Questions and Answers on Ending Free and Low-Cost Supplies
Prepared by BFHI Management Group
UNICEF, NYHQ, for UNICEF FIELD OFFICES
Q1. Does the International Code of Marketing of Breastmilk Substitutes (the
Code) ban all free and low cost supplies of infant formula and other breastmilk
substitutes?
A1. Yes, in almost all cases. Reading together the International Code and
World Health Assembly Resolution 39.28, free or subsidized supplies are
permitted for feeding orphaned and abandoned children, and for babies with
certain rare disorders. All other breastmilk substitutes should be obtained
through "normal procurement channels" so as not to interfere with the
protection and promotion of breastfeeding. Procurement generally means
purchase.
Q2. Should free supplies be donated for pre-term and low birth weight
infants? Some argue that these infants need early supplementation and therefore
free supplies should be permitted.
A2. No. Breastmilk is the medically indicated feeding of choice for almost
all pre-term and low birth weight babies.(Reference 1) Obtaining free supplies
for these babies encourages bottle (artificial) feeding, which further
threatens their survival and healthy development. Moreover, once free supplies
are available in postpartum wards and nurseries, it is extremely difficult to
control their distribution and misuse.
Q3. What does "cessation" actually mean?
A3. Infant formula manufacturers and distributors stop offering and
distributing free and low-cost supplies, and health care facilities and health
workers stop requesting and using supplies provided free or at low-cost.
Stopping a practice that has become routine, customary, and financially
beneficial to hospitals and companies requires a significant effort by all
parties. Health workers that request or accept free supplies are as much at
fault as companies that offer them.
Q4. Who is a "health worker"?
A4. According to the Code, any person working in the health care system,
whether professional or non-professional, including voluntary and unpaid
workers, in public or private practice, is a health worker. Under this
definition, ward assistants, sweepers, nurses, midwives, social workers,
dieticians, counselors, in-hospital pharmacists, obstetricians,
administrators, clerks, etc. are all health workers.
Q5. Should the prohibition extend to MCH and rural clinics?
A5. Yes. The Code defines the health care system as: "governmental,
non-governmental or private institutions or organizations engaged, directly or
indirectly, in health care for mothers, infants and pregnant women; and
nurseries or child-care institutions. It also includes health workers in
private practice."
Q6. Many manufacturers now produce and market "follow-on formulas" for babies
older than 6 months. Should restrictions on free supplies apply to follow-on
formulas?
A6. Yes. Follow-on formulas are bottle-fed other milk products which are
included in the scope of the Code.(Reference 2) The 1986 World Health Assembly
was sufficiently concerned with follow-on formulas to "specifically direct the
attention of Member States and other interested parties to the facts that: (a)
any food or drink given before complementary feeding is nutritionally required
may interfere with the initiation or maintenance of breastfeeding and
therefore should neither be promoted nor encouraged for use by infants during
this period. And (b) the practice being introduced in some countries of
providing infants with especially formulated milks (so-called "follow-up"
milks) is not necessary."
Q7. Why not permit free supplies in paediatric wards, since older infants may
already be using the feeding bottle?
A7. Because free supplies to paediatric services or other special services
for sick infants can seriously undermine breastfeeding. The WHO/UNICEF
guidelines suggest, in paragraph 50: "There will, of course always be a small
number of infants in these services who will need to be fed on breastmilk
substitutes. Suitable substitutes, procured and distributed as part of the
regular inventory of foods and medicines of any such health care facility,
should be provided for those infants.
Q8. Is there a working definition for "low-cost" supplies?
A8. Yes. There is a general agreement that ending "low-cost" or "low-price"
sales means ending sales at prices below wholesale price or lower than 80
percent of the retail price, in the absence of a standard wholesale price. The
reason for stopping low price sales is that low prices lead to overuse of
breastmilk substitutes.
Q9. The International Association of Infant Formula Manufacturers (IFM)
committed its members to the goal of ending free and low-cost supplies of infant
formula only to hospitals and maternities and only in developing
countries that have taken action to end such supplies. Are the limitations of
the commitment problematic?
A9. The fact that the IFM did not commit to ending all free and low-cost
supplies in all the world's health care facilities, with or without government
action compelling them to do so, means that UNICEF and its partners have a lot
more work and education to do. The Innocenti Declaration on the Protection,
Promotion and Support of Breastfeeding; adopted by UNICEF's Executive Board
and the World Health Assembly, calls upon all governments to give effect to
the International Code of Marketing of Breastmilk Substitutes and relevant
subsequent World Health Assembly resolutions in their entirety by 1995.
Government actions ending the distribution of free and low-cost supplies of
breastmilk substitutes to health care facilities, therefore, should be
consistent with the Code and WHA 39.28.

References
(1)See WHO/UNICEF "Guidelines concerning the main health and socioeconomic
circumstances in which infants have to be fed on breastmilk substitutes" (WHO,
A39/8 Add.1, 10 April 1986). The 1986 World Health Assembly based its adoption
of WHA 39.28 on this document.
(2)"The Code applies to the marketing, and practices related thereto, of the
following products: breastmilk substitutes, including infant formula; other milk
products, foods and beverages, including bottlefed complementary foods, when
marketed or otherwise represented to be suitable, with or without modification,
for use as a partial or total replacement of breastmilk; and feeding bottles and
teats. It also applies to their quality and availability, and to information
concerning their use." Article 2, "Scope of the Code", International Code of
Marketing of Breastmilk Substitutes (WHO, 1981).