LABELLING

Companies are breaking the rules by ...

designing labels of infant formula with attractive images or text that they might influence mothers to opt for bottle feeding rather than breastfeeding. Many labels minimize the superiority of breastfeeding statement and warnings about health hazards are often missing. Labels of follow-up milks and complementary foods often discourage sustained breastfeeding and do not include alll the information necessary for proper use of the products. Chart 9 on page 42-43 shows in which countries labels of infant forumula do not comply with the requirements of Article 9. Charts 10 and 11, respectively, show in which countries labels of follow-up formula and complementary foods were found not to comply with Articles 9.1 and 9.4.

The most frequently noted labelling violation was the presence of pictures or text which idealise the use of infant formula. Between 1985 and 1995, in compliance with Code requirements, most companies did remove the baby pictures or the mother/baby images that idealized infant formula for decades. Monitors in two thirds of the countries surveyed found, however, that the baby images had been replaced by other images that effectively promote the formulas such as feeding bottles, cuddly toy animals, other toys and flowers. For example:

This is how labels used to be.

• Dumex infant formula labels in Malaysia continue to portray a hand holding a large glossy feeding bottle, clearly idealizing artificial feeding.
• Mead Johnson's Enfamil and Prosobee formulas show the Peter Rabbit family in the famous original design by Beatrice Potter. The smallest rabbit is being bottle fed on its mother's lap.
• Abbott Ross's Isomil and Similac labels show a distinctive teddy bear which also appears on other promotional materials.

• Nutricia/Cow&Gate labels use the drawing of a bottle, a toy bear and flowers as an idealizing picture.

• Milupa's Aptamil and Nectarmil in Croatia (and Germany check) show a picture of a large feeding bottle. So do Pliva’s Bebimil, Soyamil and Laktovit in Croatia.

Monitors in many countries also reported negative messages in the labelling text which can create anxiety and inhibit lactation, thus violating the prohibition in Article 9.1 on labels that discourage breastfeeding.

• In Mauritius, Milupa's Aptamil label uses the text "Quand l'allaitement n'est pas possible..." (When breastfeeding is not possible...)
• Wyeth's Bonna label in the Philippines reads"...Bonna is intended to replace or supplement breastmilk when breastfeeding is not possible or is insufficient..."
• The Morinaga infant formula label in Bolivia says it is a "... substitute for breastmilk when the mother is unable to breastfeed..."
• Enfamil by Mead Johnson, marketed in Western Samoa, states: "Experts agree on the many benefits of breastmilk. If it is not chosen, is discontinued or if a supplement is needed, Enfamil offers excellent nutrition for baby's first year and beyond."

A company called Rapaks International Australia violates the International Code by showing baby photos on the labels of its Infant Milk Formula and Lactose-free Formula, both marked "for the infant's first months". An example of wild "free trade", these formulas are made in Switzerland and sold to Uzbekistan from where they are smuggled to other Central Asian Republics as well as Iran and Pakistan

RAPAKS INTERNATIONAL AUSTRALIA PHONE: 612 387 7000 - FAX: 612 387 7194 MADE IN SWITZERLAND IMPORTER: V/O "UZMEDIMPEX"

STANDAR LABELS ? It may well be that the only way to a non-promotional label is to require a standard design with factual and impartial information.(Caption to a photo of Iran tin and Snow tin) A standard label for infant formula is enforced by the Iran Law on Supporting and Promoting Breastfeeding. In addition to specified warnings there must be a statement: "This milk is intended for babies deprived of their mother's milk". The contents of the tin are identical to that of the Snow Brand tin next to it. Snow Brand has finally also removed its baby picture from the label.

Although most companies include the required statement as to the superiority of breastfeeding, many down-play it by making it inconspicous or positioning the statement too high so that it is half-hidden by the plactic cover of the tin. On other labels, the statement is negated by phrases praising the qualities of the formula and implying its near-equivalence with breastmilk.

Labels of infant formula manufactured by the following companies did not have a statement on the superiority of breastfeeding at all: Danone's Pre-Gallia in Côte d'Ivoire; Nutricia's Pepti-Junior in the Dominican Republic; in Indonesia, Mead Johnson's Pregestimil and Enfalac and Nutricia's Nenatal; Fasska's Biomil in Bangladesh and Nestle's Pre-Aletemil in Germany.

Other labelling violations include the absence of the obligatory heading: IMPORTANT NOTICE or its equivalent. Various brands of infant formula in 20 of the 31 countries surveyed did not have a warning against the health hazards of inappropriate preparation. Some companies also mis-use ‘under-the-lid inserts’ which are allowed only for giving additional information about the product and its use. In Kenya, Wyeth’s Nursoy and SMA each include inserts that advertises Wyeth’s other infant formulas including SMA Gold, SMA White Progress and SMA Wysoy. The Frisolac tin in Malaysia also comes with an insert advertising other products.

Some companies, such as Nestle and Fasska in Bangladesh even use infant formula labels to promote the use of the companies’ follow-up formulas for the older baby. In Mauritius, Danone/Diepal promotes its complementary foods Farigallia on the Gallia 1 label. In half of the surveyed countries, products were found which did not have the required expiry date, ingredients list, storage conditions or batch number (ART. 9.4).

Gallia infant formula labels.

Chart 9 shows in which countries companies sell infant formula with labels that do not comply with all of Article 9. A country is listed if a least one of the infant formula brands sold in that country does not comply with the particular requirement.

Other companies whose labels violate Article 9 include Celia (Niger), Citra Pangantama Sejhatera (Indonesia), Citra Suarda Cemerlag (Indonesia), Mirota (Indonesia), Conaprole (Uruguay), Fasska (Bangladesh), France Lait (Niger), Herford (Bangladesh), Hero (Dominican Rep., Venezuela) Lab G. Pom (Venezuela), Pil Andina (Bolivia), Sancor (Argentina) Sari Husada (Indonesia).

Companies are also breaking the rules by...

using labels to promote complementary foods too early in contravention of WHO policy as set out in Resolutions WHA 39.28, WHA47.5 and WHA49.15 (See p.xxx [in promo to public]. According to these resolutions, complementary foods may be introduced at about six months and should not be marketed in ways that undermine exclusive and sustained breastfeeding.

• Nestle’s Alete Honig Schleim, a gluten-free honey porridge in Germany, is recommended for use as of the second week.

• In Spain, Ordesa’s Riz Crem, an instant food for bottle feeding, is recommended from the first month. The back of the box advertises other Ordesa products such as Blevit blended foods and follow-up formulas from 4 months up to 3 years.
• In Mauritius, some of Milupa’s cereal dinners, Nestle’s fruit purees and Danone/Diepal’s Bledina vegetable puree and caramel desert are recommended from as early as 3 months on the labels.

• In Kenya, Danone/Diepal’s Bledina instant baby cereals are also recommended from 3 months.
• In Côte d’Ivoire and Benin, Nutrexpa’s Blevit is labelled for infants from 3 to 4 months.
• In Gabon, some Danone/Diepal Phosphatine instant baby cereals are labelled for the first age, while others are labelled for use after 3 months.
• Nabisco, which markets its baby cereals in Spain under the brand name Riera-Marsa, labels the products as suitable from the age of 3 months. All the cereals are for bottle feeding.

Food products recommended for such early introduction should rightly carry all the cautions that are required of regular infant formula labels. None of these labels mention that the product should be used only on the advice of a healthworker, include a warning against the health hazards of inappropriate preparation, nor include a statement as to the superiority of breastfeeding.

Many labels for complementary foods do not have a clear recommended age, leaving it to mothers to interpret when ‘first, second and third age’ foods should be introduced. Promotion of follow-up formulas and other foods before they are nutritionally required will interfere with exclusive and sustained breastfeeding.

• Gerber complementary foods in nearly all countries are labelled as ‘first, second and third foods’. Rarely are the ages clarified. In Bolivia, Malaysia, and elsewhere, Gerber Pear Juice is labelled "first foods" and "for beginners and older", which implies that it can be given even from birth. The Gerber baby face is large even on the smallest labels and clearly promotional.
• Danone/Diepal’s Gallia instant infant cereals in Gabon, Senegal and Benin are promoted for bottle feeding from "the first age". A measurement table indicates the amounts to be given at 2, 3 and 4 months. The label shows a pair of baby booties and a bottle, a picture which idealizes the use of the product .

Chart 10 shows in which countries labels of complementary foods are not in compliance with Article 9.1 and 9.4

Other companies whose labels of complementary food violate Article 9.1 include Alter (Spain), Helios (Indonesia), Hipp (Germany), Holle (Germany), Humana (Germany), Indofoods (Indonesia), Maeil (Korea), Nam Yang (Korea), Ordesa (Spain), Sari Husada (Indonesia) y Watties (W. Samoa).

Companies are also breaking the rules by ...

labelling follow-up formulas with designs, colours and names that closely resemble the company’s infant formula label.

This practice confuses the consumer. Illiterate mothers are particularly vulnerable to buying the wrong milk. Furthermore, in countries where follow-up milks are cheaper than regular infant formula mothers may be persuaded to buy it for even very young babies. Breastfeeding should be encouraged for two years and beyond. It contributes significantly to the nutrition of older babies. Claims on the labels of follow-up formula give the impression that breastfeeding should stop and be "followed up" at 6 months. Some companies promote follow-up milks for as early as four months although the Codex Alimentarius Standard for Follow-up Formula states that the product should not be introduced before the sixth month of life. At least five different companies in 11 of the 31 countries surveyed recommend follow-up milks for babies younger than six months. At list five different companies in 11 of the 31 countries surveyed recommend follow-up milks for babies younger than six months. Nine companies do not warn about the hazards of inappropriate preparation even though the product is to be prepared in the same way as standard infant formula. Fourteen companies have labels of follow-up formula in some countries that were judged to have text that discourages continued breastfeeding.

Chart 11 shows the ways in which companies violate Article 9.4 with labels of follow-up milks.