Monitoring the baby food industry against internationally agreed marketing standards
BFLG monitors and encourages the public to monitor the baby food industry against internationally agreed marketing standards.
The International Code of Marketing of Breastmilk Substitutes was adopted by the 1981 World Health Assembly (WHA) to protect infant health by stopping all forms of promotion of breastmilk substitutes and bottle-fed complementary foods. The 1996 Resolution WHA 49.15 calls for all complementary foods to be marketed or used in ways that do not undermine exclusive and sustained breastfeeding.
While governments are called on to implement the International Code and subsequent, relevant Resolutions, companies are required to ensure their activities at every level comply independently of government measures. In the UK, legislators England, Norther Ireland, Scotland and Wales have failed to implement the Code and Resolutions despite repeated calls on them to do so by the UN Committee on the Rights of the Child.
Accordingly, monitoring is serves a crucial role to demonstrates that companies are failing to meet their responsibilities under the Code and Resolutions and the need for legislation to hold them to account. Monitoring also documents the strategies that have helped create the widespread believe in the UK that formula is the same or almost the same as breastfeeding (the finding of a Department of Health survey published in 2005: Myths stop mothers giving their babies the best start in life
- text posted on the OnMedica
Although the Code and Resolutions have not been implemented in the UK, the weaker Infant Formula and Follow-on Formula Regulations, introduced by each country of the UK, do prohibit some misleading and dangerous marketing practices. In these cases it is possible to call on enforcement authorities to take action.
In theory, the Advertising Code applicable to print, radio, television and online advertising in the UK goes beyond the requirement that advertising be legal as it also requires it to be 'decent, honest and truthful'. BFLG has argued that these tests should imply in line with the Code and Resolutions as a minimum standard, but this argument has been rejected by the industry-funded Advertising Standards Authority, which overseas the voluntary Advertising Code. All the same, it is worth making a case about misleading claims in advertising (even if that advertising should, by rights, not occur in the first place) and has led to companies being called to revise advertisements.
How to monitor
"UNICEF proposes that IBFAN [the International Baby Food Action Network] and other NGOs [Non-Governmental Organisations] that regularly fulfil the monitoring role assigned by the World Health Assembly to NGOs be given renewed encouragement to continue monitoring compliance with the International Code....UNICEF views this as an issue of great consequence....It speaks, quite simply, to child survival and development. There is too much at stake for the International Code to be ignored."
UNICEF, 14 January, 1997
IBFAN conducts training on monitoring for member organisations to a standard protocol. Some of the basics of monitoring are set out here.
The UK IBFAN group, Baby Milk Action, has an online training course on monitoring that will be helpful to anyone wishing in-depth knowledge of how to monitor - click here
Monitoring involves investigation, observation and recording of information. Be inquisitive and persistent, but also sensitive.
Prepare carefully: familiarise yourself with the main points of the International Code and Resolutions and any national measures (see The Law section of this site). Find out the names of baby milk companies and their brand names in your country.
Pay close attention to detail: in all your notes, make a careful record of dates, company and brand names, name and address of hospital, clinic, store, etc. name and position of person giving information, descriptions of posters, displays, etc.
Take photographs, if possible. Mobile phones are particularly useful for this purpose. Increasingly people take photos in shops for comparison purposes.
Obtain copies of code violations wherever possible. Examples of brochures, booklets or labels may be available or you may be able to take photocopies or photographs. Make sure you have a clear record of where and when such items were found. If you write on the items be careful not to deface them.
If you are a health worker or a mother-to-be it will be straightforward to examine what happens in the hospital or clinic that you attend. If you are visiting a friend or relative you may come across violations.
While it is important to get documentary evidence to support your research, it is also important to protect the confidentiality of health workers who need it, especially when they give you sensitive information. You may even have to withhold the names of people and hospitals from your reports - details can be confirmed with you personally if necessary. If you are passing on information that should be treated sensitively, make sure documents are clearly labelled as "CONFIDENTIAL".
Visiting shops, supermarkets, pharmacies and other locations where baby milks and feeding bottles are sold will enable you to check for special displays, leaflets, posters, special prices and other promotions.
Checking the media for advertisements is easy - look particularly in magazines for parents and also check publications imported from other countries.
Radio and TV broadcast advertisements. It is important to note the channel and the time that an advertisement appears. Even if it is appearing regularly, note the required details of some examples to identify it. If possible record it.
Check to see if any products are advertised for use before they are nutritionally necessary: e.g. whole milk powder is sometimes promoted for babies from birth or the early months, baby foods and drinks are often advertised for use before the baby is 6 months old.
Looking in relevant trade journals - magazines aimed at the shops and pharmacies which sell baby products - may expose violations. Look for information about breastmilk substitutes or advertisements: they may give details of sales inducements, tie-in sales, special offers, discounts or competitions for shop owners and pharmacists.
Other direct advertising can include advertising hoardings (billboards), direct mail to consumers, displays at public events and baby shows. Keep an eye out for bottle feeding promotion at all times.
ALWAYS RECORD AS MUCH DETAIL AS POSSIBLE.
Collect information on anything which undermines breastfeeding even if you are uncertain whether it violates the International Code and Resolutions.
Reporting your findings to BFLG using the forms in this section (see section menu at the side).
You will also find information on how to report violations to the appropriate enforcement authorities.