Abstract
The World Health Assembly, WHA75, 2022, requested the Director General to prepare guidance for Member States to regulate and restrict digital marketing practices of breastmilk substitutes and to report on this at WHA77, 2024. The World Health Organization (WHO) convened a technical advisory group which developed a draft guidance and requested feedback from interested parties. In response, the International Baby Food Action Network (IBFAN) made a number of recommendations to strengthen the report.
Central to IBFAN’s recommendation was ensuring the restriction of digital marketing of ALL baby feeding products that come under the scope of the International Code. IBFAN believes that the guidance from the technical advisory group, which mentions breastmilk substitutes only, must incorporate bottles, teats, baby foods, and drinks.
IBFAN’s submission to the WHO Online public consultation: Draft guidance on regulatory measures aimed at restricting digital marketing of breastmilk substitutes follows.
Recommendations Provided by IBFAN to WHO
In the Scope of the Guidance, IBFAN proposes that “designated products” be clarified to refer to “such other products as the Minister of Health may declare as designated products.” This will empower legislators to restrict the marketing of products beyond the scope that are shown to undermine optimal maternal and child health. These can include commercial formulas for pregnant and lactating women, galactagogues, probiotic supplements, pumps, pacifiers, and other products that undermine confidence in breastfeeding.
The Scope must also include the use of formal and informal “mummy bloggers,” self-declared bloggers, or celebrities, as influencers and product promotors. To keep pace with marketing developments, the definition of sponsorship should include all forms of products placement or product recommendations, and should include all feeding products and formulas for young children up to 36 months.
Under “Recommendations” in the original document, IBFAN suggests the following additions:
ALL products must be included, the term “product placement” packshots, product packaging must be added as well as QR codes or other digital schemes.
Manufacturers should not provide advice or financial incentives. IBFAN recommends the specific inclusion of health workers or their associations.
Point-of-sale in digital environments should include custom advertisements, featured products, product placement, best sellers, frequently purchased with, customer reviews, and other promotional terms.
The inclusion of: Measures should ensure that digital marketing follows the Operational Guidance for infant and young child feeding in emergencies.
Monitoring of compliance should be by agencies that are independent of the baby feeding products industries and their associations.
That there be effective safeguards against conflicts of interest.
IBFAN strongly supports the Guidance recommendation on controls in line with the International Code on exporting countries and cross-border marketing. Resource poor countries should not be expected to bear the burden of controlling the marketing and harm caused to infant and young child health and lives.
IBFAN reiterated that the International Code is a “minimum standard for the protection of breastfeeding.”
Conclusion
The WHO proposal to restrict digital marketing is long overdue and IBFAN warmly welcomes this critical initiative to strengthen Member States’ capacity to protect breastfeeding from these predatory marketing devices. As technologies develop and are used to undermine breastfeeding and optimal infant and young child feeding practices, the WHO, governments, and all of us working to protect breastfeeding must be ready to challenge and prohibit their health damaging impact on mothers and children.