Baby Milk Ation comments on the Consultation on goats milk formulas
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If you agree please use our comments to send a submission to:
DEADLINE for ENGLAND 6th December
Proposed changes to the current regulations to authorize for the first time the use of goats' milk protein in the manufacture of infant formula and follow-on formula and some changes to the protein levels of follow-on formula made with protein hydrolysates. This follows a Directive from the EU following safety reviews of these changes by the European Food Safety Agency, and all member states must implement these changes by the beginning of March 2014.
BABY MILK ACTION responses to the Goats' milk protein in infant formula consultation
QI. Does the draft SI accurately enable the provisions of Directive 2013/46/EU? If not, please explain how the SI should be amended.
AI. The draft SI addresses compositional criteria, but not the concern that consumers may believe goats' milk protein infant formula and follow on formula is suitable for infants with cows’ milk protein allergy.
QII. The SI is drafted using ‘copy out’, meaning it does not introduce any extra burden on businesses beyond that required to implement the Directive. Do you agree?
AII. In view of the risks to infant health identified by EFSA regarding the misuse of these products and that: "Government advice remains that goats’ milk-based formula is not suitable for infants diagnosed as being allergic to cow’s milk. GPs will prescribe an appropriate infant formula with fully hydrolysed proteins" businesses should be required to add a clear and prominant warning to labels that the product may be unsuitable for use by infants with cow's milk protein allergy and that infants may also be allergic to goats milk protein.
QIII. Do the assessments and assumptions on the cost and benefits of this measure appear reasonable? Please give reasons if you do not consider this to be the case, with evidence if possible.
AIII. Please see additional comments below. Product innovation in the breastmilk substitutes market is not always beneficial as the Executive Summary implies. There may be risks to infant and young child health if the marketing of 'novel' products is not strictly controlled. The risks of misuse, the undermining of breastfeeding and the costs to health should be given much more consideration.
QIV. Manufacturers of formula milks for special medical purposes also need to comply with some of the compositional requirements for formula intended for healthy infants, therefore will also need to be familiar with the revised compositional criteria. To inform the cost benefit analysis, the Department requests data on the number of businesses operating in this sector of the UK market.
AIV. Only formulas that are prescribed for use under continuing medical supervision should be classified as foods for special medical purposes. Products that are available over the counter to parents should not fall under this category.
Additional comments: Goats milk and soya milk are widely promoted as ‘healthy’ options - so as mentioned above, great care should be taken to ensure that the presentation and marketing of these products is strictly controlled in line with the International Code of Marketing of Breastmilk Substitutes and subsequent relevant WHA resolutions.. They should not be idealised in any way (for example showing baby goats being cared for by Nanny goats) nor should they carry any health or nutrition claims. Such labelling is highly promotional, undermines breastfeeding, misleads parents and carers about the safety and nutritional value of products and masks the many risks of artificial feeding.
We support the call by First Steps Nutrition for qualitative research on whether these formula are likely to be misused for cows' milk allergy treatment.
There must also be a very clear differentiation on the labelling, presentation and marketing of goats' milk based infant formula, follow on formula and formulas for special medical purposes to ensure parents do not confuse these products.
Baby Milk Action believes that promotion of these products should be prohibited.
Infant Formula Consultation
Nutrition Legislation Team
6th Floor South Wing
Department of Health
133-155 Waterloo Road
London, SE1 8UG