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U.S. Calls for Clarification in WHO’s Proposed Guidelines

Mar 09, 2016

The U.S. Department of Health and Human Services filed comments last week with the World Health Organization (WHO) regarding proposed guidelines that aim to limit the marketing and promotion efforts of many dairy foods companies throughout the world. While HHS supports WHO’s efforts to promote optimal nutrition for young children, the comments asked for clarification of the guidelines’ goals, the public health concerns they intend to address and how they would integrate with existing WHO and Codex Alimentarius standards.

The guidelines, titled “Guidance on Ending the Inappropriate Promotion of Foods for Infants and Young Children,” came out of a recent WHO Executive Board meeting. The board is fast-tracking the approval process, with plans to ask the World Health Assembly to adopt the guidance during the Assembly’s meeting in May. In the past two weeks, IDFA and members of an ad hoc coalition have submitted comments to HHS, contacted a variety of government officials and made visits to Capitol Hill to alert U.S. officials to the harmful nutrition and trade implications of the proposed guidelines.

The comments from HHS were measured and specific, supporting WHO’s overall nutrition efforts, but they also called for added transparency, details and time before WHO moves forward with the approval process. “We expect that WHO will adequately address comments provided by Member States before presenting this guidance to the WHA for potential endorsement,” the comments said.

HHS made the following recommendations:  

  • Include a brief history of the process WHO used to develop the guidance;
  • Define key terms, such as “inappropriate promotion” and “complementary foods,” used in the guidance;
  • Review public health goals that the guidance is intended to help members achieve to confirm why the proposal would be useful;
  • Provide a summary of scientific and technical evidence used, along with appropriate citations; and
  • Explain the relationship between the guidance and other standards, such as Codex Alimentarius standards and principles for complementary feeding.

IDFA opposes the guidelines as written, because they would restrict access by parents, caregivers and healthcare providers to important information conveyed through marketing about the nutritional benefits of dairy foods for young children. IDFA believes this action could push parents toward feeding young children less-healthy alternatives. In addition, IDFA believes the guidelines could have serious trade implications for companies that export dairy products and ingredients, particularly milk powders used in infant nutrition products such as follow-up formula and growing-up milks.  

IDFA will continue working with the ad hoc coalition to build awareness of the potential confusion and nutritional harm the guidelines would create. For more information, contact John Allan, IDFA vice president of regulatory affairs and international standards, at

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