Marketers position CPCF as suitable for older infants and young children aged between 6 and 36 months (Older IYC) due to their convenience in consumption.
However, numerous CPCF products in the market are said to exhibit high sugar or salt content and employ labelling practices that may mislead caregivers, making them unsuitable for or discouraged in the diet of older IYC.
In response to these concerns, the Consortium for Improving Complementary Foods in Southeast Asia (COMMIT) was established in 2021 to address regulatory gaps associated with CPCF.
COMMIT conducted a comprehensive legal and policy desk review across seven Southeast Asian countries—Cambodia, Laos PDR, Indonesia, Malaysia, Philippines, Thailand, and Vietnam—to assess the status of existing national binding legal measures regulating CPCF. The aim is to understand the regulatory landscape and facilitate future policy actions.
This review focused on evaluating the content of these legal measures pertaining to CPCF nutrient composition and labelling. Additionally, it also compares their alignment with the recommendations provided in Codex and World Health Organization (WHO) documents.
The reviewing process
To achieve this, a survey form was distributed to 22 key government and civil society stakeholders across seven South East Asian countries between August and September 2021. Their responses played a crucial role in identifying binding legal measures relevant to CPCF.
Moreover, a regional law firm was engaged to assist in policy identification in Indonesia, Malaysia, The Philippines, and Thailand from December 2021 to March 2022. During this period, a total of 87 national binding legal documents were identified, and 35 were selected for in-depth analysis.
The review leveraged three Codex standards/guidelines specifically applicable to CPCF: 1) the standard for processed cereal-based foods for IYC; 2) the standard for canned baby foods, and 3) guidelines on formulated complementary foods for older IYC.
Three other Codex standards/guidelines were referenced as generally relevant to CPCF labelling: 1) the general standard for the labelling of pre-packaged foods; 2) guidelines on nutrition labelling, and 3) guidelines for the use of nutrition and health claims.
WHO also provides guidance through two documents—the WHO's Guidance on Ending the Inappropriate Promotion of Foods for Infants and Young Children, which outlines criteria for inappropriate promotion of CPCF, and the Nutrient Profile Model (NPM) for CPCF, offering a comprehensive set of nutrient composition and labelling requirements for all CPCF product categories in Europe.
A three-category classification—no binding legal measures, partial alignment, and full alignment—was employed to signify whether the identified measures encompassed none, some, or all components of the recommended CPCF nutrient composition and labelling practices outlined in Codex, the WHO Guidance, and the adapted NPM for CPCF.
The identified misalignment
All seven countries included in this review had a minimum of two binding legal measures broadly relevant to the nutrient composition and/or labelling of CPCF. The identified number of such measures varied, with Cambodia and Malaysia having two, Thailand four, Lao PDR and Vietnam five, Indonesia eight, and The Philippines nine.
Furthermore, each of the seven countries possessed at least one CPCF-specific binding legal measure, ranging from one in Cambodia, Malaysia, and Lao PDR to three in the Philippines and Vietnam. The effective dates of these binding legal measures spanned from 1986 in the Philippines to 2021 in Indonesia, Malaysia, and the Philippines.
The review found that Malaysia and Vietnam were fully aligned with at least one of the three CPCF-specific Codex standards/guidelines. Also, Cambodia, Indonesia, Malaysia, and the Philippines each exhibited full alignment with at least one of the three general Codex standard/guidelines.
Lao PDR was the sole country fully aligned with WHO guidance recommendations specific to breastfeeding messaging on CPCF, whereas Thailand did not achieve full alignment with any of the six Codex standards/guidelines or the WHO guidance.
Specifically, binding legal measures in Indonesia, Malaysia, and Vietnam demonstrated full alignment with the adapted NPM for CPCF concerning total fat and protein requirements for specific food categories, and partial alignment on added sugar, sodium, fruit content, and total sugar content requirements for specific food categories.
Indonesia's binding legal measure boasted the most comprehensive nutrient composition standards, encompassing eight of the 12 requirements and covering each of the 16 CPCF product categories. Conversely, Cambodia and Lao PDR lacked binding legal measures regulating the nutrient composition of CPCF.
The Philippines had one measure partially aligned with micronutrient content requirements of CPCF, and Thailand had two measures partially aligned with requirements for no added sugar and the sodium threshold.
Five countries (Indonesia, Lao PDR, Malaysia, Thailand, and Vietnam) achieved full alignment with the requirement to provide the percentage by weight of fruit, water, and protein in the ingredients list, while Lao PDR and Malaysia fully aligned with several requirements to promote and protect breastfeeding.
None of the seven countries were fully aligned with the requirements of: 1) no compositional, nutritional, health, marketing, or other claims; 2) minimum age restriction of 6 months or a maximum age restriction of 12 months for specific food categories; 3) product names reflecting ingredients in descending order as per the ingredients list; and 4) instructions not to consume soft foods via pack spout.
There were also no binding legal measures restricting the promotion of confectionery and non-BMS beverages in any of the seven countries.
Researchers urged for consolidated guidance to avoid confusion
The researchers said their review emphasises the limited alignment observed between countries' binding legal measures and the guidance documents provided by WHO and Codex.
The misalignment in guidance, particularly between national measures and global recommendations, poses the risk of confusion for consumers, notably parents seeking to make informed choices for their children. This discrepancy may lead to uncertainty and challenges in understanding the suitability of commercially produced complementary foods, ultimately impacting the health and well-being of infants and young children.
“The concept of prohibiting promotion of food products is relatively new and is well recognised as being complex, likely to be contested by the food industry and requiring strong capacity for monitoring and enforcement by governments.” Researchers wrote.
“Countries in Southeast Asia urgently require consolidated guidance on how to develop appropriate, legally binding, and enforceable standards for CPCF nutrient composition and labelling. Existing guidance is fragmented, and Codex standards are outdated and insufficient for this purpose.”
Source: Maternal & Child Nutrition
Overpromoted and underregulated: National binding legal measures related to commercially produced complementary foods in seven Southeast Asian countries are not fully aligned with available guidance
Authors: Jessica Blankenship et al.