Request for help to strengthen the UK Legislation on Infant Formula and Follow-on Formula

The UK Government is currently consulting on new legislation on the marketing of breastmilk substitutes. Thirty seven organisations – including the Royal Colleges of Midwives, Paediatrics and Child Health and Nursing, under the umbrella of the Baby Feeding Law Group and the Breastfeeding Manifesto Coalition – are concerned that the Food Standards Agency’s draft proposals issued for consultation are far too weak, and would not provide parents with independent information on which to base decisions about infant feeding, and how to reduce the risks from using the different formulas on the market.

In order to persuade the Government to put infant health before trade it would be very valuable to have as wide a range of organisations as possible to support the call for stronger legislation to control marketing. The letter below includes the demands made by the Baby Feeding Law Group and the Breastfeeding Manifesto Coalition and, if successful, will have the effect of implementing the International Code of Marketing of Breastmilk Substitutes and subsequent relevant WHA Resolutions.
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The Baby Milk Action website  has links to a large range of background papers which show the extent of the aggressive  advertising of breastmilk substitutes, along with several on-line ways to submit individual comments.

The FSA papers can be found on:
Derek Hampson
Nutrition Division
Food Standards Agency
Room 115B Aviation House
125 Kingsway
London WC2B 6NB
Dear Mr Hampson
Protecting Breastfeeding – Making Formula feeding safer
Re: Consultation on Infant Formula and Follow-on Formula (England) Regulations 2007

We are writing to contribute to the above consultation on behalf ........

We call on the UK Government to strengthen its proposed regulations in line with the International Code of Marketing of Breast-milk Substitutes and subsequent relevant World Health Assembly Resolutions (The International Code), which the UK Government has endorsed since 1981 but has not yet implemented fully.  

While the main thrust of the International Code is to protect and support breastfeeding it also plays an essential role in ensuring that parents who decide to use formula – for whatever reason – receive accurate independent information about the nutritional quality of products and how to reduce the risks.
We welcome the Government’s efforts to improve breastfeeding initiation and duration rates. Scientific evidence has consistently demonstrated that artificial feeding increases mortality rates, increases rates for illnesses such as infectious diseases, chronic diseases and auto-immune diseases, offers less than optimal development and growth, lowers cognitive and visual development and increases the risk of obesity. The seven-year study carried out by the WHO shows that babies exclusively breastfed for six months are healthier and leaner than artificially fed babies. The benefits of breastfeeding extend throughout the whole life cycle.  

However there is a long way to go and we are alarmed that the UK currently has one of the lowest breastfeeding rates in Europe. The failure of the Government to curb the aggressive promotion of breastmilk substitutes has undoubtedly contributed to this.

With this in mind we call on the UK Government to radically strengthen its proposals and to:
Ban all promotion of breastmilk substitutes (including follow-on formula and bottles and teats)  
Prohibit baby feeding companies from seeking direct or indirect contact with mothers (including a clear ban on company 'carelines', pamphlets, mail-shots, emails and promotional websites)
Prohibit sales incentives for marketing personnel employed by manufacturers or distributors of breastmilk substitutes
Prohibit all idealizing text and images from all breastmilk substitutes
Prohibit company-produced or sponsored materials on infant feeding (the Government must provide objective information on infant feeding, avoiding conflicts of interest in funding infant feeding programmes)
Where possible prohibit all health and nutrition claims on foods for infants and young children. Require any permitted claims to be placed at the back of the package near the nutrition panel in specified text
Require clear warnings about the fact infant formula is not a sterile product and may contain harmful bacteria, alongside clear instructions on how to reduce risks from possible intrinsic contamination
Prohibit the promotion of names associated with breastmilk substitutes (ie brand names and company names)
Restrict information for health professionals to scientific and factual matters with no idealising text or images
Prohibit promotion in health care facilities and gifts to health workers (samples for evaluation only)
Prohibit the promotion of any product targeting babies under 6 months (complementary foods should not be marketed in ways that undermine breastfeeding)
Require a pre-authorisation procedure for all new ingredients and listing in EU Directive 2006/141
Baby Feeding  Law Group (BFLG) Strengthening UK Baby Food Laws
Patti  Rundall,  OBE, Policy Director, Baby Milk Action
Secretariat of the Baby Feeding Law Group
C/o Baby Milk Action, 34 Trumpington St,    Cambridge   CB2 1QY   
Work Tel:  01223 464420, Mobile: 07786 523493, Fax: 01223  464417
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