a2 Milk
Headquarters
New ZealandType of ownership
PublicEstimated percentage of a2 Milk's global F&B sales from BMS
59%Estimated percentage of a2 Milk's global baby food sales from BMS
100%Countries covered in country studies
China© All rights reserved
Score 2024
Score
Score
Important:
The research findings regarding companies’ performance in this Index are based on information shared by companies or gathered by service providers, in addition to information that is available in the public domain.
The level of detail and comprehensiveness of information shared by companies and gathered through external service providers varied. In the case of limited or no engagement by companies, this Index may not represent the full extent of their efforts. Similarly, in the case of limited data collected by service providers, the findings of this Index may not provide a comprehensive representation of company practices.
ATNI’s research and Indexes do not assess compliance with local regulations or laws, but rather assess private sector performance against international standards and guidance.
BMS Country Studies
Score
The Country Studies component of the BMS and CF Marketing Indexes 2024 evaluates the extent to which a company’s marketing practices align with specific provisions of the WHO Code (not against local Code-related regulations). The main marketing channels assessed in the Country Studies for the BMS and CF Marketing Indexes 2024 are online points-of-sale, traditional and online media outlets, and product labels which were all assessed according to the NetCode protocol. a2 Milk sells BMS products only in China, one of the five countries selected for the assessment, which represents approximately 87% of a2 Milk’s estimated global BMS sales. The Country Studies results for a2 Milk are summarized below for China across each marketing channel.
Country Studies overview
| a2 Milk | Country assessments | BMS market | |||
|---|---|---|---|---|---|
| Total incidences of non-compliance across online, traditional media, and product labels | Number of product labels assessed | Company brands found | BMS market share | Proportion of a2 Milk's global BMS sales | |
| CHINA | 14 | 19 | a2 Milk | 2% | 87% |
| GERMANY | N/A | N/A | N/A | N/A | N/A |
| INDONESIA | N/A | N/A | N/A | N/A | N/A |
| US | N/A | N/A | N/A | N/A | N/A |
| VIET NAM | N/A | N/A | N/A | N/A | N/A |
(0 incidences of Code non-compliance corresponding to a country score of 100%)
(>0-10 incidences of Code non-compliance corresponding to a country score of 66%)
(>10-20 incidences of Code non-compliance corresponding to a country score of 33%)
(> 20 incidences of Code non-compliance corresponding to a country score of 0%)
The majority of a2 Milk’s sales are in China (approximately 87%), where the company possesses less than 5% share of the Chinese BMS market. A total of 14 incidences of non-compliant marketing practices were found, including advertisements and promotions related to BMS products found on online media (12) and non-compliant labels (2).
Observed incidences of non-compliance with the Code per country
Main in-country findings
The total number of non-compliant marketing practices found for a2 Milk BMS products in China was 14. The majority of incidences of non-compliance were identified through the social listening of online platforms (12), and both of the labels assessed contained one or more incidences of non-compliance. The majority of incidences of non-compliance on online media and labelling were concerning growing-up-milks (11 in total).
Online findings
• Among the total 12 incidences of non-compliance found online, three were point-of-sale promotions found on online retailer platforms, of which one promotion was for follow-up formula and two for growing-up milks. Despite ATNI’s request for a2 Milk to verify any contractual relationship with the retailers monitored, confirmation could not be obtained from the company. Promotions found on online retailer platforms had an average of two instances of non-compliance per promotion found. Along with the advertisements identified, which are non-compliances with Article 5.1 of the Code, various incentives for product purchase were identified such as discounts and deals as well as company contact registration for gifts.
• The remaining nine observations were found on the company’s local social media platform (Weibo), all (except one brand promotion) were for growing-up milks, with an average of three instances of non-compliance per advert. Besides the advertisements identified, which are non-compliances with Article 5.1 of the Code, other common incidences found with those advertisements included offering information and educational materials, product purchase incentives (such as offers, cash-back, coupons, gifts), and health care sponsorship. Six of the advertisements had at least one type of claim (health, nutritional and/ or marketing claim).
Traditional media findings
• No traditional media advertisements (TV, radio or print) were found for a2 Milk’s BMS products sold in China in the six-month period the channels were monitored.
BMS product label
• Both a2 Milk BMS product labels assessed contained two or three non-compliant incidences per product label. One product was a follow-up formula, and one was a growing-up milk.
• Both product labels contained at least one type of claim (health, nutritional, and marketing claim). Both products also had images that may idealize the use of breast-milk substitutes. For the follow-up formula, the age range was not clearly specified.
• It is worth noting that ATNI did not have the resources to collect products from the different markets and take pictures of their labels. In this iteration, ATNI’s research was based on product label images from an external provider. For some products, images were not clear enough or did not show all parts of the package, thus ATNI asked the respective companies to provide images of the labels. As a2 Milk did not respond to ATNI during the verification phase, the company had not provided images of product labels as requested by ATNI. Therefore, incomplete assessments remained for both products. Since at least one incidence of non-compliance was identified from the existing images, these labels were counted as a non-compliant observation.
Recommendations
• Given the number of incidences of non-compliant marketing practices observed in China, a2 Milk is strongly encouraged to strengthen its responsible BMS marketing policies and ensure their full alignment with the recommendations of the Code and all subsequent relevant resolutions, including the guidance supported by WHA resolution 69.9. ATNI has developed a model company policy on the responsible marketing of BMS which can guide the company on how to incorporate Code provisions and align with the latest public health requirements in practice.
• Advertisements of a2 Milk’s BMS products were found on online media and several point-of-sale promotions were found on local online retailers. a2 Milk is urged to restrict the advertising and promotion of all types of BMS products and brands on all forms of media platforms. The company should also refrain from the use of incentives that promote the purchase of its BMS products, such as discounts, offers, deals, and company contact registration for gifts.
• a2 Milk is strongly encouraged to take responsibility for monitoring its marketing practices beyond local regulations, according to the principles and the aim of the Code and subsequent relevant resolutions, and to take steps to ensure this includes online media channels.
• a2 Milk is encouraged to engage with its industry associations, retailers and/or regulators to ensure that there are no promotions of BMS products in the retail environment, and see that products are appropriately marketed in line with the Code.
• Given that both labels assessed were found to be non-compliant with the Code requirements in at least one aspect, a2 Milk is encouraged to focus on improving labeling practices across all markets to ensure full compliance with the Code and all subsequent relevant resolutions, including the guidance supported by WHA resolution 69.9. This includes ensuring that product labels clearly include a statement promoting the importance of exclusive breastfeeding for the first six months and continued breastfeeding up to two years or beyond, and that labels do not include health or nutrition claims, except if specifically provided for in national legislation.
• Clear evidence was found of a2 Milk advertising growing-up milks and promoting these on online platforms, which is contrary to the requirements of the Code, specifically the guidance supported by WHA resolution 69.9 that extended the scope of the Code to growing-up milks. Therefore, ATNI urges a2 Milk to ensure its commitments are extended to include growing-up milks in all markets.
• A2 Milk is strongly encouraged to cooperate fully with any future independent third-party assessments by providing clear and comprehensive product label images. Incomplete assessments can lead to inaccurate evaluations and hinder efforts to address incidences of non-compliance effectively.
• ATNI is calling on a2 Milk to review all incidences of non-compliance identified across all marketing channels, which were shared in detail with the company, and to take corrective action.
BMS Corporate Profile
Score
The Corporate Profile component of the BMS and CF Marketing Indexes 2024 evaluates the extent to which a company’s policies align with various provisions of the Code, the effectiveness of its related management systems as well as the company’s level of disclosure on commitments relating to BMS marketing. a2 Milk’s BMS marketing commitments were assessed across 11 topics that cover different aspects of the Code on which the company scored an average of 0,49%. This score is equivalent to the company’s initial overall Corporate Profile score before a geographic penalty (if applicable) is applied to each BMS product type. The final Corporate Profile score considers how the company’s BMS marketing commitments are applied for the different BMS product types sold by the company, and across different markets. As a2 Milk sells infant formula, follow-up formula, and growing-up milks, the company’s application of BMS commitments was evaluated for each product type, as shown in the next section on ‘Geographic application of BMS commitments by product type’. The scores and findings on each topic are described in further detail in the section below on ‘BMS Commitments by Topic’.
Geographic application by a2 Milk of BMS commitments by product type
The table below shows the percentage of product sales where commitments are upheld and the geographic penalty applied to each type of BMS. The penalty ranges from 0% up to 90% depending on whether a company fully upholds its BMS marketing commitments in all or none of the countries in which it operates, respectively, where national Code regulations are absent or less stringent than the company’s policies and standards.
|
Corporate Profile score before penalty |
Product type |
Percentage of a2 Milk’s global sales from markets where BMS commitments are upheld |
Geographic penalty applied |
Final Corporate Profile score |
|---|---|---|---|---|
| 0.5% |
Infant formula |
0% | 90% | 0% |
|
Follow-up formula |
0% | 90% | ||
|
Growing-up milk |
0% | 90% |
• No information was found in the public domain nor shared by the company describing how BMS marketing commitments are upheld for each product type and in which markets. Therefore, the corresponding geographic penalty for each product type (infant formula, follow-up formula, and growing-up milk) is the maximum of 90% and the final Corporate Profile score is 0.05%.
Infant formula
The corresponding geographic penalty for this product type is the maximum of 90%.
Follow-up formula
The corresponding geographic penalty for this product type is the maximum of 90%.
Growing-up milk
The corresponding geographic penalty for this product type is the maximum of 90%.
• ATNI calls on a2 Milk to develop and/or publish a BMS marketing policy that fully aligns with the wording of the Code, in addition to upholding the relevant national regulations in China. The policy should also cover all milks that are specifically marketed for feeding infants and young children from birth up to the age of three years, and it should be applied in all markets which the company operates in.
Topics Overview
BMS commitments by topic
Most topics include assessments on both policy commitments and management systems, except for the topic on ‘Implementation and Monitoring’, which mostly considers management systems, and the topic ‘Overarching Commitments’, which considers policy commitments only. A separate topic assesses the level of disclosure and transparency practiced by companies on the different aspects of the Code.