Industry’s Marketing Makes Clear that GUMs are Specially Formulated for Toddlers as Part of a Mixed Diet, and Should Not Be Used as a Breast-Milk Substitute

Since the adoption of the WHO Code in 1981, the world has become increasingly complex. We agree that the marketing of formula – whether infant formula, follow-up formula or growing-up milks – must be ethical, unambiguous and transparent. To this end, the infant and young child nutrition industry is committed to ensure that our marketing policies and practices are (i) transparent and consistent with the aims and principles of the WHO International Code of Marketing of Breast-Milk Substitutes, and (ii) in compliance with all regulations and laws enacted by national governments in the region.

When marketing growing-up milks, the industry makes clear that the formula is specially formulated for toddlers, is suitable for use only from 12 months onwards as part of a mixed diet, and should not be used as a breast-milk substitute. Global data shows that often, complementary feeding guidelines are not followed. Educating parents and caregivers is critical to help them provide adequate and balanced nutrition to their children.

Concerns have been raised that the promotion of growing-up milks could result in earlier discontinuation of exclusive breastfeeding, or shorten the duration of any breastfeeding, as consumers may fail to distinguish between advertising for infant formula and for toddler or growing-up milks. There have thus been calls for the use of different packaging design, labelling and materials for the promotion of follow-up formula and growing-up milks.

However, studies have found little evidence that the promotion of growing-up milks result in earlier discontinuation of exclusive breastfeeding, or shorten the duration of any breastfeeding. For instance, the Ministry of Health of Malaysia found no retrievable evidence that promoting formula milks for toddlers, pregnant and breastfeeding mothers affect breastfeeding practices. The recent Lancet series also reported that continued breastfeeding through 12 months was practiced by nearly 90% of low-middle income country mothers, and about 95% of low income country mothers, showing that breastfeeding can be maintained even while complementary foods are introduced.

We do not believe that restrictions on the sharing of brand names, trademark assets and intellectual property rights across formula milk products intended for different nutritional stages will help to raise exclusive breastfeeding rates. Instead, such restrictions could negatively impact consumer trust in a global trade environment where consumers expect consistency, transparency and traceability wherever a product is sold.

The infant and young child nutrition industry has been committed to world-class research and development, nutrition science, and continual investment in product innovation, quality and safety. Such restrictions however could discourage companies from making continued investments in R&D, scientific advancements in nutrition, health and metabolism as well as product innovations, potentially creating unintended adverse consequences for infants and young children.

We believe our industry has an important role to play in infant and young child nutrition, which is a shared responsibility that involves government, NGOs, civil society, and the private sector. We fully support the goal of improving nutrition for infants and young children and look forward to working with all stakeholders to achieve the best possible nutritional outcomes for the next generation.