UNEP are also collecting expressions of interest to participate in the Programme and become member of its Multi-stakeholder Advisory Committee.

EU COMMISSION  deliberations on the marketing of  YOUNG-CHILD FORMULAE  

IBFANBFLG BMA SCOFCAH FINAL

Working document_WG_Advisory group_YCF (2)

IBFAN_NutritionActionPlan_

IBFAN_Reform_ Framework NSA

• • EUR/RC64/16 
    WHO reform: progress and implications for the European Region
  • EUR/RC64/22
    Framework of engagement with non-State actors: report
    by the Secretariat to the regional committees
  • EUR/RC64/21
    Framework of engagement with non-State actors
    (same document as for WHA67)

 WHO Regional Meetings.

WHO Department of Nutrition for Health and Development 2025 nutrition targets policy briefs: stakeholders’ input 
Deadline: 8 October 2014

 Maintaining a healthy weight and preventing excess weight gain among children and adults.6 week consultation

The National Institute for Health and Care Excellence (NICE) is developing a public health guideline on Maintaining a healthy weight and preventing excess weight gain among children and adults.  This draft guideline is currently out for an 6 week consultation with stakeholders. The consultation on this draft guideline will take place between 23 September – 4 November 2014.
The link to the Draft Guideline and the Stakeholder Comments Form for the consultation can be found here http://www.nice.org.uk/guidance/indevelopment/gid-phg78/consultation.

Water and Food Security: Deadline: http://www.babymilkaction.org/archives/2432

Click Here

International Conference on Nutrition 2  (ICN2)

IBFAN’s Lida Lhotska delivering an intervention on behalf of Civil Society.

10-12 October.  The intergovernmental discussions on the Draft Political Declaration and Framework for Action have reopened in Rome. The proceedings can be watched on a webcast:

The discussions on the Political Declaration were put on hold as some key paragraphs could not be negotiated. The discussions on the Framework for Action go round and round in circles and IBFAN and some public interest NGOs are becoming increasingly frustrated with the process, not least the “watering down” of existing agreements and lack of attention to human rights.  There has been much talk of  ‘multi-stakeholder ‘ governance mechanisms. We believe that such language opens the door for entirely inappropriate influence from corporations so we  are of course opposing such  ideas.

An example of industry biased language that was agreed:   “Recognising that efficient and effective trade is key to achieving nutrition objectives”.  

However some countries are fighting on.  An important  intervention was made by Finland, who objected to the proposed  recommendation for  “the addition of essential nutrients to   foods.”   Finland said that fortification  is only ONE way of improving food content – there are many others – including improving soil quality.  Finland’s  suggestion was thankfully supported and the wording changed to “improve nutrient content of foods as needed”  Not wonderful but better.

Here is an excellent intervention made by IBFAN’s Lida Lhostka on behalf of Civil Society (CS)
statement 2 on day 2

HERE is another great CS intervention on the Political Declaration

CSO on Pol Dec.11.10.14

The discussion and  some of the comments are available on: http://www.fao.org/fsnforum/forum/discussions/ICN2-FFA   CLICK HERE FOR IBFAN COMMENTS   FFA_IBFAN_comments. 

CSO Statement OEWG – Final Version – 21 Sep 14

OEWG intervention

WABA invites YOUR Organisation to enorse and sign-on to this Statement    Deadline:  7 November 2014!

CLICK HERE 

• European Ombudsman  public consultation concerning the composition of European Commission expert groups   Deadline 31st August  Baby Milk Action response  2014
• Link to old EFSA comments      European Voice 2000:

• Codex consultation on REVIEW OF THE STANDARD FOR FOLLOW-UP FORMULA (CODEX STAN 156 – 1987)  SECOND CONSULTATION PAPER, JULY 2014.   DEADLINE  1^st September 2014   responses to: Jenny.Reid@mpi.govt.nz; Alice.STENGEL@dgccrf.finances.gouv.fr; tettybpom@gmail.com

• Request for information on infant and follow-on formula  DEADLINE 27th August 2014   Letter from DH: Infant formula 29072014  BMA response to DH Request on IF and FUM

• EU Corporate Social Responsibility policy: The Commission seeks stakeholders’ views on achievements and future challenges  DEADLINE 15th August 2014   CLICK HERE or HERE    CLICK HERE for Baby Milk Action’s response to this consultation  EUSurvey – Survey

• An FSN forum discussion on the ICN2 Framework for Action (zero) draft to implement the Rome Declaration on Nutrition, is now open for comments and inputs.  DEADLINE17th August. Framework for Action. International Conference on Nutrition 2   –  The discussion and all the comments so far  are available on: http://www.fao.org/fsnforum/forum/discussions/ICN2-FFA   CLICK HERE FOR IBFAN COMMENTS   FFA_IBFAN_comments    IBFAN and many other NGOs are very concerned about the involvement of the Private Sector in the International Conference on Nutrition (ICN2) and we have been taking part in many of the discussions. An FSN forum discussion on the ICN2 Framework for Action (zero) draft to implement the Rome Declaration on Nutrition, is now open for comments and inputs.  DEADLINE17th August.

• NICE consultation on Obesity: Prevention and Lifestyle Management in Children standard Deadline: 5pm on 7^th August 2014.  The draft Obesity: Prevention and Lifestyle Management in Children quality standard, along with the instructions and documents required to submit your comments, can be accessed by following this link http://www.nice.org.uk/Guidance/GID-QSD80/Consultation   Baby Milk Action IBFAN comments  BMAIBFAN_NICE_OBESITY2014FINAL.2

• Maternal and child nutrition guideline  NICE Consultation on the review proposal to consider whether this should be updated. Completed Stakeholder Comments Form must be sent to MCN@nice.org.uk by 5pm on 31st July 2014.
• BFLG MCN response FINAL
• NICE consultation on co-sleeping   DEADLINE 31st July
• Baby Milk ActionCo-Sleeping FINAL2  LLLGB NICE SIDS 2014

EFSA Public consultation on the essential composition of infant and follow-on formulae.  CLICK HERE

• EU: Public consultation on modalities for investment protection and ISDS in TTIP For background papers and instructions for responding  click here or here

• The deadline for responses to this consultation was extended to 13 July due to the level of high interest (14000 submissions).

  War on Want response to the above consultation

• Baby Milk Action ISDS   response

• EFSA FINAL OPINION
• QUESTIONNAIRE ON YOUNG-CHILD FORMULAE  EU Consultation on Article 12 of Regulation 609/2013. The UK wants comments back by  23 June  in time for the EU commission deadline of 18th July  Ares 1840923 Questionnaire on young-child formulae_Registered 27 05 2014
• CLICK HERE  BFLG IBFAN Comments on EU Q&A
• CLICK HERE for the comments from First Steps Nutrition Trust FSN EC Questionnaire on young child formulae_June 2014
• The above consultation is part of a series of discussions that the EU Commission and Member States are having about the revision of the Baby Food legislation.    CLICK HERE For the Baby Feeding Law Group comments on Foods for Special Medical Purposes
• Open EFSA meeting in PARMA 26th June