CF Index 2024

Recommendations to CF companies

Companies should prioritize efforts to enhance and harmonize compliance with the Code, specifically the WHO Guidance on Ending the Inappropriate Promotion of Foods for Infants and Young Children supported by WHA Resolution 69.9, across all countries they operate in, to protect optimal nutrition for infants and young children globally.

• Companies are urged to follow WHO guidance relating to complementary feeding and uphold globally recognized public health guidelines, with a key requirement being not to produce and sell commercial CF for infants aged under six months, which directly interferes with exclusive breastfeeding up to six months.

• Companies are urged to especially follow recommendations 3, 4, 5, and 6 of the WHA 69.9 supported guidance, to ensure the appropriate promotion of their CF products across all marketing channels.
• To comply with the recommendations of the WHA 69.9 supported guidance, companies should ensure that CF products are of appropriate nutritional quality in line with the latest WHO guidelines, such as the NPPM.
• Based on the results of the country studies, companies are especially encouraged to state the appropriate recommended age of introduction (this should not be under six months), include messages that protect breastfeeding and appropriate complementary feeding practices, and refrain from using claims when marketing CF products. Companies should also refrain from cross-promotion, whereby BMS are indirectly promoted through the promotion of CF.

• Based on ATNI’s findings, companies should have explicit commitments and guidelines on responsibly marketing their CF products in digital environments, in line with the latest digital marketing guidance by WHO. Recommendation 4 of the digital marketing guidance specifically recommends restricting in digital environments the promotion of CF that do not meet relevant nutrition standards and that are marketed as suitable for infants less than six months of age.
• In addition, the appropriate promotion of CF in digital environments requires that the marketing messages criteria outlined in the WHO Guidance on Ending the Inappropriate Promotion of Foods for Infants and Young Children are followed, to ensure that messages supporting optimal IYCF are present and that inappropriate messages which could undermine recommended practices are not included.
• Considering the above recommendations, companies are urged to develop and/or publish policies dedicated to the responsible marketing of CF that fully align with the Code, specifically the WHO Guidance on Ending the Inappropriate Promotion of Foods for Infants and Young Children supported by WHA Resolution 69.9.

• Companies should bolster their management systems to deliver consistent compliance with their stated commitments, once brought into full alignment with the Code.
• Companies should promptly take corrective actions upon receiving reports of incidences of non-compliance with the Code.
• ATNI urges companies selling CF to take responsibility for monitoring their marketing practices beyond local regulations, according to the principles and the aim of the Code and subsequent relevant resolutions, namely WHA Resolution 69.9.
• Companies should publish more information on their CF marketing policies and practices to increase transparency, and make key documents easily accessible to stakeholders.

Recommendations to investors

As shareholders, investors play a significant role in shaping food companies’ governance, strategy, and disclosure practices.

• Investors should make use of existing models, such as WHO’s designated model to assess complementary foods (NPPM), to integrate compliance with WHO guidelines on the appropriate promotion of CF products into responsible investment strategies.

• Investors can use the findings of this Index to drive companies’ progress on responsible CF marketing practices through various investment strategies, calling for transparency and compliance to the Code, specifically the WHO Guidance on Ending the Inappropriate Promotion of Foods for Infants and Young Children supported by WHA Resolution 69.9.
• Investors can use the data from this report to develop materials to support engagement with companies.
• Investors are urged to employ their influence to encourage companies to take steps towards full Code compliance.

Recommendations to policymakers 

• Following WHO guidance supported by WHA Resolution 69.9, governments should put in place measures to end the inappropriate promotion of food for infants and young children and promote enabling environments that support parents and caregivers to make well-informed feeding decisions.
• Governments can make use of existing resources, such as the Compendium of international standards and guidelines for the improved composition and labelling of commercially produced complementary foods in Southeast Asia, developed by UNICEF East Asia and the Pacific Regional Office for the COMMIT Initiative, which helps guide the development of new, or update existing, national regulations on the nutrient composition and labeling practices of commercial CF, in line with international guidance
• We suggest that particular focus be placed on restricting parallel imports to countries and recommend consideration of stricter rules to prevent the entry and marketing of parallel import products that do not comply with national regulations. The authorities could, perhaps, look at how the importation of these products might be more strictly controlled.

Recommendations to civil society and non-governmental organizations (NGOs)

• Educational campaigns targeting consumers should be conducted to raise awareness on appropriate complementary feeding practices, and the potential risks associated with the inappropriate marketing of CF products.
• NGOs, civil society, and academia can contribute to expanding the research and body of evidence on the marketing of CF, to support the development of comprehensive guidelines that address concerns over the marketing of these product.