Many thanks to Libby Salmon BVSc, MVCS, Visiting Fellow, ACERH ANU, Julie Smith, PhD. B. Econs (Hons)/B.A and Joy Heads OAM, Midwife, MHPEd, IBCLC®, FILCA for this contribution to the discussion on infant nutrition.


Australia may be at the forefront of tobacco control worldwide, but has dropped the ball in relation to global efforts to protect breastfeeding from company marketing.

This is the implication of a recently released paper in the Australian and New Zealand Journal of Public Health  which examined the effectiveness of voluntary regulation by the infant food industry.  The ANU study analysed print advertising of breast milk substitutes in both the Australian Women’s Weekly and the Medical Journal of Australia from 1950 to 2012. It identified an urgent need for comprehensive regulation to protect optimal infant and young child feeding in Australia and in the Asia Pacific region.

Current regulatory arrangements centre on the 1992 Marketing In Australia of Infant Formula: Manufacturers and Importers Agreement (MAIF Agreement), an industry agreement negotiated between infant formula companies in response to Australia’s signing of the World Health Organisation (WHO) International Code on the Marketing of Breastmilk Substitutes in 1981 (The WHO Code). Under the Agreement, the companies appoint a representative to a taxpayer-funded panel which monitors industry compliance and also ‘advises the Australian government on the Agreement’. The panel has limited the Agreement to “formula for infants up to 12 months”, and therefore excluded the so-called follow-on formulas including toddler milks which came on the market soon after the MAIF Agreement was signed.

The researchers concluded that “Companies have adopted strategies to minimise the effects of the Code on sales and profits in Australia, including increasing toddler formula …and brand promotion…to the public.”

According to the ANU study this situation is in direct contravention of the 2007 ‘Best Start’ federal Parliamentary Inquiry, which recommended implementing the full WHO Code and subsequent relevant World Health Assembly (WHA) resolutions, including by legislation and mandatory enforcement.

The results beg the questions:

Is toddler milk covered by the International Code?

Is toddler milk a necessary food for toddlers?

Has the government been adequately advised on its implementation of the Best Start recommendation?

Scope of the WHO Code

WHO has clarified on more than one occasion that follow-on formulas and toddler milk are included in the WHO Code. The WHO recommendation that infants and young children should be fed breastmilk exclusively for the first six months, and that breastfeeding continue for two years and beyond, is explicit.  In 2010, the World Health Assembly (WHA) called upon “infant food manufacturers and distributors to comply fully with their responsibilities under the International Code of Marketing of Breast-milk Substitutes and subsequent relevant World Health Assembly resolutions”.

The WHA 2010 Resolution states that the “promotion of breast-milk substitutes and some commercial foods for infants and young children undermines progress in optimal infant and young child feeding”.

Are follow up formula and toddler milk necessary?

In the face of escalating marketing of follow-up formula and toddler milks, WHO stated unequivocally in July 2013, that follow-up formula is both unnecessary, and not a suitable substitute for breast milk. It observed that follow on and toddler formulas are marketed in a way that confuses consumers, and reduces breastfeeding.

In Germany, the Federal Institute for Risk Assessment (BfR), which advises the Government on food safety, has stated its concerns about toddler milk being unnecessary and inappropriate. Toddler milk products supply higher amounts of micronutrients such as iron and zinc than cow milk, leading to “an uncontrolled intake of these nutrients and involving the risk of a nutrient oversupply”.

“From a nutritional and physiological point of view these special toddler milks are not necessary”, says BfR President Professor Dr. Andreas Hensel.

Is the Australian Government well advised on infant and young child feeding?

Regarding the Best Start Inquiry’s call for full implementation of the WHO Code, the federal Department of Health and Aging commissioned consultants to review the effectiveness of MAIF. It released their report in mid-2013.

The review identifies that labelling of toddler milks was misleading. The consultants recommended that “… products should be sufficiently different to enable consumers to clearly and quickly distinguish between infant formula and toddler milk drinks” (Recommendation 4).

However, the Department rejects this recommendation on the basis that “the WHO Code does not support an extension of focus to toddler milk”.

Such advice is alarming, directly contradicting the WHO and WHA position on infant and young child feeding, including that follow-up formula and toddler milks are within in the scope of the WHO Code.

In the wake of the Fonterra formula crisis, and the boom in Australasian formula exports to China, a serious question arises as to whether the Australian Government is doing enough to protect the safe feeding of infants and young children worldwide.

As a major dairy food exporter, it is crucial that Australia set impeccable standards domestically to maintain its public health credibility both nationally and internationally.

WHO’s clear stance on marketing of breastmilk substitutes should set the standard.

The Australian Government must respond urgently to stem the rapidly increasing promotion of toddler milk, its unquestioned acceptance as a food for young children, and the misleading labelling and unrestrained marketing practices of the local industry.