IBFAN opposes flexible labelling during emergencies

IBFAN and colleagues from ENCA, ILCA and WPHNA will be attending (in person and remotely)  the 49th Codex Alimentarius Commission meeting in Geneva. We are hoping to halt the adoption of a  proposal promoted by the USA  (Agenda Item 4.7 will be Monday 6th July) that calls for guidelines to allow flexibility regarding product labelling and ingredients for emergencies.  IBFAN believes that even though the Guidelines contain some safeguards, they will create a double standard that will put those in situations of food insecurity, famines and food deprivation at even greater risk.

IBFAN and ENCA recommend that the Guidelines on the Application of Food Labelling Provisions in Emergencies should be discontinued because they are not necessary and risky.  Our fall-back position is that they should be returned for more work. At the very least products for babies should be specifically EXCLUDED and specific reference should be  made to he Codex Code of Ethics for International Trade in Food .

Member States and Observers are invited to respond to a CIRCULAR LETTER asking whether  the Proposed guidelines  should be adopted. The deadline for comments has been extended to 26 June so we are appealing to Member States and health advocates to call for the above changes. 

Support the ENCA and IBFAN comments.  During the Labelling committee (CCFL49) in May, 2026, 3 Member States called for baby foods to be excluded from the guidelines.

Here are some of our concerns:

1. Defining an emergency is a highly sensitive political action.

2. Codex has a dual mandate to both protect health and facilitate fair trade (unlike the single mandate to protect the right to health of WHO and UNICEF) Codex  texts are often compromised and each weakness can have far-reaching influence on laws and policies  to protect human health.

3. Flexible labelling may be necessary in some cases, but it opens the door to double standards and exploitation of the most vulnerable, especially if national governments have inadequate emergency preparedness safeguards.  Many will not recognise exploitive labelling or take steps to forbid it.

5. The uncontrolled dissemination of inadequately labelled products during emergencies is a health and safety risk, especially for infants and young children, where breastfeeding is a lifeline.

6. For agencies and NGOs working in emergency relief, flexible labelling can complicate the traceability and recall procedures of contaminated or unsafe food.  See that formula possibly contaminated with Cereulide has been exported to Ukraine, the Gaza Stip and West Bank.(2)