APIYCNA has taken note of the WHO Guideline for complementary feeding of infants and young children 6–23 months of age. APIYCNA is concerned that certain recommendations are neither in line with existing regulatory frameworks nor scientifically substantiated.

APIYCNA and its members reiterate their commitment to improving nutrition and providing the highest quality products that help meet the nutritional needs of mothers, infants and young children. Furthermore, APIYCNA supports the WHO’s recommendation of exclusive breastfeeding for the first six months of life and continued breastfeeding, along with the introduction of adequate complementary foods, for up to two years and beyond.

Contradictions of accepted science

The Guideline’s recommendation 2.a mentions that ‘either milk formula or animal milk’ can be fed as of 6 months. This is against generally accepted scientific evidence that (full fat) cow’s milk can be introduced at the age of 12 months. The US Centers for Disease Control and Prevention [1], for example, advise against the introduction of cow’s milk before 12 months stating that it “has too many proteins and minerals for your baby’s kidneys to handle and does not have the right amount of nutrients your baby needs.”

Recognising the role of Follow-up Formula

The WHO Guideline doesn’t recommend the use of follow-up formula thus undermining the opinion of its own standardisation body, Codex Alimentarius, which recently finalised a review of the Standard for Follow-up Formula for Older Infants (6-12 months) and Product for Young Children (12-36 months). The revised Standard integrates the latest available science on safety and composition and recognises the different nutritional requirements of older infants and young children and follow-up formula “for use as a liquid part of a diet for older infants when progressively diversified complementary feeding is introduced”. [2]

The importance of a diversified diet with optimal nutrition intake

Young children learn to experience new tastes and textures, gradually increasing food consistency and variety. When transitioning from a liquid only diet, there is an increased need for complementary foods to provide the energy and essential nutrients for optimal growth and development. A diversified and balanced diet ensures that the nutritional needs of the growing child are satisfactorily met.

Data shows that the poor and uneven nutritional composition of unfortified complementary foods means that it is difficult to ensure varied diets that provide toddlers with optimal intakes of important nutrients like DHA (Docosahexaenoic acid), zinc, iron and vitamin D. The nutritional composition of complementary foods offered by APIYCNA members are based on the latest dietary recommendations, established scientific guidelines and applicable regulations. In respect of the Guidance on Complementary Feeding, APIYCNA notes that:

  1. For young children 12-23 months of age, the Guideline recognises that ‘milk formula provides supplemental sources of iron and other nutrients’ and yet still does not recommend its use;
  2. The Guideline similarly acknowledges evidence that iron-fortified infant cereals have a beneficial effect on mental skill development scores and motor development scores. Despite this, the Guideline concludes that their consumption should not be encouraged.

The unconsidered importance of food safety

APIYCNA regrets that the Guideline’s scope excludes issues of food safety. APIYCNA is concerned about this development as complementary foods should be prepared, stored and served with great care under safe and hygienic conditions. [3] Attention to food hygiene has resulted in fewer infant food contamination issues and improved behaviours in the preparation and serving of complementary foods. Complementary foods provided by APIYCNA members are scientifically-formulated, safe and manufactured according to strict international product quality standards.

Food safety is a key component of infant and young children nutrition, as recognised by the WHO Code of Marketing of Breast-Milk Substitutes, which was adopted to ‘contribute to the provision of safe and adequate nutrition for infants’.

To conclude, APIYCNA is concerned that the gaps in scientific substantiation of the WHO Guidance and the contradictions with established medical advice contained therein may lead to potentially negative health outcomes in the very vulnerable populations the Guidance seeks to protect. APIYCNA and its members welcome all opportunities to work constructively with all relevant stakeholders, including policymakers and healthcare professionals to promote evidence-based policies and parent and caregiver support to improve infant and young-child health and nutrition outcomes in the Asia Pacific region.

For more information about complementary feeding, read ISDI’s fact sheet or visit the dedicated page on the ISDI website. For information about follow-up formula for older infants and young children, please click here.

[1] See https://www.cdc.gov/nutrition/infantandtoddlernutrition/foods-and-drinks/cows-milk-and-milk-alternatives.html#:~:text=At%2012%20months%20old%20(but,at%20risk%20for%20intestinal%20bleeding.  retrieved 29 November 2023

[2] See https://www.fao.org/fao-who-codexalimentarius/news-and-events/news-details/en/c/1667642/ retrieved 29 November 2023

[3] See a recent publication: Infant Food Hygiene and Childcare Practices in Context: Findings from an Urban Informal Settlement in Kenya, 2020 Jan; 102(1): 220–222 (link) retrieved 29 November 2023