NEW IBFAN Comments on the JOINT FAO/WHO FOOD STANDARDS PROGRAMMES.
CODEX COMMITTEE ON NUTRITION (CCNFSDU)
PROPOSED DRAFT GUIDELINES FOR READY TO USE THERAPEUTIC FOODS (RUTF)
CODEX COMMITTEE ON FOOD LABELLING (CCFL)
Front of Pack Nutrition Labelling
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.
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 PROPOSED DRAFT GUIDELINES ON FRONT-OF-PACK NUTRITION LABELLING at Step 3 – submitted 1st September 2021
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
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.
Codex Draft Guidance for the Management of Biological Foodborne Outbreaks.
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
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
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.
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.
BFAN COMMENT ON PROPOSED DRAFT GUIDELINES FOR READY TO USE THERAPEUTIC FOODS (RUTF). (at Step 5)
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
“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.
16th December 2019 – joining by WEBEX
WHO information session on NSA consultation and secretariat proposals: IBFAN Questions/Comments
- The Secretariat’s proposals are very problematic and IBFAN is especially alarmed that the idea of the multi stakeholder global forum has risen again. We attended the WHO Health Forum in Moscow in 2011 and issued a Press release. afterwards outlining our concerns. We see no evidence of any strong Civil Society support for this idea which is full of risks for WHO, Civil Society and Public health. What extra resources does WHO have to improve its safeguards against undue commercial influence since 2011 and evaluate the impact of the new ideas?
- As we stated in Annex 3 Proposals from non-State actors in official relations many of the proposals rely on the inadequate and incorrect COI safeguards embedded in the Framework for Engagement with Non State Actors (FENSA) Will WHO correct this before Piloting any of these ideas? See previous IBFAN comments on FENSA – including to the ‘confidential’ implementation evaluation. IBFAN Initial evaluation of the Implementation of FENSA (Extranet)
- The proposals will greatly benefit the Private Sector who attend WHO meetings wearing the same badges as Civil Society. Why is this essential transparency step not listed as a proposal?
- Will WHO ensure that those entering on a public badge are publicly listed? Up till now they are not – and ISDI and others who have lost their official relations status can be present this way – with privileged access to Member States and with no public record of their presence.
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.
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
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) 45th Session of CCFL, May 2019, Ottawa Canada. (Report forthcoming).
Consultation on the Sustainable Development Goals (SDGs). Deadline 8th September
- You can send your comments/inputs individually or on behalf of your organisation to support the inclusion of Exclusive Breastfeeding as an SDG indicator and improve SDG 17 – a goal that has been used by those pushing Public Private Partnerships and Multi-Stakeholder arrangements. Goal 17: Strengthen the means of implementation and revitalize the Global Partnership for Sustainable Development.
My suggestions for text are on the policy blog :
Agenda Items 1 and 15 CX/AFRICA/19/23/1 & 5
JOINT FAO/WHO FOOD STANDARDS PROGRAMME. FAO/WHO COORDINATING COMMITTEE FOR AFRICA – new IBFAN proposal
23rd Session. Nairobi, Kenya, 2-6 September 2019
PROPOSAL FOR NEW WORK CONCERNING A REGIONAL STANDARD FOR THE LABELLING AND ADVERTISING OF BREASTMILK SUBSTITUTES AND OTHER PRODUCTS THE PROMOTION OF WHICH UNDERMINES BREASTFEEDING AND IS CONTRARY TO THE INTERNATIONAL CODE OF MARKETING OF BREASTMILK SUBSTITUTES AND SUBSEQUENT RELEVANT RESOLUTIONS OF THE WORLD HEALTH ASSEMBLY
Consultation with non-State actors on their participation in WHO governance
Excerpt from the online consultation: At its 145th meeting, after discussions on the document EB 145/4 “WHO governance reform processes: Involvement of non-State actors”, the WHO Executive Board requested a web consultation with non-State actors to be organized to hear their views and proposals regarding their participation in WHO governing bodies and organization of an informal meeting.
As part of the WHO reform processes, including the transformation agenda, the Member States are seeking ways to stimulate the participation of non-State actors in official relations in governing bodies’ meetings and exploring the idea of organizing a separate informal meeting to provide an opportunity for Member States and non-State actors for a more structured interaction before the governing body sessions. To recall, the Executive Board at is 144th session requested the Director-General “to elaborate a report and make recommendations to be submitted to the 145th session of the Executive Board”.
“The wrong question criteria, some questionable data review and conclusions and insufficient disclosure of conflict of interest.”
Public Consultation on the draft scientific opinion on appropriate age for introduction of complementary feeding into an infant’s diet.
The deadline for comments on this worrying consultation has now passed. I will be attending the consultation in Parma on 3rd July
Please respond if you can, at the very least sending an endorsement of the commentaries below to: email@example.com
In January 2016 – the European Parliament passed a Motion that rejected some draft EU proposals, which would have allowed baby foods to be labelled for use from 4 months of age and to contain high levels of sugar. The EP vote requires the European Commission (the EU’s civil service) to bring EU regulations into line with the recommendations of the World Health Organisation (WHO) on sugar and labelling. The EU is a large exporter of baby foods to Third Countries, so its laws will have a profound impact not only on the health of babies living within the EU but many outside it. It is therefore very important that the serious flaws in the EFSA recommendations are recognised.
WHO staff response: WHO_EFSA_2019
Dr Adriano Cattaneo: Cattaneo EFSA.
72nd World Health Assembly and WHO Executive Board Meeting – 20-30th May
See my Policy BLOG for more and our statements on the agenda items.
Codex Committee on Labelling (CCFL), Ottawa, Canada 13-17th May
SEE POLICY BLOG for more
I joined the IBFAN team for this meeting where several important issues were on the agenda: Along with some excellent statements from Member States and other NGOs we succeeded in stopping the adoption of the misleading ‘Biofortification’ term, andstopped the removal of the proposed ban on cross promotion of formulas. This will now go back to the Nutrition Meeting in Berlin in November. Working closely with other NGOs we made progress on Front of Pack labelling (Codex FOPNL CSO Statement )
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
Commercial interests, transparency, and independence: a call for submissions. Help the move towards independence from commercial interests.
Submissions are welcome from now, with a final deadline of 15 January 2020.
Here are some comments on the WHO papers:
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
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.
EU action on Deforestation (deadline 25.02.19)
This initiative aims to present an integrated EU approach to combat deforestation, protect forests and promote sustainable supply chains. Deforestation is a major global problem, leading to biodiversity loss, climate change and poverty. The causes are many and complex, though increased production of commodities such as soy, beef, palm oil, coffee, and cocoa drives almost 80% of all deforestation.
The Commission would like to hear your views.
Roadmaps are open for feedback for 4 weeks. Feedback will be taken into account for further development and fine tuning of the initiative. The Commission will summarise the input received in a synopsis report explaining how the input will be taken on board and, if applicable, why certain suggestions can’t be taken up. Feedback received will be published on this site and therefore must adhere to the feedback rules.
Public consultation. 14.01.2019 – 25.02.2019
Perception survey on EC public consultations
Baby Milk Action Response. EUSurvey – Final
To participate in the survey, click on the link below:
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.
DHSC EU Exit consultation 14.12.18Ongoing consultations:
UK Brexit Consultation
CODEX ALIMENTARIUS CONSULTATION – Please share with your country delegation:
FINAL REPORT of the meeting
- 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
- 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
- The Committee considered the recommendations of the EWG and in addition to editorial amendments, made the following decisions and
- 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
- 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
- One observer called for the inclusion of the word “independent” in 9.6.1 (c).
- 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.
- 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
- The Committee made further amendments, to align with the WHO guidance, to section 184.108.40.206 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.
- 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
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.
Proposed draft Guidelines for Ready-to-Use Therapeutic Foods.
Commission Notice on the classification of Food for Special Medical Purposes (FSMP) (2017/C 401/01) CLICK HERE
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.
Proposed draft definition for biofortification, Comments at Step 3 Deadline 25th October 2018. IBFAN 2018 BIO COMMENT.
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.
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
- 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.
- 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.
- The SI to be amended for England is the Food for Specific Groups (Information and Compositional Requirements) (England) Regulations 2016, SI 2016 No. 688.
- This is a limited technical consultation; the list of consultees is at Annex A.
- The informal consultation will start 20th September 2018 and end 18th October 2018. Responses should be submitted to firstname.lastname@example.org by 5pm on 18th October 2018.
EU Consultation: “healthy and sustainable food systems”. Deadline 31st August
Codex Trade consultations
Review of the Follow-up Formula Standard (CODEX STAN 156 – 1987) 2018 2nd Consultation Paper – STRUCTURE – DEADLINE 27.7.18
RESPONSE from IACFO
RESPONSE FROM IBFAN. – to follow
IACFO supports IBFAN’s position that all products that function as breastmilk substitutes should come under one standard to ensure that all the products are labelled and marketed, including the prohibition on cross branding, to. prevent the risks of misuse, needless use and confusion. There was no consensus agreement that Option 4 should dropped.
Safeguarding child health and limiting the harmful labelling and marketing of these products should be the highest priority for Codex.
IBFAN’s point by point comments on Follow-up Formula CLICK HERE
Call for written submissions (scroll down) – Visit by the United Nations Special Rapporteur on extreme poverty and human rights to the United Kingdom of Great Britain and Northern Ireland from 6 to 16 November 2018
If you are interested in Human Rights please send a submission to this consultation in preparation for the vsit by the United Nations Special Rapporteur on extreme poverty and human rights to the United Kingdom of Great Britain and Northern Ireland from 6 to 16 November 2018
Consultation on the draft report of the WHO Independent High-level Commission on NCDs (Deadline: 16 May 2018) “The WHO Independent High-level Commission is hosting a web-based consultation from 10 to 16 May 2018 on a preliminary draft report dated 1 May 2018. Member States, UN organizations, NGOs, private sector entities, philanthropic foundations, and academic institutions are invited to submit their comments by email to email@example.com by 16 May 2018.All relevant contributions received before or on 16 May 2018 will be published on this website. The comments received may serve as an input for the work of the Commission. The report will be launched on 1 June 2018. DISCLAIMER: The version dated 1 May 2018 is a working copy only and has not been endorsed by any of the Co-Chairs or Commissioners.”Draft report (1 May 2018): pdf, 454kbSource: WHO website (accessed on 11 May) See also: Commission website
In February we submitted comments to WHO outlining our concerns about the status of this Commission and three of the proposed Commissioners, most worryingly Arnaud Bernaert, from the World Economic Forum. These Commissioners all have an ‘advisory’ role on the Commission, throwing into question the status and role of Member States. Despite consistent reassurances that WHO’s policy-setting functions would be protected from commercial influence, our concerns were not taken up and, as we feared, the report blatantly promotes Public Private Partnerships and other business friendly strategies as essential to the success of NCD responses in all countries, with little or no acknowledgement of the risks.
71st World Health Assembly, 21st-26th May 2018
LATEST DRAFT WHA Resolution on infant and young child feeding:
The IBFAN team will be following the topics that relate to infant and young child feeding, climate change, conflicts of interest and governance. These are cross cutting issues that will come up in the following agenda items:
Draft thirteenth general programme of work, 2019–2023
Click Here for IBFAN EB comments on this subject
Health, environment and climate change
Human health and biodiversity
CLICK HERE for IBFAN’s EB comments on this subject.
Global strategy and plan of action on public health, innovation and intellectual property
Preparation for the third High-level Meeting of the General Assembly on the Prevention and Control of Non-communicable Diseases, to be held in 2018 Click Here for IBFAN EB comments on this subject
Preliminary evaluation of the WHO global coordination mechanism on the prevention and control of noncommunicable diseases
Click Here for IBFAN EB comments on this subject
Use of appropriate digital technologies for public health
Maternal, infant and young child nutrition
Safeguarding against possible conflicts of interest in nutrition programmes
CLICK HERE for IBFAN’s EB statement on this subject
Conflicts of Interest concerns about three members of WHO’s new High-level Commission on NCDs
CLICK HERE for Baby Milk Action’s submission.
In response to the call for comments on WHO’s proposals for an Independent Global High-level Commission on NCDs we sent comments outlining our concerns about the appropriateness of three of the proposed Commissioners, who will have an ‘advisory’ role: Arnaud Bernaert, World Economic Forum; Dr Sania Nishtar and Katie Dain of the NCD Alliance. Since our concerns were not taken up we are asking further questions about the “DUE DILIGENCE” criteria used to determine who is accepted and the transparency of the whole processes.
Brexit and the Precautionary Principle – the UK Inquiry on Science and Innovation is still open:
Write to policy makers to make sure that they do not abandon the Precautionary Principle:
Public consultation on the draft protocol for the Scientific Opinion on free sugars from all dietary sources
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.
New Deadline 29th November 2017
IBFAN SUBMISSIONS: (CLICK HERE for Policy Blog)
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.
IBFAN oral statement: IBFAN Statement GWP
UK-US trade relations inquiry launched Deadline 17th November 2017.
Our submission is published on the UK Parliament website HERE
Baby Milk Action submission
First Steps Nutrition submission:
The deadline for written submissions is Friday 17 November 2017. Written evidence should be submitted via the UK-US trade relations inquiry page.
The International Trade Committee launches an inquiry into UK-US trade relations. This will pick up on the previous Committee’s work, brought to an end by the 2017 election, examining the opportunities and challenges in negotiating a free trade agreement and increasing trade between the two countries.
- Inquiry: UK-US trade relations
- Previous Inquiry: UK-US trade relations
- International Trade Committee
Terms of Reference
Interested organisations or individuals are invited to submit written evidence to the Committee. The Committee is particularly interested in the following:
- what the UK’s priorities and objectives should be in negotiating any such agreement;
- the possible impacts (positive and negative) on specific sectors of the UK economy from such an agreement;
- the extent to which any agreement could and should open up markets in services, including public services;
- the extent to which any agreement could and should open up markets in public procurement;
- how any agreement should approach regulation, including regulatory harmonisation;
- what dispute-resolution mechanism should form part of any such agreement; and
- what involvement, if any, the UK should seek to have in the North American Free Trade Area or any future regional free trade agreement involving the USA.
The Committee encourages those who did not send submissions to the previous inquiry to submit evidence to this one.
Individuals and organisations that did submit evidence to the previous Committee’s inquiry do not need to re-send their submissions, as that evidence can continue to be considered in this inquiry. This Committee would, however, welcome additional evidence from these stakeholders if they would like to submit an updated view.
The deadline for written submissions is Friday 17 November 2017. Written evidence should be submitted via the UK-US trade relations inquiry page.
Written evidence submitted should:
- Have a one-page summary at the front Be no longer than 3,000 words
Codex Trade consultations
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);
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
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
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
CLICK HERE for IBFAN’s comment
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
Here is a selection of some of the comments on the WHO website:
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.
Here is the comment from the Geneva Infant Feeding Association
Here is a comment from Judith Richter
Here is the comment from Bill Jeffery, LLB, Executive Director
Centre for Health Science and Law (CHSL) Canada
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.
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
August 2017: Consultation on WHO Guidance on Ending the Inappropriate Promotion of Foods for Infants and Young Children
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
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:
- RUTF products should not be available, sold or promoted on the open market.
- RUTF products are for therapeutic purposes.
- Inappropriate marketing can result in unnecessary use with loss of confidence in local family foods and sustained breastfeeding.
- It is critical that these products be used in compliance with the International Code and relevant subsequent WHA resolutions and the Guidance on inappropriate marketing of foods for infants and young children.
- RUTF should not be cross promoted with Breastmilk Substitutes and should carry no promotional or idealising claims or pictures.
- IBFAN and IACFO support the use of local foods to develop culturally suitable and nutrient rich RUTFs and that national authorities are best to provide solutions to address the treatment of SAM.
- The Guidelines must state that National authorities retain the ability to provide national solutions and prevent unnecessary imports of expensive RUTF products.
- In emergency situations RUTF products may be the only available solution to feed and save children’s lives therefore no international trade standards are needed
To advocate for national positions to safeguard the appropriate use for RUTF contact your national Codex Contact Points (these can be accessed at http://www.fao.org/fao-who-codexalimentarius/members-observers/members/en/?no_cache=1) or other relevant policy makers.
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.
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
Agenda Item 14.3 Engagement with non-State actors.
IBFAN is one of WHO’s longest-standing partners. Our work since Halfden Mahler’s time – has centred on WHA Resolutions that have saved countless infant lives.
IBFAN is anxious that WHO emerges from the FENSA process as the lead agency in public health, able to fulfill its constitutional mandate and not be relegated a limited role in a ‘multi-stake-holderised’ global health architecture. Through ill-defined terms such as ‘partnership’ ‘stake-holder’ and ‘trust’ corporations claim the right to participate in public health decision-making processes, sidelining governments, the UN and peoples’ human rights.
Despite this, FENSA was adopted – with promises of due diligence and increased transparency, and that WHO would “exercise particular caution…when engaging with private sector entities …whose policies or activities are negatively affecting human health..” The DG report further promotes this notion.
The report was presented to Member States too late for us to comment before the meeting of WHO’s Programme Budget and Administration Committee meeting (as Dr Chan called for many times). The first five applications for Official Relations are a test of its thoroughness. The Gates Foundation application is an example that has prompted a new letter to the EB from 35 organisations. That the Foundation has made substantial contributions to WHO and many health initiatives is matter of public record. That it might have an influence on WHO’s nutrition policy setting– for good or for bad – we make no judgement here – is also no secret.
Less well known are its substantial investments in food and beverage industries – investments that are merely noted in the report as: “engagements with select members of the pharmaceutical… food and beverage…health care… industries in pursuit of our public health goals.”
The FENSA process could have provided clarity on the relationship between WHO and the Foundation. This opportunity has been lost, and public trust that the process will tackle the task ahead properly has been severely damaged.
We ask that the Gates decision be delayed, ‘stakeholder’ defined and FENSA reviewed and evaluated as soon as possible and that WHO is provided with adequate, untied funding to carry on its essential.
IBFAN Statement on Agenda Item 10.1 Preparation for the third High-level Meeting of the United Nations General Assembly on the Prevention and Control of Non-communicable Diseases in 2018 (delivered Saturday, 28th January. CLICK HERE for webcast. move slider to 1.37.38 – the last of 10 NGO statements)
Now the GCM proposes an annual self-reporting mechanism for NSAs that we believe will mislead the public and policy makers alike. Although it is welcome that NSAs are ‘encouraged’ to submit only actions within their core area of business, spurious marketing strategies masquerading as health initiatives could be registered and so gain credibility from the image transfer from WHO. The baby food industry hi-jacking of World Breastfeeding Week, is just one example. The promotion of voluntary – here today, gone tomorrow – initiatives, can also undermine government resolve to bring in effective legislation.
Since WHO states that it does not have the capacity to ‘quality assure’ all activities and guarantee that they are in conformity with WHO policy, this idea should be abandoned. It is far too risky.
Last, we call on WHO to be consistent in its messaging. On the one hand WHO emphasises micronutrients – on the other, it encourages consumption of fresh fruit, vegetables and minimally processed, bio-diverse foods and of course, breastfeeding. Over-emphasis on single nutrients opens the door to idealising health and nutrition claims on less healthy processed products. The public meanwhile is unaware that high heat processing and storage can destroy essential nutrients in these products.
You could stare at a banana all day and not see the nutrients it contains. Whereas a glance at a package laden with nutrition claims immediately inspires confidence.
We are keen to continue working with WHO to address this challenge
IBFAN statement on 10.4 Commission on Ending Childhood Obesity (ECHO): Implementation Plan
IBFAN participated in the development of the ECHO Report and is pleased that many of our comments were taken on board, in particular the recognition of the importance of breastfeeding and appropriate complementary feeding in obesity prevention.
As you know, States obligations with regard to breastfeeding are defined in the 3-pillar framework ‘Protect, Promote and Support’ adopted in 2002 by the WHA. Recently, a group of UN experts, among whom the Special Rapporteur on the Right to Health and the Committee on the Rights of the Child, have reiterated that these obligations, including protection against misleading marketing, constitute an integral part of States’ human rights obligations.
Mothers themselves have no obligation to breastfeed their child. Indeed, they always remain fully sovereign over their own body. It is rather the role of States to ensure that mothers do not face obstacles to breastfeeding.
States have the obligation to provide mothers with accurate and unbiased information and counseling from the start of their pregnancy, including on the continuation of breastfeeding up to 2 years or beyond. We regret that key factor, is not mentioned in Action 4. The Baby Friendly Hospital Initiative should also be mentioned as the external audit that guarantees implementation of the Ten Steps.
To be consistent with the recommendation to exclusively breastfeed up to 6 months, States should grant working mothers with a minimum of 6 months of maternity leave.
Finally in relation to education, we are pleased that Action 5 warns of the risks of corporate sponsorship and the need for conflict of interest safeguards – corporate sponsorship of education blurs the lines between marketing and education. As highlighted by the Special Rapporteur on the Right to Education the rapid increase in the commercialization of education is a major concern
IBFAN Statement Agenda item 7.1.2 (Emergences)
IBFAN is the global network that protects breastfeeding and works for policy coherence with WHO’s Resolutions.
Our work is especially important in emergencies, where responses are often characterized by influxes of unsolicited donations of all manner of baby feeding products – donations that can often do more harm than good.
Breastfeeding is a lifeline for infants and young children in emergencies, has zero environmental impact, and States have a human rights obligation to ensure that mothers are enabled to make an informed decision on infant feeding, free of conflicts of interests. Yet, breastfeeding is often forgotten or badly managed.
Meanwhile, media reports show starving babies and rarely question why they are not breastfed. IBFAN’s World Breastfeeding Trends Initiative assessment of policies and programmes on Infant feeding during emergencies show that implementation of UN recommendations on this is dismal.
WHO – as a norm-setting, rather than implementing agency – can play a key role in reversing this situation by promoting emergency preparedness protocols that aim to improve food security in the long term. Such actions could even be opportunities for public health generally.
We know emergencies prompt philanthropy, but they are also opportunities for commercial exploitation and the Business of Malnutrition. While the speedy delivery of products can be essential in certain circumstances, emergency relief protocols must prevent over-emphasis on product-based, quick-fix approaches to the treatment of malnutrition, approaches that can undermine confidence in breastfeeding and sustainable, local, bio-diverse foods. If breastmilk substitutes are required they must be purchased, distributed and used according to the UN’s agreed strict criteria. Training is essential – to support breastfeeding, of course, but also to minimize the risks of artificial feeding for non breastfed children, whilst ensuring that breastfeeding is not undermined.
We look forward to continuing work with WHO on this important issue.
Codex REPORT OF THE MEETING (including participants list)
CODEX Press Release from the meeting
CODEX – URGENT issues to be discussed at the 38th Session of the Codex Committee on Nutrition and Foods for Special Dietary Uses in Hamburg, Germany, 3-9th December 2016.
IBFAN, IACFO, ENCA and ILCA will be attending and have sent comments to the Electronic Working Groups (EWG) on RUTF, Follow-on Formulas and Bio Fortification.
Background documents and information Click Here
1 Comments on Follow-on Formulas
The fact that Codex went against the advice of WHO demonstrates its failure to put consumer protection first and the urgent need for coherence between Codex and WHO Policy. This issue was on the agenda of the Codex Commission in July, following on from the calls at the 69th World Health Assembly in May 2016, IBFAN is calling on all Governments to call for a strengthening of Codex’ Governance and Conflicts of Interest rules.
IBFAN: ibfan-comment-review-of-the-standard-for-follow-final-1 (Codex Stan 156-1987) at Step 3
2 Ready to Use Therapeutic Foods (RUTF) draft proposal for a Guideline
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 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.
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.
Please send feedback on the Draft Implementation Plan to firstname.lastname@example.org before 12 October 2016.
Public consultation on the draft scientific and technical guidance for the preparation and presentation of a health claim application
Deadline: 12 September 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.
In July 2016 the EU Commission launched a consultation with Member States asking whether health claims should be permitted on formulas and baby foods.
Here are our comments
IBFAN comments on Updated Appendix 3 of the WHO global NCD action plan 2013-2010
Consultation 25 July – 1st September 2016
WHO ACTION PLAN for the prevention and control of NCDs in the European Region
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
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
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).
page down for other comments
CODEX ALIMENTARIUS COMMISSION (CAC) 39th Session FAO Headquarters, Rome, Italy,
27 June – 1 July 2016
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)
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.
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.
107. The Commission approved the new work.
|Recommendation 3 of the Guidance states: Relevant Codex standards and guidelines1 should be updated and additional guidelines developed in line with WHO’s guidance to ensure that products are appropriate for infants and young children, with a particular focus on avoiding the addition of free sugars and salt|
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:.
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’
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
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:
IBFAN is advocating the adoption of the Resolution and endorsement of the Guidance. IBFAN’s Statement that will be delivered is HERE
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
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.
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.
|Work continues on the Review of the Follow-on Formula (FUF) standard that was adopted in 1987 and has done much harm. IBFAN and WHO and several Member States have been calling for consideration to be given to whether the standard is needed at all, given that the products are not necessary, and could be brought into the Infant Formula Standard. Any the compositional differences from infant formula could easily be addressed in footnotes. The important thing is to bring the marketing in line with WHO Policy – i.e. the International Code and subsequent relevant WHA Resolutions. The baby food industry, and Member States that support the growth in this market, argue that a separate standard is necessary. The fact that CCNFSDU went against the advice of WHO demonstrates the failure of Codex to put the consumer protection first.
The Submitters response form asks for comments on the composition of FUF and formulas for babies 12-36 months. (so called Growing up milks) The eWG still is not addressing marketing.
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.
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
CLICK HERE for a link to the new Delegated Acts in all languages
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.
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
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
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:
- 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.
- 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.
World Health Organisation Executive Board Meeting
25- 30th January 2016.
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.
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
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
- FUF_IBFAN Agenda Item 5 Review of the Standard for Follow-up Formula (FUF) – IBFAN share’s WHO’s view that FUFs and other formulas for older babies (such as the so called Growing Up and Toddler formulas that are sure to be included in the revised FUF standard) are not necessary and their marketing undermines breastfeeding (both before and after 6 months) These products can include flavoured, sweetened and fortified milk products that pose many risks to child health, including childhood obesity. We are advocating that the safety and marketing of products already on the market are dealt with under a renamed Infant formula standard.
- Agenda Item 6 Biofortification – IBFAN’s position is that the definition must clearly inform consumers that the methods used are conventional plant breeding and 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.
- IBFAN comment on the UNICEF discussion paper on RUFs 37th CCNFSDU [final] Agenda Item 8 Ready to Use Therapeutic Foods (RUTFs) In our comments on UNICEF’s proposal for a Codex instrument for RUTFs, therapeutic products that have such a highly specific and limited function. We highlight the risk of unintended consequences of expanding the global trade of these products and the fact that the evidence for their efficacy is weak. While we understand and share UNICEF’s wish to improve the safety, quality and timely delivery of products when they are needed, we have concerns that a Codex instrument may not achieve this aim. It may also divert funds away from support for breastfeeding and the use of local complementary foods combined with nutrition education – the most sustainable way to reduce the incidence of SAM. In countries such as India and Nepal the incidence of SAM has decreased without the use of imported and expensive RUTFs. IBFAN does not support the development of a separate commodity standard or guideline and believe that WHO, FAO and UNICEF should provide guidance and support to national governments on the comprehensive treatment of SAM appropriate to national needs and cultural practices rather than single product approaches
Draft Final Report of the Commission on Ending Childhood Obesity open for comment UNTIL 13 November 2015
Open for comment: 29 September – 13 November 2015
PREVIOUS COMMENTS by IBFAN
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
- The work of the Commission: timeline of events
- Ending childhood obesity: a multidimensional challenge
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.
Childhood obesity strategy 13 October 2015 | 9:30 AM
The Health Committee is holding a short inquiry, building on the previous Committee’s work on the impact of diet and physical activity on health. This inquiry specifically considers what the Government’s policy priorities should be for addressing childhood obesity.
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 email@example.com
IBFAN BFLG comments BFLG IBFAN Health Claim Comments.23.7.15
WTO Techical Barriers to Trade: Opportunity to comment on EU proposals.
CLICK here for the papers.
So far the governments of India and Afghanistan and NGOs from Hawaii, UK and Uganda have written, calling for the proposals to be stengthened and brought into line with the International Code and Resolutions. .
WHO Consultation on “Clarification and guidance on inappropriate promotion of foods for infants and young children”
Deadline: 10th 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
EFSA opens consultation on Health Claims Guidance
CLICK HERE Deadline September 11th
Ending Childhood Obesity – deadline for comments 5th June 2015
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
- 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. 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.
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
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
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
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.
WABA invites YOUR Organisation to enorse and sign-on to this Statement Deadline: 7 November 2014!
- 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 1st September 2014 responses to: Jenny.Reid@mpi.govt.nz; Alice.STENGEL@dgccrf.finances.gouv.fr; firstname.lastname@example.org
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 7th 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