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ISDI and its members support ATNI’s mission to accelerate sustainable access to nutritious and affordable foods, as well as its vision of a world where markets contribute to nutritious and affordable diets for all.

For infants and young children during the first years of life, access to nutrition is critical: healthy infants and young children require age-appropriate nutrient intake to meet their needs for optimal growth and brain development. Nevertheless, the socioeconomic environment and cultural realities are different across countries.  

Whilst we share ATNI’s objective to improve the nutritional status of infants and young children, we urge ATNI to consider compliance of marketing practices with evolving applicable legislation and regulations, as well as individual company policies and commitments. We do not believe the assessment of companies’ marketing practices solely based on the WHO’s International Code of Marketing of Breast-milk Substitutes and subsequent WHA resolutions (WHO Code) to be an effective mechanism for achieving healthy nutritional targets.

The WHO Code indeed consists of a set of recommendations directed to member states to translate, as appropriate, into local legislation, regulations or other suitable measures based on their national context and public health objectives. ISDI and its members are committed to ethical and responsible marketing and support the aims and objectives of the WHO Code.

Countries are, however, best placed to determine what is appropriate within their national context and according to their public health objectives. The marketing of breast-milk substitutes and complementary foods should, therefore, be assessed against national laws and regulations, which are the only legitimate instrument against which marketing should be benchmarked.

The 2024 ATNI Breast-Milk Substitutes and Complementary Foods Indexes represent a missed opportunity to address company efforts to improve health outcomes for infants and young children. Furthermore, by assessing non-compliance in absolute figures instead of in proportion to a company’s total portfolio and attributing third-party (e.g. retailers and social media) non-compliance to the companies, the Indexes do not provide a fair comparison between companies. This assessment does not help to strengthen a regulatory framework that supports the ultimate goal of improving access to nutrition during the critical early years of life.

The infant and young child nutrition industry remains committed to addressing nutritional challenges, providing high quality, safe and age-appropriate nutrition for infants and young children, and supporting education on healthy nutrition. Together with our members, we are ready to ‎work together with all stakeholders to support the health, wellbeing and optimal nutrition for infants and young children.

For more information, read the ISDI position on the methodology for the ATNI 2024 index on Breast-milk Substitutes and Complementary Foods.

ISDI welcomes the revision of the new global Standard for Follow-up Formula (CXS-156-87) set by Codex Alimentarius.

Adopted in Rome today, the new Standard sets rules for “formula for older infants” and “product for young children” reflecting the different dietary requirements of these two age groups. The new standard translates the existing scientific consensus on the required nutrition intake for both age groups to new rules on the composition and ingredients to be used for these two products categories. Particularly, the macronutrient balance between proteins, lipids and carbohydrates better reflects the dietary requirements of young children.

The ISDI Secretary General Jean Christophe Kremer commented: “We congratulate Codex Alimentarius and all its member states on their agreement to the updated standard, which is the result of more than 10 years of work and expert input, including from our side. The revisions will further strengthen the ability of these products to support the healthy growth and development of older infants and young children. The most significant changes we have strongly supported lie in the limitations of carbohydrates and sugars in young children products.”

The Standard also provides room for innovation which is proven to be suitable and safe for the age groups concerned. Furthermore, the Standard allows countries to add specific rules on composition and labelling. Thanks to revisions in the standard, the labels of the 2 age groups are also better differentiated between themselves and infant formula.

ISDI supports the implementation of the Standard across countries and is committed to work with authorities at national level to introduce products according to the new set of rules.

In a joint letter to the editor of The Lancet published today^[1], the Secretary Generals of International Special Dietary Foods Industries (ISDI) and Specialised Nutrition Europe (SNE) emphasise that a holistic approach is required to increase breastfeeding rates, including strengthening maternity leave, workplace policies and funding.

The joint ISDI-SNE letter responds to the ‘2023 Lancet series on breastfeeding’, authored by WHO representative Nigel Rollins et al^[2], which creates the misleading impression that advertising is the main factor limiting breastfeeding. The series also addressed engagement with healthcare professionals and digital marketing. ISDI and SNE also take this opportunity to encourage WHO to rally all stakeholders, including the private sector, at policy debates on infant and early childhood nutrition, such as the recent ‘WHO Global Congress on Implementation of the International Code of Marketing of Breastmilk Substitutes’ (20-22 June)^[3].

“An all-inclusive, supportive ecosystem involving multiple stakeholders is required to encourage breastfeeding and to improve nutritional outcomes for mothers, infants and young children. Such an approach includes transparent, science-based interactions with healthcare professionals, who require access to information about our industry’s products”, explains Jean-Christophe Kremer, Secretary General of ISDI.

“Over the years, improvements in maternal, infant and young-child nutritional health have been achieved through effective collaboration with healthcare professionals. We agree with paediatricians and medical societies who favour transparent interaction with our industry. This interaction must be carried out in compliance with professional and ethical standards”, added Beat Späth, Secretary General of SNE. ISDI, SNE and various national trade associations have been working to ensure compliance with such standards within their industry, inter alia with their Codes of Practice.

In conclusion, our industry welcomes all opportunities to work constructively with all relevant stakeholders, including policymakers and healthcare professionals, to promote evidence-based policies, ethical frameworks and parent and caregiver support to improve infant and young-child health and nutrition outcomes.

[1] Jean-Christophe Kremer, Beat Späth: Breastfeeding and the role of the commercial milk formula industry, published August 05, 2023 in The Lancet;
DOI: https://doi.org/10.1016/S0140-6736(23)01196-0

[2] Rollins N, Piwoz E, Baker P, Kingston G, Mabaso KM, McCoy D, Ribeiro Neves PA, Pérez-Escamilla R, Richter L, Russ K, Sen G, Tomori C, Victora CG, Zambrano P, Hastings G; 2023 Lancet Breastfeeding Series Group. Marketing of commercial milk formula: a system to capture parents, communities, science, and policy. Lancet. 2023 Feb 11;401(10375):486-502. doi: 10.1016/S0140-6736(22)01931-6. Epub 2023 Feb 7. PMID: 36764314. https://pubmed.ncbi.nlm.nih.gov/36764314/

[3] https://www.who.int/news-room/events/detail/2023/06/20/default-calendar/global-congress-on-implementation-of-the-international-code-of-marketing-of-breast-milk-substitutes ; See also ISDI Statement “Working together to support optimum infant nutrition and informed infant feeding choices” (19 June 2023). https://www.isdi.org/working-together-to-support-optimum-infant-nutrition-and-informed-infant-feeding-choices/

ISDI and its members recognise that breastmilk is the best source of nutrition for healthy infants and support exclusive breastfeeding for the first six months, and continued breastfeeding for up to two years and beyond.

When parents are unable to breastfeed or choose not to, a scientifically developed infant formula is the only food recognised by the WHO as a suitable and safe alternative to breastmilk. In these situations, infant formula is life saving and life sustaining.

Parents and caregivers should be supported when choosing how to feed their baby, and should have that choice respected, whatever their feeding journey. It is important that parents can make informed choices about the options that are right for their baby and situation. We support parents with factual, scientific nutritional information, including on packaging and on digital channels, so that they can make the right decision for them. It is a responsibility we take seriously.

ISDI acknowledges the importance of, and is committed to, the principles and aims of the WHO’s 1981 International Code of Marketing of Breast-milk Substitutes (WHO Code)[1] as implemented through national legislation. ISDI members comply with all laws and ‎regulations in the ‎countries in which they operate and have extensive internal approval and audit ‎processes in place ‎‎to ensure their online and offline content meets all legal, regulatory ‎and nutritional ‎science ‎requirements, in compliance with national laws and applicable industry codes.

ISDI members are cognizant of their responsibility to further the health of infants and young children that are not – or cannot be – breastfed and are thus individually taking additional steps to actively raise awareness of the WHO Code and applicable laws amongst third parties. Therefore, ISDI wishes to contribute to a balanced and sensible debate about responsible marketing of formula and protecting and supporting breastfeeding.

[1] See the World Health Organization’s International Code of Marketing of Breast-Milk Substitutes